Do orthodontic expenses have to have been incurred to be eligible for reimbursement from a medical FSA?
A. No, they do not, but the patient must be receiving a course of orthodontic, treatment related to the expense. Orthodontic expenses may be reimbursed when actual payments have been made, even if the services have not been rendered. Orthodontic expenses typically are payable to the orthodontic at the onset of treatment or through an installment-based treatment plan. This is an exception to the general rule that pertains to Medical FSAs.
No. Orthodontic expenses do not need to have been incurred to be eligible for reimbursement, but the patient must be receiving orthodontic treatment related to the expenses. The IRS informally recognizes the billing practice specific to orthodontic treatment, and informal IRS opinions indicate that orthodontic expenses may be reimbursed when payments have been made, even if the services have not been rendered. This position is an exception to the general rule pertaining to FSAs.
