You can use HSA funds for many things beyond doctor visits, but not everything—and using it for non-medical expenses triggers taxes and penalties unless you're over 65.
A Health Savings Account is designed to pay for may have access to medical expenses, but the list is longer than most people think. You can withdraw money for dental work, vision care, mental health treatment, prescription medications, medical equipment, and dozens of other health-related costs. The catch: if you spend HSA money on something that doesn't meet the IRS definition of a may have access to medical expense, you'll owe income tax on that withdrawal plus a 20% penalty—unless you're 65 or older, in which case the penalty disappears but the income tax remains.
The IRS publishes a detailed list of what counts, and it's worth understanding the boundaries because the rules are stricter than many people assume. Some things that feel medical—like gym memberships or vitamins—don't may have access to. Other things that don't sound medical at all—like certain medical alert systems or home modifications for disability—do.
Key Takeaways
- may have access to medical expenses include dental, vision, mental health care, prescriptions, medical equipment, and copays—you can use HSA funds for these without tax or penalty.
- Non-may have access to expenses like gym memberships, cosmetic procedures, and over-the-counter vitamins trigger both income tax and a 20% penalty if you're under 65.
- After age 65, you can withdraw HSA money for any reason without the 20% penalty, though non-medical withdrawals are still taxed as income.
- The IRS maintains a searchable database of may have access to expenses on Publication 502, and you should verify unusual items before spending because the rules are specific.
- You must keep receipts and documentation for all HSA withdrawals in case the IRS audits your account.
What counts as a may have access to medical expense
The IRS defines may have access to medical expenses as costs for diagnosis, cure, mitigation, treatment, or prevention of disease, plus expenses for treatments affecting any part of the body's structure or function. This covers the obvious: doctor visits, hospital stays, surgery, prescription drugs, and mental health counseling. It also covers dental cleanings, root canals, orthodontia, and dentures. Vision care—eye exams, glasses, contact lenses, and laser eye surgery—all may have access to.
Less obvious may have access to expenses include medical equipment and supplies: crutches, wheelchairs, hearing aids, glucose monitors, blood pressure cuffs, and oxygen equipment. If your doctor prescribes it for a medical condition, it usually qualifies. Certain home modifications also count—grab bars, ramps, and stair lifts installed to accommodate a disability or medical condition. Nursing home care, in-home nursing services, and certain long-term care insurance premiums are may have access to expenses. Even some transportation costs may have access to if the primary purpose is getting to medical treatment.
Over-the-counter medications are may have access to only if you have a prescription from a doctor. Aspirin, cold medicine, antacids, and allergy medication bought without a prescription do not may have access to, even if you use them for a diagnosed condition. This rule changed in 2020 and catches many people off guard.
What does not may have access to, even though it might seem medical
Gym memberships and fitness classes do not may have access to, even if your doctor recommends exercise for your health. General wellness expenses—vitamins, supplements, and herbal remedies—do not may have access to unless prescribed by a doctor for a specific medical condition. Cosmetic procedures like teeth whitening, Botox, or hair removal do not may have access to unless they're medically necessary (for example, reconstructive surgery after an accident or burn).
Weight loss programs and diet foods do not may have access to unless prescribed as treatment for a diagnosed disease like obesity or diabetes. Sunscreen and other preventive skincare products do not may have access to. Maternity clothes, even though pregnancy is a medical condition, do not may have access to. Childcare, even if you need it to attend medical appointments, does not may have access to. Travel to a medical facility—airfare, hotels, meals—generally does not may have access to, though some transportation directly to treatment may.
Pet insurance and veterinary care do not may have access to. Cosmetic dentistry like veneers or whitening does not may have access to unless it's part of necessary dental treatment. If you're unsure about a specific expense, the IRS Publication 502 has a searchable list, and you can also contact your HSA administrator to ask before you spend.
How the tax penalty works if you spend on non-may have access to things
If you withdraw HSA money for something that doesn't may have access to as a medical expense, you owe two things: income tax on the withdrawal amount, calculated at your normal tax rate, plus a 20% penalty on top of that. So if you withdraw $1,000 for a non-may have access to expense and you're in the 22% tax bracket, you'd owe $220 in income tax plus $200 in penalty—$420 total on a $1,000 withdrawal. The penalty is separate from the tax, not a replacement for it.
