What an LSA usually covers
Because the employer writes the rules, every LSA is different. Common categories include:
- Fitness: gym or studio memberships, classes, home exercise equipment, race fees.
- Mental wellbeing: meditation apps, coaching, hobby or learning costs.
- Nutrition: meal planning services or cooking classes.
- Wearables and gear: fitness trackers, outdoor gear.
- Other life costs some employers add: childcare, pet care, commuting or remote work equipment.
Employers usually set a monthly, quarterly or yearly amount, and employees submit receipts or use a card. Whether unused money expires or rolls over depends on the plan.
Why LSA money is taxable
- The general rule. IRS Publication 15-B (2026) says any fringe benefit is taxable and must be included in pay unless the law specifically excludes it.
- Cash and gift cards. Publication 15-B says cash and cash equivalents, including gift cards, are never excludable as a de minimis benefit, no matter how small.
- Gym memberships. The athletic facility exclusion covers only a facility on premises the employer owns or leases and operates. Publication 15-B also says membership in a private country club or athletic facility isn't excludable as a de minimis benefit, however often the employee uses it.
- Through a wellness program, still taxable. In IRS Chief Counsel memo 201622031, the IRS concluded that cash wellness rewards, and gym fees that don't qualify as medical care, are wages subject to employment taxes.
So employers generally add LSA payments to the employee's taxable wages and withhold taxes. Some items, such as care that counts as medical care, may be payable tax-free through a health plan, an HRA or an FSA instead. Ask a tax advisor where each item belongs.
LSA vs HSA vs FSA vs HRA
| Account | Who funds it | What it pays for | Taxed to employee? |
|---|---|---|---|
| LSA | Employer | Whatever the employer allows (wellbeing, fitness, lifestyle) | Yes, as wages |
| HSA | Employee and employer; requires a high deductible health plan | Qualified medical expenses | No, for qualified medical expenses |
| Health FSA | Employee salary reduction; employer may add | Qualified medical expenses (not premiums) | No, for qualified medical expenses |
| HRA | Employer only | Qualified medical expenses, and premiums in some HRAs | No, for qualified medical expenses |
Many employers pair an LSA with a medical account: the HSA, FSA or HRA pays for medical care tax-free, and the LSA covers wellbeing items those accounts can't. See what is HSA eligible, what is FSA eligible and what an HRA is.
How employers set up an LSA
- Pick the categories you want to support. Ask employees what they'd use before you decide.
- Set the amount and the period, and decide what happens to unused money.
- Choose how people claim it: receipts, a card, or a vendor that runs the program.
- Report payments as taxable wages through payroll, with withholding.
- Keep it separate from your health plan. If rewards are tied to the health plan, HIPAA and ACA wellness program rules may apply. The Department of Labor lists reimbursing fitness center memberships as an example of a participatory wellness program.
- Have a tax advisor or benefits attorney review the plan document before launch.
An LSA is not health insurance and not an HRA. It does not pay medical bills tax-free, and it is not an offer of health coverage for the ACA employer mandate.
Where Gabriel fits
Some employers want a benefit that puts care, not just wellness perks, within reach. Employers with 25 or more employees can add Gabriel for Teams, a care membership, alongside their health plan. It is a membership, not group health insurance and not an HRA or ICHRA.
For employees using HSA or FSA money, see are vitamins HSA eligible and is an Oura Ring HSA eligible for how medical and wellness purchases differ.
Common questions
Is a lifestyle spending account taxable?
Yes, in general. LSA payments are fringe benefits that the law doesn't exclude, so employers report them as taxable wages. Check the details with a tax advisor.
What can I use a lifestyle spending account for?
Whatever your employer's plan allows. Common categories are fitness, mental wellbeing, nutrition and gear. Check your plan's list before you buy.
What's the difference between an LSA and an HSA?
An HSA pays qualified medical expenses tax-free and requires a high deductible health plan. An LSA covers lifestyle items the employer chooses, and the money is taxable.
Can an LSA pay for a gym membership tax-free?
Generally no. IRS Publication 15-B says membership in an athletic facility isn't excludable as a de minimis benefit, and an IRS Chief Counsel memo treated gym fees paid through a wellness program as wages.
Does unused LSA money roll over?
It depends on the plan. Some reset each period and others let money roll over. Your plan document says which.
Sources
- Publication 15-B (2026), Employer's Tax Guide to Fringe Benefits IRS
- Chief Counsel Memorandum 201622031: Wellness program rewards IRS
- Publication 969, Health Savings Accounts and Other Tax-Favored Health Plans IRS
- HIPAA and the Affordable Care Act Wellness Program Requirements U.S. Department of Labor
This guide is general information, not medical advice. It does not replace a visit with a licensed clinician. Gabriel membership is not health insurance.