An HSA does not cover smartwatches by default. The IRS treats devices like the Apple Watch, Fitbit, Samsung Galaxy Watch, and Garmin as general wellness products, not medical equipment. You can make a smartwatch HSA-eligible, but only if a licensed healthcare provider documents in a Letter of Medical Necessity that the device is needed to diagnose, treat, or prevent a specific condition you have.
Why Smartwatches Fail the Default Test
IRS Publication 502 limits qualified medical expenses to costs for the “diagnosis, cure, mitigation, treatment, or prevention of disease” that are “primarily to alleviate or prevent a physical or mental disability or illness.”1IRS. Publication 502, Medical and Dental Expenses Anything “merely beneficial to general health” is out. The publication does not list smartwatches or fitness trackers by name, but it does exclude health club dues and cites blood glucose test kits as an example of an eligible diagnostic device.2IRS. Publication 502 (PDF)
A typical smartwatch tracks steps, calories, and sleep, but it also handles phone notifications, GPS, and music. That mix puts it in the consumer-product bucket. HSA Store, a curated marketplace for eligible items, confirms the Apple Watch is not automatically eligible because it is “designed for general wellness.”3HSA Store. HSA-Eligible Ways to Boost Your Health and Wellness Tracking
How a Letter of Medical Necessity Changes the Answer
A Letter of Medical Necessity, or LMN, is a prescription-like statement from a licensed healthcare provider confirming that a specific device is needed to manage a diagnosed condition. Submit it with your receipt to your HSA administrator, and reimbursement becomes possible.4HSA Store. Fitness Tracker HSA Eligibility
The letter must link one specific device to one specific condition and explain why continuous health or biometric monitoring is medically necessary.5Crates Health. Fitness Trackers HSA FSA Eligibility Guide A vague endorsement that a smartwatch is “good for your health” will not do. The IRS has stated that doctor’s notes based only on self-reported health information cannot convert personal expenses into qualified medical care.6IRS. IRS Alert: Beware of Companies Misrepresenting Nutrition, Wellness and General Health Expenses as Medical Care
Conditions That Typically Support an LMN
Providers usually write LMNs for smartwatches when the tracking features answer a real clinical need. Common examples:
- Cardiovascular conditions such as hypertension, atrial fibrillation, arrhythmias, heart disease, and high cholesterol, where heart rate and ECG monitoring have clinical value.
- Metabolic and chronic conditions such as diabetes, obesity, metabolic syndrome, and polycystic ovary syndrome, where activity and biometric tracking supports disease management.
- Sleep disorders such as sleep apnea and insomnia, where sleep tracking helps monitor treatment.
- Mental health conditions including depression, anxiety, ADHD, and chronic stress, where physiological data supports a treatment plan.
- Preventive monitoring for a family history of heart disease, fall risk in elderly patients, pregnancy, and post-surgical recovery.5Crates Health. Fitness Trackers HSA FSA Eligibility Guide
Which watch you buy matters less than why your doctor says you need it. An Apple Watch, a Samsung Galaxy Watch, or a Garmin can all qualify with the right documentation.7Crates Health. Samsung Galaxy Watch HSA FSA Eligibility
Timing and Recordkeeping
The medical necessity has to exist when you buy the device. Retroactive justification does not work; the LMN should predate or coincide with the purchase.8Saving Wiser. Is an Apple Watch HSA Eligible Keep the receipt and the letter indefinitely. There is no IRS deadline for submitting a reimbursement claim, but the paperwork has to be available if your account is audited.9Lively. HSA Reimbursement Rules
How to Get Reimbursed
Retailers like Apple and Samsung do not screen for HSA eligibility at checkout. Swiping an HSA debit card in the store will often go through, but that alone does not make the purchase compliant. The cleaner route is to pay with personal funds and seek reimbursement.
- Get the LMN first. See your doctor or use a telehealth service to obtain a letter tied to your diagnosis.
- Buy the smartwatch using a regular credit or debit card.
