Are face masks and medical gloves Health FSA-eligible?

4/23/20 – During the current COVID-19 pandemic, we have received many questions about the eligibility of face masks and gloves. Like many FSA questions, IRS rules have not specifically altered the eligibility of these items under the pandemic. You will notice that the same language is used for each, as follows:

Masks, disposable – Won’t qualify if used for general health purposes or other personal reasons. May qualify if used to treat or alleviate a specific medical condition, and if the expense would not have been incurred “but for” the condition. Might also qualify where used to prevent a specific illness that is imminent (e.g., if a household member has a contagious disease). A note from a medical practitioner recommending the item to treat a specific medical condition (or, if applicable, to prevent a specific and imminent illness) is normally required.

Latex gloves – Won’t qualify if used for general health purposes or other personal expense reasons. May qualify if used to treat or alleviate a specific medical condition, and if the expense would not have been incurred “but for” the condition. Might also qualify where used to prevent a specific illness that is imminent (e.g., if a household member has a contagious disease). A note from a medical practitioner recommending the item to treat a specific medical condition (or, if applicable, to prevent a specific and imminent illness) is normally required.

Based on these IRS rules, we recommend following the CDC guidelines recommending the use of masks for the prevention of spreading illness during the pandemic. As such, masks will be eligible without a Letter of Medical Necessity (LMN) during the pandemic. A receipt or documentation is, of course, required for any expense that does not automatically approve; and “stockpiling” is still not allowed.

Latex gloves are not part of the CDC’s recommendations – currently, handwashing is the protocol. Gloves would still need a Letter of Medical Necessity in order to be eligible.

As noted in the IRS rules, a Letter of Medical Necessity is “normally required” – so whenever the state of emergency ends, we will revert to “normal” and request a LMN for both masks and gloves.