How to Pay for FreeAir Coach with Your FSA or HSA

Quick answer — the 4 steps

1. Subscribe to FreeAir Coach (any tier) at freeaircoach.com/#pricing.
2. Email admin@freeaircoach.com with subject line “FSA/HSA Documentation.”
3. We send you (a) an itemized receipt, (b) a signed program-description letter, and (c) an LMN template to bring to your own physician if your plan requires a Letter of Medical Necessity — no charge.
4. Submit both to your FSA/HSA administrator. Most reimbursements clear in 2–3 weeks.

If your administrator denies the first submission, see section 10 — most denials are paperwork issues, not eligibility issues, and reverse on first appeal.

What IRS Code §213(d) actually says

The relevant federal authority for whether a medical expense qualifies for tax-advantaged FSA, HSA, or HRA reimbursement is 26 U.S. Code §213(d) — the section of the Internal Revenue Code that defines “medical care.” The IRS’s implementing guidance lives in IRS Publication 502, which lists qualified medical expenses for personal income-tax purposes. The Publication 502 list is the working document FSA and HSA administrators reference when deciding whether to reimburse a claim.

Smoking-cessation programs were explicitly added to the qualified-medical-expense list in 2002 (IRS Revenue Ruling 2002-19), and have remained on the list every year since. The current Publication 502 language reads:

The nicotine-gum-without-prescription carve-out has since been overridden by the CARES Act (2020), which restored over-the-counter NRT to the eligible-expense list. So as of 2026, both the underlying cessation program AND the over-the-counter NRT a user buys are FSA/HSA eligible. See section 8 for the full list of eligible adjacent expenses.

Why FreeAir Coach qualifies

FreeAir Coach is a structured smoking cessation program. The defining elements:

• Evidence-based behavioral counseling. The in-app curriculum is grounded in Cognitive Behavioral Therapy (CBT), Motivational Interviewing, and Acceptance and Commitment Therapy (ACT) — the same three pillars the U.S. Public Health Service Clinical Practice Guideline (Fiore et al., 2008) names as the evidence base for behavioral cessation programs.
• Physician clinical direction. The program was developed and is clinically directed by Dr. Eskender Beyene, MD, FCCP — a board-certified pulmonologist who treats smoking-related lung disease in active clinical practice.
• 24/7 personalized coaching. Users receive on-demand AI-powered cessation coaching grounded in the same clinical knowledge base, plus craving logging, structured quit planning, lung recovery tracking, and the DEADS craving-management protocol.
• Treats a recognized medical condition. Tobacco Use Disorder is a defined medical diagnosis (DSM-5, ICD-10 F17.x). FreeAir Coach is a treatment program for that condition.

FreeAir Coach is not a wellness gimmick or generic mindfulness app — it is a structured cessation program that meets the same definitional criteria the IRS, Public Health Service, and CDC apply when they describe a “cessation program.”

Step-by-step FSA reimbursement walkthrough

Flexible Spending Accounts (FSAs) are employer-administered, which means your specific reimbursement workflow depends on which third-party administrator (TPA) your employer contracts with — HealthEquity, WageWorks, Optum Financial, Navia, and BenefitWallet are the largest. The mechanics differ slightly by TPA but the documentation requirements are essentially identical.

1. Subscribe and pay. Purchase any FreeAir Coach plan (Monthly $9.99, Annual $79.99, or Lifetime $149) at freeaircoach.com/#pricing using your personal payment method. Do not use the FSA debit card directly — most FSA debit cards do not yet recognize app-based cessation programs as a merchant-category match, and the transaction will be rejected at the point of sale. Pay personally first, then reimburse.
2. Request documentation. Email admin@freeaircoach.com with the subject line “FSA/HSA Documentation,” the email associated with your FreeAir Coach account, and your full legal name (must match your FSA records). You’ll receive: (a) an itemized receipt with date, amount, and a service-description line that reads “Smoking cessation program subscription — FreeAir Coach,” (b) a signed program-description letter, and (c) an LMN template for your own physician to review and sign if your plan requires one. (A Letter of Medical Necessity certifies medical necessity for you specifically, so it should come from a clinician who treats you — FreeAir Coach does not create a physician-patient relationship.)
3. File the claim. Log into your FSA administrator’s portal. Find the “Submit a claim” or “Reimburse myself” flow. Attach both PDFs. Categorize the claim as “Smoking cessation” or “Tobacco cessation” if those are options; otherwise “Other medical” with a note referencing IRS Publication 502.
4. Track the claim. Most TPAs settle within 5–10 business days. Reimbursement arrives via direct deposit to the bank account on file or a paper check.
5. If denied, see section 10. Most denials are paperwork issues that resolve on first appeal.

