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HSA and FSA payments are already at fitness checkout. A client stops mid-transaction, card in hand, and asks: can I use my HSA for this? The coach has a clean answer or guesses. That moment is already happening at training studios and coaching practices every week. What follows shows whether this becomes a real revenue channel or a compliance problem.
While most fitness spending doesn’t qualify, some services do. The gating factor is the IRS standard for medical care. Health club dues purchased for general health and wellness don’t clear it. Similarly, broad wellness spending doesn’t meet the bar either. Although most people assume the rule changed in 2024, it did not. The IRS simply clarified what was already the law: wellness costs are not medical care for repayment simply because a business markets them that way.
However, specific cases do qualify. For example, amounts paid to lose weight count as medical care when treating a doctor-confirmed disease. Obesity, hypertension, and heart disease are named examples in the rule. As a result, separate fees for those weight-loss services may qualify even when gym dues don’t. That distinction is the foundation most HSA and FSA payment platforms build on. Since a licensed provider shows whether the service qualifies as medical care, the vendor’s clinical flow is what enables it. Consequently, services tied to a diagnosed condition are the strongest candidates. In other words, the distinction is not membership vs. personal training. It is purpose. Fitness spending for general health and wellness is not eligible. Fitness spending to treat a physician-diagnosed condition is.
Announcing first is how compliance problems start. The workflow below needs to be in place before a single client is told you accept HSA or FSA funds.
First, identify offers that clearly won’t qualify today. Ordinary memberships, wellness packages, and broad fitness access fall here. Second, identify offers that may qualify with clinical-need support. While standard memberships won’t qualify, personal training tied to a diagnosed condition and weight-management coaching may. Third, flag wait-for-PHIT offers: services that don’t qualify today but would if the law changes. Otherwise, both outcomes follow: checkout becomes harder to manage and the compliance posture for the whole business weakens.
Current HSA and FSA payment vendors generally support two paths. In the direct-card path, some purchases are pre-approved. The client pays at checkout with no Letter of Medical Necessity required. In the medical-necessity path, the client is routed through a provider review. They receive an LMN if appropriate, then pay directly or submit a repayment claim. For example, Flex and Truemed both describe this review-and-checkout layer as part of their merchant workflow. Therefore, repayment-first is the more realistic starting point for most coaching practices.
For instance, Truemed routes customers to a review at checkout. Flex handles compliance steps at checkout, including provider review when required. Flex also offers a repayment setup where clients start a review and submit claims if they qualify. However, not every vendor includes the clinical layer. A platform that skips it doesn’t remove the compliance requirement. Instead, it shifts the compliance exposure to you. Know that going in. Therefore, five things need to be confirmed before launch. Which offers are enabled. Whether the flow is direct-pay or repayment. How receipts are issued. What staff says when a client asks. What records the client must keep.
How a service is described matters directly under IRS rules. “12-week medically guided exercise support” is treated very differently from “summer shred package”, and not just stylistically. While IRS guidance focuses on whether an expense is for medical care, it says nothing about how the service sounds. The more lifestyle-oriented the offer framing, the weaker the compliance position. Since IRS scrutiny falls on purpose rather than presentation, the description needs to reflect the clinical rationale.
Eligibility is not automatic, and clients need to understand that before checkout. To illustrate, Flex advises customers to keep their LMN on file for at least three years for IRS audit purposes. Meanwhile, Truemed notes that LMNs are valid for 12 months and must be renewed annually. The client experience should include a plain explanation. Some services may qualify. An LMN may be required, receipts may need to be submitted, and approval depends on plan rules and IRS rules. After all, setting that message early protects both parties and keeps the HSA and FSA payment program defensible.
Word choice matters here. The right message is specific. For instance, some clients may qualify for HSA or FSA funds through a compliance partner. However, it depends on their plan and medical situation. The phrase they must never use: yes, your membership is HSA eligible. The IRS warned in 2024 against companies falsely treating general wellness expenses as medical care. In practice, one false promise at the front desk creates that exact problem. It is the compliance risk the entire vendor setup was built to prevent.
