I have a client that is terminating its VEBA. IRS Notice 2002-45 indicates that there are ordering rules relative to HRAs and FSAs.

Does anyone have a site relative to whether or not a VEBA has to be exhausted prior to reimbursement from an FSA?

Thanks.

It doesn't. Here's a chart that compares HRAs and FSAs: http://www.shrm.org/government/federal/lht_published/CMS_006509.pdf