The FSA/HSA loophole
A recurring pattern in the scans: services insurance will not cover, sold as reimbursable through your FSA or HSA, by practices that quietly refuse Medicare and Medicaid.
What the scans show
Across 110 doc bros whose payment and insurance posture was assessed.
There are two ways FSA and HSA money reaches a practice, and they are not the same. Swiping an FSA or HSA card at checkout moves the money at the point of sale, with no claim filed and little review at the moment of payment. Submitting a receipt or superbill for reimbursement creates a record that an administrator, and the account holder, can examine against the rules for qualified expenses. Steering patients toward the card and away from the reimbursement route is the quieter path. It is the difference between a transaction that just happens and one that someone might question.
Put the pieces together and the structure is striking. The practice funnels a patient into a service, then points that patient at their own tax advantaged account to pay for it. The patient, not the practice, becomes the party who interfaces with the government's tax benefit and who is on the hook for whether the expense qualifies. The practice has inserted a cutout between itself and the public funds. It reaches tax advantaged dollars it could not have billed for directly, while the patient carries the substantiation risk and the government program never sees a claim it could scrutinize.
Seen in the wild
Representative notes and quotes pulled from analyzed scans.
“This is a concierge service for people who are ready to go deep on their health and finally get the answers they’ve been looking for. No more guessing, this is your last stop.”
Practice is cash-pay / concierge with no insurance billing
From the Stephen Cabral scan →“We take the time conventional medicine won't.”
Practice is cash-only and does not accept insurance, framing it as a way to avoid bureaucracy.
From the Anna Payne scan →“A half-hour consultation is $100”
Cash-only consults and treatments not covered by insurance
From the Joshua James Redd scan →“Starting at Momentum Health is simple. We make it easy to get the information you need and get booked with the right doctor for your situation.”
Practice is cash-only and does not accept insurance.
From the Todd A Anderson scan →“We operate outside insurance so pricing is clear and predictable. Many students use HSA/FSA funds. Check with your plan administrator. We provide an itemized receipt.”
Explicitly states they operate outside insurance and provide itemized receipts for HSA/FSA reimbursement.
From the Josh Axe scan →“Accessible pricing. Transparent memberships and flexible financing keep high-level functional medicine within reach”
Explicitly states they do not accept insurance and offer 'transparent memberships'.
From the Tanner Wilson scan →“Insurance may cover some testing and services but not all. This program in general is considered to be above standard care and therefore elective as far as the insurance industry is concerned.”
Explicitly states 'We do not accept insurance' and that functional medicine is 'above standard care' and 'elective'
From the William Cole scan →“Our network of Health Restoration Clinics that think and act differently to solve the health challenges others can’t.”
The clinic is a cash-pay network of 'Health Restoration Clinics' that does not bill insurance.
From the Patrick Flynn scan →“I've created tools, books, and programs so women everywhere can have access to the information they're not being given anywhere else.”
The practice is cash-only, not accepting insurance, and promotes FSA/HSA as a payment method.
From the Jolene Brighten scan →“We do not accept insurance. And, here's why. Insurance companies decide how long and what type of care physicians can provide to their patients.”
Explicitly states they do not accept insurance or Medicare, framing it as avoiding limits on care.
From the Gloria Hamada scan →“Dr. Josselson sees patients in her New Jersey office. Phone and Zoom consultations are now available for all appointments.”
Cash-only practice with no insurance billing.
From the Melissa Josselson scan →“All for less than it would cost to meet my deductible”
Cash-only practice that does not accept insurance
From the Momentum Health & Wellness Minnesota scan →