Q.- Why can I be reimbursed from my Health FSA for my orthodontic costs but not for teeth whitening? Both are making my smile better.
A.- Health FSA may only reimburse expenses that qualify as "medical care" under Internal Revenue Code ยง213(d). To qualify, the expense must be primarily incurred for the diagnosis, cure, mitigation, treatment, or prevention of disease, or to affect the structure or function of the body for a medical purpose. Expenses that are primarily cosmetic or intended to improve appearance do not qualify for reimbursement.
Orthodontia is generally reimbursable because it corrects a physical defect and promotes the proper function of the body, including the alignment and function of the teeth and jaw. While orthodontic treatment may also improve appearance, the IRS specifically views it as medical care rather than a cosmetic procedure.
Teeth whitening is treated differently. Although it affects the appearance of the teeth, it is generally considered an elective cosmetic procedure that does not meaningfully promote the proper function of the body or treat or prevent illness or disease. As a result, teeth whitening is identified as a procedure that generally falls within the tax code's cosmetic-procedure exclusion and is not eligible for Health FSA reimbursement.
To summarize, orthodontia is eligible because it corrects a dental condition and improves oral function, while teeth whitening is ineligible because its primary purpose is cosmetic improvement rather than medical treatment.
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