OTC CGM HSA FSA Eligibility Tips (2026) | HSA Tracker
Wondering if you can use your HSA or FSA funds for that new over-the-counter continuous glucose monitor? The answer changed in 2020, and many W2 employees and self-employed individuals are missing out on significant tax savings. The CARES Act permanently expanded eligibility for OTC medical devices like CGMs, meaning products such as Dexcom Stelo and Levels Lingo are qualified medical expenses without a prescription. This guide covers the exact rules for OTC CGM HSA FSA eligibility in 2026, helping you avoid confusion, maximize your tax-advantaged accounts, and manage healthcare costs effectively. We will break down the regulations, pricing, and payment methods so you can fund your metabolic health monitoring pre-tax.
Quick Wins
Call your FSA/HSA provider and ask specifically about OTC CGM eligibility. Get a direct answer and note the date.
Bookmark the FDA clearance pages for Dexcom Stelo and Levels Lingo to easily reference them as needed.
Set up a dedicated digital folder on your computer or cloud drive labeled 'HSA/FSA - Medical Devices' and save your first receipt there now.
Confirm Your Plan's OTC CGM Policy Before Buying
High impactWhile the CARES Act makes OTC CGMs eligible, individual FSA/HSA plan administrators can have specific rules or required merchant codes. A quick call to your provider's customer service can prevent reimbursement delays.
Call your FSA card issuer and ask: 'My plan documents cite IRS Code 213(d). Are over-the-counter continuous glucose monitors, like Dexcom Stelo, an eligible expense without a prescription?' Get the
Use the Correct Product Description on Receipts
High impactVague receipts like 'sensor' or 'monitor' can trigger a review. Ensure your receipt specifies 'Dexcom Stelo Continuous Glucose Monitoring System' or 'Levels Lingo CGM Sensor.'
When checking out on stelo.com, your receipt should list 'Dexcom Stelo CGM Sensor Kit' as the line item, not just a generic SKU number. Save a PDF of this receipt.
Maximize Tax Savings by Bunching Purchases
High impactIf you have funds available, buy a larger supply of sensors to hit your annual FSA contribution or maximize HSA spending. This locks in the current price and uses pre-tax dollars efficiently.
You have $800 left in your FSA with a December deadline. Purchase two 3-month Stelo packs (total $504) and other eligible items to fully use the funds, avoiding forfeiture.
Understand the Difference Between OTC and Prescription CGMs
Medium impactPrescription CGMs (Dexcom G7, FreeStyle Libre 3) require a doctor's order and are often covered by insurance. OTC CGMs (Stelo, Lingo) do not require a prescription and are not typically covered by insurance, making HSA/FSA essential.
A prediabetic individual not on insulin would not qualify for a prescription CGM under most insurance plans. Their only pre-tax funding option is an HSA or FSA for an OTC model like Levels Lingo.
Keep a Log of Your Medical Reasoning
Low impactWhile not required for OTC devices, maintaining a simple log of how you use the CGM data for health management strengthens your position that it's a qualified medical expense if ever questioned.
Note in a health app: 'Using Stelo data to monitor glucose responses to diet and exercise, aiming to manage prediabetes and reduce metabolic risk factors.'
Check Retailer Eligibility Before Using Your Debit Card
Medium impactNot all retailers that sell CGMs are coded correctly in FSA/HSA card systems. Major pharmacies like Walgreens and CVS usually work, but marketplaces like Amazon require using the FSA/HSA store section.
Before trying to use your FSA card on Amazon, search for 'Dexcom Stelo' in the 'FSA and HSA Store' category. Using the card elsewhere on Amazon may be declined.
Know Your Annual Contribution Limits for Planning
High impactFor 2026, the FSA limit is $3,400 per employee. The HSA limits are $4,400 for self-only coverage and $8,750 for family coverage. Factor the annual cost of an OTC CGM (~$1,000) into your election amount.
A family planning to use an OTC CGM for one member should consider adding at least $1,000 to their HSA or FSA election during open enrollment to cover this cost tax-free.