“Consumers may be able to use pre-tax dollars for certain fitness expenses when a healthcare provider diagnoses a specific disease or condition, prescribes physical activity as treatment, and documents it with a Letter of Medical Necessity. Platforms that integrate HSA and FSA payments can reduce friction for consumers in the purchasing process, and fitness brands should ensure they operate in full compliance with IRS rules governing qualified medical expenses.”
AMY BANTHAM, DrPH, CEO/Founder, Move to Live More
The PHIT Act would expand the tax code. PHIT stands for Personal Health Investment Today. It would add certain fitness spending as a qualified medical expense. While the 2025 House bill (H.R. 2369) and Senate bill (S. 1144) were both filed in March 2025, neither has been enacted. Although PHIT language was included in a 2025 House budget package, that inclusion did not make it law. As of April 2026, PHIT remains a proposed bill and has not changed current HSA and FSA payment rules.
For coaches, two things follow. First, don’t build the current workflow around a bill that isn’t law. Second, if PHIT eventually passes, the chance for ordinary memberships and classes to qualify could expand substantially. The studios that already have compliance systems in place will be ready to scale when that happens.
In practice, the named risk is announcing before the workflow is ready. Indeed, a business that builds it correctly and markets it right is protected. Instead, a business that tells clients their standard membership is HSA eligible without a clinical process is not. In practice, the rollout that works is clear. Offer services suited to clinical-need workflows. Use a vendor built for HSA and FSA compliance. Finally, train staff to describe it well, and market it as eligible for qualifying clients.
That approach to HSA and FSA payments is less flashy than a blanket claim. However, it is far more defensible. The question isn’t whether clients will ask about HSA and FSA payments. It’s whether your system can answer.
FOR OPERATORS BUILDING THIS CAPABILITY
Find coaches trained in compliance-forward client intake on FitHire by Coach360. Post your role today.
Can coaches accept HSA and FSA payments for personal training today?
In some cases, yes — and this applies to both personal training and memberships. The IRS is clear on this. For example, fitness expenses qualify when the sole purpose is treating a physician-diagnosed disease, such as obesity, hypertension, or heart disease. Instead, fitness spending for general health and wellness does not qualify. The distinction is purpose, not service type. Whether a specific expense qualifies depends on the client’s medical situation, the clinical record-keeping, and whether a compliant process is in place.
What is a Letter of Medical Necessity and why does it matter?
A Letter of Medical Necessity is paperwork from a licensed healthcare provider stating that a specific service is prescribed treatment for a diagnosed condition. In other words, for HSA and FSA payment purposes, it shows that an expense is for medical care rather than general wellness, which is the distinction IRS rules require. Finally, clients should keep their LMN on file for at least three years. LMNs are typically valid for 12 months and must be renewed annually.
Does the PHIT Act change HSA and FSA payment eligibility today?
No. As of April 2026, the PHIT Act (H.R. 2369 / S. 1144) remains proposed legislation. It has not been enacted into law. Instead, build the current workflow around existing IRS rules, not expected PHIT passage. If PHIT passes in the future, it would expand qualifying rules for ordinary memberships and classes that don’t currently qualify.
About Erin Nitschke
Dr. Erin Nitschke, NSCA-CPT, NFPT-CPT, ACE Health Coach, ACE-CPT, Fitness Nutrition Specialist, Therapeutic Exercise Specialist, Pn1, FNMS, and DSWI Master Health Coach, is a seasoned college professor in health and human performance. She is a nationally recognized presenter, industry writer for IDEA, NFPT, Fitness Education Online, and Youate.com, and an active member of the ACE Scientific Advisory Panel. With extensive experience in health and exercise science, Erin specializes in holistic, evidence-based approaches to wellness. Her passion lies in empowering individuals to lead healthier, more vibrant lives through personalized coaching. Erin’s philosophy centers on education, accountability, and sustainable behavior change—guiding clients to achieve long-term success in nutrition, fitness, stress management, and overall well-being. To connect with Dr. Nitschke, email her at erinmd03@gmail.com or on Instagram: @nitschkeerin
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