SIMERPU RESEARCH · SOURCE RECAP
IRS alert: Beware of companies misrepresenting nutrition, wellness and general health expenses as medical care for FSAs, HSAs, HRAs and MSAs
SIMERPU recap and commentary: Mardy Gould
Opened — main text retrieved
Quick recap
Warns against treating general nutrition, wellness and health purchases as medical expenses for tax-favored spending accounts. Includes an example involving a general-health food claim.
SIMERPU’s viewpoint
The IRS alert illustrates why a general wellness benefit and a qualifying medical expense should be described carefully. SIMERPU would use it to test the purpose and support for a claimed reimbursement, without treating an archival news release as a complete analysis of every arrangement. Employee access to helpful services can be discussed alongside that separate tax question.
What this source contributes
The alert offers a concrete illustration of why a general-health purchase should not automatically be described as a medical expense.
What remains unanswered
An archival alert is not a complete evaluation of every service, spending account or payroll arrangement.
Mardy Gould’s take
I want employees to understand that a service can be worthwhile without every payment for it receiving the same treatment. I would ask what the service is used for and what supports the reimbursement. That keeps the discussion practical and helps avoid turning a broad wellness promise into an unsupported payment claim.
Questions I would bring to the conversation
1. What is the purpose of the expense?
2. What documentation supports that purpose?
3. Which separate rules govern the arrangement paying the reimbursement?
Mardy Gould · Co-Founder, SIMERPU →
What would change our assessment?
Specific facts about medical purpose and the payment arrangement could change the assessment of an individual expense.
Read the original source
The original author and publisher are credited below. Continue to their article, document or source page for the complete context.
Original Author: Internal Revenue Service
Publisher: IRS
Original Publication Date: 2024-03-06
Read this alongside…
Each connection has a specific purpose. Compare the sources’ facts, positions and publication dates as you read.
Frequently asked questions about medical expenses related to nutrition, wellness and general health
IRS
Source position: Neutral / explanatory
Read the IRS’s examples across nutrition, therapy and general wellness.
Read the SIMERPU recap →
26 CFR §1.105-2 — Amounts expended for medical care
eCFR / Office of the Federal Register
Source position: Neutral / explanatory
Connect medical-purpose questions to the reimbursement regulation.
Read the SIMERPU recap →
Wellness and the Tax Law
Georgia Law Review
Source position: Neutral / explanatory
Explore the broader policy debate over the medical-care and wellness boundary.
Read the SIMERPU recap →
Keep learning with SIMERPU
Build your understanding with learning resources, the free Professional Roadmap and our approach to reviewing sources.
About this source
Original Updated Date: Not stated
Source Type: Government — public guidance
Model Discussed: Tax treatment of nutrition and wellness expenses
Position: Neutral / explanatory
Period: Recent — 2023–2026
Retrieved: October 31, 2026
Research and date notes
IR-2024-65. IRS labels this an archival/historical news release; no assumption of current-law completeness.
Each record identifies the material retrieved. SIMERPU’s viewpoint and Mardy Gould’s take are editorial commentary; the source-position label describes the original source’s stance. Read the original and its qualifications when evaluating a particular arrangement.
SIMERP
U
™
Understand the details. Lead with confidence.
© 2026 SIMERPU.