"The Notice ... does not address employer-funded individual health plans.... Employers should be extremely cautious before pursuing this method of funding health insurance plans for their employees. Finally, the notice does not explain its position in Q&A 7: 'Because a health FSA that is not excepted benefits is not integrated with a group health plan, it will fail to meet the preventive services requirements.' ... Presumably the Departments have taken the position that an annual limit on claims in the health FSA is simply incompatible with the rule that no cost-sharing can occur on preventive care."  MORE >>