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ICHRA & QSEHRA: What medical expenses are reimbursable through my HRA

This article is for employees enrolled in a QSEHRA or ICHRA through Take Command who want to know what expenses can and cannot be reimbursed.

Written by Ryan H

HRA plans reimburse medical expenses that qualify as “medical care” under IRS rules, including most out-of-pocket healthcare costs and eligible insurance premiums, but they exclude non-medical or lifestyle expenses.

Your HRA Employee Packet, available in your Member Portal, includes the definitive list of what is reimbursable under your specific plan. The list below covers IRS-eligible expenses generally — your plan may be configured to cover a subset of these.

QSEHRA & ICHRA must follow guidelines set forth by IRS Publication 502, Medical and Dental Expenses. Below is an excerpt of what is included in the manual. This is not a comprehensive list, but it is a great start to understanding what the IRS considers eligible as a medical expense for tax-free reimbursement.

What medical expenses are reimbursable through an HRA?

You can be reimbursed for medical expenses that are considered “medical care” under IRS Section 213(d), meaning expenses used to diagnose, treat, or prevent a medical condition.

Reimbursable expenses include:

  • Abdominal supports  

  • Abortion  

  • Acupuncture 

  • Alcoholism treatment  

  • Allergy medications  

  • Ambulance  

  • Anesthetist  

  • Antacids  

  • Anti-diarrhea medicine  

  • Antibiotic ointments  

  • Arch supports  

  • Artificial limbs  

  • Autoette (when used for relief of sickness/disability)  

  • Birth control pills (by prescription)  

  • Blood tests  

  • Blood transfusions  

  • Braces  

  • Breast pumps and supplies  

  • Calamine lotion  

  • Cardiographs  

  • Chiropractor  

  • Cold medicine  

  • Contact lenses  

  • Contraceptive devices (by prescription)  

  • Convalescent home (for medical treatment only)  

  • Cough drops and throat lozenges  

  • Crutches  

  • Dental treatment  

  • Dental X-rays  

  • Dentures  

  • Dermatologist  

  • Diagnostic fees  

  • Diathermy  

  • Drug addiction therapy  

  • Drugs (prescription)  

  • Elastic hosiery (prescription)  

  • Eyeglasses  

  • Fees paid to health institute prescribed by a doctor  

  • First aid creams  

  • Fluoridation unit  

  • Guide dog  

  • Gum treatment  

  • Gynecologist  

  • Hearing aids and batteries  

  • Hospital bills  

  • Hydrotherapy  

  • Insulin treatment  

  • Lab tests  

  • Lodging (away from home for outpatient care)  

  • Menstruation Products 

  • Metabolism tests  

  • Motion sickness pills  

  • Neurologist  

  • Nicotine medications and nasal sprays  

  • Nursing (including board and meals)  

  • Obstetrician  

  • Operating room costs  

  • Ophthalmologist  

  • Optician  

  • Optometrist  

  • Oral surgery  

  • Organ transplant (including donor’s expenses)  

  • Orthodontics  

  • Orthopedist  

  • Osteopath  

  • Oxygen and oxygen equipment  

  • Pain relievers  

  • Pedialyte  

  • Pediatrician  

  • Physician  

  • Physiotherapist  

  • Podiatrist  

  • Postnatal treatments  

  • Practical nurse for medical services  

  • Prenatal care  

  • Prescription medicines  

  • Psychiatrist  

  • Psychoanalyst  

  • Psychologist  

  • Psychotherapy  

  • Radium therapy  

  • Registered nurse  

  • Sinus medications and nasal sprays  

  • Sleep aids  

  • Spinal fluid test  

  • Splints  

  • Sterilization  

  • Suppositories and creams for hemorrhoids  

  • Surgeon  

  • Tampons 

  • Telephone or TV equipment to assist the hard-of-hearing  

  • Therapy equipment  

  • Transportation expenses (relative to health care)  

  • Treatments prescribed by a doctor  

  • Ultraviolet ray treatment  

  • Vaccines  

  • Vasectomy  

  • Wart removal medication 

  • Wheelchair  

  • X-rays 

Common medical expenses eligible only with a Doctor's Note

These are some items that we commonly see submitted for reimbursement that require a doctor's Letter of Medical Necessity in order to be reimbursed:

  • Air conditioner (when necessary for relief from difficulty in breathing)  

  • Cupping

  • Dietary Supplements

  • Herbs 

  • Fiber supplements  

  • Massage

  • Medically necessary cosmetic surgery (breast reduction)

  • Medicated shampoo & conditioner

  • Medications often prescribed for weight loss (Semaglutides and Tirzepatides)

  • Orthopedic shoes

  • Probiotics

  • Rolfing 

  • Special school costs for treating disabilities

  • Vitamins & supplements

  • Weight loss programs

What expenses are NOT reimbursable through an HRA?

