The IRS added Q/A-15 on September 23, 2026, outlining when costs for wearable devices may qualify for reimbursement through a health flexible spending arrangement, health savings account or health reimbursement arrangement. The answer does not grant automatic approval because a product records health information.
The FAQ covers bands, watches, rings, patches, sensors and similar products that track bodily functions or other health-related information. It applies a facts-and-circumstances test to decide whether those costs count as medical expenses.
A device’s functions matter, as does the reason a person bought and uses it. A general wish to monitor health is not enough.
Reimbursement turns on a specific medical purpose and supporting facts
A product used for both medical and personal purposes does not qualify just because it tracks bodily functions. The FAQ identifies general wellness, fitness, sleep and other personal uses as examples. Tracking blood pressure or glucose alone also does not establish a medical expense, even when a disease can affect those readings.
The cost may qualify when someone buys and uses the device primarily to assist in the “diagnosis, cure, mitigation, treatment, or prevention of a specific disease.” The agency says the decision rests on “all the facts and circumstances, including the device's functions and why it was purchased and used.”
Relevant evidence can include a medical practitioner's recommendation, symptoms, a diagnosis, abnormal test results or risk factors. The review can also consider how closely the tracked information relates to the disease being evaluated or managed, and how someone reviews or uses that information.
A broad desire to monitor or improve health does not meet the test. The FAQ ties eligibility to a specific medical purpose, not merely to gathering health data.
The same standard applies to accessories, add-ons and software subscriptions. Those costs qualify only when they, too, were purchased primarily for a valid medical purpose.
EBIA’s analysis said this individualized review will generally make mixed-use products unsuitable for automatic approval through an inventory information approval system, or IIAS. It advised administrators to obtain adequate substantiation before reimbursing a claim. EBIA contributing editor and attorney John R. Hickman was credited on the analysis.
That review can require administrators to examine the claimed medical use and its evidence, rather than relying only on a product model or category.
The WEAR IT Act would create a separate $375 annual allowance
A separate proposal, H.R. 4203, would establish a specific allowance rather than use the FAQ’s case-by-case test. Rep. David Schweikert, a Republican from Arizona’s 1st District, introduced the “Wearable Equipment Adoption and Reinforcement and Investment in Technology Act,” or “WEAR IT Act,” on June 26, 2025. Rep. Ami Bera was its original cosponsor.
The bill went to the House Committee on Ways and Means. It would amend the tax code to treat qualifying costs as medical care, up to $375 per taxable year. The proposed changes cover health savings accounts under Section 223(d)(2), Archer medical savings accounts under Section 220(d)(2)(A), and health FSAs and HRAs under Section 106. The bill text sets out the proposal.
Its definition includes a device or software, including a subscription, worn on the body or primarily used with a worn device. The technology must collect and analyze physiological data for diagnosing, curing, mitigating, treating or preventing a disease, impairment or health condition, or help render a diagnosis or provide treatment, mitigation or cure.
The proposal sets different timing language by account type. For HSA and Archer MSA distributions, it would apply to amounts paid after December 31, 2025. For FSA and HRA reimbursements, it would cover expenses incurred after December 31, 2025.
Earlier wellness guidance also rejected general-health claims
The new answer joins an existing group of wellness-expense FAQs. In 2023, the agency issued guidance addressing gym memberships, nutritional counseling, weight-loss programs and food or beverages purchased for health reasons.
A 2024 agency news release reminded taxpayers and administrators that personal expenses for general health and wellness cannot be reimbursed through these arrangements. It also cautioned that a doctor’s note based on self-reported health information does not turn nonmedical food, wellness or exercise expenses into medical costs.
Dykema attorneys Amy Christen, Jillian Foerster and Tyler Hubert said devices that monitor sleep, glucose levels, blood pressure or other health information “aren't automatically eligible for reimbursement.” They said the guidance raises questions for employers and benefits administrators about medical necessity, documentation and reimbursement procedures.
H.R. 4203 remains separate from the FAQ. It has not passed the House or Senate, has not been presented to the President and is not law, according to its congressional legislative record.
This article is for informational purposes only and does not constitute tax advice. Consult a qualified tax professional or CPA about your specific situation.
