According to IRS Publication 502 and 2023 IRS guidance, exercise and supplements can qualify for HSA or FSA spending with a Letter of Medical Necessity tying the intervention to the prevention or reversal of a specific condition. Additionally, food interventions can qualify when the food is recommended by a doctor, prevents or reverses a specific condition, and is supplemental to the patient’s normal diet. Again, the IRS has explicitly confirmed that this guidance hasn’t changed. At a recent industry conference, an IRS official explicitly said Truemed’s process follows existing law - but continued giving her opinion that HSA/FSA coverage for food and exercise should be rare.