You will be given a definition of a task first, then some input of the task.
In this task, you are given a summary for US Congressional and California state bill, your task is to generate a Title for this bill. The preferred titles are under forty words and mention the purpose of the bill.

Medical FSA Improvement Act of 2009 - Amends the Internal Revenue Code to: (1) allow an increased exclusion from gross income through 2011 for distributions from a medical flexible spending arrangement; and (2) make self-employed individuals eligible for benefits under medical flexible spending arrangements and accident and health plans.
Output:
To amend the Internal Revenue Code of 1986 to increase participation in medical flexible spending arrangements.