Responding to LMN Denial Based on "MD Signature" Requirement

An HSA/FSA administrator denies a claim because the Letter of Medical Necessity (LMN) wasn’t signed by a medical doctor (MD).

When this happens, we aim to educate the administrator—via the customer—that an MD signature is not required under IRS regulations.

What to communicate:

• IRS guidance does not mandate that an LMN be signed specifically by an MD.

• Any licensed healthcare provider who is legally authorized to diagnose and treat medical conditions—such as a Nurse Practitioner (NP), Physician Assistant (PA), or Doctor of Osteopathy (DO)—can issue a valid LMN.

• The LMN provided meets these criteria: it's issued by a licensed provider in the customer’s state, includes a diagnosis, treatment rationale, and clearly explains how the expense qualifies under IRS Publication 502 and CARES Act provisions.

• The customer should request that their administrator reassess the claim under the correct interpretation of IRS rules.

We always aim to resolve the issue at this stage without escalating to MD signature, unless absolutely necessary.

If the administrator continues to deny the claim after the customer resubmits with the clarification above:

• Let the customer know we’ll escalate.

• Internally, route the case to have the LMN re-issued by a licensed MD.

• Tell the customer that the re-issued LMN (signed by an MD) will be available for download within their portal at Truemed.com .

• IRS Publication 502 does not specify that a medical doctor (MD) must sign LMNs.

• The determining factor is whether the signer is a legally recognized healthcare provider authorized to diagnose and recommend treatment.

• Some administrators enforce stricter internal documentation rules, but those are preferences—not requirements under IRS law.

Always attempt to resolve these cases by correcting misapplication of IRS rules. Only escalate to an MD signature when absolutely required.