Dinesh-Ramanesh Virk

Historically, FSA users would forfeit any unused FSA funds at the end of each plan year thanks to the "use-it-or-lose-it" rule. While this rule is still in place, two important changes have emerged over the past decade to provide a measure of relief to FSA users: the rollover and 2.5 month grace period. FSA plan sponsors can choose to offer ONE of the two rules when administering FSAs, but not both.

Rollover (Carryover)

This FSA regulation gives account holders the ability to "roll over" up to $615 (for plan years starting in 2023) into the next plan year's account to prevent a large portion of funds from being forfeited. The FSA plan sponsor can elect to allow less than $610 to be rolled over, but the same rollover limit must apply to all participants under the current FSA plan rules. The FSA rollover does not count toward the following year's maximum election amount. For example,: the maximum rollover amount for plan years ending in 2022 was $570 and the maximum FSA contribution for 2023 is $3,050. Therefore if an employee carries over the maximum amount from 2022 and then contributes the maximum amount, they would have a total of $3,620 to spend in 2023.

2.5 Month Grace Period

The other option is the 2.5 month grace period. This gives account holders the ability to spend down the remainder of the previous year's FSA funds before March 15 (for FSA plans ending December 31), after which any unspent funds would be forfeited back to one's employer. Unlike the FSA run-out, which can be offered in conjunction with a rollover or grace period and provides up to 3 months after plan year end to spend down remaining funds for expenses incurred during the prior plan year only, the grace period allows users to spend down remaining FSA dollars on new expenses incurred within the new plan year as well.

How do I know if I have the rollover or grace period?

Your end of year options can determine how you will spend your allocation over the course of the year, so it's vital that you know your FSA plan details before setting an election amount for the coming year. Aspiring FSA users should inquire about these regulations during their health benefits Open Enrollment to plan out the optimal healthcare spending for the coming year.

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