BAS Blog

Question of the Week - FSA Without Medical Plan

Written by BAS | Aug 10, 2023 6:28:39 PM

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.

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