You report non-may have access to withdrawals on Form 8889 when you file your tax return. The IRS doesn't automatically know you spent the money on something non-may have access to—they know only if you report it or if they audit your account. But if you're audited and can't produce receipts showing the money went to may have access to expenses, the IRS will assess the tax and penalty retroactively, plus interest.
The 20% penalty applies only to the amount you withdraw for non-may have access to expenses. If you withdraw $5,000 and $4,000 is for may have access to medical bills and $1,000 is for a gym membership, only the $1,000 faces the penalty. You still owe income tax on all $5,000, but the penalty applies only to the non-may have access to portion.
What changes after you turn 65
Once you reach 65, the 20% penalty disappears. You can withdraw HSA money for any reason—medical or not—without facing the penalty. However, you still owe income tax on non-medical withdrawals. So at 65, withdrawing $1,000 for a gym membership costs you only the income tax (roughly $220 at the 22% bracket), not the additional $200 penalty.
This makes an HSA function somewhat like a traditional IRA after 65: you can use it for anything, but you pay income tax on withdrawals. Many people use this feature to let their HSA grow untouched during working years, then use it more flexibly in retirement. You still need to keep receipts for may have access to medical expenses even after 65, because if the IRS audits you, you need to show which withdrawals were medical (and thus not subject to income tax) and which were not.
Keeping records and avoiding audit trouble
The IRS requires you to keep receipts and documentation for every HSA withdrawal. This means the receipt from the pharmacy, the explanation of benefits from your insurance, the invoice from your dentist—whatever shows you spent the money on a may have access to expense. You don't send these to the IRS when you file your tax return, but you must have them if you're audited.
Many people make the mistake of thinking that because their HSA administrator doesn't ask for receipts, they don't need them. That's wrong. Your HSA administrator's job is to process withdrawals, not to verify they're may have access to. The IRS's job is to verify that, and they do it through audits. If you can't produce a receipt showing you spent $3,000 on dental work, the IRS will treat that $3,000 as a non-may have access to withdrawal and assess tax and penalty.
Keep receipts for at least three years after you file the tax return for that year. The IRS can audit back further in some cases, so keeping them longer is safer. Digital copies are fine—photograph your receipts or save PDFs from your provider's online portal. Organize them by year and by expense type so you can find them quickly if needed.
Using HSA funds for family members' medical expenses
You can use your HSA to pay for may have access to medical expenses of your spouse and dependents, even if they're not covered under your health plan. You don't need to be the one receiving the treatment—if your spouse has a dental procedure or your child needs glasses, you can pay for those expenses with your HSA funds. The key is that the expense must be may have access to and must belong to someone you can claim as a dependent on your tax return (or your spouse, regardless of dependent status).
You cannot use your HSA to pay for medical expenses of adult children who are no longer your dependents, or for parents or other relatives, unless you claim them as dependents on your tax return. The rules are strict: the person receiving the care must be you, your spouse, or your dependent.
Frequently Asked Questions
Can I use my HSA to pay for my spouse's medical bills if they have their own health insurance?
Yes. You can use your HSA for may have access to medical expenses of your spouse regardless of what insurance they have or whether they're covered under your plan. You just need to be married and file taxes together. Keep the receipts showing the expense was for your spouse.
Does my HSA have to be used by the end of the year, or can I let it grow?
HSA funds roll over year to year with no limit on how much you can accumulate. Unlike a Flexible Spending Account (FSA), there's no "use it or lose it" rule. You can let your HSA grow for decades and withdraw funds whenever you need them, even years later. Keep receipts for the year the expense occurred, not the year you withdraw the money.
If I use my HSA for a non-may have access to expense by mistake, can I fix it?
You can correct it if you catch it before filing your tax return for that year. Withdraw the money back into your HSA and report it correctly on Form 8889. If you've already filed and reported it as non-may have access to, you can file an amended return. After that, the tax and penalty stand unless you go through an audit process.
What happens to my HSA if I change jobs or lose my health insurance?
Your HSA stays yours. It's not tied to your employer or your health plan. You can keep the account open, keep contributing if you're still may be able to access, and withdraw funds for may have access to medical expenses whenever you need them. The account follows you between jobs and health plans.
Can I use my HSA to pay for therapy or counseling?
Yes, if it's treatment for a diagnosed mental health condition. Therapy, counseling, and psychiatric care all may have access to as medical expenses. Copays and deductibles for mental health treatment also may have access to. The treatment must be provided by a licensed mental health professional.