How to Use FSA Funds for Egg and Embryo Freezing

A practical guide to what’s eligible, what’s not, and how to plan ahead

Fertility preservation—such as egg freezing and embryo freezing—is increasingly common, but it can also be expensive and confusing to finance. One question many patients ask is:

Can I use my FSA (Flexible Spending Account) to pay for egg or embryo freezing?

The short answer: sometimes, yes - but it depends on medical necessity and documentation. Below is a practical guide to help you understand how FSAs work, what’s typically eligible, and how to maximize your benefits.

What Is an FSA?

A Flexible Spending Account (FSA) is an employer-sponsored, pre-tax account that allows you to set aside money for qualified medical expenses.

Key features:

• Funded with pre-tax dollars

• Annual contribution limits (set by the IRS each year)

• Use-it-or-lose-it (most FSAs do not roll over in full)

• Covers a wide range of IRS-defined medical expenses

FSAs are governed by IRS rules, not by individual clinics.

Are Egg Freezing and Embryo Freezing FSA-Eligible?

1. Medically Necessary Fertility Preservation

Egg or embryo freezing may be FSA-eligible when it is deemed medically necessary.

Common examples:

• Fertility preservation prior to cancer treatment

• Fertility impact from endometriosis, autoimmune disease, or surgery

• Premature ovarian insufficiency or diminished ovarian reserve

• Gender-affirming care that may affect fertility

In these cases, FSAs often require:

• A Letter of Medical Necessity (LMN) from a licensed physician

• Clear documentation that the procedure is intended to preserve fertility due to a medical condition

Eligible expenses may include:

• Ovarian stimulation monitoring

• Egg retrieval procedures

• Anesthesia

• Lab fees related to fertilization (for embryo freezing)

• Initial cryopreservation fees

2. Elective or Preventive Egg Freezing

If egg or embryo freezing is done for personal, lifestyle, or timing reasons (for example, delaying childbearing without a diagnosed medical condition), it is usually not FSA-eligible.

That said:

• Some ancillary expenses may still qualify

• FSA administrators interpret rules differently

• Documentation matters

Expenses That Are Often FSA-Eligible (Even If the Procedure Isn’t)

Even when the freezing itself is not covered, FSAs often reimburse related medical services, such as:

• Fertility testing and diagnostics(bloodwork, ultrasounds, AMH tests)

• Physician consultations

• Medications prescribed by a doctor

• Anesthesia and procedural fees

• Lab work connected to diagnosis or treatment

Each expense is reviewed line by line, not as a bundle.

What About Storage Fees?

This is one of the most misunderstood areas.

• Initial cryopreservation fees may be eligible if the procedure is medically necessary

• Ongoing annual storage fees are often not eligible, especially if they are for future, elective use

• Some administrators allow short-term storage tied to active treatment, but long-term storage is commonly excluded

Always check with your specific FSA administrator.

How to Use Your FSA for Egg or Embryo Freezing (Step by Step)

Step 1: Talk to Your Clinic Early

Ask:

• Can you provide a Letter of Medical Necessity?

• Can billing be itemized (rather than bundled)?

• Are diagnosis codes included on invoices?

Itemization dramatically increases the chance of reimbursement.

Step 2: Confirm With Your FSA Administrator

Before paying, ask your FSA provider:

• Which CPT or expense categories are eligible?

• Is an LMN required?

• Can medications be reimbursed separately?

Get confirmation in writing when possible.

Step 3: Pay Strategically

Best practices:

• Use your FSA card for clearly eligible expenses

• Pay out of pocket for unclear items, then submit claims selectively

• Save all invoices, prescriptions, and LMNs

Step 4: Submit Claims Promptly

FSAs have strict deadlines. Missing documentation or late submission is one of the most common reasons claims are denied.

FSA vs HSA: Important Distinction

If you have an HSA (Health Savings Account) instead of an FSA:

• HSAs are generally more flexible

• Funds roll over indefinitely

• Many people find HSAs easier to use for fertility-related expenses

However, HSAs still follow IRS medical-necessity rules.

What If Treatment Is Done Outside the U.S.?

FSAs may reimburse medical expenses incurred abroad if:

• The procedure would be considered eligible if done in the U.S.

• Documentation is clear and translated

• Payments are itemized

This is administrator-specific and often requires extra review.

Common Mistakes to Avoid

• Assuming bundled IVF packages are fully reimbursable

• Skipping the Letter of Medical Necessity

• Using FSA funds for long-term storage without approval

• Waiting too long to submit claims

• Not itemizing medication costs separately

Final Takeaway

Using FSA funds for egg or embryo freezing is possible, but it requires:

• Understanding medical necessity rules

• Proactive documentation

• Strategic billing and submission

For many patients, FSAs can meaningfully reduce out-of-pocket costs—especially when used thoughtfully alongside insurance, HSAs, or employer fertility benefits.

Disclaimer:

This article is for informational purposes only and does not constitute tax or legal advice. Eligibility for FSA reimbursement depends on IRS rules and your individual plan administrator. Always confirm with your FSA provider.urney to parenthood may be closer than you think.