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Can I request reimbursement from the HCSAccount program for services I receive before the Plan Year begins if I am not billed until after the Plan Year starts?

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Can I request reimbursement from the HCSAccount program for services I receive before the Plan Year begins if I am not billed until after the Plan Year starts?

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No. According to IRS guidelines, a qualified expense is incurred at the time the service is provided, not when you are billed (or charged) or actually pay for this service. Therefore, reimbursements made during a Plan Year are only made for eligible expenses incurred during that same Plan Year. Can health care services that require up-front payment to the provider be reimbursed from the HCSAccount in a single Plan Year, even if the health care is delivered over several Plan Years (e.g. orthodontia)? No. IRS regulations do not allow medical expenses to be reimbursed through a health flexible spending account until they have been incurred. Expenses are not incurred until treatment is provided to the participant, regardless of when the participant pays the provider.

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