Almost everything written about health savings accounts and supplements is either a sales pitch or a shrug. This page is neither. It sets out what the IRS documents actually say, where custodian practice has drifted away from them, and — the part almost nobody separates — the three different questions hiding inside "is it eligible?"
"Is it HSA-eligible?" is not one question. It is three, and they disagree with each other constantly. A single yes-or-no answer has to lie about at least one of them, so this site keeps them apart:
| The question | What it is really asking | Who decides |
|---|---|---|
| Medical care? | Is it §213(d) “medical care” at all? | The law |
| Card / claim desk? | Will a custodian’s debit card or claim desk wave it through without a letter? | Industry practice |
| Schedule A? | Is it deductible as an itemised medical expense on your return? | A different rule again |
Three worked examples of why one boolean would mislead you, taken straight from the categories below:
| Example | Medical care | Card | Schedule A | What it shows |
|---|---|---|---|---|
| Glucosamine | Letter needed | Yes | Letter needed | Practice has outrun the law |
| OTC aspirin | Yes | Yes | No | The CARES Act amended §223, not §213(d) |
| Protein powder | No | No | No | No letter fixes this one |
Most supplements are not HSA- or FSA-eligible. The exception in Pub. 502 is narrow and it has two halves that people collapse into one: a practitioner has to recommend the supplement as treatment, and a physician has to have diagnosed a specific condition for it to treat. "I take magnesium for sleep optimisation" is not that. "My physician diagnosed iron-deficiency anaemia and put me on ferrous sulfate" is.
In IR-2024-65 the IRS went further and warned about companies selling doctor’s notes for a fee: notes "based merely on self-reported health information" do not convert non-medical wellness expenses into medical ones. If a website offers to sell you a letter for a flat fee after a questionnaire, the IRS has already told you in writing what it thinks of the resulting document.
So this ledger does two things and refuses to do a third. It tracks what you spent and tells you which bucket each purchase falls in. It will not tell you a purchase qualifies — your plan administrator decides that, and the IRS decides after them.
These change every year by revenue procedure. The figures below are the ones recorded in this project's reference data, with the procedure that set each of them.
| 2025 | 2026 | Source | |
|---|---|---|---|
| HSA contribution limit — self-only | $4,300 | $4,400 | Rev. Proc. 2025-19 (2026 HSA/HDHP figures) |
| HSA contribution limit — family | $8,550 | $8,750 | Rev. Proc. 2025-19 (2026 HSA/HDHP figures) |
| HSA catch-up, age 55+ | $1,000 | $1,000 | Rev. Proc. 2025-19 (2026 HSA/HDHP figures) |
| HDHP minimum deductible — self / family | $1,650 / $3,300 | $1,700 / $3,400 | Rev. Proc. 2025-19 (2026 HSA/HDHP figures) |
| HDHP out-of-pocket maximum — self / family | $8,300 / $16,600 | $8,500 / $17,000 | Rev. Proc. 2025-19 (2026 HSA/HDHP figures) |
| Health FSA salary-reduction limit | $3,300 | $3,400 | Rev. Proc. 2025-32 (2026 FSA limit) |
| Maximum FSA carryover | $660 | $680 | Rev. Proc. 2025-32 (2026 FSA limit) |
| HSA contribution deadline for that tax year | April 15, 2026 | April 15, 2027 | IRS Pub. 969 |
They get written about together and they behave in opposite ways. One forgives you for logging late. The other punishes you for it.
There is no deadline at all. Notice 2004-50 Q&A-39: a distribution "can be used to pay or reimburse expenses incurred in any prior year as long as the expenses were incurred after the HSA was established. Thus, there is no time limit on when the distribution must occur." Two hard conditions: the expense must post-date the day you established the account, and it must not have been reimbursed from another source or already itemised on Schedule A.
Use-or-lose at plan-year end. Your plan may offer either a 2½-month grace period or a carryover — never both. A "run-out period" extends only the window to file a claim, not the window in which the expense may be incurred. So an FSA rewards logging as you go; an HSA forgives you for logging late.
The unextended due date of your return — April 15 following the tax year. Filing an extension does not extend it.
