FSA Skincare Rules: Sunscreen, Acne & Anti-Aging
Skincare is the most confusing category in the FSA world. Why is one face cream eligible while another is rejected? It comes down to one simple question: Is it cosmetic, or is it medical?
1. The Sunscreen Rule (SPF 15+)
This is the easiest win. According to the IRS, sun protection is medical because it prevents skin cancer.
The Rule: Any sunscreen with SPF 15 or higher is 100% FSA/HSA eligible. This includes:
- Daily Face Moisturizers (if they have SPF 15+).
- Mineral Sunscreens (like Supergoop or CeraVe).
- Lip Balms with SPF.
Plan Administration Warning: If the product is primarily a "Tanning Oil" with low SPF, it may be rejected. Stick to products labeled "Broad Spectrum."
2. Acne Care (The CARES Act Update)
Before 2020, you needed a prescription for acne wash. Now, thanks to the CARES Act, Over-the-Counter (OTC) drugs are fully eligible.
What qualifies: Any product with an "Active Ingredient" listed on the 'Drug Facts' label, such as:
- Salicylic Acid (Cleansers)
- Benzoyl Peroxide (Spot treatments)
- Adapalene (Retinoids)
- Pimple Patches (Hydrocolloid bandages are eligible as 'First Aid').
3. Anti-Aging & "Cosmetic" Items
This is where claims get denied. General moisturizers, eye creams, and anti-aging serums (like Hyaluronic Acid or Vitamin C) are considered Cosmetic and are NOT eligible.
The Exception: If you have a diagnosed medical condition (like severe eczema or rosacea), you can buy these items IF you have a Letter of Medical Necessity (LMN) from a dermatologist.