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Considerations for Employers Having Both an HSA Program and Health Flexible Spending Accounts
McKenna Long & Aldridge LLP Link to more items from this source
[Guidance Overview]
May 7, 2012
"Special considerations apply if you currently offer health flexible spending accounts ('health FSAs') that allow up to an extra 2-1/2 months after the end of the plan year in which participants can spend their money (known as a 'grace period'). If you are considering offering an HSA in 2013, you may want to take steps now to inform your employees who currently participate in your health FSA (or the health FSA of their spouse, if the employee is eligible to be reimbursed under that FSA), that if the health FSA contains a grace period, they need to have spent all of the money in their health FSA (even if they have not yet submitted the claim or been reimbursed) on or before December 31, 2012 if they want to qualify for an HSA for the entire 2013 taxable year."

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