Limited Purpose FSA

A limited-purpose FSA (flexible spending account) is similar to a general purpose FSA, except that qualified medical expenses are limited to eligible dental and vision costs for the employee, employee’s spouse and any eligible dependents. With an FSA, money is earmarked from the paycheck before accounting for taxes. This money can be used for pre-tax FSA dollars to spend on qualified vision or dental costs throughout the life of the plan. Examples of qualified costs including dental exams, eye appointments, glasses and many more.

The limited portion of the FSA allows the employee or employee’s spouse to participate in both the FSA and a health savings account (HSA). This benefit allows both to maximize the amount of savings and tax benefits. In addition, depending on the type of FSA plan chosen, the employee can carry over five hundred dollars of unused funds to the subsequent year.

HSA Eligibility

An HSA is both a health care account as well as a savings account. An HSA offsets the expenses of a high deductible plan and provides savings for any out of pocket (OOP) health care costs that the employee, employee’s spouse or eligible dependents currently have or may have during the future.

Before an employee can open an HSA account, he or she must:

  • Be covered under an HDHP
  • Be only covered under an HDHP, even if enrolled in another plan
  • Not be enrolled in Medicare
  • Not be claimed as a dependent on someone else’s tax return

Eligible Expenses

Qualified medical expenses are typically included in the employee plan packet provided by the employer. With a limited-purpose FSA, any reimbursable expenses under the FSA cannot also be reimbursable expenses under the HSA.

Limited-purpose FSA: Additional Features

The employee's entire health FSA election is available on the first day of the plan year. If the FSA is active, the available funds decrease as the claims are paid. Also, the employer chooses the reimbursement schedule. The employer also can decide the features included in the FSA plan, and the way it is set up determines if the employee can carry over any unused funds to the subsequent year.

The employee must review the summary description of the FSA plan to figure out whether it includes a carryover feature or a grace period extension. A carryover plan allows the employee to carry over any unused funds from one year into the next year. The amount allowed is typically five hundred dollars, although the amount will vary depending on the specific plan. If the plan allows for a grace period, the employee will have a certain extension of time to use the funds remaining in the FSA before they go away. The grace period usually lasts a little over two months. The IRS does not allow an FSA to have both a carryover or a grace period feature.

An FSA also has what’s called a “run out period.” A run-out period is a set amount of time after the end of the plan where the employee can submit claims for qualified medical expenses incurred during the past year. However, not all FSA plans have this feature and the time period for this feature can vary depending on the plan.After the run out period ends, the IRS has mandated that all of the unused funds left in the account after the grace period or run out period are forfeited.

The forfeited money will be gone forever. It cannot be paid back to the account holder and cannot be transferred between any other accounts. Thus, it is beneficial to the account holder to accurately account for the amount of health care costs he or she estimates will be spent during the plan year. In order to minimize the risk of losing money, the account holder should choose a plan amount that closely resembles the estimate. This chosen amount cannot be altered during the year unless the account holder undergoes a change in status or other event that is deemed qualified under the rules of the IRS. If the employee meets that status or qualified event, the FSA plan must also allow the change.

If an employee ceases to be employed for the employer or becomes ineligible for the FSA plan, the pre-tax contributions and participation in the plan will automatically cease as well. Any costs for health care that the employee incurs after the plan’s end will not be reimbursable expenses.

If you need help setting up a limited purpose FSA, you can post your legal need on UpCounsel’s marketplace.