News

Are Vitamins FSA/HSA Eligible?

When it comes to vitamins and supplements, you want to be careful when using your HSA or FSA.

April 18, 2024
Sam O'Keefe
Co-founder & CEO of Flex
Flex - Are Vitamins FSA/HSA Eligible?
Flex - Are Vitamins FSA/HSA Eligible?

Overview

Overview

Overview

Vitamins and supplements are one of the most asked about items for Health Savings Account (HSA) and Flexible Spending Account (FSA) coverage. So are they eligible?

We’ll review which items qualify, when you’ll need a doctor’s approval, and why you should be wary of many products that claim they qualify for reimbursement.

Are Vitamins and Supplements FSA/HSA Eligible?

In general, vitamins and supplements are not eligible.

For an item to be HSA and FSA-eligible, the IRS states that the qualified medical expense “must be primarily to alleviate or prevent a physical or mental disability or illness”. 

Since almost all vitamins and supplements are considered “dual-purpose” — they may have a medical purpose but can also be used for general health — they are not included in the Eligible Product List.

What the IRS says

Here’s what the IRS says about vitamins and supplements specifically: “you can’t include in medical expenses the cost of nutritional supplements, vitamins, herbal supplements, ‘natural medicines,’ etc., unless they are recommended by a medical practitioner as treatment for a specific medical condition diagnosed by a physician. These items are taken to maintain your ordinary good health and aren’t for medical care.”

You’ll notice the exception: some products may be eligible for reimbursement but require a Letter of Medical Necessity (LOMN) from a licensed healthcare professional.

Which Vitamins and Supplements Are Eligible?

There are only three types of dietary supplements that are eligible: 

  • Prenatal vitamins: Contain daily vitamins and minerals (such as folic acid) that can help lower the risk of developmental problems in a growing baby

  • Glucosamine and/or chondroitin products: Shown to ease joint pain caused by arthritis. Note that glucosamine must be the main ingredient

  • Fiber laxative supplements: An effective intervention to help with problems producing and expelling solid waste for a short duration

This is because each one is intended to treat a specific medical condition.

Everything else will require a LOMN for HSA/FSA reimbursement.

Requirements for a Letter of Medical Necessity

The IRS developed and oversees the guidelines for what is eligible for HSA or FSA spending but they allow an exception: doctors can recommend certain products or services that fall outside their approved item list if they address a specific medical condition for a patient.

This is presented in a Letter of Medical Necessity (LOMN). LOMNs allow consumers to get reimbursed for health-related items from their HSA or FSA.

A LOMN must include:

  • Basic patient information

  • Provider details

  • Condition details: What specific diagnosis or condition you’re managing, mitigating, or treating with the purchase

  • Recommended treatment: What product or service the consumer is looking to purchase

  • Purchase rationale: Why the individual needs the product or service. This may include details on the product or service, demonstrated effectiveness, alternatives that have been explored, and cost.

  • Provider signature

Note that when it comes to obtaining a LOMN for supplements, consumers need to demonstrate that they are “primarily to alleviate or prevent a physical or mental disability or illness”.

Situations where vitamins and supplements address a specific medical condition

To help clarify when a LOMN may be used, we’re sharing some examples:

  • If someone has a documented iron deficiency (anemia) a doctor may recommend iron supplements. 

  • Electrolyte replacements for the prevention or treatment of dehydration (as a result of sickness or extreme exertion) are eligible if they do not contain added supplements. This can also include rehydration for babies, such as Pedialyte. Note that this does not include sports drinks.

  • Calcium may be eligible for someone who has osteoporosis.

Buyer beware when it comes to supplements

The vitamin and supplement industry is big business in the U.S. and also highly under-regulated.

As a consumer, be mindful that many product claims are unsubstantiated, while safety evaluation, efficacy requirements and quality assurance are often inadequate.

Generally speaking, if a product sounds too good to be true, it is — and this is what makes proving that a vitamin or supplement is medically necessary challenging.

Tax penalty if you use HSA or FSA inappropriately

Lastly, be prepared to meet The Taxman if you use your HSA or FSA funds inappropriately.