The asymmetry has a practical consequence in August, which is when you are probably reading this: an FSA balance has a clock on it and an HSA balance does not. Everything in the year-end checklist is really about the FSA.
For the categories where the default answer is no but the rules leave room, the mechanism that moves the answer is a letter from a clinician. It is worth being precise about what that document is, because there is an industry built on being imprecise about it.
It is a signed statement from a practitioner who has actually evaluated you, naming a diagnosed condition, naming the specific item, and explaining how the item treats that condition. It is not a receipt, a note bought from a website after a questionnaire, a blanket blessing for a shopping cart, or an approval. Submitting one is not approval — your administrator decides, and the IRS can look at it afterwards.
There is no Magellan letter service, and one is not coming. Only a clinician who has actually evaluated you can write a letter that means anything, because the causal sentence in the middle of it is clinical judgement about you specifically — the one part a questionnaire cannot manufacture. In IR-2024-65 the IRS warned in writing about companies selling notes based on self-reported information. We are not going to become one of them.
The six fields administrators look for, and the three things a letter cannot do →
Pub. 969: records sufficient to show that the distributions were exclusively to pay or reimburse qualified medical expenses, that those expenses hadn’t been previously paid or reimbursed from another source, and that they hadn’t been taken as an itemised deduction in any year. Don’t send them with your return — keep them with your tax records.
There is no HSA-specific retention period anywhere in Pub. 969, Notice 2004-50 or §223 — "keep receipts forever" is practitioner advice, not an IRS rule. The only stated rule is the general one: keep records until the period of limitations for that return runs out. The advice is still sound though, and here is the actual reason: because a distribution can reimburse an expense from any earlier year, the clock runs from the return reporting the distribution, not the year of the purchase. A 2026 receipt can still be the substantiation for a 2046 withdrawal.
A non-qualified distribution is included in gross income and hit with an additional 20% tax under §223(f)(4)(A), reported on Form 8889. The 20% is waived after age 65, disability or death — but ordinary income inclusion still applies. Worth knowing if you treat the HSA as a retirement vehicle.
All fifteen expense categories in this project's reference data, scored against the three tests. Every classification below is at the category level and is attributed to that reference data — it is not a Magellan determination about any product you might buy.
| Expense category | Medical care | Card | Sch. A | Basis |
|---|---|---|---|---|
| 💊 Dietary supplements & vitamins | Letter needed | Letter needed | Letter needed | IRS |
| 🤰 Prenatal vitamins | Letter needed | Yes | Letter needed | Practice |
| 🦴 Glucosamine / chondroitin | Letter needed | Yes | Letter needed | Practice |
| 🌾 Fiber supplement / psyllium | Partly | Partly | No | IRS |
| 🩹 OTC drugs (aspirin, antacids, allergy) | Yes | Yes | No | IRS |
| 🩸 Menstrual care products | Yes | Yes | No | IRS |
| 🧴 Sunscreen (SPF 15+, broad spectrum) | Yes | Yes | No | IRS |
| 🥤 Food, groceries, protein powder, shakes | No | No | No | IRS |
| 🏋️ Gym membership / health club dues | No | No | No | IRS |
| 🚴 Fitness / exercise equipment | Letter needed | Letter needed | Letter needed | Practice |
| 🥗 Nutritional counseling / dietitian | Letter needed | Letter needed | Letter needed | IRS |
| 🧬 Lab panels / biomarker testing | Partly | Yes | Partly | IRS |
| 📈 Monitors & devices (CGM, BP cuff, glucose) | Yes | Yes | Yes | IRS |
| 🩺 Doctor visits, copays, prescriptions | Yes | Yes | Yes | IRS |
| 📦 Something else | Letter needed | Letter needed | Letter needed | Practice |
What the IRS documents say, what custodians actually do, and the three questions hiding inside "is it eligible?"
All fifteen expense categories scored against the three tests, with the citation behind each one.
A dated, printable spend-down plan — and the trap the internet tells you to walk into every December.
Twenty-two questions with the citation attached to each answer.
What one is, the six fields administrators look for, and the three things a letter cannot do.
Open the HSA / FSA ledger in the Magellan app →