Taxation and Regulatory Compliance

Can I Use My HSA for Toothpaste?

Understand HSA eligibility for dental and everyday health items, clarifying what truly qualifies as a medical expense.

Health Savings Accounts (HSAs) are tax-advantaged savings accounts designed to help individuals pay for qualified medical expenses. They offer potential tax benefits, including tax-deductible contributions, tax-free growth, and tax-free withdrawals for eligible expenses. HSAs are typically paired with high-deductible health plans.

General HSA Eligibility for Over-the-Counter Products

To qualify as an eligible HSA expense, an item or service must meet the Internal Revenue Service (IRS) definition of “medical care,” as detailed in IRS Publication 502. This definition specifies that an expense must be primarily for the diagnosis, cure, mitigation, treatment, or prevention of disease, or for affecting any part or function of the body. Expenses for general health or purely cosmetic purposes are not eligible. Items merely beneficial to general health, like vitamins (unless for a specific medical condition), do not qualify.

The Coronavirus Aid, Relief, and Economic Security (CARES) Act, effective January 1, 2020, expanded HSA eligibility to include many over-the-counter (OTC) medications and products without requiring a prescription. This change made a wider range of non-prescription drugs and medicines eligible for reimbursement. However, the fundamental rule remains that the expense must relate to medical care, not general hygiene or cosmetic enhancement.

Toothpaste and Dental Care Eligibility

Standard toothpaste is not considered an eligible HSA expense. It falls under the category of general hygiene items, such as manual toothbrushes, dental floss, and mouthwash, which are ineligible for reimbursement. These products maintain general health rather than treating or preventing a specific medical condition.

However, certain dental care items and procedures are eligible for HSA use. Medically necessary dental treatments, such as fillings, root canals, crowns, extractions, and braces, are covered expenses. If a specific toothpaste or other dental product is prescribed by a dentist to treat a diagnosed medical condition, like severe gum disease or xerostomia (dry mouth), it may become eligible. In such cases, the medical necessity transforms a general hygiene item into a qualified medical expense.

Verifying Eligibility and Record Keeping

To confirm the eligibility of an expense, individuals should consult official IRS publications or refer to their HSA plan administrator’s guidelines. Many reputable online resources also provide lists of eligible HSA expenses. This proactive verification helps ensure compliance with tax regulations.

Maintaining detailed records is important for HSA users. Individuals should retain all receipts for expenses paid with HSA funds. For items that might be considered questionable but are medically necessary, a Letter of Medical Necessity (LMN) from a licensed healthcare provider is required. This letter must clearly state the diagnosed medical condition, explain how the product or service treats or alleviates that condition, and include the provider’s credentials and signature. In the event of an IRS audit, failure to provide adequate documentation for non-qualified distributions can result in a 20% penalty and inclusion of the distribution in taxable income. Keep these records for at least three to seven years, or as long as the tax return remains open to audit.

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