FSA vs. HSA for Recovery Products: Eligibility, Deadlines, and Receipts

The short answer

A health FSA and an HSA both let you pay qualified medical expenses with money that has not been subject to federal income tax. When you are buying recovery equipment, three differences matter.

Who owns it. A health FSA is an employer-established plan, and Publication 969 notes that self-employed people aren’t eligible for one. An HSA is yours: “An HSA is ‘portable.’ It stays with you if you change employers or leave the work force.”

Whether a clock is running. Health FSAs are, in Publication 969’s words, “generally ‘use-it-or-lose-it’ plans.” An HSA has no year-end cliff; amounts left at the end of the year generally carry over.

What you have to prove, and to whom. A health FSA reimburses a claim under an employer plan’s terms, and the plan or its administrator applies those terms, its dates and its substantiation rules. An HSA holder takes a distribution; federal tax law then decides whether it is tax-free, and the holder keeps the records that show it.

One federal definition of medical care sits under both accounts; what sits on top of it differs by account, and that difference is what this page separates. It does not tell you whether a specific item is eligible — when your question narrows to one exact product, see Where this article stops.

The two questions people merge

These sound like one question. They have different answers from different authorities.

Question A — is this the kind of expense the tax code treats as medical care? A federal test, written in the Internal Revenue Code and explained in the IRS publications, sitting underneath all of these accounts. The IRS states the connection directly: expenses for medical care under section 213 “also are eligible to be paid or reimbursed under an HSA, FSA, Archer MSA, or HRA” (IRS FAQ).

Question B — what happens when the money actually moves? Federal rules still govern here. They just do not answer Question B alone, and they do not answer it the same way for both accounts.

• Health FSA — administration under an employer plan. Publication 969 writes plan terms into the definition itself: “Qualified medical expenses are those specified in the plan that would generally qualify for the medical and dental expenses deduction.” Reimbursement is a claim: the plan can specify which qualified expenses it reimburses, and the plan or its administrator applies the plan’s terms, dates and substantiation requirements. A plan may reimburse less than federal rules permit and may set shorter deadlines than the federal maximums allow.
• HSA — tax treatment and your own records. No employer plan adjudicates your spending. Publication 969 defines HSA qualified medical expenses federally, as amounts paid for “medical care” as defined in Code section 213(d), to the extent not compensated for by insurance or otherwise. You can take a distribution whenever you like; whether it is tax-free is a federal tax question, and the publication puts the proof on the holder — you must keep records sufficient to show the distributions went exclusively to qualified medical expenses, that those expenses were not previously paid or reimbursed from another source, and that they were not taken as an itemized deduction.

So Question B is plan administration for an FSA and tax qualification plus recordkeeping for an HSA. This article describes the shape of both and answers neither for you: the FSA answer is in plan documents PainRecoveryPro has not seen, and the HSA answer turns on your own facts and records.

The one-screen comparison

Every row is sourced in Sources and dates. Where a row says a publication states no rule, that is a statement about the publication; your plan document may well have one.

What a health FSA actually is

A benefit your employer establishes, which Publication 969 notes may be offered as part of a cafeteria plan. You decide before the plan year starts how much pay to divert into it, and that money is not subject to federal income tax or employment taxes. You designate the amount at the beginning of the plan year and can change or revoke the election only if law and the plan specifically allow it.

Two consequences matter to a shopper.

The whole year’s money is available on day one. A federal requirement, not a plan courtesy: you must be able to receive your full elected amount “at any time during the coverage period, regardless of the amount you have actually contributed.” The administrator guide read for this article works the same rule as an example — an employee electing $1,200 a year through $100 monthly deductions is “eligible for reimbursement up to the full $1,200 in the first month, even though you have only deposited $100.”

The cap is per employer, so a household can hold two. HealthCare.gov describes the salary-reduction limit as applying “per year per employer,” and says a married reader’s spouse can elect separately through their own employer — two plans, two plan years, two sets of deadlines.

