Concierge medicine memberships and Direct Primary Care plans sit in a gray zone for HSA and FSA reimbursement — some parts of your GoodLife Health membership qualify, some don't, and the difference comes down to how the invoice is itemized.
TL;DR
- IRS rules treat concierge medicine access fees differently from itemized clinical services — know the split before you file.
- GoodLife Health memberships start at $179/month; the lab review and prescribing portion is the reimbursable piece, not the flat access fee.
- A Letter of Medical Necessity turns a denied HSA/FSA claim into an approved one for GLP-1 prescribing and hormone panels.
- Verdict: submit itemized invoices, not membership statements, and expect partial reimbursement in 2026, not full.
- A flat monthly access fee is not automatically a qualified medical expense under IRS Section 213(d) — itemized clinical services usually are.
- GoodLife Health memberships start at $179/month; only the lab review and prescribing portion is typically reimbursable.
- A Letter of Medical Necessity, submitted alongside an itemized invoice, resolves more denials than any other single step.
- Most FSA administrators process complete claims within 5-10 business days in 2026 when documentation is submitted together.
- Expect partial, not full, reimbursement — administrators pay for identifiable medical services, not the bundled membership charge.
Why this matters
HSA and FSA dollars are pre-tax, which means the IRS decides what counts as "medical care" under Section 213(d) — and a flat monthly retainer for phone access doesn't automatically qualify just because a doctor sent it. This has tripped up members since concierge and Direct Primary Care models scaled past niche practices, and it's still the single most common billing question GoodLife Health clinicians hear in 2026.
The distinction that matters: a membership fee paid purely for access (faster response times, longer visits, a phone number) is not automatically a qualified medical expense. A fee paid for specific services — a lab panel, a prescribing consult, a testosterone or GLP-1 protocol review — usually is. Most Direct Primary Care and concierge invoices bundle both, which is why a full concierge medicine cost breakdown matters before you file anything with your plan administrator.
Miss this distinction and your FSA administrator denies the claim outright. Get it right and you recover a meaningful chunk of what you're already paying for hormone optimization, weight loss prescribing, or ongoing lab work.
What you'll need
- Your HSA or FSA account login and current balance
- An itemized invoice from your GoodLife Health membership — not just a monthly statement
- IRS Publication 502 (free, on IRS.gov) for the qualified medical expense definition
- A Letter of Medical Necessity template, if your plan administrator requires one
- 15-20 minutes to separate access fees from clinical service line items
The steps
1. Pull an itemized invoice, not a membership receipt
A generic "$179/month membership" line item gets denied almost every time. What gets approved is an invoice that separates the access fee from specific services rendered — lab review, clinician consult time, prescribing for tirzepatide or testosterone, hormone panel interpretation.
Ask your clinic for a superbill or itemized statement that breaks out CPT-style service codes where possible. Expected outcome: a document your FSA or HSA administrator can actually match against Section 213(d) definitions instead of guessing.
Common mistake: submitting the monthly membership charge as-is and assuming the reviewer will infer what's medical. They won't — vague line items get rejected by default.
2. Separate the access fee from the treatment fee
Most Direct Primary Care and concierge models charge one flat number that covers both unlimited access and actual clinical work. Your job is to estimate — with your clinic's help — what portion of that fee corresponds to identifiable medical services versus pure access.
Check how much a Direct Primary Care membership costs against what's included in your specific plan before you draw the line. Expected outcome: a defensible percentage split you can document if your administrator asks for backup.
Common mistake: claiming 100% of a bundled membership fee as medical. Reviewers who catch this flag the entire claim, not just the disputed portion.
Access Fee vs. Treatment Fee
What typically qualifies for HSA/FSA reimbursement
| Fee type | What it covers | Reimbursement status |
|---|---|---|
| Access fee | Faster response times, longer visits, a phone number | Not automatically a qualified medical expense |
| Treatment fee | Lab panel, prescribing consult, testosterone or GLP-1 protocol review | Usually qualifies when itemized separately |
3. Confirm your plan's specific exclusions
Every HSA custodian and FSA administrator writes their own list of excluded expenses, and concierge medicine retainers show up explicitly excluded on some plan documents dating back to guidance the IRS issued in 2006 distinguishing access fees from medical care. That guidance still shapes how administrators write their exclusion lists in 2026.
Call your plan administrator directly and ask: "Does this plan exclude concierge or retainer-based membership fees specifically?" Expected outcome: you know before you submit, instead of finding out after a 30-day denial cycle.
Common mistake: assuming all HSA/FSA plans follow identical rules. They don't — custodians interpret Section 213(d) with real variation.
4. Request a Letter of Medical Necessity for treatment components
When a service ties to a diagnosed condition — GLP-1 prescribing for obesity, testosterone therapy for confirmed low-T, thyroid management — a Letter of Medical Necessity from your clinician converts a soft claim into a documented one. This single document resolves more denials than any other step in this process.
Ask your GoodLife Health clinician to include: the diagnosis, the treatment prescribed, and why ongoing monitoring through the membership is clinically required. If you're also managing prescription costs, see how to afford tirzepatide without insurance for how the letter interacts with drug cost reimbursement specifically. Expected outcome: a one-page document your administrator can attach to the claim file.
Common mistake: requesting the letter after a denial instead of before submission. Front-load it — it prevents the back-and-forth entirely.
