IRS FAQs Explain When Health FSAs, HSAs, or HRAs Can Reimburse Nutrition, Wellness, and General Health Expenses

IRS FAQs Explain When Health FSAs, HSAs, or HRAs Can Reimburse Nutrition, Wellness, and General Health Expenses

The IRS has issued FAQs that explain when certain costs related to nutrition, wellness, and general health are medical expenses under Code § 213 that may be paid or reimbursed under a health FSA, HSA, or HRA. As background, Code § 213 defines medical care as amounts paid for the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting a structure or function of the body. The FAQs explain that medical expenses must be primarily to alleviate or prevent a physical or mental disability or illness, and do not include expenses that are merely beneficial to general health. 

The FAQs confirm that the costs of dental, eye, and physical exams are medical expenses that can be paid or reimbursed by a health FSA, HSA, or HRA because these exams diagnose whether a disease or illness is present. The costs of smoking cessation programs and programs that treat drug-related substance use or alcohol use disorders are also medical expenses because they treat a disease. For the cost of therapy to be a medical expense, the therapy must treat a disease—thus, amounts paid for therapy to treat a diagnosed mental illness are medical expenses, while amounts paid for marital counseling are not. Likewise, the costs of nutritional counseling and weight-loss programs are medical expenses only if the counseling or program treats a specific disease diagnosed by a physician (e.g., obesity or diabetes); otherwise, these costs are not medical expenses. The cost of a gym membership is a medical expense only if the membership was purchased for the sole purpose of affecting a structure or function of the body (e.g., a prescribed plan for physical therapy to treat an injury) or treating a specific disease diagnosed by a physician (e.g., obesity or heart disease). However, the cost of exercise for the improvement of general health is not a medical expense, even if recommended by a doctor. 

The FAQs also explain the circumstances under which the cost of food or beverages purchased for weight loss or other health reasons will qualify as medical expenses, and that the cost of non-prescription drugs can be paid or reimbursed by a health FSA, HSA, or HRA even though these items (except for insulin) are not deductible under Code § 213. The FAQs confirm that the cost of nutritional supplements is not a medical expense unless the supplements are recommended by a medical practitioner as treatment for a specific medical condition diagnosed by a physician. 

Source: Thomson Reuters 

IRS FAQs Explain When Health FSAs, HSAs, or HRAs Can Reimburse Nutrition, Wellness, and General Health Expenses

Can an Adult Child’s Medical Expenses Be Reimbursed Tax-Free From a Parent’s HSA?

QUESTION: Our company sponsors a high-deductible health plan (HDHP) in conjunction with employee HSAs. Can the medical expenses of our employees’ adult children who otherwise qualify for tax-free coverage under the HDHP be reimbursed tax-free from the employees’ HSAs? 

ANSWER: Not necessarily—it depends on whether the adult children qualify as tax dependents under the HSA rules. As group health plans, HDHPs that provide dependent coverage of children must make the coverage available until a child turns age 26. (The age 26 mandate does not generally apply to HSAs because they are not group health plans.) The income exclusion for employer-provided health coverage includes employees’ children who are under age 27 as of the end of the taxable year, regardless of whether those children qualify as tax dependents. But similar provisions do not appear in the HSA tax-free reimbursement rules. Instead, whether an adult child’s medical expenses can be reimbursed tax-free from a parent’s HSA depends on whether the child qualifies as a tax dependent for HSA distribution purposes—i.e., whether the adult child is a qualifying child (for example, due to disability) or a qualifying relative (where the parent provides over one-half of the child’s support). Distributions from a parent’s HSA that reimburse a nondependent adult child’s medical expenses are taxable and may be subject to an additional 20% tax. 

Thus, the medical expenses of some adult children who are enrolled as dependents in your company’s HDHP will not qualify for tax-free reimbursement from the employee-parent’s HSA. It is possible, however, that these children may be HSA-eligible themselves. If they cannot be claimed as tax dependents and they meet the other HSA eligibility requirements, they could open HSAs of their own. 

Source: Thomson Reuters

IRS FAQs Explain When Health FSAs, HSAs, or HRAs Can Reimburse Nutrition, Wellness, and General Health Expenses

What do all these employee benefit acronyms stand for?

Everyone in the employee benefits field uses acronyms like COBRA, FSA, and CDHC. What do these and other employee benefit acronyms stand for? 

Here’s an explanatory list of common employee benefit acronyms used:

ACA – Patient Protection and Affordable Care Act 

AHP – Association Health Plan 

ASG – Affiliated Service Group 

ASO – Administrative-Services-Only 

ATIN – Adoption Taxpayer Identification Number 

BA – Business Associate 

CDHC – Consumer-Driven Health Care 

CE – Covered Entity 

COB – Coordination of Benefits 

COBRA – Consolidated Omnibus Budget Reconciliation Act 

COLA – Cost-of-Living Adjustment 

CONUS – Continental United States 

DCAP – Dependent Care Assistance Program 

DOL – Department of Labor 

EIN – Employer Identification Number 

EAP – Employee Assistance Plan 

EBHRA – Expected Benefit HRA 

EBSA – Employee Benefits Security Administration 

EEOC – Equal Employment Opportunity Commission 

EFAST2 – ERISA Filing Acceptance System II 

EOB – Explanation of Benefits 

EOI – Evidence of Insurability 

ePHI – Electronic Protected Health Information 

ERISA – Employee Retirement Income Security Act 

FICA – Federal Insurance Contributions Act 

FLSA – Federal Labor Standards Act 

FMLA – Family and Medical Leave Act 

FSA – Flexible Spending Amount 

FUTA – Federal Employment Tax Act 

GHP – Group Health Plan 

HCE – Highly Compensated Employee

HCP – Highly Compensated Participants 

HDHC – High Deductible Health Coverage 

HDHP – High Deductible Health Plan 

Health FSA – Health Flexible Spending Arrangement 

HHS – Department of Health and Human Services 

HIPPA – Health Information Technology for Economic and Clinical Health Act 

HMO – Health Maintenance Organization 

HRA – Health Reimbursement Arrangement 

HSA – Health Savings Account 

ICHRA – Individual Coverage HRA 

IIAS – Inventory Information Approval System 

MCC – Merchant Category Code 

PBM – Pharmacy Benefit Manager 

PCOR Fees – Fees for Patient-Centered Outcomes Research 

PEO – Professional Employer Organization 

POP – Premium-Only Plan 

PPO Plan – Preferred Provider Organization Plan 

QB – Qualified Beneficiary 

QE – Qualifying Event 

QMCSO – Qualified Medical Child Support Order 

QSEHRA – Qualified Small Employer Health Reimbursement Arrangement 

R&C – Reasonable and Customary 

RRE – Responsible Reporting Identity 

SBC – Summary of Benefits and Coverage 

SMM – Summary of Material Modification 

SPD – Summary Plan Description 

TPA – Third Party Administrator 

UCR Rate – Usual, Customary, and Reasonable Rate 

VEBA – Voluntary Employees’ Beneficiary Association 

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Understanding IRS Rules: The Importance of Substantiating Health FSA and DCAP Claims

Understanding IRS Rules: The Importance of Substantiating Health FSA and DCAP Claims

Introduction In the realm of cafeteria plans, health Flexible Spending Accounts (FSAs) and Dependent Care Assistance Programs (DCAPs) play a ...

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