Wrap plan - include FSA or no?

[t.haley]

Client currently offers variety of ERISA-covered welfare plans and wants to consolidate into single wrap plan. Plans include a self-insured health plan (with VEBA) and a combination 125/health FSA/dependent care plan (single plan document, single plan number). I have read conflicting opinions on whether including a health FSA in a wrap is advisable given the existence of the self-insured health plan/trust. Some advise against it because the trust requirement (which would not otherwise apply to the health FSA given DOL 92-01) will then apply to the FSA pre-tax contributions. Thoughts?

[QDROphile]

The plan and trust document provisions will determine the operation of the FSA and the application of the trust. Mind your words, be they expressed in one collection of pages or in several collections of pages.