FSA Reg Writers Breathe Sign of Relief

From an OMB document on procedure for the 2 for 1 regulation:

" In general, Federal spending regulatory actions that cause only income transfers between taxpayers and program beneficiaries (e.g., regulations associated with Pell grants and Medicare spending) are considered "transfer rules" and are not covered by EO 13771. Additionally, an action that establishes a new fee or changes the existing fee for a service, without imposing any new costs, does not need to be offset; nor does an action that establishes new penalties or fines or changes those already in existence."

 The way I read this most if not all FSA regulations are excluded.