Finasteride (Propecia)
Cosmetic gray area (treat cautiously)Treat it as not eligible by default. Finasteride is FDA-approved for androgenetic alopecia, which is the argument for eligibility, but IRS audits historically lean toward the cosmetic exclusion for hair loss. With a prescription plus a Letter of Medical Necessity naming the diagnosis, you have a defensible claim.
Minoxidil (Rogaine)
Cosmetic gray area (treat cautiously)Same gray area as finasteride, with one extra wrinkle: minoxidil is sold over the counter, so there is no prescription record backing the purchase. An LMN from your clinician naming the diagnosis carries the whole claim. Without one, treat it as out of pocket.
Hair transplants
Not HSA-eligibleNot eligible. IRS Publication 502 names hair transplants in the cosmetic-surgery exclusion by name. This is one of the few hair loss questions with a flat answer, and the answer is no.
PRP injections
Cosmetic gray area (treat cautiously)Platelet-rich plasma sits in the same gray area. The procedure is directed at appearance, which is the exact language of the cosmetic exclusion. An LMN tying it to a diagnosed condition is the only documentation path, and even then this is a harder claim to defend than prescription medication.
Laser caps and LLLT devices
Cosmetic gray area (treat cautiously)Low-level laser therapy devices are FDA-cleared for androgenetic alopecia, which parallels the finasteride argument. The IRS has never addressed them. The cautious position is identical: not eligible without an LMN that names the diagnosis and the device.
Hair-growth supplements (biotin, Nutrafol, saw palmetto)
Not HSA-eligibleNot eligible. Supplements taken for general health do not qualify, and hair-growth blends fall squarely in that bucket. A clinician recommendation does not change this - Pub 502 only allows nutritional supplements when they treat a specific medical condition, and even then the documentation bar is high.