Question of the Week - FSA Without Medical Plan

Posted by BAS - 10 August, 2023

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Q.- We employ fewer than 50 employees and do not offer a medical or dental plan. Can we offer our employees a health FSA?

A.- You should not offer a health FSA without a medical plan unless the FSA is a limited purpose FSA. An employer must offer a “regular” medical plan if it wants to offer a general health FSA. This is because to be considered an “excepted benefit” and not subject to coverage requirements, the employer must have a medical plan that provides minimum essential coverage to those who are eligible to participate in the FSA.


Benefit Allocation Systems (BAS) provides best-in class, online solutions for: Employee Benefits Enrollment; COBRA; Flexible Spending Accounts (FSAs); Health Reimbursement Accounts (HRAs); Leave of Absence Premium Billing (LOA); Affordable Care Act Record Keeping, Compliance & IRS Reporting (ACA); Group Insurance Premium Billing; Property & Casualty Premium Billing; and Payroll Integration.

MyEnroll360 can Integrate with any insurance carrier for enrollment eligibility management (e.g., Blue Cross, Blue Shield, Aetna, United Health Care, Kaiser, CIGNA and many others), and integrate with any payroll system for enrollment deduction management (e.g., Workday, ADP, Paylocity, PayCor, UKG, and many others).

Topics: Human Resources Administration, Flexible Spending Accounts, Dental Plan, Medical Plan


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