I am sorry, but you have an unusual situation. Locking an FSA account? It taking 3+ months to close the FSA books on 2024? This is unusual.
And when you add that to having a carryover of FSA funds from 2024 rather than the more common grace period (companies like the grace period, because it means that the requests for payment will be over and done with, not being deferred until the night of December 31st), you have found yourselves in a situation that to my knowledge has not been discussed by the IRS in its notices.
My feeling is that it would be difficult to explain why it was OK to do HSA contributions one month, then FSA reimbursements the next month, then back to HSA contributions. The programs were not set up that way.
Normally, if you have an FSA, it's for all year. I was only interested in finding out your grace period to pin down when your FSA program had definitely ended.
Well, as you know, we do not do your tax returns here on the Community (we do have a TurboTax Live Full Service that will complete and sign your return). We provide information on what the IRS and the States say, but if there is no previous statement on your exact situation, all I can say is that whatever you decide, document it completely, in case any one ever asks.
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