Yes, transgender counseling and gender-affirming surgery are eligible for reimbursement with a Flexible Spending Account (FSA) or Health Savings Account (HSA) when they are used to treat gender dysphoria or a related medical diagnosis.
Why Is Transgender Counseling or Surgery FSA/HSA Eligible?
Gender-affirming care, including mental health counseling and surgical procedures, is considered medically necessary treatment for individuals diagnosed with gender dysphoria or gender identity disorder. Under IRS Code Section 213(d), medical expenses must be incurred primarily for the diagnosis, treatment, or prevention of a disease or condition to qualify as reimbursable.
According to IRS Publication 502, medical care for the purpose of treating a diagnosed mental or physical condition is eligible. This includes therapy and surgeries related to gender dysphoria when recommended by a licensed healthcare provider.
FSA- and HSA-eligible transgender-related expenses may include:
Mental health counseling with a licensed therapist or psychiatrist
Hormone replacement therapy (HRT) prescribed by a medical provider
Gender-affirming surgeries (e.g., chest/top surgery, facial feminization, genital reconstruction)
Lab work and imaging related to treatment
Pre- and post-operative care
Medical devices and supplies associated with recovery
- Associated prescription medications
What’s Not Covered?
The following are not eligible:
Procedures performed strictly for cosmetic reasons without a medical diagnosis
Travel, lodging, or meals associated with care unless they separately qualify under IRS rules
Non-medical support services not provided by a licensed healthcare professional
Elective procedures not part of a treatment plan for gender dysphoria or a covered mental health condition
To qualify, care must be related to the treatment of a diagnosed condition and provided by a licensed professional.
How to Use Your FSA or HSA for Transgender Counseling or Surgery
You can use your FSA or HSA card to pay for qualifying therapy sessions, procedures, and medications. If you pay out of pocket:
Save itemized invoices and receipts for each service
Ensure treatments are documented as part of a care plan for a medical condition
Submit documentation to your plan administrator if required
For more information, refer to IRS Publication 502.
