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 84 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.
“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 →“We'll give you a superbill/itemized receipt/invoice to submit themselves for reimbursement”
Promotes HSA/FSA payment via superbill/receipt submission
From the William Cole scan →“broken free from the limiting approach of 'standard care'”
Frames non-acceptance of insurance as avoiding 'standard care' limitations
From the William Cole scan →“This program in general is considered to be above standard care and therefore elective as far as the insurance industry is concerned.”
Insurance industry: Claims functional medicine is 'above standard care' and 'elective', implying insurance won't cover it because they 'don't want you well'
From the William Cole scan →“Please be aware that we do not accept insurance.”
Explicitly states they do not accept insurance, framing it as a commitment to exceptional care.
From the Todd Vincent Farney scan →“particularly in chronic and previously treatment-resistant cases”
Implies their 'root-cause' approach is for 'previously treatment-resistant cases,' suggesting insurance-covered care failed.
From the Todd Vincent Farney scan →“do not accept insurance”
Does not bill/accept private insurance (cash-pay)
From the Todd Vincent Farney scan →“we do not accept insurance”
Cash-based practice, so Medicare/Medicaid are not billed (government programs are insurance)
From the Todd Vincent Farney scan →“we do not accept insurance”
Private Insurers: Claims they do not accept insurance, implying their services are not covered or recognized.
From the Todd Vincent Farney 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 →“Direct Primary Care Provider”
Promotes 'Direct Primary Care' which is inherently cash-based and not covered by insurance.
From the Tanner Wilson scan →“Functional and longevity medicine should be effective, precise, and affordable—not overwhelming or out-of-reach”
Insurance companies: Claims their care is 'not overwhelming or out-of-reach' and implies standard care is 'reactive' and insufficient.
From the Tanner Wilson scan →