HSAs with FSAs

[Guest jgarber]

We have just recently began offering HDHP's w/HSA's. I am trying to fully understand what can be reimbursed through a "limited purpose" and a post-deductible FSA.

I think I understand that the post-deductible FSA can only reimburse eligible medical expenses after the deductible of the HDHP has been satisfied. Don't see any real issue here.

My questions surround how the limited-purpose FSA works. The IRS Notice says that it can pay or reimburse expenses only for preventive care and permitted coverage (eg dental and vision care). Since this limited purpose FSA is able to reimbuse for preventive care expenses, can the FSA reimburse expenses for preventive care, such as well-child doctor visits and immunizations, that would be applied against the deductible of the HDHP?

Also - should the FSA TPA offer a separate plan document or plan amendment for the post-deductible and limited purpose FSA's as opposed to offering only one FSA and with the understanding that those HDHP/HSA participants only submit reimbursement for qualifying expenses?

[Jacmo]

Answer to 3rd paragraph: Yes. The plan document and spd spell out what preventive services are payable. Actually, I don't see why you couldn't provide for both post-deductible and preventive care services in the same documents. They would amend their current documents to make these changes (keep the same plan #).