Yes, medical fees for an adopted child are eligible for reimbursement with a Flexible Spending Account (FSA) or Health Savings Account (HSA), as long as the child qualifies as your tax dependent.
Why Are Medical Fees for an Adopted Child FSA/HSA Eligible?
Medical expenses are considered eligible for FSA and HSA reimbursement under IRS Code Section 213(d) if they are incurred by you, your spouse, or a dependent. According to IRS Publication 502, a legally adopted child or a child who has been lawfully placed with you for adoption is considered a dependent—even if the adoption has not been finalized.
Once the child meets the IRS definition of a dependent, their eligible medical expenses may be reimbursed through your FSA or HSA. This includes expenses related to:
Doctor and hospital visits
Immunizations and well-child checkups
Prescription medications
Vision and dental care
Mental health counseling and therapy
Over-the-counter medicine and medical supplies that qualify as healthcare expenses
What’s Not Covered?
The following are not eligible for FSA or HSA reimbursement:
Legal fees, agency costs, or court costs associated with adoption
General childcare, babysitting, or educational expenses
Medical expenses for a child who has not been lawfully placed with you or does not yet qualify as your dependent
While the adoption process itself is not a medical expense, once a child is under your legal care and meets IRS dependency rules, their qualifying medical expenses are covered just like any biological child.
How to Use Your FSA or HSA for Medical Fees for an Adopted Child
Once your adopted child is considered a dependent:
Use your FSA or HSA card at checkout for eligible medical expenses
Save your receipts and any documentation showing the child’s dependent status
If your plan administrator requests verification, provide a placement letter or documentation showing legal guardianship or adoption status
You can also browse buyFSA.com to purchase pre-approved medical products for your family—all items listed are verified as FSA- and HSA-eligible.
For further details on dependent eligibility and medical expenses, refer to IRS Publication 502.
