FSA-eligible items are also HSA-eligible in nearly every case. Both accounts pull from the same IRS definition of a qualified medical expense, so a product or service that qualifies for one almost always qualifies for the other. The one meaningful exception is a limited purpose FSA, which is restricted to dental and vision expenses even though the underlying IRS rule would allow more.
Why the Two Lists Overlap
The overlap exists because there is only one rule. Section 213(d) of the Internal Revenue Code defines a qualified medical expense as an amount paid for the diagnosis, cure, treatment, or prevention of disease, or for anything that affects a structure or function of the body.1Office of the Law Revision Counsel. 26 USC 213 – Medical, Dental, Etc., Expenses That single sentence governs both HSAs and FSAs.
IRS Publication 502 fills in the specifics, listing individual items and services that meet the 213(d) definition. The same publication applies to both account types, so there is no separate federal “HSA list” and “FSA list.”2Internal Revenue Service. Publication 502 (2025), Medical and Dental Expenses A plan administrator can layer on documentation requirements or its own restrictions, but the underlying federal eligibility is identical.
Common Items Both Accounts Cover
The CARES Act, passed in 2020, expanded the shared list in two ways worth knowing. Over-the-counter medications like pain relievers, cold medicine, and allergy treatments no longer need a doctor’s prescription for reimbursement. Menstrual care products, including tampons, pads, liners, and cups, are now fully qualified expenses.3Internal Revenue Service. IRS Outlines Changes to Health Care Spending Available Under CARES Act
Beyond those, both accounts cover the everyday health purchases most people expect. Bandages and other basic medical supplies qualify. So do diagnostic devices used to monitor or treat illness, including blood sugar test kits, blood pressure monitors, and thermometers.2Internal Revenue Service. Publication 502 (2025), Medical and Dental Expenses Broad-spectrum sunscreen rated SPF 15 or higher qualifies; sunscreen below that threshold does not.
Either account can also pay for your spouse’s or dependents’ qualified expenses, not just your own. The 213(d) test applies to the expense, not the person incurring it, so a prescription for your child or a dental visit for your spouse can come out of the same account you use for yourself.
Expenses Neither Account Covers
The 213(d) definition draws a hard line: an expense has to address a medical condition or affect a specific body structure or function. Anything bought for general health or personal appearance sits outside that line, regardless of which account you hold.
- Cosmetic procedures such as face lifts, hair transplants, hair removal, and liposuction are not qualified expenses. The exception is cosmetic surgery needed to correct a deformity from a congenital condition, an accident, or a disfiguring disease.2Internal Revenue Service. Publication 502 (2025), Medical and Dental Expenses
- Teeth whitening is classified as cosmetic and excluded, even though cleanings and fillings qualify.2Internal Revenue Service. Publication 502 (2025), Medical and Dental Expenses
- General gym memberships are not qualified. A membership qualifies only when purchased for the sole purpose of treating a specific physician-diagnosed condition such as obesity or heart disease.4Internal Revenue Service. Frequently Asked Questions About Medical Expenses Related to Nutrition, Wellness and General Health
- Vitamins and supplements qualify only when a medical practitioner recommends them to treat a specific diagnosed condition. A daily multivitamin taken for general wellness does not count.4Internal Revenue Service. Frequently Asked Questions About Medical Expenses Related to Nutrition, Wellness and General Health
- Exercise programs, swimming lessons, and dance classes don’t qualify even when a doctor recommends them, because the IRS treats them as general health improvement rather than medical treatment.4Internal Revenue Service. Frequently Asked Questions About Medical Expenses Related to Nutrition, Wellness and General Health
The pattern is consistent once you notice it. Anything marketed as “wellness” rather than as treatment for a diagnosable condition is likely to be rejected by both account types. If you can’t point to a specific medical problem a doctor identified, assume the item doesn’t qualify.
The Limited Purpose FSA Exception
A limited purpose FSA is the one place where the overlap breaks. Employers offer it alongside an HSA because of an IRS rule: if you have access to a general-purpose health FSA that reimburses broad medical expenses, you cannot contribute to an HSA.5Internal Revenue Service. Publication 969 (2025), Health Savings Accounts and Other Tax-Favored Health Plans A limited purpose FSA sidesteps that by restricting reimbursement to dental and vision expenses only, such as eyeglasses, contact lenses, dental cleanings, and orthodontic work. Because it doesn’t cover general medical costs, it doesn’t disqualify you from an HSA.
If your employer offers both, you can fund both, but you have to use them for different purchases. The HSA handles your broader medical expenses; the limited purpose FSA covers dental and vision. Submitting a general medical bill to a limited purpose FSA will get the claim denied. This is the scenario where an item can be eligible under the IRS definition and still ineligible under your specific account rules.
Same Eligibility, Different Consequences
Eligibility is only half the story. The two accounts treat non-qualified spending very differently, and that matters when you’re deciding which account to use for a borderline purchase.
For an HSA, any distribution not used for a qualified medical expense gets added to your taxable income for the year and hit with an additional 20% tax penalty.5Internal Revenue Service. Publication 969 (2025), Health Savings Accounts and Other Tax-Favored Health Plans A $500 non-qualified purchase costs $100 in penalty alone, before income tax.
FSAs work differently because the plan administrator screens claims before the money moves. When you submit a claim or swipe an FSA debit card, the administrator checks eligibility. Non-qualified claims are denied, or you’re asked to repay them, and card transactions at non-medical retailers are often declined automatically. If a non-qualified expense slips through and isn’t repaid, the amount becomes taxable income.
Both accounts require documentation that every reimbursement covered a qualified expense: date, description, amount, and provider. For items that aren’t obviously medical, such as a humidifier or a specialized mattress, a Letter of Medical Necessity from your doctor is the standard way to establish eligibility. The letter should identify the condition being treated and explain why the specific product is required. Keep records for at least three years from the date you file the return covering those expenses.6Internal Revenue Service. How Long Should I Keep Records?
So the short version stays short. If an item qualifies for your FSA, it qualifies for your HSA, unless your FSA is a limited purpose account. Everything else about the two accounts differs, but the eligible-items list does not.