HSA Eligible Expenses for Physicians (2026)
A complete guide to HSA-eligible expenses for physicians in 2026. Covers IRS Publication 502 rules, new OBBBA updates, and the stealth IRA strategy.
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Key takeaways
The Stealth IRA Opportunity
Most physicians know their HSA can cover doctor visits and prescriptions. Far fewer know it can also cover therapy, LASIK surgery, fertility treatments, long-term care insurance premiums, COBRA coverage between jobs, and certain home modifications — all completely tax-free.
The IRS-approved expense list is significantly broader than most HSA holders realize, and for physicians who have built a meaningful HSA balance using the stealth IRA strategy, knowing exactly what qualifies determines how effectively that balance can be deployed.
This guide covers every major category of HSA-eligible expenses in 2026, the physician-specific expenses most commonly overlooked, what requires a Letter of Medical Necessity, what is explicitly not covered, and how to document everything so a tax-free withdrawal made years from now holds up if the IRS ever asks.
The Legal Foundation: What Makes an Expense HSA-Eligible
The IRS defines qualified medical expenses as amounts paid for the "diagnosis, cure, mitigation, treatment, or prevention of disease, and for treatments affecting any part or function of the body," as outlined in Section 213(d) of the Internal Revenue Code and detailed in IRS Publication 502. The HSA-specific rules are in IRS Publication 969.
The critical phrase is primarily for medical care. Expenses that are merely beneficial to general health — a gym membership, vitamins, organic food — do not qualify on their own. The same expense can become eligible when prescribed by a physician to treat a specific, diagnosed medical condition. This distinction is where the Letter of Medical Necessity becomes relevant, covered in detail below.
Qualified HSA expenses can be incurred by you, your spouse, and any dependents you claim on your federal tax return. The dependency definition for HSA purposes is slightly broader than the standard tax definition — the person only needs to have been your dependent either when the medical services were provided or when you paid the bill.
One rule that catches people off guard: expenses must be incurred after your HSA was established. A medical bill from 2023 cannot be reimbursed tax-free from an HSA you opened in 2024. The HSA must exist before the expense is incurred.
What Changed in 2026: The OBBBA Expansion
The One Big Beautiful Bill Act, signed July 4, 2025, made one of the largest expansions of HSA rules since the accounts were created in 2003. According to the IRS guidance (Notice 2026-05), several categories that were previously excluded or uncertain are now explicitly covered:
- •Direct Primary Care membership fees are now HSA-eligible expenses effective January 1, 2026. A physician paying $100 per month for a DPC membership — for themselves or a family member — can now reimburse that cost tax-free from their HSA. To qualify, total DPC fees can't exceed $150 per month for an individual or $300 per month for an arrangement covering more than one person. For physicians evaluating DPC membership for their own family's healthcare, this makes the cost significantly more favorable after tax.
- •Bronze and catastrophic plans are treated as HSA-compatible starting January 1, 2026, whether or not they're bought through a Marketplace exchange. Self-employed physicians, locum tenens practitioners, and practice owners purchasing individual coverage now have broader access to HSA-qualified plans on the individual market.
- •Telehealth pre-deductible coverage is now permanently permitted without disqualifying HSA eligibility, for plan years starting on or after January 1, 2025. Previously extended through temporary legislation repeatedly, this is now a permanent rule. Physicians can use telehealth benefits before meeting their HDHP deductible and still contribute to and use their HSA freely.
The Core Categories: What Your HSA Covers
Medical and Preventive Care
The broadest and most straightforward category. Every physician-billed medical service for the diagnosis, treatment, or prevention of disease qualifies. This includes:
- •Annual physical examinations and preventive screenings.
- •Specialist consultations.
- •Emergency room visits, urgent care, and hospital stays including room and board.
- •Surgical procedures — elective or emergency — performed for medical reasons.
- •Laboratory fees and diagnostic tests including MRI, CT scans, X-rays, and bloodwork.
- •Vaccines and immunizations.
- •Physical therapy and occupational therapy.
- •Chiropractic care.
- •Acupuncture — recognized as an HSA-eligible expense under Publication 502.
