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Do Orthodontic Services Have to Have Been Incurred to Be Eligible for Reimbursement from a Medical FSA?

No, they do not, but the patient must be receiving a course of orthodontic, treatment related to the expense. Orthodontic expenses are reimbursed when actual payments have been made, even if the services have not been rendered. Orthodontic expenses typically are payable to the orthodontist at the onset of treatment or through an installment-based treatment plan. This is an exception to the general rule that pertains to Medical FSAs. 

The Orthodontic contract should be submitted with initial claim to show treatment plan. 

Note: Reimbursement for Orthodontia is to be made from the plan year in which the payment  was made. Example: A plan year that runs 1/1/2020-12/31/2020 Payment made in December 2020 will be reimbursed from the 2020 plan year. Payments made in January 2021 will be reimbursed from the 2021 plan year.