Asked and Answered: I'm new to FSAs - can you explain the vitamin thing again?

Eligibility

At first glance, vitamins and supplements seem like natural candidates for FSA-eligibility. They are designed to fill "gaps" in the average diet, and maybe offset minor nutritional deficiencies along the way -- yes, even those related to larger health problems.

But IRS guidance -- which governs eligibility -- says, specifically in IRS 213(d), that all FSA-eligible expenses must conform to the following standard:

"The diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body."

And this is where the debate starts...

"I need my vitamins like others need their medicines!"

Vitamins are perhaps the most-glaring example of a product that can either be necessary or "dual-purpose." Daily multivitamins are used to promote better health and well-being, but because there's no specific health need or condition that is helped by using multivitamins, so they fall outside the accepted qualifications for eligibility.

Is there a medical basis for needing a multivitamin? Absolutely. But promoting general well-being isn't the same as treating a specific condition.

In the past, we've used toothbrushes and floss as a good comparison point for the vitamin debate, and it still holds up. Though we all know proper dental cleaning is necessary for all-around health and wellness, using a toothbrush and floss has not been identified as having a direct role in treating or solving a specific medical condition.

"Which vitamins ARE eligible?"

Though multivitamins are likely the most-popular OTC supplement, only a handful of targeted vitamins have achieved FSA- and HSA-eligibility, provided the patients have documentation from their doctors claiming the need.

I think we can all agree prenatal vitamins meet the requirements for eligibility, since they have shown to prevent birth defects and boost fetal development in ways that most modern diets can't quite seem to achieve.

Likewise, glucosamine/chondroitin supplements are extremely popular because of their proven benefits for treating arthritis.

Because the above exceptions have proven value in treating specific needs and conditions, they can be purchased with tax-free health dollars, and without any written approvals from physicians.

"Are vitamins on the radar for eligibility?"

We obviously can't answer that. But we can tell you that vitamins were added under S.12, The Health Savings Act of 2019, which was introduced by Senator Rubio but has not yet advanced to a vote. Until then, if a doctor determines your body needs a specific vitamin supplement -- even if it falls outside of regular parameters -- then a Letter of Medical Necessity might do the trick.

(Remember, we said "might.")

Chances are, the letter will need to be detailed in explaining why these specific products will benefit you, and how long the expected use will be (such as the duration of specific treatment). It's not a guarantee by any means, but a well-presented case made to your benefits administrator can go a long way toward getting the supplements right for you, on a tax-free basis.

Speaking of your benefits administrator, they can probably provide you with the best advice on exactly which vitamins will qualify under what conditions and with how much documentation on hand.

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