Can I Use My HSA for Teeth Whitening Strips?

Having a bright, white smile can give you a big confidence boost. Teeth whitening strips are a popular over-the-counter option for whitening your teeth at home. But can these strips be paid for with a health savings account (HSA)?

Let’s take a closer look at whether teeth whitening qualifies as an HSA-eligible expense and specifically if whitening strips can be reimbursed.

What are Teeth Whitening Strips?

Whitening strips are thin, flexible strips coated with a whitening gel containing ingredients like hydrogen peroxide or carbamide peroxide.

Here’s how whitening strips work:

• You stick the strips to the front surfaces of your top and bottom teeth.

• The whitening gel on the strip makes contact with your teeth to lift stains.

• Whitening chemicals like peroxide help bleach teeth and brighten your smile.

• Strips are worn for 30 minutes to an hour at a time and replaced with fresh strips.

• A full treatment involves wearing strips for multiple days or weeks.

Popular over-the-counter whitening strip options include Crest Whitestrips, Colgate Optic White strips, and store brand alternatives. These provide an affordable and convenient way to whiten teeth at home.

Is Teeth Whitening an Eligible HSA Expense?

Whether you can use your HSA to buy teeth whitening strips depends on whether teeth whitening qualifies as an eligible medical expense.

Unfortunately, the IRS does not consider teeth whitening of any kind to be an HSA-qualified expense. The costs of whitening treatments and products like whitening strips cannot be reimbursed with an HSA.

That’s because teeth whitening is classified as a cosmetic treatment by the IRS, not a legitimate medical expense. The purpose is to improve your appearance and aesthetics versus treating a diagnosed dental disease or medical condition.

The IRS publication 502 on allowable medical expenses states:

• “You can’t include in medical expenses the cost of … cosmetic surgery or similar procedures, unless the surgery is necessary to ameliorate a deformity arising from, or directly related to, a congenital abnormality, a personal injury resulting from an accident or trauma, or a disfiguring disease.”

Since teeth whitening isn’t considered necessary to treat a deformity or diagnosed disease, it doesn’t qualify. The same applies to other cosmetic dental procedures like veneers.

However, if you had severe intrinsic tooth staining due to a medical condition or accident, there may be an exception for whitening or veneers in limited cases.

Are Any Teeth Whitening Costs HSA-Reimbursable?

The general rule is that all teeth whitening products and procedures are ineligible HSA expenses, including popular drugstore whitening strips. But there are a couple potential exceptions where whitening costs may qualify in special medical circumstances.

Here are two examples where teeth whitening might be reimbursable with an HSA:

• Whitening treatment for intrinsic staining or discoloration directly resulting from an underlying medical condition, like drug side effects or enamel defects. Proper documentation of the condition would be required.

• Professionally administered in-office whitening that is medically necessary to treat severe intrinsic tooth discoloration caused by trauma or accident-related injuries.

However, for these exceptions to apply, the teeth whitening must be treating an underlying disease or accident-related defect. Purely cosmetic reasons like wanting whiter teeth for your wedding wouldn’t qualify.

Abnormal intrinsic tooth staining from medical causes is also different from extrinsic staining, like that from coffee, smoking, or certain foods and drinks. Whitening for extrinsic staining reasons would not be eligible.

Overall though, the vast majority of teeth whitening costs, including drugstore whitening strips, cannot be paid for with HSAs based on IRS regulations. Routine cosmetic whitening is ineligible.

Are Other Dental Care Costs HSA-Eligible?

You may be wondering if other common dental care services and products besides teeth whitening qualify for HSA reimbursement.

Unfortunately, most routine dental expenses are not eligible either, including:

• Teeth cleanings
• X-rays
• Fillings
• Tooth extractions
• Dental braces
• Dentures

Like cosmetic treatments, the IRS considers most standard preventive, restorative, and orthodontic dental care to be non-medical.

However, some specific dental services may qualify if medically necessary to treat diagnosed dental disease or oral health issues stemming from a medical condition. For example:

• Dental treatment needed to alleviate pain from a congenital abnormality
• Oral surgery to remove cysts or lesions
• Teeth extractions due to gum disease from an autoimmune disorder
• Dentures needed after cancer treatment affects the jaw and teeth

Proper documentation to confirm the underlying medical condition would be required for these exceptions. But the vast majority of routine dental care costs are not HSA-eligible.

Can FSAs Reimburse Teeth Whitening or Dental Costs?

Some employer-sponsored health flexible spending accounts (FSAs) may offer more flexibility to reimburse certain dental and teeth whitening costs that HSAs can’t cover.

With an FSA, the employer gets to determine what expenses are reimbursable, beyond what the IRS allows for medical care. Many expand their FSA to reimburse preventive dental services like cleanings, x-rays, and fluoride treatments.

However, cosmetic treatments like teeth whitening strips would still not qualify with an FSA either per IRS guidance. You’d need to check your specific employer’s FSA plan rules to see if any dental or orthodontic services are eligible for reimbursement.

If you have both an HSA and FSA (like a limited-purpose FSA), you’d need to tap the FSA first for any eligible dental costs before using HSA funds.

Can I Pay for Teeth Whitening with HSA Funds and Just Not Seek Reimbursement?

Some HSA account holders may wonder if they can skirt the rules and directly pay for ineligible cosmetic treatments like teeth whitening strips using their HSA debit card or checks, but just not submit the expenses for reimbursement.

This is not recommended, even if you don’t mind forfeiting the expense being reimbursed. Paying outright for ineligible expenses from your HSA could disqualify your account and lead to tax penalties and fees.

The IRS requires HSAs to only be used for qualified medical expenses, with few exceptions like disbursements for non-medical reasons after age 65. But in general, you should only use HSA funds to directly buy products and services considered eligible by the IRS and not mix in ineligible expenses.

Strategies to Pay for Teeth Whitening with HSAs

While teeth whitening strips and similar cosmetic treatments aren’t eligible HSA expenses, here are some strategies you can leverage to pay for them using your account:

• Withdraw cash from your HSA using qualified distributions to spend on anything. However, this should be a last resort since non-medical HSA withdrawals are taxable income and incur a 20% penalty if you’re under age 65.

• Pay for teeth whitening out of pocket with non-HSA funds. Keep all medical receipts to reimburse yourself later from your HSA balance for qualified dental or medical costs to build up cash.

• If your employer’s FSA includes teeth whitening or dental care, use that account to pay for routine dental expenses instead of the HSA. Then reimburse yourself from the HSA for eligible medical costs only.

• Invest your HSA funds and let them grow tax-free for years. Then reimburse yourself for a wide range of dental, vision, and medical expenses tax-free upon retirement.

Key Takeaways – HSAs and Teeth Whitening

• Teeth whitening is considered a cosmetic expense by the IRS and does not qualify for HSA reimbursement. This includes drugstore whitening strips.

• Rare exceptions may apply if whitening is to medically treat intrinsic tooth discoloration directly stemming from a medical condition or accident-related trauma. Proper documentation would be needed.

• Most routine dental care like cleanings, fillings, and braces are not HSA-eligible either per IRS regulations. Limited exceptions apply if treating diagnosed dental disease.

• Consider paying for teeth whitening and dental costs using non-HSA funds instead. You can reimburse yourself from the HSA later for qualified medical expenses.

• Be cautious using HSAs to directly purchase ineligible products and services. This could jeopardize your account.

• Leverage other tax-advantaged accounts or cash-basis distributions to pay for teeth whitening if you have the funds available.

Understanding what expenses are HSA-qualified is key to avoiding issues. While convenient and affordable, popular teeth whitening products like strips currently remain ineligible.