FSA / HRA FAQs
Over-the-Counter
Are Over-the-Counter (OTC) items eligible for reimbursement from my Medical Flexible Spending Account (FSA) or Health Reimbursment Account (HRA)?
What requirements must be met for an OTC item to be eligible for reimbursement?
What documentation do I need to submit for reimbursement of eligible OTC items?
What OTC items are not eligible for reimbursement?
Can I purchase large quantities of OTC items?
Are Over-the-Counter (OTC) items eligible for reimbursement from my Medical Flexible Spending Account (FSA) or Health Reimbursement Account (HRA)?
Effective January 1, 2011, Medical FSA and HRA funds may no longer be used for OTC drugs and medicines (other than insulin) without a directive from a medical provider. This means that beginning January 1, 2011:
| • | These items can no longer be purchased with a benefit card. |
| • | If an OTC drug or medicine is required to treat a specific medical condition, you may submit a claim for reimbursement, but you must include a Certification of Medical Necessity form completed by your medical provider. |
This rule does not apply to eligible OTC medical supplies that are not drugs or medicines. As long as OTC items are allowed under your plan, Medical FSA and HRA funds can continue to be used for these expenses without a Certification of Medical Necessity form. This means that they can be either purchased with a benefit card or a claim may be submitted for reimbursement.
What requirements must be met for an OTC item to be eligible for reimbursement?
| • | To be eligible for reimbursement: | |
| – | A medical item must be used "primarily for the prevention or alleviation of a physical or mental defect or illness" and would not be used except for a particular medical condition. | |
| – | A drug or medicine requires a Certification of Medical Necessity form completed by your medical provider. | |
| – | The item must be used by the Medical FSA/HRA participant or the participant's spouse or dependent. | |
| – | The item must not be used for general health or cosmetic purposes. | |
| • | See some examples in the OTC Chart. | |
| • | The expense must be for medical care during the timeframe indicated in your Plan Highlights. | |
What documentation do I need to submit for reimbursement of eligible OTC items?
Along with your completed claim form, you must submit an itemized receipt that includes the following information:
| • | Name of the provider | |
| • | Date of the purchase | |
| • | Name of the item being purchased | |
| • | Your out-of-pocket cost for the service | |
Your signature on the claim form certifies that the item qualifies as an eligible expense under IRS regulations, is for use by you, your spouse or eligible dependent, and is not reimbursable from any other source.
If required, include a completed Certification of Medical Necessity form along with your receipt and claim form.
What OTC items are not eligible for reimbursement?
Items are not eligible for reimbursement if they are normally used for general health, are not used to treat a medical medical condition (e.g. toothpaste, mouthwash, lotion, shampoo) or are cosmetic in nature (e.g. teeth whitening products, wrinkle reducers). See additional examples in the OTC Chart.
Can I purchase large quantities of OTC items?
Reasonable quantities of eligible OTC items are reimbursable if purchased for either existing or imminent medical conditions. If large quantities are necessary for the treatment of an existing condition, the medical provider must indicate on the Certification of Medical Necessity form that the quantity being purchased is necessary for the treatment of a diagnosed medical condition.
| Sample OTC Chart (through 12/31/2010) | |
| Sample OTC Chart (effective 1/1/2011) |