There is no definitive list as to what constitutes a "qualifying medical expense." A partial list is provided by the IRS (pdf). A determination of whether an expense is for "medical care" is based on all the relevant facts and circumstances. To be an expense for medical care, the expense has to be primarily for the prevention or alleviation of a physical or mental defect or illness. The policy holder is responsible for deciding what constitutes a "qualifying medical expense," and should be familiar with the guidelines.