Transportation to and from medical appointments qualifies as well. If you drive your own vehicle, the IRS medical mileage rate for 2026 is 20.5 cents per mile for driving from January 1 through June 30 and 23.5 cents per mile from July 1 through December 31. Bus, train, and rideshare fares to medical appointments are fully eligible. Lodging while traveling for medical care qualifies up to $50 per night per person — up to $100 per night if a companion must travel with you (Publication 502's example is a parent traveling with a sick child).
Prescription Medications
All prescription medications dispensed by a licensed pharmacist are HSA-eligible without any additional documentation. This includes maintenance medications for chronic conditions, antibiotics, controlled substances prescribed by a physician, insulin, and any other drug requiring a prescription.
Prescription medications for mental health conditions — antidepressants, anti-anxiety medications, mood stabilizers, ADHD medications, sleep aids — qualify on the same basis as any other prescription drug. There is no distinction between physical and mental health prescriptions for HSA purposes.
Over-the-Counter Medications and Products
Since the CARES Act took effect in 2020 and permanently changed OTC rules, over-the-counter medications are HSA-eligible without a prescription. This remains in effect for 2026.
OTC medications that qualify include pain relievers such as ibuprofen, acetaminophen, and naproxen. Allergy medications. Cold and flu medications. Antacids and digestive aids. Sleep aids. First aid supplies including bandages, antiseptics, and wound care products.
The CARES Act also made menstrual care products — tampons, pads, menstrual cups, and similar items — qualified medical expenses, as Publication 969 notes. Over-the-counter oral contraceptives (including emergency contraceptives) and male condoms also qualify: Publication 502 lists condoms, and IRS Notice 2024-75 went further by letting an HDHP cover both before the deductible as preventive care. Personal protective equipment such as masks, hand sanitizer, and sanitizing wipes also qualifies when bought primarily to prevent the spread of COVID-19.
The practical takeaway for physicians: your next trip to CVS or Walgreens for personal OTC medications can be paid with your HSA card or reimbursed from your HSA. Keep the receipt.
Dental Care
Dental care is one of the most underutilized HSA expense categories. The full scope of dental expenses covered includes:
- •Dental exams, X-rays, and cleanings.
- •Fillings, crowns, bridges, and root canals.
- •Tooth extractions.
- •Orthodontic treatment — including adult orthodontics and Invisalign when used to correct a dental condition.
- •Dentures and implants.
- •Periodontal treatment for gum disease.
- •Oral surgery.
Cosmetic dental procedures present a gray area. Teeth whitening and purely aesthetic procedures do not qualify. Porcelain veneers placed for cosmetic reasons are not covered. However, the same procedure performed to address a structural or functional dental problem — replacing a damaged tooth, correcting bite problems causing pain — can qualify depending on documentation of medical necessity.
Vision Care
Vision care is broadly covered and highly relevant for physicians whose professional performance depends directly on visual acuity.
Comprehensive eye examinations. Prescription eyeglasses and frames. Prescription contact lenses and associated supplies including contact lens solution. LASIK laser vision correction surgery — fully eligible as an HSA expense for physicians considering this procedure. PRK, LASEK, and other refractive surgery procedures qualify on the same basis. Prescription sunglasses qualify; non-prescription sunglasses do not. Cataract surgery and other medically necessary eye procedures are covered.
For surgeons, interventional physicians, and any specialist whose precision depends on vision quality, LASIK represents a meaningful HSA opportunity. If a LASIK procedure costs $4,000 to $6,000, paying it from an HSA saves approximately $1,400 to $2,100 in federal taxes at a 35 percent marginal rate — plus state tax savings on top. Publication 502 lists laser eye surgery to treat defective vision as a medical expense, making it one of the highest-dollar individual HSA expenditures that qualifies cleanly without any additional documentation.
Mental Health Services
Mental health services are fully eligible HSA expenses and an area of particular relevance for physicians given the burnout rates reported across many specialties.
Individual therapy and counseling with a licensed psychologist, psychiatrist, licensed clinical social worker, or licensed professional counselor. Group therapy sessions. Inpatient mental health treatment, including meals and lodging during residential treatment. Substance abuse treatment programs. Psychiatric medication management appointments.
The IRS makes no distinction between physical health and mental health in determining HSA eligibility. A therapy session qualifies on exactly the same basis as a cardiology appointment. For physicians who are paying out of pocket for therapy — which many do deliberately to maintain confidentiality outside their employer's insurance network — the HSA reimbursement makes that cost entirely tax-free.
