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Can I use my HSA for Concierge or Holistic Medicine?

Updated: Mar 1, 2020

According to our research, HSA’s can be used to pay for medical expenses that would not ordinarily be covered by your insurance. It is very important to use your HSA/FSA properly in case you are audited by the IRS.


Can Concierge Fees be reimbursed from a Health FSA or HSA?

A quick rule of thumb is if the expense is directly related to a qualified medical service that has been provided, it is reimbursable. If it is only for access to services, or the right to “get in the door,” then it is not a qualified medical expense for HSA/FSA reimbursement purposes.


Access Fees: Participant subscribes to a medical concierge to have access to care. At the time services are rendered, additional fees directly related to the medical care given are charged and billed to insurance.

Reimbursable? No – the subscription portion of the fee is not eligible. But generally, the amount related to actual care provided would be considered as an eligible medical expense.

Annual Physical. A fee is charged for an annual physical and includes no additional non-medical services or “amenities.”

Reimbursable? Yes – but if the fee was paid up front, it is only reimbursable once the physical has actually been performed. Keep in mind that annual physicals are often reimbursed at 100% by insurance; if the employee doesn’t have any out-of-pocket expense for the physical, nothing is reimbursable by the FSA or HSA.

Concierge Fees. Fees are exclusively for special treatment or extras like expedited or longer appointments, special waiting rooms, newsletters, etc. and are charged whether medical services are actually provided or not.

Reimbursable?No – These are not qualified medical expenses and, therefore, are generally not eligible for reimbursement through the participant’s HSA or FSA.

Monthly Retainer Fees. Like concierge fees above, but the fee offsets part or all of the cost of future services. The same is true of a monthly fee that a patient must pay in addition to any co-pays, deductibles, or other charges for office visits.

Reimbursable? No Think of it as being like an insurance plan that will cover potential future expenses. They are like insurance because they are payable whether or not medical care is provided. Thus, they fall under the “no reimbursement of insurance premiums” rule that applies to health FSAs.

Bottom line on CONCIERGE: Most of these arrangements do not meet the criteria to be considered qualified health care expenses under the Code. If you want to submit such expenses under your employer’s FSA plan, expect to be asked to back up the reimbursement claims with documentation that medical services were rendered.

Holistic/Alternative Medicine and HSA/FSA

Because money withdrawn from a health savings account to pay medical expenses is tax-free, anyone who has an HSA can funnel all alternative medical expenses through their HSA and get a tax write-off. This could include biofeedback, naturopathy, Ayurvedic medicine, aromatherapy, magnetic healing, reflexology, and the list goes on.

You can use HSA funds for acupuncture, aromatherapy, Ayurvedic Medicine, homeopathy, nutritional consulting, and Traditional Chinese Medicine (TCM), among other therapies. It is good to be in control of your own healthcare, as much as possible. Having money in an HSA provides some of this healthcare freedom.

Always ask you Holistic provider to supply written documentation that Holistic services were medically necessary. Remember to keep all your receipts in real time. It is not your Holistic provider’s responsibility to produce this at year’s end when you need it in a hurry.

If you use your HSA/FSA for any reason, be sure to keep your receipts and any supporting documentation such as a prescription from your provider in case of an IRS audit.

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