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One of the most common questions we receive in our HSA Learning Center from our customers is related to the eligibility of daily multivitamins and supplements. Traditionally, multivitamins are used to fill in the nutritional gaps that a person is lacking in his/her diet, but certain supplements can also help to alleviate a nutritional deficiency that may be caused by an underlying health problem. When it comes to FSA/HSA eligibility, vitamins seem to fall into a gray area, but we hope to clear up the confusion!
For a product or service to be FSA/HSA eligible, it must be primarily for “medical care” as defined by the IRS under Internal Revenue Code 213(d):
"The term “medical care" means amounts paid— for the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body."
Therefore, eligible expenses under 213(d) are primarily for medical care and not for general good health or cosmetic purposes. While this seems straightforward, vitamins are a prime example of a product that can be used for general good health or a specific medical purpose.
With this IRS definition in mind, while daily multivitamins are not FSA/HSA eligible, there are some types of vitamins that are eligible with consumer-directed healthcare accounts. For instance, prenatal vitamins are FSA/HSA eligible, as they help prevent birth defects and support fetal development, while glucosamine/chondroitin supplements are also eligible when used to treat arthritis.
However, in some cases, doctors may prescribe a specific vitamin supplement to treat a medical condition. In this case, the recommended vitamin or supplement may be HSA/FSA eligible with a Letter of Medical Necessity (LMN) to show that these vitamins are necessary for the treatment of a medical condition. The letter will typically need to outline how these products will be used to aid the treatment process, and how long the treatment will last. If you are considering a specific vitamin for treatment of a medical condition, talk to your FSA/HSA benefits administrator to determine what types of documentation may be required.