Concierge doctor fees are partially tax deductible, but only the slice of the retainer that pays for actual medical services counts. The rest, which buys guaranteed access, same-day scheduling, after-hours phone calls, and administrative coordination, is not deductible. Concierge retainers commonly run from $2,000 to $10,000 a year, and for most patients only a fraction of that qualifies as a medical expense under IRS rules.
Which Part of the Fee Counts as Medical
The tax code defines medical care as amounts paid for the diagnosis, treatment, or prevention of disease, or to affect any structure or function of the body.1Office of the Law Revision Counsel. 26 USC 213 – Medical, Dental, Etc., Expenses A comprehensive annual physical, bloodwork, preventive screenings, and vaccinations your concierge doctor performs as part of the retainer fit that definition. The premium you pay for the privilege of reaching your doctor on a cell phone or getting an appointment within 24 hours does not.
The IRS looks at the substance of what you’re paying for, not the label the practice puts on it. A single line item called “annual membership fee” gets broken apart into its component services. The portion buying identifiable medical services qualifies. The portion buying access, coordination, and administrative convenience does not.
Services that typically qualify:
- Annual physical exams and comprehensive wellness visits
- Preventive screenings such as blood pressure checks and cholesterol panels
- Lab work, including blood tests and urinalysis
- Vaccinations and immunizations administered in-office
Services that do not qualify:
- Guaranteed same-day or next-day appointment availability
- 24/7 phone or text access to the physician
- Referral management, specialist scheduling, and medical records handling
- Lifestyle perks like travel medicine consultations that don’t involve treatment
The 7.5% AGI Floor
Even when part of your concierge fee qualifies, you can only deduct medical expenses that exceed 7.5% of your adjusted gross income. That threshold was made permanent in 2020.1Office of the Law Revision Counsel. 26 USC 213 – Medical, Dental, Etc., Expenses You also have to itemize on Schedule A, which means your total itemized deductions have to beat the standard deduction before any medical write-off produces a dollar of tax savings.2Internal Revenue Service. Topic No. 502, Medical and Dental Expenses
Run the math on a realistic example. If your AGI is $100,000, the first $7,500 of qualifying medical expenses produces no deduction at all. Suppose your practice allocates $600 of your $5,000 retainer to a physical exam and lab work. That $600 lands in the pot with your other medical costs for the year. If the total still falls below $7,500, the deduction is worth nothing. This is where most concierge patients find the deduction isn’t as valuable as they hoped.
In practice, the concierge-fee deduction tends to matter only when it’s stacked with other large itemized deductions, like mortgage interest or significant out-of-pocket medical bills from a serious illness.
Getting the Allocation From Your Practice
The split has to be based on the fair market value of each medical service included in the retainer. If an annual physical would cost $500 as a standalone appointment, that’s what you can treat as the qualifying amount, not an inflated figure chosen to make the deduction look bigger.
The allocation has to come from the practice, not from your own estimate. Ask your concierge physician for a written statement that assigns specific dollar amounts to the medical services included and separates them from the non-medical components. If the practice refuses to provide this breakdown, or lumps everything into one undifferentiated fee, you have no defensible basis for claiming any deduction.
Paying With an HSA or FSA
Health Savings Accounts and health care Flexible Spending Arrangements can pay for the qualifying medical portion of a concierge fee with pre-tax dollars. The appeal is that HSA and FSA reimbursements skip the 7.5% AGI floor entirely, which often delivers a tax benefit the Schedule A route cannot.3Office of the Law Revision Counsel. 26 USC 223 – Health Savings Accounts
The same split rules apply. Only the portion allocated to actual medical services is eligible. You cannot use HSA or FSA funds for the access and convenience side of the retainer. If you swipe your HSA card for the full undifferentiated fee and the IRS later finds that most of it was non-medical, the non-qualifying portion becomes taxable income, plus a 20% penalty if you’re under 65.
A traditional concierge arrangement where the doctor still bills your insurance normally should not interfere with eligibility to contribute to an HSA, because the retainer buys access rather than prepaid medical care. Direct primary care arrangements, where a flat monthly fee covers most primary care and the doctor often doesn’t bill insurance at all, are treated differently and have their own HSA eligibility rules worth checking before you enroll.
Documentation to Keep
The burden of proof for any medical deduction sits with you. For a bundled concierge fee the bar is higher than for a standard doctor’s bill, because you have to show which piece of the payment was medical.
For each year you claim the deduction, keep:
- A written fee breakdown letter from the practice listing each medical service and its assigned fair market value, separate from the non-medical components
- Payment records: canceled checks, credit card statements, or HSA/FSA transaction records showing amount and date
- Explanations of benefits for any services your concierge doctor also billed to insurance, so you can show what the plan covered and what came out of the retainer
The fee breakdown letter is the piece that holds everything together. Without it, every dollar of the retainer looks like an access fee to an auditor, and access fees are not deductible. Get the letter when you pay, not years later in response to an IRS notice. An allocation created under audit pressure has almost no credibility.
What Happens If You Overclaim
Deducting the full retainer when only a fraction qualifies can trigger the IRS accuracy-related penalty of 20% on the resulting underpayment.4Internal Revenue Service. Accuracy-Related Penalty The penalty applies when the IRS determines you were negligent or disregarded the rules. Writing off an entire $5,000 retainer when $600 of it covered medical services is exactly the kind of position that qualifies.
You’ll also owe the tax on the disallowed portion plus interest running from the original due date of the return. A substantial understatement, which carries the same 20% penalty, exists when the understated tax exceeds the greater of 10% of the correct tax liability or $5,000, and that line can be easier to cross than people expect when a large retainer deduction is combined with other aggressive positions on the same return.4Internal Revenue Service. Accuracy-Related Penalty
The safest approach is to claim only the amount your practice has formally allocated to identifiable medical services, confirm the allocation reflects real fair market values, and keep the paperwork. If your practice won’t provide a written allocation, the defensible move is to claim none of the retainer at all.