Deliberately not covered: the specific amount you may elect. It changes annually, it is not what decides whether a purchase works, and your enrollment materials carry the figure your plan uses.

What an HSA actually is

An account in your name that you can contribute to only while you have HSA-eligible coverage. Publication 969’s summary: contributions remain in the account until you use them, earnings are tax free, distributions may be tax free if used for qualified medical expenses, and the account is portable.

There is no spending deadline. “You don’t have to make withdrawals from your HSA each year.” Buying in December is no different from buying in March.

There is a start date. “For HSA purposes, expenses incurred before you establish your HSA aren’t qualified medical expenses. State law determines when an HSA is established.” If you are opening an account because a procedure is coming, the sequence matters.

Losing the ability to contribute is not losing the account. Contributing requires HSA-eligible coverage; taking a distribution does not. A job change does not itself close the account or stop distributions. Whether you can keep contributing is a separate question that turns on whether you remain HSA-eligible.

Deliberately not covered: annual contribution limits, HDHP thresholds, catch-up contributions and investment choices. None changes whether a purchase is a qualified medical expense, and all are restated every year.

Can you have both?

Yes and no — the distinction is between holding and contributing.

Publication 969 states the general rule: “An employee covered by an HDHP and a health FSA or an HRA that pays or reimburses qualified medical expenses can’t generally make contributions to an HSA.” A general-purpose health FSA is disqualifying coverage for HSA contribution purposes.

It also names the designs that avoid the conflict, listing a limited-purpose and a post-deductible health FSA or HRA among arrangements an employee can hold while still contributing. These exist in practice: the federal FSAFEDS program offers a Limited Expense Health Care FSA alongside its general one (OPM).

One interaction catches people at a plan-year turn: coverage during a grace period by a general-purpose health FSA is allowed “if the balance in the health FSA at the end of its prior-year plan is zero.” Last year’s grace period can follow you into the new year and affect your HSA contribution position.

Which arrangement you are actually enrolled in, and what it means for your contributions, is a question for your plan documents and your benefits contact. Nothing here is a decision rule for an individual, and this article does not advise anyone which account to choose at open enrollment.

Deadlines: the FSA section

Four different dates can exist, and they do different things. Mixing them up is what turns “spend it or lose it” into a rushed purchase against the wrong deadline.

1. Your period of coverage

Publication 969: distributions from a health FSA “must be paid only to reimburse you for qualified medical expenses you incurred during the period of coverage.”

The plan year is the outer frame for that period — but it is not automatically your period. Join mid-year, leave mid-year, or continue coverage after employment ends, and your own coverage dates can be narrower than the plan year. Publication 969 does not fix those dates; entry, termination and continuation are plan-specific, so your plan documents and benefits contact settle them.

Two practical consequences:

• A plan year is not necessarily a calendar year. The State of Illinois plan used here as an administrator example runs July 1 through June 30. If your plan year does not end December 31, December is not your deadline, whatever the seasonal advice says.
• “The plan year ends June 30” and “my coverage ended when I left in March” are different facts. Find out which governs you before you buy.

2. A grace period, if your plan offers one

A plan “can provide for a grace period of up to 2 1/2 months after the end of the plan year,” during which qualified expenses can be paid from amounts left at the end of the previous year. HealthCare.gov describes the same option as one of two an employer “may offer.”

A grace period extends the window for incurring an expense. It buys more time to buy.

3. A carryover, if your plan offers one instead

A carryover moves money into the next plan year. It does not extend the window for incurring an expense against the old one.

Publication 969 lets plans carry unused amounts up to a maximum into the following plan year, adds that “The plan may specify a lower dollar amount,” and notes that amounts above the maximum are forfeited and that a carryover does not change how much you may contribute by salary reduction.