Use Reimbursement if Your Debit Card is Declined
Medium impactIf your FSA/HSA card is declined at the point of sale, pay with a personal card and submit for reimbursement. This is a common backup method and often works when direct payment fails.
Your HSA debit card gets declined on the Levels website. You use your personal credit card, get cash back, then log into your HSA provider's portal and submit the receipt for reimbursement.
Verify That Your HDHP is HSA-Qualified
High impactTo contribute to an HSA, you must be covered by a qualified High Deductible Health Plan. Not all HDHPs qualify. Check your plan documents or ask your HR department for confirmation.
Your health plan has a $3,000 deductible, but if it covers certain benefits before the deductible is met (like a copay for telehealth), it may not be HSA-qualified, blocking contributions.
Coordinate FSA Spending with Your Spouse's HSA
Medium impactIf you have an FSA but your spouse has an HSA-eligible HDHP, they can contribute to their HSA. However, your FSA must be a limited-purpose type to avoid disqualifying their HSA contributions.
You have a general-purpose FSA through your job. Your spouse, on a separate HDHP, cannot make HSA contributions. They would need to switch to an HSA-eligible plan and you'd need to cancel or change
Save Screenshots of FDA Clearance Pages
Low impactFor audit proof, save a screenshot of the FDA clearance announcement for the specific OTC CGM you purchased. This demonstrates the device is a legitimate medical device.
Go to the FDA news release for 'Dexcom Stelo Glucose Bioseensor' dated June 2024. Save the page as a PDF and file it with your purchase receipt.
Calculate Your Exact Tax Savings
Medium impactEstimate your marginal tax rate (federal + state). Multiply the cost of the CGM by this rate to see your exact savings. For many, a 25% rate on a $1,068 expense saves $267.
You are in the 22% federal bracket and a 5% state bracket. Your combined rate is 27%. A $1,068 Stelo subscription costs you only $779 after tax savings ($1,068 * 0.73).
Consider the FSA Carryover Cap of $680
Medium impactIf your FSA plan allows a carryover, you can roll over up to $680 of unused funds into the next plan year. This can fund part of an OTC CGM purchase early in the new year.
You have $680 carried over from 2025 to 2026. You use this money in January to buy a 3-month supply of Lingo sensors for $249, reducing your out-of-pocket cost to zero.
Review Your Plan's 'List of Eligible Expenses'
Low impactMany FSA and HSA providers publish an online list or search tool for eligible items. Search for 'continuous glucose monitor' or 'medical device' to see if OTC CGMs are explicitly listed.
Log into your FSA provider's website, find the 'Eligible Expenses' tool, and type 'CGM'. If 'Over-the-Counter Glucose Monitors' appears, screenshot this as supporting documentation.
Set Up Autoship for Consistent HSA Spending
Low impactIf using an HSA, setting up monthly autoship for sensors creates a predictable, budgetable medical expense. It also ensures you never run out of sensors and have regular documentation.
Enroll in Dexcom Stelo's monthly $89 subscription. Your HSA debit card is charged automatically each month, creating a clean record of 12 identical transactions for the year.
Use HSA Funds for CGMs in Retirement Planning
Medium impactHSAs offer a powerful retirement savings component. If you can afford to pay for OTC CGMs out-of-pocket now, you can save your HSA receipts and reimburse yourself tax-free years later, allowing funds to grow.
You pay $1,068 annually for Stelo with after-tax dollars but save the receipts. In 20 years, you reimburse yourself for $21,360 of accumulated expenses from your now-larger HSA, tax-free.
Be Aware of Age Restrictions on OTC CGMs
Medium impactDexcom Stelo and Levels Lingo are cleared for adults 18 and older. You cannot use FSA/HSA funds to purchase these for a minor child, as they are not approved for pediatric use.
You want to monitor your 16-year-old's glucose. An OTC CGM is not an eligible expense for them. You would need a prescription CGM, which may be eligible if prescribed.
Compare Total Annual Cost of OTC vs. Prescription Routes
Medium impactWhile a prescription CGM may be covered by insurance, consider copays, deductibles, and premium costs. For non-insulin users, the OTC + HSA/FSA route is often cheaper than upgrading insurance plans.
