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Guide · 2024

HSA FSA wellness purchases: what qualifies and what does not

This publication shares ownership with PeptaraLabs, Lab Ranked Agency, and Dental Link.

HSA FSA wellness purchases qualify only when the money goes to medical care, which the IRS defines as the diagnosis, cure, treatment, or prevention of disease. Gadgets and habits that only support general good health usually do not count. This guide sorts the common buys so you know what to expect before you swipe the card. It is general information, not tax advice.

The basic test the IRS uses

Health savings accounts (HSAs) and flexible spending arrangements (FSAs) both use the same idea of a medical expense. The IRS says medical expenses are the costs of diagnosis, cure, mitigation, treatment, or prevention of disease, and for the purpose of affecting any part or function of the body. The costs must be mainly to ease or prevent a physical or mental illness.

Notice what is missing. Feeling better, looking better, or staying fit is not on that list. That gap is why so many popular wellness buys land in the gray zone.

Plan rules can be stricter than the tax rules. Your plan may also ask for proof of the purchase. Check your plan documents before you buy.

Sources: IRS Publication 502, Medical and Dental Expenses (2023 edition); IRS Publication 969, Health Savings Accounts and Other Tax-Favored Health Plans (2023 edition)

What usually qualifies

Some items are clear. Doctor visits, dental care, eyeglasses, prescriptions, and hearing aids all count as medical care under IRS Publication 502.

A 2020 law added two more categories. Under the CARES Act, signed on March 27, 2020, over-the-counter medicine (whether or not prescribed) and menstrual care products count as medical care. That applies to HSAs, FSAs, and similar accounts for amounts paid or incurred after 2019. So you no longer need a prescription for items such as pain relievers or allergy pills.

Also note that the rule is about medicine. A bottle of cold tablets counts. A bottle of daily multivitamins is a different question, covered below.

Sources: IRS Publication 969, Health Savings Accounts and Other Tax-Favored Health Plans (2023 edition); the CARES Act (Public Law 116-136, March 27, 2020), as summarized in that publication

What usually does not qualify

Publication 502 names several wellness favorites that are not medical expenses.

Sources: IRS Publication 502, Medical and Dental Expenses (2023 edition)

Supplements and gadgets: when a doctor's note matters

This is the gray zone. For vitamins, herbal products, and similar items, Publication 502 says you cannot include the cost unless a medical practitioner recommends them as treatment for a specific medical condition diagnosed by a physician. The IRS adds that these items are usually taken to maintain ordinary good health.

The same logic reaches wellness gadgets. A fitness tracker, a sleep mask, or a home air monitor is built for general use. The IRS personal use rule treats such items as nondeductible unless they are used mainly to prevent or ease a specific illness. A device with a clear medical purpose, such as a blood pressure cuff for diagnosed high blood pressure, sits on firmer ground than a general lifestyle product.

For borderline buys, many plan administrators ask for a letter of medical necessity from your doctor. The letter should name the condition and say why the item is part of treatment. Publication 502 does not use that exact phrase, so ask your own plan what it accepts. Without a diagnosis and a practitioner's recommendation, assume the purchase will not qualify.

Sources: IRS Publication 502, Medical and Dental Expenses (2023 edition) (sections on nutritional supplements and personal use items)

Rules and limits that apply to your account

The two accounts work differently, so the stakes differ.

With an HSA, money used for non-qualified purchases is taxed as income and may face an extra 20 percent tax. You must also keep records showing that each withdrawal paid for a qualified expense that was not paid or reimbursed from another source. You do not send those records with your return, but you should keep them. For 2024, the HSA contribution limit is $4,150 for self-only coverage and $8,300 for family coverage.

An FSA is tied to your employer's plan. For 2023, the health FSA salary reduction limit was $3,050, and a plan could allow a carryover of up to $610 in unused money. Plans may set a lower carryover, or none, so check your own rules early in the year rather than in December.

Sources: IRS Publication 969, Health Savings Accounts and Other Tax-Favored Health Plans (2023 edition)

A quick checklist before you buy

When the answer is unclear, ask your plan administrator or a tax professional before you spend. A small delay costs less than a tax bill and a penalty.

Sources: IRS Publication 502, Medical and Dental Expenses (2023 edition); IRS Publication 969, Health Savings Accounts and Other Tax-Favored Health Plans (2023 edition)