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QSEHRA & ICHRA: Letter of Medical Necessity (LMN) requirements for reimbursement of certain medical expenses

This article is for employees and employers using Take Command Health who are submitting claims for medical expenses that require a Letter of Medical Necessity (LMN) under an HRA (ICHRA or QSEHRA).

Written by Support

A Letter of Medical Necessity (LMN) is required when an otherwise potentially eligible medical expense needs provider certification to confirm it is medically necessary, and reimbursement is only allowed if the LMN is complete, signed, dated, and covers the treatment period.

Without a valid LMN, these types of expenses will be denied for reimbursement.

What is a Letter of Medical Necessity (LMN)?

A Letter of Medical Necessity is a document from a licensed healthcare provider that confirms:

  1. The patient has a specific medical condition or diagnosis

  2. The recommended treatment or product is medically necessary

  3. The treatment is intended to address the diagnosed condition

  4. The expected duration of treatment

  5. Provider certification (signature, credentials, and date)

The LMN is used to justify reimbursement for expenses that are not automatically eligible under IRS rules without additional documentation.

According to the Internal Revenue Service (IRS), some healthcare services and products are only eligible for reimbursement through your HRA when your doctor or provider certifies that they are medically necessary.

When is an LMN required?

An LMN is required when the expense is:

  1. Not clearly eligible under IRS Section 213(d) without documentation

  2. A product or service that requires medical justification

  3. Commonly flagged for additional review due to non-standard usage

Typical categories that often require an LMN include:

  • Certain supplements or vitamins

  • Probiotics

  • Massage therapy

  • Orthopedic or corrective footwear (in non-standard cases)

  • Weight management medications or treatments (as required by plan rules)

  • Other wellness items where medical necessity must be established

If an expense is clearly eligible under IRS rules (e.g., standard prescription drugs), an LMN is typically not required.

What must be included in a valid LMN?

A valid LMN must include all of the following:

  1. Patient identification

    • Name of the individual receiving treatment

  2. Specific diagnosis

    • Must be precise and medically detailed (not general symptoms)

    • Example: “lumbar spinal stenosis with L3 disc herniation” instead of “back pain”

  3. Treatment description

    • Exact product, service, or therapy being prescribed

    • Must clearly connect to the diagnosis

  4. Medical necessity statement

    • Provider must explicitly certify that the treatment is medically necessary

  5. Treatment duration

    • Must include clear start and end dates

    • Indefinite or lifetime durations are not accepted

  6. Provider verification

    • Must be signed, dated, and include provider credentials

    • Must be on letterhead or clearly attributable to the provider

How long is an LMN valid?

An LMN is valid:

  1. For up to 1 year from the provider’s signature date, unless a shorter duration is specified

  2. Only for the treatment period explicitly listed in the letter

  3. For a single plan year (a new LMN is required each plan year)

If treatment continues beyond the validity period:

  • A new LMN must be submitted

  • Continuation is not automatic

When do I need to submit an LMN?

You must submit an LMN:

  1. With the first claim for the expense or treatment

  2. When submitting reimbursement for a new product or service category requiring justification

  3. At the start of each plan year if the expense continues

If an LMN is missing:

  • The claim will be placed on hold or denied

  • Reimbursement will not be processed until documentation is complete

Does an LMN guarantee reimbursement?

No.

Even with a valid LMN:

  1. The expense must still qualify under IRS and plan rules

  2. The LMN must meet all documentation requirements

  3. The claim must be eligible under the employer’s HRA plan design

An LMN only confirms medical necessity—it does not override eligibility rules.

What happens if my LMN is incomplete?

An LMN may be rejected if:

  1. Diagnosis is too vague

  2. Treatment is not clearly defined

  3. Dates of treatment are missing

  4. Provider signature or credentials are missing

  5. Document is undated or expired

If rejected:

  • You will be asked to submit a corrected LMN

  • The claim will remain unpaid until resolved

Do I need a new LMN every year?

Yes. A new LMN is required:

  1. Every plan year

  2. When treatment changes significantly

  3. When the original LMN expires

LMNs cannot be used indefinitely across multiple years.

How do I submit an LMN?

  1. Obtain the LMN from your licensed healthcare provider

  2. Ensure it includes all required elements

  3. Combine it with your receipt or claim documentation (if applicable)

  4. Upload it through your Take Command Health portal with your expense submission

  5. Submit for review

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