Step-by-step HSA reimbursement walkthrough

Health Savings Accounts (HSAs) are personal accounts, not employer-administered, which means the reimbursement workflow is simpler — you don’t need approval from a third-party administrator. You do still need to keep documentation in case the IRS audits you, since HSA disbursements for non-qualified expenses incur both income tax and a 20% additional tax.

1. Pay out-of-pocket first. As with FSA, pay personally and reimburse yourself rather than using the HSA debit card directly — merchant-category coding for app-based cessation is inconsistent.
2. Request documentation. Same email as FSA: admin@freeaircoach.com, subject “FSA/HSA Documentation.” You’ll receive the itemized receipt, program-description letter, and LMN template for your physician.
3. Reimburse yourself from the HSA. Log into your HSA bank’s portal and either initiate a distribution to your linked checking account or request a check. Categorize as “Qualified medical expense.”
4. Save the receipt and documentation forever. The IRS can audit HSA distributions years after the fact. Save the itemized receipt and LMN in your tax records permanently. We recommend a dated PDF folder labeled by tax year.

HSA reimbursements are tax-free at the federal level (and in nearly all states — California and New Jersey treat HSA contributions differently for state income tax, but the qualified-medical-expense list is the same). You don’t need to claim the reimbursement on your tax return; the HSA bank handles the IRS reporting.

Letter of Medical Necessity template

Because an LMN certifies that an expense is medically necessary for you specifically, it should be signed by a clinician who actually treats you — your primary care physician, pulmonologist, or other prescriber. FreeAir Coach provides this ready-to-sign template you can bring to your appointment; your doctor reviews, personalizes, and signs it.

Many administrators accept this format without revision. If your administrator requires a specific LMN form, bring that form to your physician. For questions about the program-description letter or receipts, email admin@freeaircoach.com.

Why some administrators ask for an LMN

An LMN is documentation from a licensed physician confirming that the expense is medically necessary for the patient. It exists for two reasons: (1) to give the FSA/HSA administrator confidence that they are reimbursing a legitimate medical expense rather than a wellness or lifestyle product, and (2) to give the user a paper trail in case of an IRS audit.

Many administrators require an LMN for app-based and digital wellness products by default — even when the underlying expense category clearly qualifies — because the administrator’s claims-review software flags any non-pharmacy, non-clinic merchant for human review. The LMN is a paperwork formality, not a denial.

FreeAir Coach provides the LMN template, program-description letter, and receipts at no charge to every subscriber who requests them. Including complete documentation with the initial submission gives the claim its best chance, though reimbursement decisions always rest with your plan administrator.

Other smoking-cessation expenses your FSA/HSA may cover

Once you’re thinking about cessation as a reimbursable medical expense, it’s worth knowing the full picture. The following are all FSA/HSA-eligible under §213(d) when used for tobacco cessation:

The combination most users find most effective — and what the U.S. Public Health Service Clinical Practice Guideline explicitly recommends — is behavioral counseling (FreeAir Coach) plus pharmacotherapy (NRT or prescription Varenicline/Bupropion). The Cochrane Collaboration’s systematic reviews of cessation interventions consistently show the combination significantly outperforms either alone.

Effective cost after FSA/HSA reimbursement

Because FSA and HSA contributions are made with pre-tax dollars, every dollar you reimburse is effectively discounted by your marginal federal income tax rate (and, for FSA, your FICA rate of 7.65% as well). The effective-cost math:

Effective-cost figures are illustrative based on combined federal marginal income tax + FICA rates and assume full reimbursement. State income tax savings (most states) and any administrator-specific exclusions may change actual savings. FreeAir Coach is not a tax advisor; consult yours.

For a typical 24%-bracket user purchasing the Annual plan, FSA reimbursement turns $79.99 of post-tax money into ~$54 of effective spending — about a 32% discount. For Lifetime in the 32% bracket, that’s a $60 effective discount on a one-time purchase that never recurs.

Common reimbursement denials and how to respond

Most FSA/HSA denials are paperwork issues, not eligibility issues. The four most common denial categories and how to respond to each:

If a denial doesn’t match any of the above, email us with the denial language — we maintain a denial-response library and can usually generate the right resubmission package within 24 hours. There’s no charge for resubmission documentation.

Frequently asked questions