These costs would not normally be considered qualified because they're health costs. However, if this course is at a qualified institution and these are required expenses outlined by the institution in the course description, you have a strong argument that these are qualified expenses that would fall under the "fee" in tuition, fees, room & board. This is why the language is vague concerning qualified expenses. Document everything, of course, and if you want to be extra conservative you might seek the opinion of a qualified tax professional.
VP, Research & Development
This information does not constitute tax advice and is provided for informational purposes only. Please consult your tax advisor, financial advisor, local taxing authority, and/or plan provider or sponsor for more information.