The $660 in that text is the 2025 figure — the edition available on August 31, 2026 is captioned “For use in preparing 2025 Returns.” For plan years beginning in 2026 the federal maximum is $680, set by Rev. Proc. 2025-32, §3.15, in Internal Revenue Bulletin 2025-45. Both are federal maximums, not amounts your plan gives you, and HealthCare.gov adds the blunter point: “Your employer doesn’t have to offer these options.”

A health FSA generally cannot have both a grace period and a carryover. Publication 969: “A plan adopting a carryover provision is not permitted to also provide a grace period with respect to health FSAs. (See Notice 2013-71.)” HealthCare.gov: “it can be either one of these options, but not both.” That is the general rule as of August 31, 2026. If your own plan materials describe something else, ask your administrator to explain what your plan does under the official rules in force when you read this — an administrator can tell you how your plan is written and operated, not set aside federal law.

4. The run-out period for filing a claim

A separate date from all three above. You incur an expense by one deadline, then have some further period to submit the claim for an expense already incurred. The IRS publications used here do not set that date — the plan does.

The administrator material shows the shape. On the State of Illinois plan, whose plan year ends June 30, unused amounts roll over “after the September 30 run-out period ends,” and the FY26 guide tells participants: “You may turn in FY25 receipts during the run-out period of July 1 through September 30, 2025.” Those are one plan’s dates for one fiscal year, quoted as an illustration and not as a rule that travels. What generalizes: incurring and filing are two different deadlines, and missing the second loses money that was properly spent.

What happens when you leave the job

Publication 969 states no single rule for a health FSA balance at termination, and this article will not invent one. What ends the arrangement, what your last date to incur is, and whether continuation coverage is offered are questions your summary plan description and benefits contact answer. Ask before your last day, not after.

Deadlines: the HSA section

Short on purpose. None of the pressure above is an HSA characteristic. No plan year to beat, no grace period to track, no carryover cap to compare, no run-out period on your own account.

Two dates exist, and neither creates December urgency:

• The contribution deadline for a tax year runs past the end of that year. The edition of Publication 969 available on August 31, 2026 states: “You can make contributions to your HSA for 2025 through April 15, 2026.” Check the edition current when you read for the corresponding date.
• The establishment date is a floor, as above: expenses incurred before you established the HSA are not qualified medical expenses for it.

If you hold both accounts, the deadline thinking above applies to the FSA side only.

The qualified-expense framework

One definition sits under both accounts, and it is a test, not a list.

Publication 502 states it: “Medical expenses are the costs of diagnosis, cure, mitigation, treatment, or prevention of disease and for the purpose of affecting any part or function of the body.” It adds that they “include the costs of equipment, supplies, and diagnostic devices needed for these purposes,” and draws the outer line: “They don’t include expenses that are merely beneficial to general health, such as vitamins or a vacation.”

Three things follow for a recovery-equipment shopper.

Equipment and supplies are contemplated by the definition — that is the equipment-and-supplies clause above. HealthCare.gov puts it in shopping language for FSAs: funds may cover “medical equipment like crutches, supplies like bandages, and diagnostic devices like blood sugar test kits.”

Over-the-counter medicines no longer require a prescription under the federal rule. Publication 969 states it in the health FSA section: “Expenses incurred for over-the-counter medicine (whether or not prescribed) and menstrual care products are considered medical care and are considered a covered expense.” The change came from the CARES Act and applies to amounts paid after December 31, 2019 (IR-2020-122).

Read that narrowly. It is a rule about over-the-counter medicines and drugs — not a statement that anything sold over the counter is a qualified medical expense, and not a promise that a given plan will process a claim for one. Recovery equipment is not made eligible by being sold without a prescription: it still has to meet the definition above, and for a health FSA it still has to be an expense the plan specifies and the administrator can substantiate. Some plan and consumer materials still carry the pre-2020 prescription requirement for OTC drug items — two sources read for this article did on August 31, 2026, both named in Sources and dates. Where a plan handout and current IRS guidance disagree, ask your administrator rather than assuming either document settles it.

