When must expenses reimbursed under an FSA Plan be incurred?
Expenses reimbursed under a Flexible Spending Account must be incurred during the participant’s period of coverage under the FSA. Expenses are treated as having been incurred when the participant is provided with the care that gives rise to the expenses not when the participant is formally billed or charged or pays for the care. See below for treatment of orthodontia expenses. Expenses are not treated as incurred during a period of coverage if the expenses are incurred before the later of (1) the date the FSA is first in existence or (2) the date the participant first becomes enrolled in the FSA.
