If you live with a condition that impacts your life, you may be sitting on savings that you don't know exist. The health insurance industry provides a mechanism with HSA/FSA benefits to acquire goods and services that help you either deal with these challenges or prevent them from worsening.
The options range from fitness wearables to walking canes, offering a massive opportunity for people to save money while adding value to their day-to-day, increasing their health and quality of life.
NULU, for example, is an adaptive food preparation and cutting tool designed specifically to restore independence in the kitchen for people facing one or more physical challenges such as:
- Arthritis (osteoarthritis, rheumatoid arthritis)
- Multiple sclerosis (MS)
- Parkinson's disease
- Age-related weakened grip strength, dexterity, and coordination
- Tremors
- Stroke-related symptoms
- Carpal tunnel syndrome
- Wheelchair-based cutting and seated meal prep
- Standing fatigue and balance issues
- Vision impairment
With any of these, here is an example of the savings math.
Assume that you suffer from one or more of these conditions and have an HSA/FSA benefit.
HSA/FSA contributions are deducted from your paycheck before federal income tax, state income tax (in most states), and FICA payroll tax (7.65%) are applied. Here's what that looks like for a real purchase:
Say you're buying a $69.99 NULU Adaptive Cutting Tool, and your marginal federal income tax rate is 22%.
Paying out-of-pocket (post-tax dollars): You'd need to earn roughly $107.10 before taxes to have $69.99 left to spend, once you account for:
- 22% federal income tax
- 7.65% FICA (Social Security + Medicare)
- State income tax (varies; assume 5% here for example)
$69.99÷(1−0.22−0.0765−0.05)=$69.99÷0.6535≈$107.10
Paying with HSA/FSA (pre-tax dollars): You spend exactly $69.99 — no tax bite at all, because the money was never taxed in the first place.
Your savings: roughly $37.11 on this purchase, or about 34.6% — right in that 20–35% range, depending on your specific tax bracket and state. Higher earners in higher tax brackets land toward the top of that range; lower earners land toward the bottom — but everyone saves something, and it only happens with a compliant LMN on file.
You would think that with a clear benefit and the means to use it that this should be simple, but it is anything but. To understand why, let's first explore what a Letter of Medical Necessity is and why it matters for adaptive daily living aids.
The "Dual-Use" Problem — Why Adaptive Kitchen Tools Require Documentation
Here's the catch that trips most people up: many products like the NULU cutting tool are what the IRS and plan administrators call "dual-use" items — meaning they have both a general personal use (anyone can use a cutting tool) and a specific medical use (someone with arthritis, Parkinson's, or standing fatigue needs its adaptive design to prepare food safely).
Because dual-use products aren't automatically classified as medical the way a prescription or a wheelchair is, plan administrators apply extra scrutiny. Without documentation, a dual-use daily living aid defaults to a personal expense — even when your actual medical need is completely legitimate. This is exactly the gap an LMN is designed to close: it converts a dual-use item into a documented, IRS-compliant medical expense.
What Is a Letter of Medical Necessity (LMN), and Why Does It Matter?
A Letter of Medical Necessity (LMN) is a clinician-signed document that tells your HSA/FSA administrator why a specific product is a medical necessity for your diagnosed condition, not just a lifestyle purchase. Take the NULU Adaptive Cutting Tool as an example: on its own, a cutting tool looks like a standard kitchen gadget. But paired with a compliant LMN tied to a diagnosed condition, it qualifies as an eligible medical expense under IRC §213(d).
What a Compliant LMN Requires for HSA/FSA Approval
To satisfy administrators (like HealthEquity, WEX, or Optum) and IRS §213(d) standards, a compliant LMN must include:
- Site-specific ICD-10 diagnosis codes (e.g., M19.041 for hand osteoarthritis, M18.11 for CMC joint OA)
- A direct citation to IRC §213(d) establishing the legal and tax basis
- A stated duration of need (e.g., 12 months, or lifetime for chronic conditions)
- Objective functional deficits, including the need to cut while seated due to wheelchair use or standing fatigue
- A verified clinician signature and credentials
Missing any one of these elements is one of the most common reasons an HSA/FSA reimbursement claim gets rejected.
The 4 Pathways to Getting an LMN for Adaptive Equipment
1. Clinician Provided
Who signs: Your Physician, PA, OT, or PT — someone who already knows your case.
How it works: You ask your existing healthcare provider to draft an LMN from scratch during or after an appointment.
The friction: This isn't about willingness — clinicians want to help. The real bottleneck is time and administrative resources. Most providers don't have spare bandwidth in a packed schedule to research the exact ICD-10 pairings, legal citations, and duration statements HSA/FSA administrators require. The result is often a generic note that gets rejected for missing required elements.
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Pros:
- Signed by someone who already knows your medical history
- No direct third-party platform fee
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Cons:
- High time and administrative burden on the clinician
- Frequently results in generic notes that get rejected for missing required elements
- Puts the drafting burden entirely on a busy provider
2. Checkout Services — Truemed, Flex
Who signs: A telehealth provider on the platform's network.
How it works: Integrated directly into a participating merchant's checkout flow. You complete a short health questionnaire during purchase, and an affiliated clinician reviews and issues the LMN.
Cost: Free to the user (the merchant absorbs the platform fee).