Passing the federal test settles neither account by itself. The definition tells you what kind of expense qualifies in general; it does not settle a particular purchase. Meeting the federal baseline does not guarantee that a health FSA will reimburse the expense — the plan can specify which qualified expenses it reimburses, and its terms, dates and substantiation still apply. Nor does the baseline alone establish that a particular HSA distribution is tax-free: that turns on the facts of the expense and on records sufficient to show them. Publication 502 says as much about itself: it “covers many common medical expenses but not every possible medical expense.”

One category belongs here and then stops. Some products are dual-purpose — usable for a medical purpose or for general wellbeing, which puts them against the “merely beneficial to general health” line. A plan may require a prescription, a doctor’s directive or a letter of medical necessity before reimbursing one; the administrator guide read for this article defines the category exactly that way for its own plan. Which items your plan treats that way, and how to obtain and submit the documentation, is product-level work this article hands off.

Which document answers which question

Publication 502 is not the reimbursement rule. Its own first line: “This publication explains the itemized deduction for medical and dental expenses that you claim on Schedule A (Form 1040).” It is the right place for the definition of medical care and for worked examples, and the wrong citation for “therefore my FSA will pay for this.” Account mechanics come from Publication 969, the §213 FAQ material, and your plan. HealthCare.gov’s HSA glossary routes readers the same way — Publication 969 for the accounts, Publication 502 for the expense list.

The publications close the loop in the other direction too: you cannot take the benefit twice. Expenses paid with a tax-free HSA distribution, or reimbursed from an FSA, cannot also be deducted.

Receipts, records, and substantiation

Substantiation is the step that can defeat a purchase that qualified in every other respect. You do not control how a plan rules on a claim, or how thin your own file will look later — you control what you collect at the moment of purchase, and that is the easiest moment to collect it.

What federal material requires

For a health FSA, Publication 969 sets a floor: “You must provide the health FSA with a written statement from an independent third party stating that the medical expense has been incurred and the amount of the expense,” plus a statement that the expense “hasn’t been paid or reimbursed under any other health plan coverage.” Note what independent third party rules out: your own note, your own spreadsheet, your own recollection. Payment cards are legitimate, but Publication 969 says only that if their use meets certain substantiation methods “you may not have to provide additional information.” The word doing the work is may: a swipe does not close a claim.

For an HSA, the obligation is yours rather than an administrator’s to request: keep records sufficient to show that distributions went exclusively to qualified medical expenses, that those expenses were not previously paid or reimbursed from another source, and that they were not taken as an itemized deduction. Publication 969: “Don’t send these records with your tax return. Keep them with your tax records.”

The IRS gave the same practical advice when the OTC rule changed: taxpayers “should save receipts of their purchases for their records and so that they are able to submit claims for reimbursements” (IR-2020-122). Submitting a claim is the FSA route; saving the receipt is what both accounts run on.

What one administrator actually asks for

Federal material sets the floor; administrators set the form. What follows is what one named administrator requires on one employer’s plan — Optum Financial, on the State of Illinois FY26 plan — quoted because it shows the level of detail these requests reach, not because it is a universal standard. Your administrator’s requirements may differ and should be read directly.

“Receipts must contain the date of service, name and address of service provider, description of the service provided, amount charged, and name of person receiving the service. Nonitemized cash register tapes, credit card receipts and cancelled checks alone do not provide proper substantiation.”

The same plan’s manual claim form names the unacceptable substitutes outright: “Cancelled checks, credit card documentation or balance forward statements are not acceptable.” That is the distinction worth internalizing before you buy — proof that you paid is not the proof a plan wants. It wants proof of what was purchased, for whom, on what date, at what price, from whom.

A card transaction is not final either. On that plan, if a receipt or explanation of benefits is needed, “you will also be notified by email or letter within a week of your payment card swipe,” and an unsubstantiated transaction “will be deemed ineligible and you will be required to repay your account,” with the card suspended if documentation is not submitted within 60 days.

