Many of you have already read our last post titled “Can a Holistic Nutrition Professional Accept Health Savings Account (HSA) or Flexible Spending Account (FSA) Payments for Services Rendered?” One of our members inquired, “I order functional lab tests and have considered this to be a service that an HSA/FSA could be used to pay for.”
The United States Internal Revenue Service (IRS), IRS Publication 502 (2023), Medical and Dental Expenses provide detailed information on what is covered under HSA/FSA Accounts. The IRS states, “You can include in medical expenses the amounts you pay for laboratory fees that are part of medical care.” We then have to ask the question: how does the IRS define medical expenses and medical care? The IRS states, “Medical Expenses are the costs of diagnosis, cure, mitigation, treatment, or prevention of disease, and for the purpose of affecting any part or function of the body. These expenses include payments for legal medical services rendered by physicians, surgeons, dentists, and other medical practitioners. They include the costs of equipment, supplies, and diagnostic devices needed for these purposes. Medical care expenses must be primarily to alleviate or prevent a physical or mental disability or illness. They don’t include expenses that are merely beneficial to general health, such as vitamins or a vacation.”
As holistic nutrition professionals, it’s important to remember that we are not licensed in any state to diagnose, cure, mitigate, treat, heal, or prevent disease. Nor do we provide Medical Nutrition Therapy (MNT); this is a clear boundary within our Scope of Practice, and it’s important to remind our clients that we have limitations since we are not licensed. If your client wants to pursue out-of-pocket lab testing, you may provide that option. If they want to be reimbursed, they will need to seek the advice of their HSA or FSA Plan Administrator.
The NANP interprets the information in IRS Publication 502 not to allow laboratory testing to be reimbursable unless the practitioner is a licensed medical professional. Click here to access IRS Publication 502.