This is the only expense category besides ordinary medical care that answers yes to all three questions at once: it is §213(d) medical care, the card clears, and it is deductible on Schedule A. The authority is unusually clean.
Reimbursable without a letter.
Reimbursable without a letter.
Reimbursable without a letter.
Notice 2010-59: the OTC-drug restriction never applied to items that aren’t medicines or drugs — including "diagnostic devices such as blood sugar test kits." Eligible regardless of prescription status.
Classification is at the expense-category level, comes from this project's HSA reference data, and is not a Magellan determination about any individual product. Your plan administrator decides what your plan reimburses.
Notice 2010-59 made the point that the restriction on over-the-counter medicines and drugs never applied to items that are not medicines or drugs in the first place — and it named diagnostic devices such as blood sugar test kits explicitly. That is why a glucose meter or a blood-pressure cuff does not need a prescription to be reimbursable, and why the CARES Act change in 2020 was irrelevant to this category: there was nothing to fix.
The reference set classifies monitors and devices — CGM, blood-pressure cuff, glucose meter — as the clean case. It does not separately classify general-purpose consumer wearables, and a wearable that reports sleep stages and readiness scores is not obviously the same thing as a diagnostic device. Unclassified in this reference set means one thing only: ask your plan administrator how they code it, and do not assume the answer from an adjacent aisle.
If you want the accuracy question rather than the tax question, that is a different and more interesting read: how sleep scores compare to polysomnography and the number everyone misreads.
If you are staring at an FSA balance in December, this is the category to look at first, not the supplement shelf. It is the one with the cleanest authority behind it, the one custodians decline least often, and — unlike a supplement — the one where the reference data does not depend on a letter that you would need a clinician appointment to obtain. The year-end checklist puts that in order.
Below are the catalogue's monitors and sensors. The classification above is at the expense-category level and is not a determination about any individual product — a continuous glucose monitor and a fitness watch may be coded very differently by the same administrator.
20 PubMed citations · $139
In randomized trials and meta-analyses, continuous and flash glucose monitoring modestly…
20 PubMed citations · $97.19
Across prospective cohorts and meta-analyses, home/self-measured blood pressure predicts…
19 PubMed citations · $110
Large prospective cohorts and pooled analyses of more than 10,000 people show that ambulatory…
22 PubMed citations · $129
Research on the biomarker this device tracks - blood-oxygen saturation and nocturnal…
23 PubMed citations · $399
The biomarkers a body-composition scale tracks are each linked to healthy aging: higher…
The reference data records no letter requirement for diagnostic devices. If your administrator asks for one anyway, that is their substantiation process, not the underlying rule.
Whatever the category, three limits hold on every letter:
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.
Log purchases in the Magellan HSA / FSA ledger →