Physicians using the stealth IRA strategy who are paying for therapy out of pocket should be saving the receipts. At $150 to $250 per session, a year of weekly therapy represents $7,800 to $13,000 in documented, reimbursable expenses that can be withdrawn tax-free from the HSA at any point in the future.
Fertility and Reproductive Treatments
Fertility treatment for you, your spouse, or a dependent is HSA-eligible — Publication 502 lists procedures such as in vitro fertilization, including temporary storage of eggs or sperm. This category is more expensive and more commonly needed than most HSA guides acknowledge.
- •In vitro fertilization including all related procedures — egg retrieval, fertilization, embryo transfer, and associated laboratory fees.
- •Fertility medications and injections.
- •Temporary storage of eggs or sperm as part of IVF. Egg or sperm freezing for other reasons — for example, ahead of chemotherapy or radiation — isn't addressed directly in Publication 502, so confirm with a tax advisor before reimbursing it.
- •Fertility evaluations and diagnostic testing.
- •Surrogacy costs for a gestational surrogate are not covered. Publication 502 excludes amounts paid for the identification, retention, compensation, and medical care of a gestational surrogate, because the surrogate isn't you, your spouse, or your dependent.
Vasectomy and tubal ligation both qualify as HSA-eligible medical procedures.
For physicians who have pursued fertility treatment — IVF costs often run well into five figures — the ability to retroactively reimburse from an HSA for expenses incurred in prior years (with receipts intact) represents a meaningful tax-free withdrawal opportunity. There is no IRS time limit on when you can reimburse an HSA-eligible expense — a 2022 IVF bill can be reimbursed in 2035, provided the HSA existed when the expense was incurred and the receipt is documented.
Hearing Care
Hearing examinations. Hearing aids and batteries. Cochlear implant surgery. Hearing aid maintenance and repair. Custom earplugs for noise-induced hearing protection when prescribed for medical purposes.
Long-Term Care
Premiums for a qualified long-term care insurance contract are HSA-eligible up to an age-based IRS limit. For 2026, per Rev. Proc. 2025-32:
| Age at End of Tax Year | Maximum Annual Premium Deductible |
|---|---|
| 40 or younger | $500 |
| 41–50 | $930 |
| 51–60 | $1,860 |
| 61–70 | $4,960 |
| 71 or older | $6,200 |
- Maximum Annual Premium Deductible
- $500
- Maximum Annual Premium Deductible
- $930
- Maximum Annual Premium Deductible
- $1,860
- Maximum Annual Premium Deductible
- $4,960
- Maximum Annual Premium Deductible
- $6,200
Long-term care services are also eligible when they are qualified long-term care services — care a chronically ill person needs under a plan of care prescribed by a licensed health care practitioner, which can include nursing home or in-home care. For physicians approaching retirement age or planning for aging parents, the ability to pay long-term care insurance premiums from an HSA creates a tax-free way to fund one of the largest potential retirement expenses.
COBRA and Certain Insurance Premiums
Health insurance premiums generally do not qualify as HSA expenses. Publication 969 lists four exceptions:
- •COBRA continuation coverage premiums are HSA-eligible. A physician between jobs, on leave, or transitioning between practices who is paying COBRA premiums can reimburse those costs tax-free from their HSA. Because COBRA usually means paying the full premium, including the share an employer used to cover, this can be a large eligible expense during a transition period.
- •Health coverage while receiving unemployment compensation under federal or state law.
- •Medicare premiums are HSA-eligible once you are 65 or older. Medicare Part A, Part B, Part D, and Medicare Advantage plan premiums can all be paid or reimbursed from an HSA tax-free; premiums for a Medicare supplemental (Medigap) policy cannot. This is one of the most valuable HSA features for retired physicians — it lets the HSA cover a significant portion of healthcare costs in retirement tax-free.
- •Long-term care insurance premiums up to the age-based limits above.
Regular employer-sponsored health insurance premiums, ACA Marketplace plan premiums (in most circumstances), and other standard health insurance premiums do not qualify.
Physician-Specific Expenses Worth Knowing
Several HSA-eligible expenses are particularly relevant to physicians that general personal finance guides rarely cover.
