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Do Orthodontic Services Have to Have Been Incurred to Be Eligible for Reimbursement from a Medical FSA?

No, they do not, but the patient must be receiving a course of orthodontic, treatment related to the expense. Orthodontic expenses may be reimbursed when actual payments have been made, even if the services have not been rendered. Orthodontic expenses typically are payable to the orthodontist at the onset of treatment or through an installment-based treatment plan. This is an exception to the general rule that pertains to Medical FSAs. 

The Orthodontic contract should be submitted with initial claim to show treatment plan.