I get the question almost every enrollment season. Someone wants to join, they've been told concierge medicine sounds expensive, and they're trying to figure out whether their HSA or FSA can soften the blow. The short answer is: it depends what you're paying for.
Most people use "concierge medicine" to mean one thing — the membership. The IRS doesn't. The IRS distinguishes between paying for access to care (the membership) and paying for medical care itself (the visit, the lab, the procedure). HSA and FSA rules follow that distinction tightly.
The membership fee, usually no
The IRS rules for HSAs and FSAs come from Section 213(d) of the Internal Revenue Code. That section defines a medical expense as something paid for the diagnosis, cure, mitigation, treatment, or prevention of disease. Pretty broad.
The problem with the membership is that you can pay it and never need anything diagnosed, cured, mitigated, treated, or prevented. You're paying so that the doctor is available. The IRS has consistently treated that kind of access fee as ineligible for tax-favored reimbursement, even when the resulting care would be eligible.
There are some narrow exceptions. Practices that structure their fee as prepayment for specifically enumerated services — for example, "the membership entitles you to one annual physical, four sick visits, and twelve telehealth check-ins" — can sometimes qualify the membership for reimbursement, because the fee maps to specific services. Most concierge memberships don't work that way. Mine doesn't. The fee covers access and time, and the services happen as needed.
So if you ask whether my membership fee can be reimbursed from your HSA, my honest answer is probably not. If it really matters to you, ask your HSA administrator in writing. Some administrators will reimburse based on a doctor's letter; others won't. Either way, get the answer before you spend.
What is eligible: everything else
The good news is that almost everything else you do inside a concierge practice qualifies the same way it would in any other practice. If I send you for blood work and the lab bills you, that's eligible. If you have an annual physical and there's a separate charge for advanced screenings, that's eligible. If I come to your house for an urgent visit and there's a charge for the in-home portion, that's eligible. Vaccinations, EKGs, in-office procedures, prescription medications I order, telehealth visits that have a specific charge — all of it is the same as any other medical care under your HSA or FSA.
In practice, members who do a lot of advanced screening or have a chronic condition we're actively managing find that the services side of the relationship runs into thousands of dollars per year. Those thousands are HSA-eligible. The membership often isn't. People who plan correctly use after-tax dollars for the membership and pre-tax dollars for the services.
How to actually claim it
Keep receipts. The membership receipt is for your records; the service receipts are what you submit. Most HSA administrators want an itemized receipt showing the date, the provider, the service, and the amount. The administrator does not need to know that the service was rendered inside a concierge practice. They need to know it was a real medical service.
If your HSA is the kind with a debit card, paying directly for a lab or a procedure with the card creates the cleanest paper trail. If you pay out of pocket and reimburse later, save the itemized receipt and submit it through your administrator's portal.
For couples filing jointly, only the spouse whose name is on the HSA can reimburse from it, but the expenses can be for either spouse or a dependent. Don't get tripped up on that one.
The tax-deduction angle for the membership
Even though the membership doesn't qualify for HSA reimbursement, you may still be able to deduct it on Schedule A as a medical expense. The rules are different. Schedule A allows deduction of medical expenses that exceed 7.5% of your adjusted gross income, and the IRS has historically been more permissive about treating concierge memberships as medical expenses on Schedule A than as HSA-eligible expenses. I wrote a longer piece on the Schedule A side here.
So the practical strategy for many of my members ends up being: pay the membership with after-tax dollars, deduct it on Schedule A if your total medical expenses exceed the 7.5% threshold, and reimburse the actual services from your HSA along the way.
What concierge medicine actually looks like
This is also a good place to mention what you're actually buying when you pay the membership. In my practice, the panel is capped at fifty patients. That's well below the two thousand to three thousand a traditional primary care physician carries, and well below the two hundred to four hundred most concierge doctors carry. That cap is what allows me to give every patient my cell number and answer it directly, do same-day visits across Palm Beach County including in their home, and coordinate every part of their care personally. None of that bills through insurance.
Whether that model is worth the membership fee is a different question. If you want to think about it, I wrote about that here.
One more thing
I'm a physician, not a tax advisor. The IRS interpretations of Section 213(d) shift, and HSA administrators apply them inconsistently. Use this as a starting point and ask your CPA about your specific situation before you make a decision based on a tax outcome.
If you want to talk through whether the practice itself is a fit for you, reach out. I'll answer directly.