- •Ergonomic equipment with a Letter of Medical Necessity. A standing desk, ergonomic chair, lumbar support device, or other workplace equipment prescribed by a physician to treat a specific musculoskeletal condition qualifies with documentation. For physicians experiencing back pain, repetitive strain injuries, or other occupational health conditions common in clinical practice, this can turn necessary workplace equipment into a tax-free HSA expense.
- •Home modifications for medical purposes. Wheelchair ramps, grab bars, widened doorways, and other home modifications made for medical reasons are HSA-eligible. The amount deductible is limited to the cost that exceeds any increase in home value the modification creates — but modifications that add no market value, like grab bars, qualify in full.
- •Weight loss programs with medical necessity. A medically supervised weight loss program prescribed to treat obesity, hypertension, or another diagnosed condition qualifies. General wellness programs and gym memberships do not qualify without an LMN for a specific condition.
- •Stop smoking programs. Prescription cessation medications and physician-supervised stop smoking programs are fully eligible without any additional documentation.
- •Sleep studies and CPAP equipment. Sleep apnea diagnosis, overnight sleep studies, CPAP machines, masks, and associated supplies all qualify. Replacement CPAP supplies — tubing, filters, cushions — qualify as ongoing HSA expenses.
- •Wearable health monitors. Continuous glucose monitors for diagnosed diabetics are HSA-eligible. Wearable devices purchased specifically to diagnose or monitor a medical condition may qualify with appropriate documentation. General fitness trackers and smartwatches purchased for wellness purposes do not qualify.
What Requires a Letter of Medical Necessity
A Letter of Medical Necessity is a written statement from a licensed physician explaining that a specific item or service is medically necessary to treat a diagnosed condition. Without an LMN, certain expenses that could qualify do not qualify — and with one, expenses that would otherwise be ineligible become eligible.
Common physician expenses that may require an LMN to qualify:
- •Fitness and exercise expenses for a specific diagnosed condition. A physician-prescribed exercise program to treat cardiovascular disease, obesity, or a specific musculoskeletal condition can qualify with an LMN. A general gym membership for fitness does not.
- •Nutritional supplements and specialized diets. Vitamins and supplements are generally not eligible. When specifically prescribed to treat a diagnosed deficiency or condition — iron supplementation for documented iron-deficiency anemia, for example — they may qualify with an LMN.
- •Air purifiers and home air quality equipment. Prescribed for a patient with asthma, severe allergies, or other documented respiratory conditions, a HEPA air purifier can qualify as an HSA expense with appropriate documentation.
- •Ergonomic workplace equipment as described above — prescribed for a specific occupational injury or musculoskeletal diagnosis.
The LMN should be written on the prescribing physician's letterhead, include the diagnosis being treated, the specific item or service recommended, and the medical rationale. Keep the LMN with the receipt for the expense permanently — it is your documentation if a withdrawal is ever questioned.
What Is Not Eligible: Common Misconceptions
Several expenses physicians commonly assume are covered are not HSA-eligible without the right documentation — or at all.
- •Cosmetic procedures without a medical purpose do not qualify. Botox for wrinkles, rhinoplasty for aesthetic purposes, and teeth whitening are not eligible. The same procedures performed to treat a documented medical condition — Botox for chronic migraine treatment, rhinoplasty to correct a deviated septum causing breathing obstruction — do qualify.
- •General vitamins and supplements purchased for overall health are not eligible. As noted above, medically prescribed supplements for a documented deficiency may qualify with an LMN.
- •Standard gym memberships and fitness equipment are not eligible without an LMN for a specific condition. The IRS is explicit that expenses beneficial to general health but not treating a specific condition do not qualify.
- •Toothpaste, soap, and general personal hygiene products are not eligible. Medicated shampoos prescribed for scalp conditions and similar medically prescribed personal care products may qualify.
- •Health insurance premiums in most circumstances as described above.
- •Funeral and burial expenses are explicitly excluded.
- •Maternity clothes and nursing supplies — breast pumps and lactation supplies are eligible; maternity clothing is not.
How to Document HSA Expenses Correctly
The IRS requires documentation to substantiate tax-free HSA withdrawals. You report distributions on Form 8889 with your tax return, but Publication 969 says not to send receipts with the return — keep them with your tax records. If the IRS questions a distribution, you must be able to show it paid for qualified medical expenses that weren't reimbursed from another source or taken as an itemized deduction.