The following expenses are not eligible for reimbursement under QSEHRA or ICHRA:

  • Advance payment for services scheduled for next year  

  • Airborne/Emergen-C

  • Athletic club membership  

  • Automobile insurance premiums  

  • Baby Powder

  • Boarding school fees  

  • Bottled water  

  • Commuting expenses of a disabled person  

  • Cosmetic surgery and procedures  

  • Cosmetics (including face cream and moisturizer)  

  • Cosmetics, hygiene products, and similar items  

  • Cotton Swabs

  • Dental Floss

  • Diaper Pail Plastic Bags

  • Elderberry 

  • Funeral, cremation, or burial expenses  

  • Health programs offered by resort hotels, health clubs, and gyms  

  • Illegal operations and treatments  

  • Illegally procured drugs  

  • Lip balm (including Chapstick and Carmex)  

  • Marriage Counseling (all other mental health counseling eligible)

  • Maternity clothes  

  • Premiums for life insurance, income protection, disability, loss of limbs/sight, or similar benefits  

  • Premiums for cash benefit indemnity plans

  • Scientology counseling  

  • Shaving Cream

  • Social activities  

  • Special foods and beverages  

  • Specially designed car for the handicapped other than an autoette or special equipment  

  • Stop-smoking programs  

  • Tanning lotion  

  • Swimming pool  

  • Toiletries 

  • Toothpaste 

  • Travel for general health improvement  

  • Tuition and expenses for school where availability of medical care isn't the reason for attending    

  • Weight-loss drugs for general wellness 

Even if an item feels “health-related,” it is not reimbursable unless it meets IRS medical care requirements and your plan allows it.

For a searchable reference, see IRS Publication 502 for the complete IRS medical expense list.

When do I need a Letter of Medical Necessity (LMN)?

Some expenses are only reimbursable if your doctor provides a Letter of Medical Necessity.

These commonly include:

  • Vitamins or supplements prescribed for a condition

  • Weight loss programs (medical necessity only)

  • Massage therapy prescribed for treatment

  • Certain medical equipment or special items not normally covered

To be reimbursed:

  1. Obtain a Letter of Medical Necessity from your provider

  2. Upload it with your receipt when submitting the claim

  3. Ensure the documentation clearly explains the medical condition being treated

Are medical expenses reimbursable if I paid them before joining the HRA?

No.

You can only be reimbursed for expenses incurred after your HRA effective start date.

  • Expenses before your eligibility date are not eligible

  • The service date (not payment date) determines eligibility

  • Coverage must be active at the time the expense is incurred

Can my HRA reimburse insurance premiums?

Yes, if allowed by your employer’s plan.

Eligible premiums may include:

  • Individual health insurance plans (ACA-compliant)

  • Medicare premiums

  • COBRA coverage

  • Some spouse’s employer plan premiums (portion not already pre-tax or employer-paid)

Your reimbursement must follow IRS rules and your employer’s plan design.

How do I know if an expense is eligible?

Follow these steps:

  1. Check if the expense is medical in nature (diagnosis, treatment, prevention)

  2. Confirm it is not excluded by your employer’s HRA plan

  3. Verify it was incurred while your coverage was active

  4. Ensure you have valid documentation (receipt, EOB, or invoice)

  5. Submit the claim through your Take Command portal

If you are unsure, submit the expense for review—eligibility is determined during claim processing.

Why was my reimbursement denied?

Common reasons include:

  • Expense is not considered medical care under IRS rules

  • Missing or incomplete documentation

  • Expense occurred before your HRA start date

  • Item requires a Letter of Medical Necessity but none was provided

  • Expense is excluded by your employer’s plan design

You can resubmit with corrected documentation if the issue is fixable.

Do all HRAs cover the same expenses?

No.

Every employer’s HRA plan can customize what is reimbursable.

  • Some plans only reimburse insurance premiums

  • Others reimburse a broad range of out-of-pocket medical expenses

  • Employers define final eligibility rules in the plan document

Always defer to your specific plan design if there is a difference.

What if I’m not sure whether something is eligible?

If you’re unsure:

  • Submit the expense for review through your portal

  • Include all supporting documentation

  • The Take Command team will determine eligibility based on IRS rules and your employer’s plan

You do not need to pre-verify every expense before submitting.


Common questions about eligible expenses

My claim was denied but I believe the expense should be eligible — what should I do?

Before resubmitting, check:

  • The denial reason shown in the Reimbursements section of your portal or in the email notification.

  • Whether the expense requires a Letter of Medical Necessity (LMN) — see the list above. If so, obtain an LMN from your provider, combine it with the receipt into a single PDF, and resubmit.

  • Whether the submitted amount exactly matches the amount on your documentation — mismatches between the submitted amount and what appears on the receipt are a common denial reason.

  • Whether the service date (not the billing date) falls within your HRA eligibility period.

If you have addressed these and the claim is still being denied, contact Customer Experience with your claim ID or submission date and a description of what documentation you submitted.


My Letter of Medical Necessity was rejected again — why?

Common reasons an LMN is rejected even after resubmission:

  • The LMN date is after the purchase date — the LMN must be dated on or before the date of service.

  • The LMN is from a prior plan year — most LMNs are valid for one plan year and must be renewed each year for the same ongoing condition.

  • The LMN and receipt were not combined into a single PDF file before upload.

  • The LMN does not document the specific medical condition and clinical rationale — a note simply saying 'medically necessary' is not sufficient.

If you have corrected all of the above and the claim is still rejected, contact Customer Experience before submitting again. Include your claim ID and a description of what has been tried — repeated submissions without resolving the root cause can slow processing.


Does my QSEHRA or ICHRA cover dental and vision expenses?

Dental and vision expenses are generally eligible under IRS rules, subject to your employer's specific plan design:

  • Dental: cleanings, fillings, extractions, orthodontics, oral surgery, and dental X-rays are generally covered.

  • Vision: eye exams, prescription glasses, contact lenses, and LASIK surgery are generally covered.

  • Dental and vision insurance premiums: eligible if your employer's plan includes premium reimbursement and the premiums are for separately purchased dental/vision plans.

Check your HRA Employee Packet (available in your Member Portal) to confirm which expense categories your specific plan covers.

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