Does the FDA consider a hair cut a medical procedure?
In my opinion a medical procedure is something done to living tissue of the body NOT something done to an extract/secretion. If the dna kit is acting on a swab sample there is nothing 'medical' about it. likewise testing a stool sample is not 'medical' but instead a biochemistry procedure. However an allergy test that you apply to your skin is medical, as is any cream ointment or tincture that is likewise applied to tissue (that includes water sold as treatment homoeopathy).
Of course this is only my opinion, and not that of the FDA.