"Prior to this guidance, many employers had assumed the entire flex credit could be counted as an employer contribution for affordability purposes. After this rule, that is no longer the case. Now, employers may need to designate a portion of the total flex credit amount that may only be spent on benefits providing medical care (such as medical, dental, vision and health FSA) in order to be able to count the flex credit in the affordability calculation, including application of the affordability safe harbors under the Code 4980H regulations."