A Letter of Medical Necessity should name the specific diagnosis — not just "weight management" but the ICD-adjacent condition — and the specific treatment tied to it, along with why ongoing monitoring through the membership is clinically required. Vague letters get vague reviews.
5. Submit the claim with both documents attached
File the itemized invoice and the Letter of Medical Necessity together, not sequentially. Administrators process combined submissions faster because they don't have to request follow-up documentation mid-review.
Most FSA administrators process claims within 5-10 business days in 2026 when documentation is complete on the first pass. Expected outcome: either an approval or a specific, documented reason for denial you can appeal.
Common mistake: submitting the invoice alone and waiting to see if it's questioned. It almost always is, without the letter attached.
6. Track the reimbursed percentage against your actual membership cost
Once a claim clears, log what portion of your $179+/month fee was approved versus denied. This number becomes your template for every future billing cycle — you won't need to rebuild the documentation logic each month, just resubmit the same structure.
Expected outcome: a repeatable claim you can file with minimal friction going forward, instead of relitigating the split every 30 days.
Get an itemized membership invoice
See what's covered before you file your first HSA or FSA claim.
[Explore membership plans](https://goodlifehealth.ai/)
Get the itemization right once, and every claim after it follows the same template.
Troubleshooting
Claim denied as "non-qualified access fee": Resubmit with an itemized breakdown instead of the flat membership charge — most denials at this stage are a documentation problem, not an eligibility problem.
FSA administrator wants CPT codes you don't have: Ask your clinic to code the visit and prescribing components separately; not every Direct Primary Care practice defaults to this, so you may need to request it explicitly.
HSA debit card declined at point of charge: Pay out of pocket first, then file a manual reimbursement claim with the itemized invoice — this avoids point-of-sale category mismatches entirely.
Invoice doesn't separate access fee from treatment: Request a revised statement before filing anything. A single combined line item is the top reason claims bounce back for more information.
Letter of Medical Necessity gets questioned: Make sure it names the specific diagnosis (not just "weight management" but the ICD-adjacent condition) and the specific treatment tied to it — vague letters get vague reviews.
Partial approval feels too low: Ask your administrator for their reasoning in writing. Some approve only the clinical consult minutes, not lab review time — knowing the formula lets you adjust documentation next cycle.
Tools and resources
- IRS Publication 502 — the federal definition of qualified medical expenses
- Your HSA/FSA plan administrator's exclusion list (request directly, don't assume)
- An itemized invoice from your GoodLife Health membership
- A Letter of Medical Necessity template from your clinician
- Direct Primary Care membership cost reference for estimating your access-versus-treatment split
What to do next
Once your first claim clears, the harder question is whether concierge medicine is worth the out-of-pocket gap in the first place. How to evaluate a Direct Primary Care practice before joining walks through the questions to ask before you commit a full year of membership fees to any clinic, GoodLife Health included.
FAQ
Can I use HSA or FSA funds for concierge medicine in 2026?
Partially. The itemized clinical service portion of a concierge or Direct Primary Care membership typically qualifies under IRS Section 213(d) in 2026, but a flat access fee alone usually does not without documentation separating the two.
Does GoodLife Health provide itemized invoices for HSA/FSA claims?
Members can request an itemized statement separating access fees from specific clinical services like lab review and prescribing consults, which is the documentation most FSA administrators require.
What is a Letter of Medical Necessity and do I need one?
It's a one-page document from your clinician naming a diagnosis and the treatment prescribed for it. You need one whenever a claim ties to an ongoing condition like low testosterone or obesity management, since it converts a vague claim into a documented one.
Will my entire monthly membership fee be reimbursed?
No. Most HSA and FSA administrators reimburse only the portion tied to identifiable medical services, not the full membership charge, since part of the fee covers access rather than treatment.
How long does an HSA/FSA claim take to process in 2026?
Most administrators process complete claims within 5 to 10 business days in 2026 when the itemized invoice and Letter of Medical Necessity are submitted together.
What's the difference between concierge medicine and Direct Primary Care for reimbursement purposes?
Both use membership-based billing, so the same access-fee-versus-treatment-fee split applies to each. Neither model is automatically more or less reimbursable than the other under IRS rules.
Can I use FSA funds for GLP-1 prescribing through a concierge membership?
Yes, when the prescribing consult and monitoring are itemized separately from the base membership fee and tied to a documented diagnosis.
What if my claim gets denied the first time?
Request the specific denial reason in writing, then resubmit with an itemized invoice and Letter of Medical Necessity attached together rather than sequentially.
One last thing
The IRS distinction between "access fee" and "medical care" traces back to guidance from 2006, and it still governs how plan administrators write their exclusion lists in 2026 — nearly two decades later, the same split determines whether your concierge medicine claim clears or bounces. Get the itemization right once, and every claim after it follows the same template.
Related guides
- What is a concierge medicine practice and who is it for
- Direct primary care membership plans explained
Related Reading
- Best Concierge Medicine Providers 2026 — Ranked
- Best Direct Primary Care for Families in 2026: Ranked
- Best GLP-1 for Weight Loss in 2026 | Ranked
- Best Direct Primary Care for Hormone Therapy in 2026
References
- Direct Primary Care: Practice Distribution and Cost Across the Nation (J Am Board Fam Med). 2015. pubmed.ncbi.nlm.nih.gov/26546651/