Frequently Asked Questions About Medical Expenses Related to Nutrition, Wellness, and General Health, Q/A-15 (added Sept. 23, 2026)
The IRS has added a new FAQ to its existing guidance regarding when costs related to nutrition, wellness, and general health qualify as Code § 213 medical expenses that may be paid or reimbursed by a health FSA, HSA, or HRA. In 2023, the IRS issued FAQs explaining when various wellness-related expenses (e.g., gym memberships, nutritional counseling, weight-loss programs, and food or beverages purchased for health reasons) qualify as medical expenses. A 2024 IRS news release reminded taxpayers and administrators that personal expenses for general health and wellness cannot be reimbursed under these arrangements, cautioning that some companies were mistakenly claiming that doctors’ notes based on self-reported health information could convert nonmedical food, wellness, and exercise expenses into medical expenses. The new FAQ (Q/A-15) addresses when the cost of wearable devices (such as bands, watches, rings, patches, sensors, or similar devices) that track bodily functions or other health-related information will qualify as reimbursable medical expenses.
According to the FAQ, whether a wearable device’s cost is a medical expense depends on all the facts and circumstances, including the device’s functions and why it was purchased and used. A wearable device with both medical and nonmedical uses—e.g., one that provides tracking information related to general wellness, fitness, sleep, or other personal uses—is not a medical expense merely because it tracks information related to health generally, or because it tracks bodily functions like blood pressure or blood glucose levels that can be affected by specific diseases. However, the cost of such a device is a medical expense if the individual purchases and uses the device primarily to assist in the diagnosis, cure, mitigation, treatment, or prevention of a specific disease. Relevant facts and circumstances in making that determination may include a medical practitioner’s recommendation; the individual’s symptoms, diagnosis, abnormal test results, or risk factors; the relationship between the information tracked and the disease being evaluated or managed; and the way the information is reviewed or used. But a generalized desire to monitor or improve health is not sufficient. The FAQ also notes that the cost of accessories, add-ons, or software subscriptions used with the device are medical expenses only if they are also purchased primarily to serve a valid medical purpose.
EBIA Comment: This FAQ addresses a question that has become more common as wearable health-tracking devices have grown in popularity. The FAQ makes clear that the mere fact that a wearable device tracks health-related data does not automatically make the device a reimbursable medical expense. Administrators should be prepared to apply a facts-and-circumstances analysis when evaluating claims for wearable devices and should ensure that adequate substantiation is obtained before reimbursing these expenses. This facts-and-circumstances determination will generally make such devices (e.g., with both general health and specific medical uses) ineligible for reimbursement under an inventory information approval system (IIAS). For more information, see EBIA’s Cafeteria Plans manual at Sections XX.D (“Expenses Reimbursed Must Be for Medical Care”), XX.J (“Adequate Claims Substantiation Must Be Received From the Participant and an Independent Third Party”), XX.L (“Health FSA Expenses That Are Difficult to Administer”), 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: Thanks to attorney John R. Hickman for his contributions to this article, with final editing by EBIA staff. Mr. Hickman is a partner in the Employee Benefits Practice Group with Alston & Bird in Atlanta, http://www.alston.com, and is a Contributing Author of EBIA’s Cafeteria Plans, Consumer-Driven Health Care, and Health Care Reform manuals.
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