A health matching account is not a legitimate, federally regulated savings product. It is a private arrangement sold by companies that promise to multiply your deposits with “matching credits” you can spend on medical costs, and the largest provider is currently under a federal preliminary injunction after the U.S. Department of Justice alleged it operated a Ponzi scheme. Before putting money into anything marketed under this name, you need to understand what the product actually is, what it isn’t, and where your money would sit.
What HMA Sellers Promise
Companies selling HMAs describe them as medical expense savings accounts with a matching benefit. You make monthly deposits, and the provider adds a non-cash “Health Matching Credit” to your account balance based on a multiplier. Some plans advertise up to $2 in credits for every $1 you deposit. Your statement would then show your cash deposits plus these credits, and you would supposedly spend the full combined amount on qualifying medical costs using a prepaid debit card issued by the provider.
The pitch is designed to sound better than the accounts you already know about. No high-deductible health plan required. No use-it-or-lose-it rule. Balances roll over indefinitely. The provider frames it as a supplement to any insurance, useful for deductibles, copays, dental, vision, and elective procedures like LASIK.
HMAs Are Not a Recognized Account Type
Health matching accounts are not authorized, defined, or regulated under any section of the Internal Revenue Code or any federal financial regulation. Some HMA marketing claims the accounts are “governed by IRS Code Section 213,” but that statute simply lets taxpayers deduct medical expenses exceeding 7.5% of adjusted gross income. It says nothing about matching accounts, matching credits, or any savings vehicle by that name.1Office of the Law Revision Counsel. 26 U.S. Code 213 – Medical, Dental, Etc., Expenses
HMAs are not held at FDIC-insured banks or credit unions the way HSA funds are. They are not tax-advantaged under any provision of federal law. The “Health Matching Credits” that make up the bulk of your advertised balance are not cash, not insured, and not backed by any regulatory framework. They exist as numbers in the provider’s own system, and nothing more.
The DOJ Case Against Health Matching Account Services
On October 17, 2025, the U.S. Department of Justice filed a civil complaint for injunctive relief against Health Matching Account Services, Inc., Pet Health Matching Account Services, Inc., and their owners, Regina Gorog and Elliott Gorog. Five days later, a federal court entered a temporary restraining order freezing the company’s bank accounts and prohibiting it from enrolling new members or operating its website. A preliminary injunction remains in effect as of January 2026.2United States Department of Justice. United States v. Health Matching Account Services, Inc., et al.
The government’s evidence established probable cause that the accounts were a Ponzi scheme. Court documents showed that in October 2023, more than 8,000 customers collectively held account balances totaling roughly $33 million, while the company had about $130,000 in its bank account. The matching credits customers believed they could spend on medical care did not exist as accessible funds. Court filings also referenced a message allegedly sent by one of the owners stating, “it’s my Ponzi scheme I can do what I want lol.”2United States Department of Justice. United States v. Health Matching Account Services, Inc., et al.
These are civil allegations, and the defendants are presumed innocent until proven otherwise. But the practical effect is already here: if you had money in an HMA through this provider, you currently cannot access it.
What a Legitimate Medical Savings Account Looks Like
Federal tax law recognizes a small set of tax-advantaged accounts for medical expenses. They share features HMAs lack: statutory authorization, IRS oversight, custody at regulated financial institutions, and defined annual contribution limits.
A Health Savings Account is a trust account established under Section 223 of the Internal Revenue Code and must be held at a qualified financial institution such as a bank, credit union, or insurance company.3Office of the Law Revision Counsel. 26 USC 223 – Health Savings Accounts Contributions are tax-deductible, growth is tax-free, and qualified medical withdrawals are untaxed. Your funds are yours permanently and roll over every year. Enrollment requires a high-deductible health plan, and annual contributions are capped by statute — $4,400 for individuals and $8,750 for families in 2026, with a $1,000 catch-up allowed at age 55 and older.4Internal Revenue Service. Revenue Procedure 2025-19
A Flexible Spending Account is employer-sponsored and funded with pre-tax payroll deductions, capped at $3,400 in 2026. FSAs generally follow a use-it-or-lose-it rule, though employers may offer either a short grace period or a limited carryover, not both.
If a product marketed as a medical savings account doesn’t fit into either of these categories, it isn’t sitting under the federal protections that make those accounts safe.
Warning Signs on Any Similar Product
The same pattern can appear under a different brand name. Be skeptical of any medical savings product that:
- Promises matching credits that are not cash and exist only inside the provider’s own system.
- Cites IRS Code Section 213 or another tax provision as authorization. Section 213 governs individual deductions for medical expenses, not savings accounts.
- Holds your money outside a bank or credit union with federal deposit insurance.
- Sets no annual contribution limit. Every IRS-recognized health account has a statutory cap.
- Requires ongoing monthly fees to keep access to money you have already deposited.
If You Already Have Money in an HMA
If you deposited money with Health Matching Account Services or a related entity, the DOJ maintains a case page with updates on the proceedings and any recovery process for affected members.2United States Department of Justice. United States v. Health Matching Account Services, Inc., et al. In past Ponzi cases, courts have sometimes appointed receivers to recover and distribute remaining assets, but victims rarely get their full deposits back.
If your goal was simply a tax-friendly way to save for medical costs, an HSA paired with a high-deductible health plan is the closest legitimate equivalent to what HMAs claimed to offer. The tax benefits are real, the funds sit at an insured institution, and your balance does not depend on whether the company holding it stays solvent. Your employer’s benefits office or any bank that offers HSA custody can start the enrollment.