How does this affect an employees access to the health FSA for medical expenses before or after the QRD?
A plan must permit an employee to submit health FSA claims for medical expenses incurred before the date a QRD is requested and must pay or reimburse substantiated claims for those medical expenses. An employer may amend the plan to allow one of the following two options for reimbursing medical claims after the date a QRD is requested: (1) permit employees to continue to submit health FSA claims incurred before the end of the health FSA plan year (and grace period, if applicable); or (2) terminate an employee’s right to submit claims.
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