As defined under Proposed Treas. Reg. 1.125-2 (1989), Q/A-7(c), a flexible spending arrangement (FSA) is a medical reimbursement plan or dependent care assistance plan (DCAP), under which the maximum amount of reimbursement that is reasonably available to a participant for a plan year is not "substantially" in excess of the total premium (including both employee-paid and employer-paid portions) for the plan year. A maximum amount of reimbursement for a plan year is not substantially in excess of the total premium if such maximum reimbursement amount is less than 500% of the total premium (including both employee-paid and employer-paid portions) for the plan year.