The catch: These platforms are marketplace-limited — the LMN sign-off only works for products already onboarded to their specific merchant catalog. This creates a real gap for categories like adaptive food prep. Because tools like the NULU Adaptive Cutting Tool are dual-use daily living aids rather than standard OTC medical items, they are often unlisted or face extra onboarding friction. If the product isn't in their catalog, this pathway is unavailable.
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Pros:
- Free to the user (brand pays)
- Fast, embedded directly into checkout
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Cons:
- Restricted to products in their specific marketplace
- Adaptive kitchen tools and food prep aids are often unlisted
- Signed by an unfamiliar telehealth clinician with no ongoing relationship to your care
3. Third-Party Provider — Burst
Who signs: An independent telehealth provider outside of any merchant checkout flow.
How it works: A standalone service you seek out separately to obtain an LMN — offering an online questionnaire, clinical review, and signed letter across various products.
Cost: Burst charges the user directly for the telehealth consult and LMN generation.
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Pros:
- Not tied to a single merchant's marketplace — flexible across different products
- Independent access whenever you need documentation
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Cons:
- Charges the user directly for the consult and LMN generation
- Adds an out-of-pocket cost before you have made your purchase
- Signed by an unfamiliar telehealth provider, not your personal doctor
4. Brand-Enabled — NULU
Who signs: Your own treating clinician.
How it works: NULU's free, session-based tool lets you enter your specific functional limitations — including whether you need to cut while seated due to wheelchair use, lower extremity issues, or standing stamina limitations — and instantly generates a fully compliant, pre-formatted draft report. It includes the correct ICD-10 references, IRC §213(d) citations, and duration-of-need language already built in. You bring that ready-made document to your own doctor for a quick review and signature.
Cost: Free. No consumer fee. No marketplace gatekeeping. No personal data stored.
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Pros:
- Completely free — no user fee or marketplace restrictions
- Signed by your own trusted clinician who knows your history
- Removes the administrative drafting burden that makes Pathway 1 difficult
- Session-based and private by design (no health data stored)
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Cons:
- Requires a brief clinician visit or portal message for final signature
Why NULU Has Thrown Our Hat into the LMN Arena
At NULU, we have found ourselves and, in turn, our users in the dual-use space, Undeterred, we believe the healthcare system has an ironic blind spot: eating is treated as a basic necessity, but the tools needed to safely prepare food are treated as optional — open to interpretation, buried in dual-use ambiguity, and left for patients and physicians to sort out on their own.
We don't think that's right. As part of our mission, we're committed to being the option with the least cost to the user — not just in dollars, but in time, confusion, and administrative burden. Rather than asking doctors to become HSA/FSA compliance experts, or asking patients to pay a third party just to access their own benefits, we do the compliance work up front so the only thing left is a quick signature from someone who already knows and trusts your care.
We want to cut the red tape and make reimbursement or pre-authorization easier with our own tool leverages your relationship with your clinical team without creating a burden for them which often precludes their ability to provide support in this area. To fully realize this vision, we need your help.
Try Our Free Beta LMN Generator
We consider our NULU Navigator Letter of Medical Necessity Generator Beta an essential first step for anyone exploring this path. It's free to use, stores no personal data, and walks you through the necessary clinical questions — upper body conditions, seated meal prep (wheelchair or standing stamina), and vision impairment — to produce a ready-to-sign draft in minutes.
As a beta tester, you'll also get access to:
- A free adaptive cutting glove, as a thank-you for helping us refine the tool (subject to terms and conditions).
- Support for both pathways — HSA/FSA reimbursement and DME/Medicare documentation, depending on your coverage
If you've been putting off exploring whether you qualify, this is the lowest-friction way to find out.
- NULU Navigator Letter of Medical Necessity Generator Beta
- Also try the NULU Navigator Beta for personalized use recommendations for your individual needs and challenges.
Frequently Asked Questions (FAQ)
Are adaptive kitchen tools HSA and FSA eligible?
Yes. When prescribed or recommended by a licensed clinician to treat, mitigate, or prevent the symptoms of a diagnosed medical condition (such as arthritis, tremors, stroke recovery, or mobility limitations), adaptive kitchen tools qualify for pre-tax reimbursement under IRC §213(d) with a Letter of Medical Necessity.
Why do adaptive food prep tools require a Letter of Medical Necessity (LMN)?
Adaptive kitchen tools fall under the IRS "dual-use" category because they can be used for everyday food prep by anyone, but are medically necessary for individuals with physical impairments. The LMN provides the formal clinical justification plan administrators require to approve the expense.
Can I get an LMN if I need to cut while seated or from a wheelchair?
Yes. Functional deficits that require seated meal preparation — such as wheelchair use, lower-extremity joint pain, or limited standing stamina and fatigue — are valid clinical justifications for an adaptive cutting aid and should be explicitly documented in your LMN.
How do I get reimbursed for my NULU cutting tool through my HSA or FSA?
- Generate your pre-formatted clinical draft using NULU's free LMN generator.
- Have your treating physician, PA, OT, or PT review and sign the letter.
- Purchase your NULU Adaptive Cutting Tool using your HSA/FSA debit card or personal payment method.
- Submit the itemized receipt along with your signed LMN to your benefits administrator for verification or reimbursement.
