Using Your Health FSA for Telemedicine Services

What is Telemedicine?

Telemedicine is the provision of care by physicians or health care professionals through technology (like the Internet or video conferencing) rather than in person.¹

• Convenience & Cost: A telemedicine consultation functions just like a regular physician office visit to obtain a diagnosis and treatment plan. It can substitute for an emergency room or urgent care visit—especially during non-office hours—and is often a less expensive, more convenient option.

• How it's Offered: While these services are most likely offered through your employer-sponsored major medical plan, you can also find and use telemedicine providers on your own (similar to using an out-of-network urgent care clinic).

Does Telemedicine Qualify for FSA Reimbursement?

Yes. Health FSAs can reimburse telemedicine expenses, as well as related deductibles or copayments, provided they meet the following legal requirements:

• Qualifying Medical Care: The purpose of the consultation must be to diagnose, treat, or mitigate a medical condition (it cannot be for cosmetic purposes), and the practice must be legal in the applicable state or other locality.²

• State Regulations: State medical licensing laws may preclude or restrict a provider licensed in one state from delivering telemedicine services to individuals in another state.³ In addition, state laws may restrict the scope of benefits that providers can deliver over the telephone or Internet.⁴

What to Do: Submitting a Claim

To receive reimbursement from your health FSA, you must submit a third-party statement from the telemedicine provider.⁵

Your receipt or bill (written or electronic) must include:

• A description of the service itself

• The specific date of service

• The exact amount of the expense

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Footnotes

1 Because of the broad range of technologies available to connect patients with health information and providers, other terms, such as "telehealth" or "mHealth" (for mobile technology), are also used, sometimes interchangeably. These terms are sometimes referred to collectively as "connected health." But here we refer to "telemedicine" as a remote, one-on-one consultation with a physician or other health care professional, as opposed to a nurse helpline or an app to refill prescriptions. See Joseph Kvedar, Molly Joel Coyne & Wendy Everett, Connected Health: A Review of Technologies and Strategies to Improve Patient Care With Telemedicine and Telehealth, 33 Health Affairs no. 2 (Feb. 2014) (as visited May 13, 2015); Public Health Institute Center for Connected Health Policy, What is Telehealth? (as visited May 13, 2015); Partners Healthcare Center for Connected Health, What is Connected Health? (as visited May 13, 2015). 

2 Informal, nonbinding remarks of Donna Crisalli, IRS, Office of Chief Counsel, Aug. 12, 2011 ECFC Annual Symposium.

3 See, e.g., New York State Department of Health, Statements on Telemedicine (as visited May 13, 2015):

It is the location of the patient that defines where the care has been delivered and the jurisdiction of applicable regulations. Physicians and physician assistants who practice or hold out to practice or engage in any physician- patient relationship in New York must be licensed and currently registered in New York. 

American Telemedicine Association, 50 State Telemedicine Gaps Analysis: Physician Practice Standards & Licensure (Sept. 2014) (as visited May 13, 2015).

4 See, e.g., LiveHealth Online website (provides a map showing states in which services are unavailable, states that allow doctors to provide services but not prescriptions, and states that allow both services and prescriptions) (as visited May 12, 2015); and Texas Board Curbs Telemedicine, Prompts Lawsuit, mHealth News (Jan. 23, 2015) (reporting on the Texas Medical Board's emergency rule prohibiting prescription of "any dangerous drug or controlled substance" without an in-person physician-patient visit) (as visited May 13, 2015).

 5 Some telemedicine providers may be equipped to accept payment via a health FSA debit card transaction.