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The $550 Carryover vs. the Grace Period
ABD Insurance & Financial Services Link to more items from this source
[Guidance Overview]
June 1, 2020

"Employers generally should not amend a plan that offers the grace period mid-year to convert to the carryover for the current plan year. Employees may have made their elections intending to utilize their health FSA balance during the grace period by combining a year-one and year-two election for a high cost procedure ... IRS guidance suggests that this approach may be subject to 'non-Code legal restraints,' such as an ERISA breach of fiduciary duty claim."

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