Food and Groceries: FSA and HSA Eligibility
Ordinary food is not FSA or HSA eligible. Special food for a diagnosed condition may be reimbursable with a letter, but only for the excess cost over normal food.
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Short answer
Ordinary food is not reimbursable. Special food for a diagnosed illness, such as gluten-free food for celiac disease, can be reimbursable with a letter, but only for the amount exceeding a normal diet. A clinician must diagnose the condition and document how the special food treats it.
Weight-loss program fees may be reimbursable with a letter for a diagnosed condition, but food or meal replacements are never reimbursable, regardless of the program. The key is the cost difference: you're reimbursed only for what special food costs above ordinary food.
The answer: ordinary food is not reimbursable
Groceries and ordinary food are not qualified medical expenses under FSA, HSA and HRA rules. This includes diet food and beverages. The IRS states that "you can't include the cost of diet food or beverages in medical expenses because the diet food and beverages substitute for what is normally consumed to satisfy nutritional needs". Anything that replaces your normal diet for general weight loss, health improvement or wellness does not qualify for reimbursement.
When special food needs a letter
Special food for a diagnosed medical condition can be reimbursable, but with limits. A clinician must diagnose the condition and explain how the special food treats it.
Under Publication 502's special food rule, three conditions must be met. The food doesn't satisfy normal nutritional needs. It alleviates or treats an illness. And a physician confirms the medical need. Gluten-free food for celiac disease is the most common example. Any other special food has to pass the same three tests.
How to get reimbursed for special food
Request your letter before you buy the special food. The letter must be dated on or before the purchase it covers. You can use any card to pay at any store or online retailer. Once you have the letter from your clinician, Burst files the reimbursement claim with your FSA, HSA or HRA administrator, and the administrator pays you out of your account by deposit or check.
When food is reimbursable, when it needs a letter, when it's not
Here's how different food and meal situations break down across FSA, HSA and HRA accounts.
Food or Meal | FSA, HSA or HRA? | Why |
|---|---|---|
Ordinary groceries (produce, meat, dairy, grains) | Not reimbursable | Food for general nutrition is a personal, living expense |
Diet food or beverages (low-calorie meals, diet shakes) | Not reimbursable | They substitute for normal nutrition and improve appearance or general health, not treat illness |
Weight-loss program fees | With a letter | Reimbursable only if diagnosed with obesity or a condition where weight loss is medically necessary |
Weight-loss food or meal replacements (program meals, shakes) | Not reimbursable | Food is never reimbursable, even within a paid weight-loss program |
Gluten-free food for diagnosed celiac disease | With a letter | Special food for a diagnosed condition, reimbursable only for the excess cost over normal food |
Related food and nutrition items
Nutritional supplements and vitamins follow a different rule than food. They can be reimbursable with a letter when a clinician recommends them as treatment for a specific diagnosed condition such as a nutrient deficiency. Fiber laxatives with a Drug Facts label (such as Metamucil) are reimbursable outright as over-the-counter medicine. A fiber supplement sold with a Supplement Facts label is reimbursable with a letter.
Getting special food with a letter reimbursed with Burst
If what you're buying needs a letter of medical necessity, Burst writes it and files the claim. $35 once, about two minutes to request, reviewed by a licensed clinician, typically in your inbox within 24 hours. Burst files the reimbursement claim with your FSA, HSA or HRA administrator, and the administrator pays you out of your account by deposit or check. No letter, no charge. Claim denied, money back. The letter has to be dated on or before the purchase it covers, so request it before you buy.
Get reimbursed for my special food
Frequently asked questions
Are groceries FSA or HSA eligible?
No. Ordinary groceries and food are not reimbursable from FSA, HSA or HRA accounts. The IRS does not consider general food a medical expense, even if you're on a diet or trying to improve your health.
Can I use my HSA for diet food or weight-loss programs?
Diet food and beverages are never reimbursable. A weight-loss program fee may be eligible with a letter if you have a diagnosed condition such as obesity, but the food or meal replacements themselves are not covered.
Is gluten-free food FSA or HSA eligible?
Gluten-free food is reimbursable with a letter if you have diagnosed celiac disease. The letter must come from your clinician and document that you need gluten-free food to treat your condition. You get reimbursed only for the amount by which gluten-free food costs more than ordinary food.
What is the excess cost rule for special food?
Special food is reimbursable only for the difference between its cost and a normal diet. If gluten-free bread costs $8 and regular bread costs $4, the excess is $4. That $4 difference is the reimbursable amount. This limit applies to all special food purchased to treat a diagnosed condition.
Does any special food qualify with a letter?
Only food that meets all three IRS tests: it doesn't satisfy normal nutritional needs, it alleviates or treats an illness, and a physician confirms the need in writing. Gluten-free food for diagnosed celiac disease is the clear case. Standard weight-loss meal replacements never qualify, whatever the program.
Does FSA have different rules than HSA for special food?
FSAs are generally "use-it-or-lose-it" plans where balances expire at the end of the year (unless your plan allows a small carryover). If you have special food expenses and an FSA, use the funds before the year ends. With an HSA, funds stay in your account indefinitely. The special food rule itself is the same across FSA, HSA and HRA accounts.
Keep reading: Vitamins and supplements FSA eligibility, Complete guide to FSA and HSA eligible items, What Can I Use My HSA Funds On?, and all guides on this topic.
Sources
IRS Publication 502 - Medical and Dental Expenses (diet food and beverages not reimbursable, special food rule and excess-cost limit, weight-loss program eligibility, general definition of medical expenses)
IRS Publication 969 - Health Savings Accounts and Other Tax-Favored Health Plans (FSA use-it-or-lose-it rule, account definitions and qualified medical expenses)
Healthcare.gov Glossary - FSA, HSA and HRA Information (Account types and general qualified medical expense guidance)
