Are employer contributions for medical expense reimbursement an FSA?

[Guest Tara Curran]

An employer wants to adopt a medical expense reimbursement plan whereby the employer sets aside a certain amount of money to be used for medical reimbursement and the employees do not have any taken out as salary deferrals. Is this a welfare benefit plan that requires a cafeteria plan document as well as a reimbursement plan document? Can the contributions be discriminatory? Does this fall under IRS Code Section 105?