HSA/FSA & Account Types

HSA/FSA Accounts for Dependents

Who Counts as a Dependent?

For HSA and FSA purposes, the IRS recognizes three categories of people you can spend on behalf of:

  • Your spouse
    If you are married, you can use your HSA or FSA to pay for your spouse’s qualified medical expenses, even if your spouse is not enrolled in your health plan.
  • Qualifying children
    A child qualifies as a dependent if they meet the IRS definition, which generally means they are:
    • Under age 19 at the end of the tax year (or under age 24 if a full-time student)
    • Living with you for more than half the year
    • Not providing more than half of their own financial support
    • Not filing a joint tax return (with limited exceptions)
  • Qualifying relatives
    In some cases, other individuals you financially support — such as a parent or sibling — may qualify as a dependent under IRS rules. If they meet the criteria for a qualifying relative, you can generally use your HSA or FSA for their eligible medical expenses.

Tax dependency rules can be nuanced. If you are unsure whether someone qualifies as your dependent for HSA/FSA purposes, consult a tax advisor or review IRS Publication 502.

How It Works in Practice

HSA You can use your HSA funds for your own expenses, your spouse’s expenses, or any qualifying dependent’s expenses, even if that person is not covered under your High-Deductible Health Plan. The funds simply need to be spent on a qualified medical expense for an eligible individual.

Health Care FSA The same rules apply: your FSA can be used for eligible medical expenses for you, your spouse, and your qualifying dependents. There is no need to set up separate accounts.

Only the account holder (or their spouse on a shared FSA) can make spending decisions from the account. Dependents cannot access or spend from your account directly.

Using Truemed for Dependent Purchases

Truemed can sometimes be used for purchases that are medically appropriate for a qualifying dependent, not just the account holder. The key requirement is that the purchase is medically necessary for the specific individual it is intended to benefit.

Support for minors depends on the merchant and product
Truemed can issue LMNs for minors at some merchant partners, but not all. Whether this is supported depends on the type of products being purchased.

If purchases on behalf of a minor are eligible, the option will appear in the health intake survey during checkout. If you do not see it, LMN issuance for a minor is not supported for that product or merchant. In that case, you may need to obtain an LMN for your minor directly from their PCP or pediatrician.

Who completes the health intake survey

  • If your dependent is under 18, you (the account holder) can complete the health intake survey on their behalf.
  • If your dependent is 18 or older, they must complete their own survey independently.
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Purchasing for both a minor and an adult in the same order If you are buying products for both a minor and an adult, you will need to split the order into two separate purchases and obtain two separate LMNs in order to qualify both.

Here is how the process works once Truemed support is confirmed for your dependent:

  1. Complete the health intake form on your dependent’s behalf, providing their health information
  2. An independent, licensed clinician reviews the intake and determines whether the purchase is medically necessary for that individual
  3. If it qualifies, an LMN is issued and you pay using your HSA or FSA card as normal

The LMN documents medical necessity for the specific person the purchase is for, which is what makes the transaction IRS-compliant.

Common Questions

Q: Can I use my HSA/FSA for my adult child who is still on my health insurance?
A: It depends on their tax status. Under the Affordable Care Act, you can keep a child on your health insurance until age 26. However, for HSA/FSA purposes the child must qualify as your tax dependent. An adult child who files their own taxes or supports themselves financially generally does not qualify, even if they remain on your health plan.

Q: My spouse has their own HSA. Can we each spend on the other?
A: Yes. Each spouse can use their own HSA for the other’s qualified medical expenses.

Q: Can I use my Dependent Care FSA for my child’s medical expenses?
A: No. A Dependent Care FSA covers childcare costs only (daycare, preschool, after-school programs). For a child’s medical expenses, use your Health Care FSA or HSA instead.

Q: Truemed does not show an option for my minor in the intake survey. What should I do?
A: If the option to request an LMN for a minor does not appear during checkout, it means that merchant or product type is not currently supported through Truemed for minor dependents. You can reach out to the child’s PCP or pediatrician to obtain an LMN directly, or contact support@truemed.com for guidance.

Questions?