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HSA Eligible Items: Medical Supplies and the IRS Rules

How the IRS decides HSA eligible items, with quoted Publication 502 entries for medical supplies and equipment, exclusions, and required records.

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Short answer

An item is HSA-eligible when its cost is a qualified medical expense, meaning “medical care” under Code section 213(d), and it was not paid or reimbursed by insurance or another source. IRS Publication 502 supplies the working test: the expense must be “primarily to alleviate or prevent a physical or mental disability or illness.” Bandages, crutches, a blood sugar test kit, oxygen equipment and hearing-aid batteries are named in that publication; toothpaste and general-health vitamins are not. This is general tax information, not tax or medical advice.

Definition and scope

IRS Publication 969 (for use in preparing 2025 returns, checked 2026-11-01) says qualified medical expenses are those specified in the plan that would generally qualify for the medical and dental expenses deduction. It describes them as amounts paid by the HSA beneficiary for “medical care” (as defined in Code section 213(d)) for the beneficiary, a spouse and dependents, “but only to the extent the amounts are not compensated for by insurance or otherwise.”

The same publication states two scope rules that catch buyers out: expenses incurred before the HSA is established are not qualified medical expenses, and, for HSA purposes, over-the-counter medicine (whether or not prescribed) and menstrual care products count as medical care. A prescription is therefore not what makes an over-the-counter medicine eligible.

How the test works for a supply or device

There is no single master list of products. The rule runs in three steps, all from IRS text:

  1. Publication 969 sends the question to “medical care” and, through the plan, to the expenses that would generally qualify for the medical and dental expenses deduction.
  2. Publication 502 explains that medical care covers the cost of equipment, supplies and diagnostic devices needed for the purposes of diagnosing, treating, or preventing disease, and that expenses must be “primarily to alleviate or prevent a physical or mental disability or illness.”
  3. Publication 502 excludes expenses “merely beneficial to general health, such as vitamins or a vacation,” and gives a plain example of an ordinary personal item: “the cost of a toothbrush and toothpaste is a nondeductible personal expense.”

Item names matter less than the purpose the item serves for the person who uses it. A product category on a store shelf is not itself an IRS determination.

HSA eligible expenses list: supplies and equipment the IRS names

The table lists only entries quoted from IRS Publication 502 (tax year 2025 edition, checked 2026-11-01). It is an excerpt, not a complete list.

Item What Publication 502 says
Bandages “You can include in medical expenses the cost of medical supplies such as bandages.”
Crutches “the amount you pay to buy or rent crutches.”
Wheelchair Amounts paid “for a wheelchair used for the relief of a sickness or disability”; operating and maintaining it is also a medical expense.
Blood sugar test kit In the diabetes example, “You can include the cost of the blood sugar test kit in your medical expenses.”
Oxygen and oxygen equipment Amounts paid “to relieve breathing problems caused by a medical condition.”
Hearing aid “the cost of a hearing aid and batteries, repairs, and maintenance needed to operate it.”
Eyeglasses and contact lenses Amounts paid for eyeglasses and contact lenses “needed for medical reasons.”

Items that are not eligible

Item Source statement
Toothbrush and toothpaste Publication 502: “a nondeductible personal expense.”
Nutritional supplements, vitamins, herbal supplements Publication 502: you “can’t include” the cost “unless they are recommended by a medical practitioner as treatment for a specific medical condition”.
Insurance premiums Publication 969: HSA funds may not pay for insurance, except long-term care insurance, health care continuation coverage (such as COBRA), coverage while receiving unemployment compensation, and certain Medicare and other coverage for people 65 or older.
Expenses before the HSA existed Publication 969: such expenses “aren’t qualified medical expenses.”

Where it matters for labs, clinics and supply decisions

The HSA is held by an individual, so the eligibility question belongs to the account holder’s tax position, not to the seller or the institution that stocks the item. For staff who handle medical supplies, the practical consequence is limited to what the IRS text supports: an item’s description does not decide eligibility, and organisations that buy supplies for patients or staff face their own purchasing rules, covered separately in government purchase card rules and prohibited items, maverick spend in lab purchasing and how hospital supply chains are organised. For how organisations treat the tax life of equipment they own, see medical equipment depreciation life.

Records to keep

Publication 969 requires the account holder to keep records sufficient to show that:

  • the distributions were exclusively to pay or reimburse qualified medical expenses;
  • those expenses had not previously been paid or reimbursed from another source; and
  • the expenses had not been taken as an itemized deduction in any year.

The publication also states that money withdrawn for other reasons is subject to income tax and may be subject to an additional 20% tax.

Common misunderstandings

  • “A prescription is always needed.” Publication 969 treats over-the-counter medicine “whether or not prescribed” as medical care.
  • “If a store sells it as HSA-eligible, it always qualifies.” The IRS test turns on whether the cost is for medical care, not on a shelf label. Publication 502 excludes items that are merely beneficial to general health.
  • “Spending before opening the account counts.” Publication 969 says expenses incurred before the HSA is established are not qualified medical expenses.
  • “Anything health-related counts.” Vitamins and supplements are excluded unless recommended by a medical practitioner as treatment for a specific medical condition.

FAQ

What are HSA eligible items?

Items whose cost is medical care under Code section 213(d) for the account holder, spouse or dependents and is not compensated by insurance or otherwise (IRS Publication 969).

Where is the official HSA eligible expenses list?

The IRS does not publish a product-by-product list in Publication 969. It points to expenses that would generally qualify for the medical and dental expenses deduction, which Publication 502 describes by example.

Are bandages and crutches HSA eligible?

Publication 502 names both: medical supplies such as bandages, and the cost to buy or rent crutches.

Can I pay insurance premiums from an HSA?

Generally not. Publication 969 lists the exceptions: long-term care insurance, continuation coverage, coverage while receiving unemployment compensation, and certain Medicare and other coverage at 65 or older.

Sources

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