- Log into your HSA provider’s portal, open the reimbursement section, enter the expense, and upload both the receipt and the LMN.
- Reimbursement usually posts in two to four weeks, depending on the administrator.10Garmin. How to Get HSA FSA Reimbursement for Garmin Products
If your balance is lower than the purchase price, you can be reimbursed for part of it.10Garmin. How to Get HSA FSA Reimbursement for Garmin Products
Services That Issue LMNs Online
Several companies now connect buyers with licensed providers who can evaluate eligibility and issue an LMN without an in-person visit. Truemed is the most visible and has partnered with brands including Garmin, COROS, and Amazfit.11Truemed. Are Fitness Trackers FSA Eligible The usual flow: complete an online health questionnaire after purchase, wait for provider review, and receive an LMN within a day or two if approved.10Garmin. How to Get HSA FSA Reimbursement for Garmin Products
These services have drawn IRS scrutiny. In March 2024, the agency issued a public alert warning taxpayers to “beware of companies misrepresenting nutrition, wellness and general health expenses as medical care” for tax-advantaged accounts, and specifically flagged the use of doctor’s notes based on self-reported information. IRS Commissioner Danny Werfel said “taxpayers should be careful to follow the rules amid some aggressive marketing.”6IRS. IRS Alert: Beware of Companies Misrepresenting Nutrition, Wellness and General Health Expenses as Medical Care A July 2025 report in The New York Times described Truemed provider recommendations for items like beef hot dogs for insomnia and kettlebells for decades-old arm fractures, raising questions about whether every LMN meets IRS standards.12The New York Times. Truemed FSA HSA Calley Means The convenience is real, but so is the enforcement risk if the letter cannot stand up to review.
Wearables Marketed as Eligible Without an LMN
A few wearable companies claim their products qualify for HSA or FSA funds without a letter. These are marketing positions, and your administrator and the IRS still have the last word.
Oura says purchases of the Oura Ring made in 2023 and after are HSA/FSA eligible and that most providers do not require an LMN, though some may.13Oura. Oura Ring FSA HSA Its support page notes eligibility “may vary by plan or employer” and that card transactions can sometimes be declined even with sufficient funds.14Oura. Purchase With HSA or FSA Funds
Ultrahuman states that its Ring AIR is “always eligible” because it appears on the SIGIS product list, the database point-of-sale systems use to auto-approve HSA/FSA transactions. It has integrated Sika Health and Flex to allow direct HSA/FSA card payments at checkout.15Ultrahuman. Ultrahuman Ring AIR Is Now FSA Enabled
WHOOP announced in late 2023 that its memberships and wearables are FSA/HSA eligible without an LMN, citing the device’s health-monitoring features.16Buy FSA. Is WHOOP FSA HSA Eligible
What Happens If You Get It Wrong
Using HSA funds for an ineligible expense has real costs. The IRS treats the amount as a taxable distribution and adds a 20% penalty on top of regular income tax.8Saving Wiser. Is an Apple Watch HSA Eligible If your administrator flags a transaction you cannot substantiate, you may be asked to repay the plan, and failure to do so can result in suspension of your HSA debit card.17HSA Bank. Frequently Asked Questions
Administrators also have discretion on gray-area claims. Where IRS guidance is unclear, some will accept an LMN and others will not, and employers acting as plan administrators sometimes make the final call.18Chard Snyder. Health FSAs: Why Are Some Expenses Not Reimbursable
Pending Legislation
The Personal Health Investment Today (PHIT) Act, included in a reconciliation tax package the U.S. House passed in May 2025, would let HSA and FSA funds cover “qualified physical activity expenses” like gym memberships, fitness classes, and youth sports fees, capped at $500 per individual or $1,000 per family per year.19Health and Fitness Association. Health Fitness Association Applauds House Passage of Reconciliation Package With PHIT Act Language The bill moved to the Senate and has not been enacted. Even if it becomes law, whether smartwatches would count as a “qualified physical activity expense” is not yet settled.