That notice window, that suspension and that repayment mechanic are this administrator’s, on this plan. What generalizes is that money spent from a health FSA card can be recovered by the plan under its own terms if the purchase is not substantiated — the reason to gather paperwork at the moment of purchase rather than at the moment of the request.

A checklist to work before you buy

Six decisions, in order. None of them adjudicates a particular product — that is the work this page hands off in Where this article stops.

1. Name the account you are spending from. Health FSA, HSA, or both. Every step below branches on that answer, and if you hold both, decide now which one pays — the no-double-benefit rule turns on it, and the two accounts keep records differently.
2. Fix your dates. FSA: your own period of coverage and the last day to incur an expense against it; whether your plan offers a grace period or a carryover, and which; and your run-out deadline for filing a claim. HSA: confirm the account was established before the expense is incurred, because expenses incurred earlier are not qualified medical expenses for it. Write the FSA dates down where you will find them.
3. Apply the shared purpose test — without deciding the product. Ask whether the expense is for the diagnosis, cure, mitigation, treatment or prevention of disease, or for the purpose of affecting a structure or function of the body, rather than something merely beneficial to general health. That framework is the same under both accounts. It is a test applied to your facts, not a verdict on a model number.
4. Read what sits on top of the test. FSA: your plan’s terms and your administrator’s documentation requirements, including whether the item is treated as dual-purpose. HSA: no employer plan adjudicates the distribution, so plan instead to keep records sufficient to show it went to a qualified medical expense.
5. Get any required supporting document before the purchase. Where a plan requires a prescription, a doctor’s directive or a letter of medical necessity, obtaining it first is easier than retrofitting it afterward.
6. Set the record up at checkout. An itemized receipt or invoice showing the date, the seller or provider, a description of what was purchased, the amount charged, and the person the item is for — a card slip or an order confirmation showing only a total is not this. Keep proof the expense was not reimbursed elsewhere, do not take the same expense twice across an FSA, an HSA and the itemized deduction, and check the return terms before you commit: returnability depends on the seller’s policy and on any restrictions on the product, and unopened status may matter to a seller but guarantees nothing.

Find your own plan's answer

The framework above is general. On the health FSA side, these artifacts hold your answers, and none can be guessed:

• The summary plan description (SPD) — your plan’s own terms, including whether it offers a grace period, a carryover, or neither.
• Your plan-year dates and your own coverage dates. Not necessarily January to December, and not necessarily the whole plan year.
• Your run-out deadline for filing claims, a separate date from the last day to incur.
• The administrator’s portal and its eligible-expense list, plus its documentation rules for dual-purpose items.
• Your employer’s benefits contact — the person who can tell you what your plan does when you leave.

On the HSA side there is no such document to consult: what stands in for it is your account’s establishment date, the federal definition of medical care, and the records you keep. Your trustee can tell you when the account was established and what it holds; it does not decide whether a distribution is tax-free.

The administrator material says the same about its own limits, carrying two disclaimers on its final page: “Please contact your plan administrator with questions about enrollment or plan restrictions,” and “This communication is not intended as tax or legal advice.”

Where this article stops

This page covers account mechanics. The next question — is this exact product eligible, and what would I need to show for it? — is different work: reading merchant labels for what they are, finding the plan’s own list, and assembling documentation for one specific item.

What this page does not decide

• It does not confirm eligibility or guarantee reimbursement for any item under any plan, and does not tell any HSA holder that a distribution will be tax-free.
• It is not medical advice — no diagnosis, treatment, protocol, duration, or statement about whether a product suits you. Your clinician’s, surgeon’s and care team’s instructions, and the manual for anything worn on or applied to the body, take precedence over anything here.
• It is not tax advice, and gives no filing instructions and no guidance on whether to itemize.
• It does not recommend a product, brand, merchant or purchase channel, and does not suggest that recovery products in general are eligible. The definition is a test applied to a particular expense, not a category pass.
• It does not describe every account type. Dependent-care FSAs, HRAs and Archer MSAs are outside its scope beyond the passing references above, and it does not address non-U.S. readers, state income-tax treatment, or self-employed plan structuring.
• PainRecoveryPro has not reviewed anyone’s plan documents, and has not tested, used or purchased any product.

