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Are lab panels and biomarker tests eligible?

🧬 Lab panels / biomarker testing

A plain blood panel is the easy case — diagnostic testing sits squarely inside §213(d) medical care. The interesting part of this category is not the panel; it is the box the panel sometimes arrives in.

How the reference data classifies this category

Is it medical care at all? (§213(d))
Partly

Only part of the cost, or only in a narrow case.

Will the card go through? (custodian practice)
Yes

Reimbursable without a letter.

Deductible on Schedule A? (a different rule)
Partly

Only part of the cost, or only in a narrow case.

🧬 Lab panels / biomarker testing

Partly medical careYes card / claim deskPartly Schedule AIRS authority

Diagnostic testing is squarely §213(d) medical care. The wrinkle is bundled consumer kits: a 2019 private letter ruling split a DNA kit between its medical (genotyping, lab services) and non-medical (ancestry) components and required an allocation of the price. A private ruling binds only the taxpayer who asked for it. A plain blood panel is the easy case.

Source: IRS Pub. 502 ↗ · custodian / plan-administrator practice — not IRS authority

Classification is at the expense-category level, comes from this project's HSA reference data, and is not a Magellan determination about any individual product. Your plan administrator decides what your plan reimburses.

The bundled-kit problem

In 2019 a private letter ruling split a consumer DNA kit between its medical components — genotyping, laboratory services — and its non-medical components, such as an ancestry readout, and required the price to be allocated between them. Only the medical portion counted. A private letter ruling binds only the taxpayer who requested it and is not precedent for anyone else, but the reasoning tells you exactly what shape of product creates the question.

The practical test: is the thing you bought only a lab result? If a kit sells you a lab result plus something that is not a lab result — a coaching subscription, a lifestyle report, an ancestry panel — then there is an allocation question sitting inside the price, and your administrator will have a view on it. A single-analyte mail-in panel does not have that problem.

Why this category is worth spending a balance on

Each test in this catalogue is linked to the peer-reviewed literature on what the marker actually predicts, which is a separate question from whether you can pay for it with pre-tax money. Lp(a) is arguably a once-in-a-lifetime test; ApoB is the number to ask for; hs-CRP is the one most often over-read. Read those before you read a price.

Where this lands in the catalogue

The catalogue's diagnostic tests, each linked to the research on what the marker predicts. The classification above is at the expense-category level and is not a determination about any individual kit — in particular, bundled consumer kits raise the allocation question described above.

ApoB Home Test Kit

18 PubMed citations · $79

Large Mendelian randomization studies, prospective cohorts and meta-analyses — in one pooling…

Lp(a) Mail-In Test

19 PubMed citations · $152

Large meta-analyses, prospective cohorts, and Mendelian randomization studies establish…

hs-CRP Inflammation Test

19 PubMed citations · $99

Across large prospective cohorts and meta-analyses, higher hs-CRP is consistently associated…

Omega-3 Index Test

22 PubMed citations · $54.95

In prospective cohort studies and pooled analyses spanning dozens of cohorts, higher blood…

Fasting Insulin / HOMA-IR Kit

16 PubMed citations · $79.99

Higher fasting insulin and HOMA-IR reflect greater insulin resistance, a central feature of…

Cystatin C / eGFR Kidney Test

18 PubMed citations · $55

Across large cohorts and meta-analyses, cystatin C-based eGFR is at least as accurate as…

See all Diagnostics & Epigenetic Tests →

What a letter can and cannot do here

The reference data records the card answer for lab testing as yes and the medical-care answer as partial — the partiality is the bundling problem, not a letter problem.

Whatever the category, three limits hold on every letter:

  • Submitting a letter is not approval. Your plan administrator makes the final call, and the IRS can look at it later.
  • A letter cannot make an ineligible expense eligible. It only documents medical necessity where the rules already leave room — protein powder stays out no matter who signs what.
  • Your own treating physician is the right person to ask, because they have the chart. That is not a formality; it is the whole basis on which the letter has any value.

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Education only — not tax, legal or medical advice. Magellan does not decide what your plan will reimburse, and Magellan does not write, sign, sell, review or arrange Letters of Medical Necessity. Eligibility depends on your own plan documents and your own circumstances: confirm with your plan administrator before you spend, and take tax questions to a tax professional. Figures on this page come from the IRS documents cited beside them; they change, so check the citation.