"[E]mployers who wish to add a carryover option to their Health FSAs (as well as those who alternatively offer a grace period feature) may want to consider providing a limited-purpose or post-deductible Health FSA with respect to the plan year to which the carryover is made (or period covered by the applicable grace period) in order to allow those individuals who wish to make HSA contributions in such plan year (or applicable grace period) to be able to do so. As the impact of the new $500 carryover option on HSA eligibility was not expressly addressed in the IRS guidance, it may be expected that the IRS will directly address this impact in future guidance."  MORE >>