Frequently asked questions

Every answer rests on the sources in Sources and dates, and the caveat at the top of this page applies to all of them.

What is the actual difference between an FSA and an HSA?

Ownership and time. A health FSA is an employer-established arrangement funded by a salary-reduction election and is generally use-it-or-lose-it. An HSA is your own account, requires HSA-eligible coverage to contribute to, is portable, and carries unused amounts forward. The underlying definition of medical care is the same for both; what differs is who applies it to your money.

Does FSA money roll over?

Only if your plan says so, and only up to a cap — and the plan “may specify a lower dollar amount.” The $660 in the Publication 969 edition available on August 31, 2026 is the 2025 figure; the federal maximum for plan years beginning in 2026 is $680 (Rev. Proc. 2025-32, §3.15). HealthCare.gov adds the condition attached to both options: “Your employer doesn’t have to offer these options.”

Can I have a grace period and a carryover?

Not for a health FSA, as the rules stood on August 31, 2026: a plan adopting a carryover “is not permitted to also provide a grace period with respect to health FSAs,” and HealthCare.gov says it can be “either one of these options, but not both.” If your plan materials say otherwise, ask your administrator to explain your plan under the official rules in force when you read this — an administrator can tell you what your plan does, not override federal law.

What is a run-out period, and is it the same as a grace period?

No, and confusing them is expensive. A grace period extends the time to incur an expense — up to 2½ months after plan-year end, if your plan offers one. A run-out period is time to file a claim for an expense already incurred. The federal publications used here do not set a run-out date; your plan does.

Do I lose my FSA money if I leave my job?

Publication 969 states no single rule, and this article will not supply one. Ask your benefits contact for your last date to incur, your last date to file, and whether continuation coverage is offered — before your last day.

What happens to my HSA if I change employers?

It goes with you; the account is portable. A job change does not by itself close the account or stop distributions — the account stays open and you can still take money out of it. Whether you can keep contributing depends on whether you still have HSA-eligible coverage. And whether a distribution is tax-free still depends on its going to a qualified medical expense and on your keeping records sufficient to show that, not on where you work.

Can I have an FSA and an HSA at the same time?

You can hold both, but a general-purpose health FSA generally blocks HSA contributions — an employee covered by an HDHP and a health FSA “can’t generally make contributions to an HSA.” Publication 969 then names the designs employers use to avoid the conflict: a limited-purpose or post-deductible health FSA or HRA. Which one you are enrolled in is a plan-documents question.

Is a knee brace, a cold pack, crutches or a shower chair the kind of thing either account can pay for?

The definition contemplates equipment, and HealthCare.gov names crutches and bandages among what FSA funds may cover. That is a statement about a category of expense, not about any particular purchase, and it does not mean every recovery product qualifies. Whether your health FSA reimburses a specific item, and with what documentation, is a question for your plan and administrator; whether an HSA distribution for it is tax-free turns on the federal test and your records.

Who decides — the IRS, my employer, my administrator, or the store?

It depends on the account, and the store least of all in either case. Federal rules define medical care for both and decide whether an HSA distribution is tax-free. For a health FSA, your employer’s plan specifies which qualified expenses it reimburses and by when, and your administrator applies those terms to your claim and its documentation. For an HSA, no employer plan adjudicates your spending — you take the distribution and keep records sufficient to show it paid a qualified medical expense. A merchant’s shelf label is evidence of how that merchant classifies an item, not a decision by anyone who can make one.

What receipts do I need, and what if I cannot produce one?

