Flex-Ed: Is concierge medicine FSA-eligible?
Concierge medicine (also known as boutique practice) is becoming increasingly more popular. Basically, concierge medicine is a "highly attentive" way to get healthcare, in which patients pay extra fees in exchange for more personalized care and better access to their doctors. Doctors carry fewer patients, and are usually more available to speak with them. Not a bad setup if you're tired of quick appointments that only leave you with more questions.
Concierge physicians or boutique practices charge a fee for this additional level of service and accessibility. This fee ranges from a small monthly fee to annual fees in the thousands and is usually accompanied by regular fees for services received. In exchange for the annual fee, a concierge doctor is typically available 24-hours a day and office visits are often longer and more thorough.
So, if you're interested in concierge medicine (or at least learning more about it) you're probably wondering, "Can I use my FSA to pay for concierge medicine fees?" As you'll see below, it's not a "yes" or "no" answer.
Well...are concierge medicine services and fees FSA-eligible?
Short answer? Not usually and probably.
As the IRS indicates that only fees for medical services actually performed or received can be reimbursed, the fees paid to retain a concierge doctor where no services are actually received are not eligible. However, if the patient receives an actual service from the doctor, such as a medical visit, the fee for that service is reimbursable provided that the patient has sufficient documentation.
To further clarify the issue, here are a few examples that illustrate what we're saying:
Example 1: Anne pays concierge Dr. Smith $2,500 annually as a retainer for his promised care as needed. Anne has a fairly healthy year, does not visit Dr. Smith, and submits the $2,500 fee to be reimbursed from her FSA. The $2,500 is not eligible, as Anne did not receive any medical services throughout the year.
Example 2: The following year, Anne pays Dr. Smith $2,500 as a retainer for his promised care as needed, but this year, Anne visits Dr. Smith 10 times to receive medical care. Each visit is attributed to the $2,500 retainer fee, in the amount of $250 per medical visit. Provided that Anne has sufficient documentation to show that $2,500 worth of medical services was actually received, her FSA may be used to reimburse these expenses.
Example 3: Anne changes doctors and starts using concierge Dr. Nathan, who charges $1,000 per year plus an additional fee of $100 per office visit. Anne visits Dr. Nathan three times throughout the year for medical care. Anne may be reimbursed with sufficient documentation for the 3 medical visits, or $300. The $1,000 annual fee isn't eligible.
So, no, paying a concierge doctor a retaining fee doesn't offer much in the way of FSA eligibility, but if you need the doctor for medical services throughout the year, it certainly can. And in a world where doctors are increasingly busy, more time with a dedicated physician is still a really attractive option for those willing and able to spend for it. As always, be sure to check with your benefits administrator.
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