One of the most common questions we receive in our FSA 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!
What determines vitamin eligibility?
A product/service's FSA eligibility is dictated by the Internal Revenue Service (IRS), which adheres to IRS 213(d). This regulation states that all FSA eligible expenses must conform to the IRS's definition of medical care:
"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."
While this seems straightforward, vitamins are a prime example of a product that can be considered necessary for "general health" or is considered "dual purpose." This means that while the product/service may have a medical basis, they are used primarily to promote one's general health and do not have a direct role in treating a specific medical condition. For instance, a toothbrush or dental floss are considered dual purpose items as they have both a medical and non-medical purpose.
What vitamins are FSA/HSA eligible?
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 and others that may be eligible with proper documentation from a physician. 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 that falls outside of FSA regulations. In this case, your benefits administrator may require 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.