A silver HDHP with an HSA might have a lower premium than a gold PPO. The tax savings from using HSA funds for an OTC CGM could make the HDHP+HSA combination more cost-effective overall.
Document the Medical Purpose if Submitting Manually
Low impactWhen submitting a manual reimbursement claim through your HSA/FSA portal, there is often a 'reason' field. Briefly state the medical purpose, such as 'monitoring blood glucose for metabolic health management.'
In the reimbursement description, write: 'Purchase of Dexcom Stelo CGM sensors for monitoring and managing prediabetic glucose levels as a qualified medical expense under IRS 213(d).'
Know That OTC CGM Eligibility is Permanent
Low impactThe CARES Act change from 2020 is permanent law, not a temporary provision. You can confidently plan for using FSA and HSA funds for OTC CGMs in 2026 and beyond without fear of a rule sunset.
When doing multi-year financial planning for healthcare costs, you can include the annual expense of an OTC CGM as a permanent eligible item in your HSA spending projections.
Combine with Other Eligible Expenses for Maximum Benefit
Medium impactPair your OTC CGM purchase with other eligible items like diabetic testing supplies (lancets, control solution), fitness trackers if prescribed, or nutritional counseling to fully use your FSA/HSA funds.
You have a $3,400 FSA. You spend $1,068 on Stelo, $300 on a Withings body comp scale (if prescribed), and $500 on nutritional counseling.
Check if Your Plan Requires a Flexible Spending Code
Low impactSome FSA administrators use flexible spending codes (FSC) for specific product categories. An OTC CGM might fall under 'Medical Devices' or 'Monitoring Devices.' Knowing the correct code speeds up claims.
Your FSA provider tells you to use FSC 101 (Medical Monitoring Devices) when submitting a manual claim for a Levels Lingo CGM purchase. You include this code on the claim form.
Understand the 'Dual Purpose' Rule for HSAs
High impactHSA funds used for non-qualified expenses before age 65 incur income tax plus a 20% penalty. Ensure your OTC CGM purchase is a qualified expense to avoid this. Keeping receipts is your defense.
You use HSA funds for a Stelo CGM. This is qualified. If you used those same funds for a general fitness tracker without a prescription, it would be non-qualified and penalized.
Use Year-End FSA Funds Before They Expire
High impactMany FSAs have a December 31 deadline with a short grace period. If you have leftover funds, purchasing OTC CGM sensors is an excellent way to avoid forfeiting your money.
It's mid-December, and you have $400 left in your FSA. You order a 2-sensor pack of Dexcom Stelo for $99 and a 3-month supply of Lingo for $249, using all but $52 of your expiring funds.
Confirm Direct Payment Works Before Shopping
Low impactTest your FSA/HSA debit card on a small eligible purchase at a known retailer (like a pharmacy) to ensure it's activated and has no spending blocks before attempting a larger CGM purchase.
Before buying a $99 Stelo sensor pack, use your FSA card to buy $10 of eligible bandages at CVS. If it goes through, your card is ready for the larger online purchase.
Educate Your Financial Advisor About OTC CGM Eligibility
Low impactMany financial advisors are not fully updated on the CARES Act changes. Informing them helps them provide better tax planning advice regarding your HSA contributions and healthcare spending.
In your annual financial review, tell your advisor, 'I'm using my HSA for an over-the-counter CGM, which is now a permanent eligible expense.
Pro Tips
Buy sensors in multi-pack subscriptions. The 3-month plan for Dexcom Stelo costs $84 per month, saving you $5 monthly versus the single-month plan. This larger upfront purchase is perfect for FSA 'use-it' years or HSA investment accounts.
Time your purchase for year-end FSA deadlines. If you have a 'use-it-or-lose-it' FSA with a December 31 deadline, order a 3-month supply of OTC CGM sensors in late November. This uses expiring funds and sets you up for the new year.
Set up a separate digital folder for all CGM receipts and product descriptions. Label it 'Medical Expenses - OTC CGM' and include screenshots of the FDA clearance pages. This creates an audit trail in minutes.
