You can buy diapers with an HSA only when they are needed to relieve the effects of a diagnosed medical condition, such as adult incontinence or a disability that prevents continence in an older child. Regular diapers for a healthy infant are not HSA-eligible. The IRS states plainly that you cannot include the cost of diapers or diaper services as a medical expense “unless they are needed to relieve the effects of a particular disease.”1Internal Revenue Service. Publication 502 (2025), Medical and Dental Expenses
That single exception is where most eligible purchases live, so the details of how it works matter more than the general rule.
When Diapers Qualify as a Medical Expense
The purchase has to be tied to a diagnosis. Diapers used to manage normal infant development do not qualify; diapers used to manage a condition that impairs bladder or bowel control do.
Situations that commonly meet the standard include:
- Adult incontinence products — absorbent briefs, underpads, and protective liners — used by adults with bladder or bowel conditions caused by neurological disorders, spinal injuries, prostate surgery recovery, or other diagnosed conditions.
- Diapers for older children who have not reached continence milestones because of a diagnosed condition such as autism spectrum disorder, cerebral palsy, or spina bifida.
- Diapers or incontinence products needed during recovery from a surgery or treatment that temporarily affects bladder or bowel control.
Related items can qualify on the same basis when they are part of managing the diagnosed condition, including bed pads, specialized liners, and prescribed skin barrier creams used to prevent secondary complications.
You Need a Letter of Medical Necessity
To use HSA funds for diapers, get a Letter of Medical Necessity (LMN) from a licensed healthcare provider. The letter connects the purchase to a specific condition and gives your HSA administrator the documentation to approve the expense.
A complete LMN identifies the patient and their relationship to the account holder, names the specific diagnosis (ideally with a diagnostic code), explains why diapers are medically necessary to manage that condition, states how long the patient is expected to need them, and carries the provider’s credentials and signature.
Most administrators require the letter to be renewed periodically, often annually, to confirm the condition and the ongoing need. Many offer downloadable LMN templates that prompt the provider for every required detail.
How to Pay With HSA Funds
Using Your HSA Debit Card
The simplest option is to swipe your HSA debit card at a pharmacy or medical supply retailer that carries incontinence products. Some general retailers use an Inventory Information Approval System that checks each item at checkout, so the card may clear the incontinence supplies while declining non-medical items in the same cart.
If the retailer’s system can’t verify the item, the card may be declined even when the expense is genuinely qualified. Pay out of pocket in that case and file for reimbursement.
Reimbursing Yourself Later
Submit a reimbursement claim through your HSA administrator’s online portal with an itemized receipt showing the date, item description, and amount. The administrator may also request the LMN if one isn’t already on file. Most reimbursements process within five to fourteen business days.
There is no deadline for reimbursing yourself. As long as the expense was incurred after the HSA was opened and you keep the documentation, you can pay now and reimburse yourself months or years later.
What Happens If You Use HSA Funds for Regular Diapers
If you tap the HSA for an expense that doesn’t qualify, the withdrawal is added to your taxable income for the year, and the IRS charges an additional 20 percent tax on top of income tax on the non-qualified amount.2Internal Revenue Service. Instructions for Form 8889 (2025) – Section: Part II, HSA Distributions
The 20 percent additional tax does not apply to distributions made after the account holder turns 65, becomes disabled, or dies (in which case the distribution goes to a beneficiary). In those cases the money is still taxable as income; only the extra 20 percent is waived.3Internal Revenue Service. Publication 969 (2025), Health Savings Accounts and Other Tax-Favored Health Plans
HSA distributions are reported on Form 8889 with your federal return.
Records to Keep
You don’t send documentation with your return, but you have to produce it if audited. For each qualifying diaper purchase, keep the itemized receipt, the current LMN and any prior renewals, and any insurance Explanation of Benefits if part of the cost was covered and you paid the balance from your HSA.
The IRS generally asks for tax records for three years after filing.4Internal Revenue Service. How Long Should I Keep Records Because HSA reimbursements can be claimed years after the expense, keep the paperwork as long as the account is open and you might still reimburse yourself for older costs.
Did the CARES Act Add Baby Diapers?
No. The CARES Act of 2020 added menstrual care products to the list of HSA-qualified expenses and allowed over-the-counter medications to be reimbursed without a prescription, effective for purchases after December 31, 2019.5Internal Revenue Service. IRS Outlines Changes to Health Care Spending Available Under CARES Act It did not add regular baby diapers, and the “unless needed to relieve the effects of a particular disease” standard in Publication 502 still governs.1Internal Revenue Service. Publication 502 (2025), Medical and Dental Expenses Bills to make baby diapers HSA- and FSA-eligible have been introduced in Congress but none have been enacted as of 2026.