Only medical expenses may be reimbursed with funds from a health savings account (HSA), a health flexible spending arrangement (FSA), Archer medical savings account (Archer MSA), or a health reimbursement arrangement (HRA). However, many have questioned whether certain expenses related to nutrition, wellness and general health, such as a gym membership, could qualify as a medical expense. In a recent FAQ, the IRS provided additional guidance for determining when an expense is a medical expense that may be reimbursed or qualify as a deduction under Section 213 of the Internal Revenue Code.
Medical expenses that may be reimbursed or deducted under Section 213 “must be primarily to alleviate or prevent physical or mental disability or illness.” However, expenses which are “merely beneficial to general health” do not qualify as a medical expense. For example:
The cost of therapy to treat a diagnosed mental illness is a medical expense, but the cost of marital counseling would not be considered a medical expense.
Nutritional counseling could be reimbursed as a medical expense, but only if the nutritional counseling is to treat a specific disease diagnosed by a physician (such as obesity, diabetes, hypertension, or heart disease).
A gym membership also could be reimbursed, but only if the sole purpose of the gym membership is to affect the structure or function of the body, or to treat a specific disease diagnosed by a physician.
The cost of exercise, even though it may be based on a doctor’s recommendation or directive to exercise more, is not a reimbursable medical expense if it is only to improve the patient’s general health.