If your FSA offers a grace period or carryover, plan your OTC CGM purchase for early in the plan year. This ensures you have maximum funds available and can budget for any additional healthcare needs later.
Contact your HSA provider or FSA administrator *before* your first purchase. Ask, 'Does my plan require a specific product code for OTC CGM reimbursement?' Some use flexible spending codes; knowing yours prevents rejected claims.
Frequently Asked Questions
Are over-the-counter CGMs like Dexcom Stelo really eligible for HSA and FSA reimbursement?
Yes, due to the CARES Act of 2020. This law amended IRS Code Section 213(d) to include over-the-counter medications and medical devices as qualified medical expenses. OTC CGMs fall under this category. You do not need a prescription or a Letter of Medical Necessity for OTC models, which distinguishes them from prescription-only CGMs like the Dexcom G7. Final approval can depend on your specific plan administrator, but the IRS rule supports eligibility.
What is the difference between using an HSA and an FSA for an OTC CGM purchase?
The main differences involve contribution limits, rollover rules, and ownership. For 2026, the FSA limit is $3,400 per employee with a potential carryover of up to $680 if your plan allows it. HSA limits are higher at $4,400 for self-only and $8,750 for family coverage, and HSA funds roll over indefinitely. FSAs are use-it-or-lose-it annually unless your plan offers the carryover. HSAs are individually owned and portable, while FSAs are employer-sponsored.
Do I need a diabetes diagnosis to use HSA/FSA funds for an OTC CGM?
No, a specific diagnosis is not required by the IRS. The eligibility scope under 'qualified medical expense' includes devices for the diagnosis, mitigation, treatment, or prevention of disease. This covers individuals with diabetes, prediabetes, or other metabolic conditions like PCOS or reactive hypoglycemia. The key is that the expense must be primarily for medical care.
How do I actually pay for an OTC CGM with my HSA or FSA card?
You can use your FSA/HSA debit card directly at approved vendors. For Dexcom Stelo, shop on stelo.com; for Levels Lingo, use hellolingo.com. Many major retailers like Amazon and Walgreens also accept these cards for eligible items. If you pay with a personal credit card for rewards or cash flow reasons, you can submit the itemized receipt for reimbursement from your HSA or FSA. Ensure the receipt clearly shows the product name (e.g., 'Dexcom Stelo Sensors') and the date of purchase.
Will my health insurance cover an OTC CGM if I don't use insulin?
Most standard health insurance plans do not cover OTC CGMs for non-diabetic or prediabetic users. Insurance typically only covers prescription CGMs for individuals with specific conditions like Type 1 or Type 2 diabetes requiring insulin. This coverage gap is precisely why FSA and HSA funds are the primary funding source for individuals interested in metabolic health monitoring without an insulin-dependent diagnosis.
What documentation do I need to keep for my taxes or a potential audit?
Keep your itemized sales receipt showing the merchant name, date, product description, and amount paid. For OTC CGMs, you do not need a doctor's note or prescription. However, it is wise to also save a printout of the product description from the manufacturer's website that confirms it is a medical device. In the event of an IRS audit, you must be able to show that the expense was for medical care. Organizing these documents digitally in a dedicated folder is a best practice.
Can I use my FSA funds if I also have an HSA?
This depends on your HSA eligibility. To contribute to an HSA, you must be enrolled in a qualified High Deductible Health Plan (HDHP). If you have an HSA, you generally cannot also have a general-purpose FSA, as that would disqualify you from HSA contributions. However, you may be eligible for a limited-purpose FSA (LPFSA) that covers only dental, vision, and preventive care expenses. OTC CGMs would not be eligible under an LPFSA.
How much can I realistically save by using pre-tax funds for an OTC CGM?
Your savings depend on your federal and state income tax brackets. A typical estimate is 20 to 30 percent. For example, the annual cost of Dexcom Stelo on a monthly subscription is $1,068. Using pre-tax FSA or HSA funds could save you between $250 and $270 on that cost. If you opt for the 3-month autoship plan at $1,008 per year, your savings would be roughly $240 to $300. This effectively reduces the net price of the device, making ongoing health monitoring more affordable.
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