Using your funds fornon-qualified expenses before the age of 65 will net you a 20% withdrawal penalty on top of regular income tax. This means you'll need to report the distribution on your tax return, and it will be subject to your regular income tax rate.

Other Common Questions

Are multivitamins FSA or HSA eligible?

Short answer: No. You’d be very hard-pressed to make the argument that a multivitamin addresses a specific medical condition.

Can I buy probiotics with HSA/FSA?

Probiotics and prebiotics are considered dual-purpose — they may have a medical purpose but can also be used for general health — so they are not included in the Eligible Product List. According to the Special Interest Group for IIAS Standards (SIGIS), a non-profit that helps craft the industry standard to meet IRS requirements, only “under narrow circumstances, they will be eligible if used to treat medical condition or at-risk for illness diagnosed by physician.”

Are Tylenol, Ibuprofen, Advil, and other over-the-counter medicines HSA/FSA-eligible?

Yep! OTC products are one of the many items that you can use your HSA/FSA for as long as they are intended for medical care and are primarily for a medical purpose.

How Flex Can Help

For businesses that offer pre-approved vitamins and supplements — i.e., prenatal vitamins, glucosamine, fiber — Flex can help you to accept HSA/FSA as a form of payment. 

Since most items fall outside of standard IRS guidelines they require a LOMN to be reimbursed. Flex partners with merchants to offer this process during the checkout flow, making it easier for consumers (should they meet the criteria of needing the item for a specific medical condition).

Here’s how it works:

Select the "checkout with Flex" option on the payment page. Complete the following steps to pay with your HSA or FSA debit card:

  1. Fill out a short eligibility form, sharing relevant information with Flex’s medical team. 

  2. If you qualify, Flex sends the LOMN to you via email.

  3. Then, simply enter your HSA or FSA card details and complete the purchase. 

Voilà. A simple supplement to your vitamin or supplement sale.

Supplementing your HSA and FSA Diet

As with most things, the answer to the seemingly simple question we started with is, it depends. We hope this helps clarify which vitamins and supplements are eligible and in which cases other items might be reimbursable.

Vitamins and supplements are one of the most asked about items for Health Savings Account (HSA) and Flexible Spending Account (FSA) coverage. So are they eligible?

We’ll review which items qualify, when you’ll need a doctor’s approval, and why you should be wary of many products that claim they qualify for reimbursement.

Are Vitamins and Supplements FSA/HSA Eligible?

In general, vitamins and supplements are not eligible.

For an item to be HSA and FSA-eligible, the IRS states that the qualified medical expense “must be primarily to alleviate or prevent a physical or mental disability or illness”. 

Since almost all vitamins and supplements are considered “dual-purpose” — they may have a medical purpose but can also be used for general health — they are not included in the Eligible Product List.

What the IRS says

Here’s what the IRS says about vitamins and supplements specifically: “you can’t include in medical expenses the cost of nutritional supplements, vitamins, herbal supplements, ‘natural medicines,’ etc., unless they are recommended by a medical practitioner as treatment for a specific medical condition diagnosed by a physician. These items are taken to maintain your ordinary good health and aren’t for medical care.”

You’ll notice the exception: some products may be eligible for reimbursement but require a Letter of Medical Necessity (LOMN) from a licensed healthcare professional.

Which Vitamins and Supplements Are Eligible?

There are only three types of dietary supplements that are eligible: 

  • Prenatal vitamins: Contain daily vitamins and minerals (such as folic acid) that can help lower the risk of developmental problems in a growing baby

  • Glucosamine and/or chondroitin products: Shown to ease joint pain caused by arthritis. Note that glucosamine must be the main ingredient

  • Fiber laxative supplements: An effective intervention to help with problems producing and expelling solid waste for a short duration

This is because each one is intended to treat a specific medical condition.

Everything else will require a LOMN for HSA/FSA reimbursement.

Requirements for a Letter of Medical Necessity

The IRS developed and oversees the guidelines for what is eligible for HSA or FSA spending but they allow an exception: doctors can recommend certain products or services that fall outside their approved item list if they address a specific medical condition for a patient.

