Embryo Storage: FSA Eligibility

Embryo storage for the individual and/or spouse, when required for treatment, diagnosis, mitigation, prevention or cure of a medical condition and accompanied by a Letter of Medical Necessity (LMN) is eligible with a flexible spending account (FSA), health savings account (HSA) or a health reimbursement arrangement (HRA). Embryo storage is not eligible with a limited care flexible spending account (LCFSA) or a dependent care flexible spending account (DCFSA).

What is embryo storage?

Embryo storage is the process of cryopreservation for left over embryos after a cycle of in-vitro fertilization (IVF). IVF does not have a guaranteed success rate, and so the cryopreservation of embryos allows for subsequent IVF attempts without having to repeat every step of the process. Some steps of the IVF process are demanding and/or difficult for some individuals, so embryo storage allows for a medically safer and simpler opportunity to re-attempt fertility treatment.

Embryos are frozen, which is called cryopreservation, through either the process of vitrification or slow programmable freezing (SPF). Frozen embryos kept at the appropriate temperature can last for long periods of time (ScienceDirect). Embryos frozen for over 16 years have been successfully used in IVF. There is no hypothetical short-term limit to the amount of time an embryo can remain safe while in cryopreservation storage. Theoretically, radiation damage will affect the DNA of an embryo in storage after approximately 1000 years.

Embryos are kept at proper temperatures using liquid nitrogen. Computerized systems are required to maintain the proper temperature and maintenance is required to ensure additional liquid nitrogen is added to the storage system. Stored embryos, when needed for use, are thawed approximately one hour before the IVF procedure is to take place (Cleveland Clinic).

How do I obtain a Letter of Medical Necessity (LMN) for embryo storage?

A Letter of Medical Necessity (LMN) to store embryos for an individual and/or spouse is necessary for reimbursement under a consumer-directed healthcare account. This letter must outline how a patient’s reproductive problems related to their medical condition necessitates embryo storage.

Eligibility Table

Flexible Spending Account (FSA) Limited Care FSA Dependent Care FSA Health Savings Account (HSA) Health Reimbursement Account (HRA)


Eligible with Rx

Eligible with LMN

Not Eligible

Legal Information / Regulations

Letter of Medical Necessity Required.