There are a host of general health expenses which may be able to qualify as tax-favored reimbursable medical expenses only if certain conditions are met. The IRS has a dedicated webpage addressing such expenses at IRS Medical Expense FAQ.
On September 23, 2026, the newest Q&A added to the list addresses wearable tech. As with most of the other “general health” FAQs on the list, consumer wearable tech is not a reimbursable medical expense unless it meets certain medical criteria specific to the individual and their physician’s treatment plan. So, the default should be that it is not a valid medical expense until the employee can substantiate that it meets the IRS’s rules to be reimbursable.
This can cause some frustration for employees, as these products are often advertised as qualifying for such tax-favored medical expense treatment without the caveats of what the IRS requires for that item or service to officially be reimbursable.
Employers sponsoring a health FSA or HRA may want to confirm that their plan administrator is applying these rules when reviewing claims for wearable devices, and consider a brief reminder to employees before they make a purchase. In most cases, the employee will need a letter of medical necessity from their physician connecting the device to the diagnosis or treatment of a specific medical condition.
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