“I recently had a discovery call with a prospective client who asked if I accepted FSA as payment. Can I accept payments from HSA or FSA for my services?”
NANP Legislative Affairs has received several inquiries like the one above. Health Savings Accounts (HSAs) and Flexible Spending Accounts (FSAs) are tax-advantaged accounts that allow people with health insurance policies to set money aside for health care and related costs. The Internal Revenue Service (IRS) refers to these costs as Qualified Medical Expenses.
Most often, nutrition and general wellness counseling services are not covered by HSAs and FSAs. The IRS states that services covered are for the diagnosis, cure, mitigation, treatment, or prevention of disease, which is outside the Scope of Practice of Holistic Nutrition Professionals.
Some exceptions exist, but your client must confirm with their plan administrator if your services will be covered. In some cases, the administrator may require your client to obtain a Letter of Medical Necessity (LMN) from their doctor to reimburse you for your services.
What Should I Tell My Prospective Client?
- Ensure your client understands that you are a holistic nutrition professional who is not licensed in any state. Explain that this may prevent you from accepting payments from the client’s HSA or FSA.
- Ask your client to verify with their HSA or FSA Administrator whether your services are covered before providing services.
- Have your client pay you directly and provide them with a bill of services for them to submit to their HSA or FSA Administrator.
- Let your client know they are responsible for any charges that are not reimbursable (this should be in your Financial Agreement Policy form) and ask for a backup payment method.
- Always keep thorough records and notes for all clients, whether they are paying with HSA/FSA or out of pocket.
Note: Today, most HSA/FSA plans provide their users with Debit Cards. You may need to speak with your payment service provider to determine if they are set up to run HSA/FSA payments. This may require different hardware or changes to how you are registered with the software application you use.
