The City carefully weighed the pros and cons of amending its Section 125 FSA Plan to allow a rollover provision and has decided not to do so at this point in time.
Our FSA Plan currently has a 90 day grace period, which allows employees to submit claims incurred in 2013 against their 2013 FSA election until the end of March of 2014. There was some concern that allowing a rollover would have added confusion over the coordination of the grace period and the rollover benefit.
Also, participants (and employers) can be disqualified from making HSA contributions if medical expenses are subject to reimbursement by another plan, such as an FSA during the rollover period. While our current grace period disqualifies contributions for just 90 days, a rollover would disqualify contributions for at least the entire plan year or longer.
We also felt that when employees enrolled in the FSA a year ago, they did so based on their past experience with the “use it or lose it” rule.