Both Health Savings Accounts (HSAs) and Flexible Spending Accounts (FSAs) cover mental health therapy — including out-of-network sessions. A superbill from your therapist is the documentation you need to get reimbursed or justify the expense to your account administrator.
Are Therapy Sessions an Eligible Expense?
Yes. The IRS classifies mental health treatment — including psychotherapy with a licensed therapist — as a qualified medical expense under both HSA and FSA rules. This applies whether your therapist is in-network or out-of-network, and regardless of whether you submit the session to insurance.
HSA vs FSA: The Key Differences
- HSA (Health Savings Account) — Requires enrollment in a High-Deductible Health Plan (HDHP). Funds roll over every year with no deadline. You own the account; it moves with you if you change jobs or health plans. 2025 contribution limits: $4,300 (individual) / $8,550 (family).
- FSA (Flexible Spending Account) — Employer-sponsored; does not require an HDHP. "Use it or lose it" — unspent funds typically expire at plan year end (some plans allow a $640 rollover or a 2.5-month grace period). 2025 contribution limit: $3,300.
How to Pay for OON Therapy With Your HSA or FSA
- Pay your therapist directly using your HSA debit card or FSA debit card. Transaction is done — no reimbursement paperwork needed if you used the card.
- Or pay out of pocket and submit a reimbursement claim to your HSA or FSA administrator (via their online portal or app), attaching the superbill as supporting documentation.
Either way, keep the superbill. The IRS may require documentation in an audit, and your account administrator may request it before processing a reimbursement claim.
What the Superbill Must Include for HSA/FSA
Your account administrator needs to verify the expense was for a qualified medical service. A complete superbill satisfies this because it includes:
- Provider's name, NPI, and license number
- Patient name and date of service
- CPT code (procedure type)
- ICD-10 diagnosis code (confirming it is a medical service)
- Fee charged and amount paid
FSA Deadline Planning
If you have an FSA with a December 31 plan-year end, schedule any remaining therapy sessions and obtain superbills before the deadline. FSA funds forfeited are gone — even if the therapy sessions would have been eligible. Some employers offer a 2.5-month grace period or limited rollover, so check your plan documents.
HDHP Requirement for HSA
You can contribute to an HSA only while enrolled in a qualifying High-Deductible Health Plan. For 2025, an HDHP requires a minimum deductible of $1,650 (individual) or $3,300 (family). Once you have funds in your HSA, you can spend them on qualified expenses regardless of your current health plan — the HDHP requirement applies only to contributions, not withdrawals.