Apparently there is a 1997 IRS general information letter someone obtained in a FOIA request stating that a FSA can reimburse the entire cost of orthodontic expenses paid "up front" even if all services have not been rendered. I know that the IRS can "diavow" this position, but does anyone know where I can get a copy of this letter?

Email me a fax number and I can send it to you, once I am back in my office I will also post the web location.

Keep in mind, the letter does not require plans to reimburse in this manner, only says that when it is basically impossible to match cost with service it can be done. You need to look to your specific plan document as to how it handles it.