An itemized record showing the date, the seller or provider, a description of what was bought, the amount, and who it was for. An FSA claim also needs a statement that the expense was not reimbursed elsewhere, and your administrator sets the exact fields; an HSA holder keeps records sufficient to show the distribution paid a qualified medical expense. On one administrator’s plan, an unsubstantiated transaction is deemed ineligible and must be repaid, with the card suspended after 60 days — that plan’s terms. What is not plan-specific is that records missing at the moment of purchase are hard to build later, and the exposure differs by account: a health FSA plan can require repayment or another correction under its own terms when a transaction is not substantiated, while an HSA holder without sufficient records may simply be unable to support tax-free treatment of the distribution.

Does over-the-counter mean I need a prescription?

Not for over-the-counter medicines, as a matter of federal rules: expenses for “over-the-counter medicine (whether or not prescribed)” are medical care and a covered expense, for amounts paid after December 31, 2019. That is a rule about medicines and drugs — it does not make every product sold over the counter a qualified expense, and it does not decide how a plan processes a claim. Some plan handouts and consumer pages still print the older requirement; two sources read for this article did on August 31, 2026. If yours does, ask your administrator.

Methodology

This article is research-based. It was written from primary federal publications — IRS Publications 969 and 502, IRS FAQ guidance, one Internal Revenue Bulletin and one IRS news release — from HealthCare.gov and OPM consumer material, and from one named plan administrator’s published guide and claim form. Every source was opened and read on the date recorded below, and where a source is quoted it is attributed in the sentence that quotes it.

Byline: Kade Lato. Kade Lato is the founder’s editorial pen name. No clinical, tax, or benefits-administration credential is claimed.

PainRecoveryPro has not hands-on tested, used or purchased any product, and has not reviewed any reader’s plan documents. No claim here rests on personal experience. No tax, benefits-administration or clinical credential is claimed for this page or its author, and nothing here has been reviewed by a professional in any of those fields.

This article carries no affiliate links, tracking parameters or referral codes, and names no product, brand, price or merchant. See also Editorial Standards and the Medical Disclaimer.

Sources and dates

Every source below was opened and read on August 31, 2026. Figures are stated with the year they belong to.

Limitations and conflicts recorded on August 31, 2026

• Publication 969’s edition lags the current plan year. The edition available on August 31, 2026 is captioned “For use in preparing 2025 Returns” and states the 2025 figures, including the $660 carryover maximum. The 2026 federal maximum of $680 is therefore taken from Rev. Proc. 2025-32, and both figures are labeled with their year wherever they appear.
• HealthCare.gov’s FSA page had not been updated to 2026 figures. On August 31, 2026 it displayed a $3,300 contribution limit and a $660 carryover with no year label. Its numbers are deliberately not quoted here; its structural statements about grace periods and carryovers are.
• Two sources still print the pre-2020 over-the-counter rule. HealthCare.gov’s FSA page stated that FSA funds may be spent “on prescription medications, as well as over-the-counter medicines with a doctor’s prescription,” and the Optum FY26 guide carries an “Eligible with a prescription” list stating that OTC items that contain a drug or medication “require a prescription in order to be reimbursed.” Both conflict with the current federal position. Neither is used as a rule anywhere in this article; the conflict is reported and readers are directed to their own administrator.
• IR-2020-122 is a 2020 news release and carries the IRS’s own caution that “News items may not be updated after their release.” It is cited only for the OTC and menstrual-care change and the receipts instruction, alongside the current publication text.
• The administrator material is one plan. The State of Illinois / Optum guide is dated to fiscal year 2026 and carries a 2024 copyright and document code (WF13314108 319831-032024); the claim form carries a 2022 copyright (136873A-062022). Its plan-year dates, run-out date, notice window and card-suspension rule are that plan’s and are never presented here as general rules.
• The related PainRecoveryPro guides referenced above are unpublished. Their status was confirmed before writing, and no live link to either appears on this page.

Last reviewed: August 31, 2026.