Comment on FR Doc # Z7-14827

Ladies/Gentlemen: I have the following comments/questions in regard to Prop. Reg. Sec. 1.125-1(m) ("Payment or reimbursement of employees' individual accident and health insurance premiums: 1. If a cafeteria plan includes a direct reimbursement arrangement as described at (ii) of the Example that is included with the above provision, must that arrangement operate in accordance with the rules applicable to flexible spending arrangements as described at Sec. 1.125-5? If not, should such an arrangement not then be identified in the regulations as a fourth type of fsa? 2. Must a benefit option described in Sec. 1.125-1(m) be limited to the payment reimbursement of premiums for accident or health insurance coverage under a contract owned by the employee-participant, or may premiums for coverage owned by a spouse or dependent of an employee-participant (or by an employer of a spouse or dependent) also be covered? In regard to the definition of "premium only plan" at Prop. Reg. Sec. 1.125-1(a)(5), why do cafeteria plans that limit benefit options to allowing for the pre-tax payment of group term life insurance premiums as well as accident and health premiums fall outside the definition? Thank you.