Yes, organ donation and transplant services are eligible for reimbursement with a Flexible Spending Account (FSA) or Health Savings Account (HSA) when the procedures are performed for medical care and are not reimbursed by insurance or another source.
Why Are Organ Donation and Transplant Services FSA/HSA Eligible?
Organ transplant procedures are recognized as qualified medical expenses under IRS Code Section 213(d) because they are performed to treat serious or life-threatening medical conditions. Covered expenses include the medical care involved in the transplant, as well as certain costs related to the donor.
According to IRS Publication 502, you can use FSA or HSA funds for the medical expenses of a donor or potential donor, if the procedure is performed for the benefit of the account holder, their spouse, or eligible dependent. This includes surgery, hospitalization, and related care.
FSA- and HSA-eligible transplant-related expenses may include:
Evaluation, surgery, hospitalization, and post-operative care for organ recipients
Medical care for organ or bone marrow donors (when done for the recipient's benefit)
Prescription medications related to the transplant, such as immunosuppressants
Diagnostic testing and lab work before or after surgery
Follow-up care, monitoring, and specialist visits
- Certain associated travel and lodging costs (subject to IRS limits)
What’s Not Covered?
The following are not eligible:
Costs covered by insurance or another reimbursement source
Donor compensation (e.g., financial payments made to a donor)
Travel, lodging, or meals exceeding IRS limits or unrelated to medical necessity
Funeral expenses for donors or recipients
Cosmetic procedures unrelated to the transplant
To be eligible, the services must be medically necessary and related to the treatment of the recipient, not elective or experimental in nature.
How to Use Your FSA or HSA for Organ Donation and Transplant Services
You can use your FSA or HSA card to pay for transplant-related expenses directly through your medical provider or transplant center. If you pay out of pocket:
Request itemized bills from all providers (hospital, surgeon, labs, pharmacy, etc.)
Confirm that any donor-related expenses are clearly tied to the recipient’s care
Submit documentation to your FSA or HSA administrator if reimbursement is required
For more detailed information, refer to IRS Publication 502.
