These three categories share a single origin and a single, widely-missed catch. The CARES Act dropped the prescription requirement for over-the-counter drugs paid for after 31 December 2019, and added menstrual care products. Sunscreen rides along because it is an FDA monograph over-the-counter drug. All three are reimbursable. None of the three is deductible on Schedule A.
CARES Act §3702 dropped the prescription requirement for amounts paid after Dec 31 2019 — but it amended §223, not §213(d). So these are HSA/FSA-reimbursable and still not deductible on Schedule A. Don’t let an HSA list drive a Schedule A entry.
Same CARES Act change. §223(d)(2) now treats amounts paid for menstrual care products as paid for medical care.
Sunscreen is an FDA monograph OTC drug, so it rides the CARES Act rule — that part is IRS-based. The "SPF 15+ / broad spectrum" threshold is not in any IRS document; it comes from FDA labelling and card-substantiation coding.
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.
CARES Act §3702 amended §223 — the section that governs health savings accounts. It did not amend §213(d) — the section that governs the itemised medical expense deduction. So the same bottle of aspirin is a qualified HSA distribution and is not a Schedule A medical expense. That is not a loophole or an oversight you can argue around; it is two different sections of the code reaching two different answers about one purchase.
The failure mode this produces is specific and common: someone uses an HSA eligibility list as a shopping list for their Schedule A. Do not do that. They are different lists.
Every eligibility list on the internet says sunscreen qualifies if it is SPF 15 or higher and broad spectrum. That threshold appears in no IRS document. It comes from FDA labelling and from the codes custodians use to substantiate card swipes. It is a real constraint on whether your card clears — it is simply not a tax rule, and it is worth knowing which of the two you are up against when a claim is declined.
The catalogue's topical pain products carry an active ingredient and a strength in their names — diclofenac 1%, lidocaine 4%, capsaicin 0.1%, methyl salicylate with menthol. That is the shape of a Drug Facts panel. The reference data classifies the expense category "OTC drugs" as reimbursable without a letter; it does not adjudicate any individual product, and your administrator codes the specific item.
The rest of the skin shelf is a different question. Serums, retinoids and acids are not classified anywhere in this reference set, and administrator forms carry an attestation that the treatment is not cosmetic — which is the sentence doing the work. Treat those as unclassified and ask your administrator before you assume.
The topical analgesics below are the catalogue's over-the-counter drug products, and the sunscreen is the catalogue's one FDA monograph sunscreen. The classification above is at the expense-category level and is not a determination about any individual product.
17 PubMed citations · $25.59
Randomized trials and meta-analyses, including Cochrane reviews, indicate that topical…
17 PubMed citations · $12
Randomized trials and meta-analyses show that topical capsaicin produces modest reductions in…
22 PubMed citations · $13
The best-supported use of topical lidocaine is localized neuropathic pain, especially…
18 PubMed citations · $15.99
Menthol is used for the temporary relief of minor muscle and joint pain, including strains,…
18 PubMed citations · $16.97
Randomized trials of methyl-salicylate/menthol patches and menthol-based topical products…
19 PubMed citations · $45
In a randomized community-based trial in Australia, adults assigned to daily sunscreen showed…
See all Topical Pain Relief → · See all Skin & Topical Longevity →
No letter is needed here — the reference data records the card and claim-desk answer as yes for all three categories. A letter is the mechanism for the categories where the rules leave room and the default answer is no.
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 →