QUESTION: Several participants in our company’s health FSA have asked whether vitamins qualify for reimbursement. What should I tell them?
ANSWER: Unless your plan imposes additional limits, the answer depends on whether the vitamins are being taken for general health or for a specific medical condition. Health FSAs can only reimburse expenses that are for “medical care” as defined in Code § 213(d). Vitamins and other dietary supplements taken for general health do not qualify as medical care under Code § 213(d), even if recommended by a medical practitioner. If they are recommended to treat an individual diagnosed with a specific medical condition, however, they may constitute medical care and be reimbursable. Before reimbursing vitamins or other dietary supplements, your health FSA administrator should obtain from the participant a medical practitioner’s written statement that the vitamin or supplement is to treat a specific medical condition.
For example, if a health FSA participant with iron deficiency anemia purchases iron supplements recommended by a doctor to treat the condition, those supplements would be eligible for reimbursement from your company’s health FSA, assuming that the other requirements for reimbursement were met. But multivitamins purchased by participants for their own or their children’s general health would not qualify.
Because plans may be more restrictive than IRS requirements, you should review your plan document to confirm that vitamin expenses are not excluded. Most health FSA administrators maintain a table or other records showing how they handle different types of expenses. This can streamline administration and demonstrate that the health FSA is consistent in its interpretation of what is reimbursable. (ERISA plans are required to maintain reasonable procedures governing benefit claims that ensure consistency in the claims approval process.) Expenses are often organized into three categories: (1) those that normally qualify for reimbursement; (2) those that normally do not qualify; and (3) those that might qualify with proper substantiation. Vitamins and other “dual-purpose” expenses (e.g., expenses that could be either for general health purposes or for medical care) would fall into this third category.
For more information, see EBIA’s Cafeteria Plans manual at Sections XX.L.3 (“Vitamins, Natural Medicines, and Nutritional and Herbal Supplements”) and XX.M (“Table of Common Expenses, Showing Whether They Are for ‘Medical Care’”); see also EBIA’s Consumer-Driven Health Care manual at Sections XV.C (“What Is an HSA-Qualified Medical Expense?”) and XXIV.B (“HRAs May Reimburse Only Code § 213(d) Expenses”).
Contributing Editors: EBIA Staff.