Are all supplements HSA eligible? Understanding IRS guidelines

November 24, 2025 •

3 min read

According to IRS guidelines, most nutritional supplements and vitamins are not automatically HSA eligible unless prescribed for a specific medical condition. This means that the answer to whether all supplements are HSA eligible is a definitive 'no,' but there are important exceptions and rules to understand to maximize your account benefits.

Quick Summary

HSA eligibility for supplements hinges on medical necessity and proper documentation. General wellness supplements do not qualify, while supplements prescribed by a healthcare provider for a specific condition may be eligible with a Letter of Medical Necessity. Prenatal vitamins are a key exception that is automatically covered.

Key Points

Not all supplements are eligible: The IRS requires supplements to address a specific, diagnosed medical condition to be HSA-eligible.
Medical necessity is key: Supplements taken for general health or wellness are not considered qualified medical expenses.
Get a Letter of Medical Necessity: For most non-prescription supplements, you will need an LMN from a healthcare provider to prove medical necessity.
Prenatal vitamins are an exception: Prenatal vitamins are automatically HSA-eligible because they are considered essential for managing pregnancy.
Keep detailed records: Always save your LMNs and receipts for all eligible supplement purchases in case of an IRS audit.
Avoid penalties: Using HSA funds for non-qualified expenses can result in taxes and penalties, so it is crucial to understand and follow the rules.

The Core IRS Rule: Medical Necessity

The fundamental principle behind Health Savings Account (HSA) eligibility for supplements is medical necessity. The IRS defines a qualified medical expense as something used for the "diagnosis, cure, mitigation, treatment, or prevention of disease". Products taken for general health, without a specific diagnosis or doctor’s recommendation, are considered for general wellness and are not eligible for tax-free spending. This critical distinction is what makes most over-the-counter supplements ineligible.

General wellness vs. specific treatment

General Wellness: A daily multivitamin taken for overall health, a probiotic for general gut support, or a fish oil supplement for routine wellness are all typically considered for general wellness. These expenses do not address a specific medical condition and are therefore not HSA-eligible.
Specific Treatment: If a healthcare provider diagnoses a specific condition, such as anemia, and recommends an iron supplement as part of the treatment, the iron supplement is now considered a qualified medical expense. The key is the medical justification tied to a specific diagnosed condition.

How a Letter of Medical Necessity (LMN) works

For many non-prescription supplements, a Letter of Medical Necessity is the key to unlocking HSA eligibility. This document from a licensed healthcare provider certifies that the supplement is required to treat a specific medical condition. The LMN must be obtained before the purchase and must include:

The patient's diagnosed medical condition.
The specific supplement recommended for treatment.
How the supplement is expected to alleviate or treat the condition.
The duration of the recommended treatment.

Once you have the LMN, you must keep it, along with your receipts, for your records in case of an IRS audit.

Exceptions to the Rule: Automatically Eligible Supplements

While most supplements require a specific medical diagnosis and an LMN, there is one notable exception that is automatically HSA eligible: prenatal vitamins. The IRS recognizes that these supplements are essential for managing a specific medical condition—pregnancy—and do not require a separate prescription or LMN. This includes both prescription and over-the-counter prenatal vitamin formulations.

The impact of recent rule changes

Following the CARES Act of 2020, over-the-counter (OTC) medications became HSA-eligible without a prescription. However, this change did not extend to most dietary supplements and vitamins, which remain subject to the medical necessity rule. Recent guidance from the IRS in late 2024 and 2025 has reinforced stricter documentation requirements, emphasizing that only supplements part of a doctor-prescribed treatment plan will be eligible.

How to Claim Your HSA Funds for Supplements

There are two main ways to use your HSA for eligible supplement purchases:

Direct Payment with HSA Debit Card: If you are certain a supplement is HSA-eligible (like a prenatal vitamin) or have the required LMN, you can use your HSA debit card directly at the point of sale. Many retailers and pharmacies now have systems to identify eligible items at checkout.
Reimbursement: If you paid for an eligible supplement with personal funds, you can submit a claim to your HSA administrator for reimbursement. This is particularly useful for purchases where eligibility is not automatically recognized. You will need to provide your purchase receipt and, if necessary, the LMN as proof.

Comparison Table: Eligible vs. Non-Eligible Supplements


Feature	HSA-Eligible (with LMN or exception)	HSA-Ineligible (General Wellness)
Purpose	To treat, prevent, or mitigate a specific diagnosed medical condition.	To maintain general health or for performance enhancement.
Examples	Prenatal vitamins (automatic); Iron for diagnosed anemia; Vitamin D for documented deficiency; Glucosamine for arthritis; Probiotics for IBS.	Daily multivitamins; Protein powders; Creatine; General herbal remedies; Weight loss supplements.
Requirement	Prescription or Letter of Medical Necessity from a healthcare provider.	No specific medical documentation or diagnosis required.
Documentation	Keep LMN and receipts for audit purposes.	No documentation needed as it is a personal expense.

Conclusion

In summary, the assumption that all supplements are HSA eligible is a common and costly misconception. While HSAs offer a powerful way to pay for healthcare with pre-tax dollars, strict IRS rules govern supplement eligibility. The key takeaway is that eligibility is determined by a specific medical necessity, with proper documentation from a healthcare provider, rather than the purchase being for general wellness. Notable exceptions, such as prenatal vitamins, are automatically covered. Always consult with your doctor and your HSA administrator to ensure your supplement purchases are compliant and to avoid potential tax penalties.

For more detailed information on qualified medical expenses, refer to IRS Publication 502.

Frequently Asked Questions

No, standard multivitamins taken for general health purposes are not HSA-eligible without a Letter of Medical Necessity from a healthcare provider stating they are required for a specific medical condition.

Yes, prenatal vitamins are a special exception and are HSA-eligible without a prescription or Letter of Medical Necessity. This applies to both over-the-counter and prescription varieties.

An LMN is a document from a licensed healthcare provider stating that a specific supplement is necessary to treat or prevent a diagnosed medical condition. It is required for many non-prescription supplement purchases to be HSA-eligible.

A formal prescription is not always required, but strong documentation of medical necessity, like an LMN, is essential. The recommendation must come from a qualified healthcare professional, not just a general recommendation.

Probiotic supplements for general gut health are not HSA-qualified. However, if a gastroenterologist or other healthcare provider recommends them to treat a specific condition like IBS, they may be eligible with proper documentation.

Yes, you can be reimbursed for eligible supplement expenses already paid for with personal funds. You will need to log the expense with your HSA provider and, if required, provide the receipt and LMN.

Using HSA funds for non-qualified expenses can result in the withdrawal being taxed as income and may incur a 20% penalty, in addition to other fees.