BlogIRS Section 213 — What Qualifies as a Medical Expense
Compliance & Regulation

IRS Section 213 — What Qualifies as a Medical Expense

The legal foundation for all HSA/FSA spending. Learn what's automatically eligible, what's dual-use, and how medical necessity bridges the gap.

VeloMedicine Editorial Team4 min read

The Legal Foundation

IRS Section 213 defines medical care as amounts paid for the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body.

That definition is the legal basis for HSA and FSA spending, and it is the starting point for evaluating whether a product can be reimbursed.

What's Automatically Eligible

Prescription medications, many medical devices, first aid supplies, and diagnostic equipment generally fit cleanly within the definition of medical care.

Because their purpose is already clearly medical, these products do not usually need an LMN to qualify.

The Dual-Use Category

Some products can be used for everyday wellness or for the treatment of a specific medical condition. That is what makes them dual-use.

Fitness equipment for obesity treatment, supplements for documented deficiencies, and sleep devices for insomnia are common examples that may qualify when clinically justified.

What Never Qualifies

General health and wellness purchases without a medical nexus do not become eligible simply because they promote a healthy lifestyle.

Cosmetic procedures, items already reimbursed by insurance, and purchases that lack a condition-specific rationale generally remain outside the scope of Section 213.

The Role of Medical Necessity

For dual-use items, medical necessity is the bridge between a gray-area product and a qualified medical expense.

A licensed provider documents that bridge in the LMN, tying the product to the consumer's specific condition and intended treatment outcome.

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