Sarah Borders October 21, 2026 2 min read

IRS “General Health” FAQ Site Adds New Q&A Regarding Wearable Tech

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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Sarah Borders

Principal, Benefits Compliance Solutions. Sarah has spent the last 15 years in the employee benefits industry, has numerous designations and serves on NAHU’s Employer Working Group Subcommittee and is an active board member of Austin AHU. She recently stepped down as Vice President of Benefits Compliance at one of the nation's largest brokerage firms to start her own compliance consulting practice. Her designations include an active license with the Texas Department of Insurance, CEBS (Certified Employee Benefits Specialist), Certified Health Care Reform Professional, HIPAA certification and Health Care Service Associate. She holds an MBA from Texas A&M Corpus Christi and a BA from University of Incarnate Word. Her consulting firm, Benefits Compliance Solutions, partners with employers to identify unknown risks and avoid hundreds of thousands of dollars in fines and lawsuits from failure to comply with their healthplan obligations.

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