This is presented in a Letter of Medical Necessity (LOMN). LOMNs allow consumers to get reimbursed for health-related items from their HSA or FSA.

A LOMN must include:

  • Basic patient information

  • Provider details

  • Condition details: What specific diagnosis or condition you’re managing, mitigating, or treating with the purchase

  • Recommended treatment: What product or service the consumer is looking to purchase

  • Purchase rationale: Why the individual needs the product or service. This may include details on the product or service, demonstrated effectiveness, alternatives that have been explored, and cost.

  • Provider signature

Note that when it comes to obtaining a LOMN for supplements, consumers need to demonstrate that they are “primarily to alleviate or prevent a physical or mental disability or illness”.

Situations where vitamins and supplements address a specific medical condition

To help clarify when a LOMN may be used, we’re sharing some examples:

  • If someone has a documented iron deficiency (anemia) a doctor may recommend iron supplements. 

  • Electrolyte replacements for the prevention or treatment of dehydration (as a result of sickness or extreme exertion) are eligible if they do not contain added supplements. This can also include rehydration for babies, such as Pedialyte. Note that this does not include sports drinks.

  • Calcium may be eligible for someone who has osteoporosis.

Buyer beware when it comes to supplements

The vitamin and supplement industry is big business in the U.S. and also highly under-regulated.

As a consumer, be mindful that many product claims are unsubstantiated, while safety evaluation, efficacy requirements and quality assurance are often inadequate.

Generally speaking, if a product sounds too good to be true, it is — and this is what makes proving that a vitamin or supplement is medically necessary challenging.

Tax penalty if you use HSA or FSA inappropriately

Lastly, be prepared to meet The Taxman if you use your HSA or FSA funds inappropriately.

Using your funds fornon-qualified expenses before the age of 65 will net you a 20% withdrawal penalty on top of regular income tax. This means you'll need to report the distribution on your tax return, and it will be subject to your regular income tax rate.

Other Common Questions

Are multivitamins FSA or HSA eligible?

Short answer: No. You’d be very hard-pressed to make the argument that a multivitamin addresses a specific medical condition.

Can I buy probiotics with HSA/FSA?

Probiotics and prebiotics are considered dual-purpose — they may have a medical purpose but can also be used for general health — so they are not included in the Eligible Product List. According to the Special Interest Group for IIAS Standards (SIGIS), a non-profit that helps craft the industry standard to meet IRS requirements, only “under narrow circumstances, they will be eligible if used to treat medical condition or at-risk for illness diagnosed by physician.”

Are Tylenol, Ibuprofen, Advil, and other over-the-counter medicines HSA/FSA-eligible?

Yep! OTC products are one of the many items that you can use your HSA/FSA for as long as they are intended for medical care and are primarily for a medical purpose.

How Flex Can Help

For businesses that offer pre-approved vitamins and supplements — i.e., prenatal vitamins, glucosamine, fiber — Flex can help you to accept HSA/FSA as a form of payment. 

Since most items fall outside of standard IRS guidelines they require a LOMN to be reimbursed. Flex partners with merchants to offer this process during the checkout flow, making it easier for consumers (should they meet the criteria of needing the item for a specific medical condition).

Here’s how it works:

Select the "checkout with Flex" option on the payment page. Complete the following steps to pay with your HSA or FSA debit card:

  1. Fill out a short eligibility form, sharing relevant information with Flex’s medical team. 

  2. If you qualify, Flex sends the LOMN to you via email.

  3. Then, simply enter your HSA or FSA card details and complete the purchase. 

Voilà. A simple supplement to your vitamin or supplement sale.

Supplementing your HSA and FSA Diet

As with most things, the answer to the seemingly simple question we started with is, it depends. We hope this helps clarify which vitamins and supplements are eligible and in which cases other items might be reimbursable.

Flex is a modern marketplace for consumers to discover and purchase HSA/FSA eligible products. From fitness and nutrition, to sleep and mental health, Flex takes a holistic view of healthcare and enables consumers to use their pre-tax money to do the same.