What counts as acceptable documentation:
An Explanation of Benefits from your insurance carrier. An itemized receipt from a pharmacy, medical office, or laboratory showing the date, provider, amount, and description of service. A credit card or bank statement showing the payment, paired with a description of the service.
How to store them:
A dedicated folder in cloud storage — Google Drive, Dropbox, iCloud — organized by year is the most reliable long-term system. Photograph paper receipts immediately when you receive them. The IRS does not specify a format, only that records be accessible and legible.
How long to keep them:
Indefinitely. Since there is no time limit on when you can reimburse an HSA-eligible expense from a prior year, a receipt from 2024 might be used to support a withdrawal in 2040. Permanent storage in cloud backup is the appropriate approach.
The Retroactive Reimbursement Strategy: Why Documentation Matters So Much
The most powerful HSA strategy for high-income physicians is to pay every medical expense out of pocket during their working years, save every receipt, and allow the HSA to compound tax-free for decades. When they eventually reimburse themselves — at retirement, or earlier if needed — they withdraw the original documented expense amount tax-free, while the growth those dollars earned in the meantime stays in the account (and can cover future medical costs tax-free as well).
A physician who paid $5,000 in dental work out of pocket in 2026 and saved the receipt can reimburse themselves from the HSA at any point in the future. If the HSA grew at 7 percent annually, the $5,000 that would have covered that dental bill in 2026 has grown to approximately $9,836 in 2036. The physician can withdraw $5,000 tax-free for the documented expense, and the other $4,836 of growth stays invested.
The documentation is the key that unlocks this strategy. Without the receipt, the $5,000 withdrawal could be challenged as a non-qualified distribution subject to income tax and a 20 percent additional tax. With the receipt, it is entirely tax-free regardless of when it is taken.
Maintain a running spreadsheet of unreimbursed HSA-eligible expenses by year. Each row: date, provider, amount, category, receipt file location. This document is your retirement reimbursement log and should be treated as a financial asset.
Use our HSA Contribution Calculator to estimate the tax-free balance you can accumulate over your career based on your contribution amount, investment return, and years until retirement.
Frequently Asked Questions
Can I use my HSA for my spouse's medical expenses even if they are not on my health insurance plan?
Can I use my HSA to pay for my children's medical expenses if they are on a different health plan?
What happens if I accidentally use my HSA for a non-qualified expense?
Can I reimburse expenses from years ago that I paid out of pocket?
Does my HSA cover medical expenses when I travel internationally?
Can I use my HSA at age 65 for non-medical expenses without penalty?
Can I use my HSA to pay for a Direct Primary Care membership in 2026?
Sources
- Publication 502, Medical and Dental Expenses, Internal Revenue Service. Accessed September 27, 2026.
- Publication 969, Health Savings Accounts and Other Tax-Favored Health Plans, Internal Revenue Service. Accessed September 27, 2026.
- Revenue Procedure 2025-32 (2026 inflation adjustments, including long-term care premium limits), Internal Revenue Service. Accessed September 27, 2026.
- Standard mileage rates, Internal Revenue Service. Accessed September 27, 2026.
- Treasury, IRS provide guidance on new tax benefits for Health Savings Account participants under the One, Big, Beautiful Bill (IR-2025-119), Internal Revenue Service, December 9, 2025. Accessed September 27, 2026.
- Notice 2026-05 (HSA provisions of the One Big Beautiful Bill Act), Internal Revenue Service. Accessed September 27, 2026.
For a complete breakdown of how to build long-term wealth with your HSA rather than just spending it down each year, see our HSA Strategy for Physicians guide.
Use our HSA Contribution Calculator to model your projected tax-free balance at retirement based on your contribution amount, investment return, and years until retirement.
Related reading: Backdoor Roth IRA for Physicians · Physician Tax Strategies Guide
Disclaimer: This article is for educational purposes only and does not constitute tax, financial, or legal advice. HSA-eligible expense rules are governed by IRS Publication 502 and are subject to legislative changes. When in doubt about whether a specific expense qualifies, consult a qualified CPA or tax advisor before making a withdrawal. MedMoneyGuide has no affiliate or advertising relationships with the companies it covers.

About the Author
Joshua Dunigan, DO | Family Medicine Resident & Founder
I'm a family medicine resident physician in Des Moines, Iowa (class of 2027). I founded MedMoneyGuide to give physicians specialty-specific financial guidance, with sources you can check.