Expanding FSA/HSA Eligibility for Oral Care Products

East Asian American Woman Using Mouthwash

FSA-HSA eligibility expansion will:

  • Close gaps in oral health disparities
  • Help Americans improve their overall health and well-being
  • Lower overall healthcare spending in America

Greater Access to Self-Care Products is Key

Costs on everyday, essential self-care items can add up quickly, and Americans are asking for increased flexibility to use the pre-tax savings in their Flexible Spending Accounts (FSAs) and Health Savings Accounts (HSAs) for better self-care, including for oral care products. Unfortunately, most products for oral health care are not currently eligible medical expenses for FSA and HSA spending.

Policymakers should encourage – and empower – individuals to take responsibility for their oral health by supporting daily oral health self-care policies that make beneficial oral care products more accessible. Doing so is a win-win, both in terms of improving the wellness of Americans while also reducing the strain on the healthcare system overall.

The Problem: Oral Health Concerns are Decreasing Americans’ Quality of Life

The Centers for Disease Control and Prevention (CDC) considers tooth decay to be a “common chronic disease...” that when left untreated “can progress and lead to infection, tooth loss, and more complex and expensive treatments.”

Tooth decay, gingivitis, periodontitis, and other oral health conditions take a toll on Americans. In fact, the implications of neglecting oral health extend far beyond the dental chair, profoundly impacting the physical, mental, and economic wellbeing of individuals and the nation.

Nearly half (46%) of Americans ages 30 and older show signs of gum disease.

However, Americans experience oral health differently. In fact, several social determinants including age and economic status affect equitable access to oral healthcare available across the country, with the burden of oral disease falling on vulnerable groups:

  • One-in-five low-income adults — two times higher than the overall rate — admit their oral health is poor, leading to more than 42% having difficulty biting and chewing, 43% experiencing physical pain, and 19% having difficulty with speech.
  • Young adults (ages 18-34) are not in much better shape, with 41% reporting pain as their top oral health problem, and 35% feeling embarrassed due to the condition of their mouth.
  • Rural Americans face even worse oral health outcomes throughout their lives, are less likely to receive preventive dental services, are more likely to seek dental care in an emergency department and have nearly double the prevalence of tooth loss than other populations.
  • Dental caries (cavities) are one of the most common chronic diseases among children, affecting one-in-four preschoolers. Children from low-income families are twice as likely to have cavities as children from higher-income families.

Brush-Up on FSAs and HSAs

Employees with FSAs or HSAs are able to put aside pre-tax dollars to pay for “qualified medical expenses,” certain healthcare costs related to medical care, prescription drugs, over-the-counter (OTC) medications, feminine hygiene products, and other items throughout pharmacy aisles.

However, current law does not recognize certain oral healthcare products — such as manual toothbrushes, electric toothbrushes, water flossers, mouthwash, or OTC anti-cavity toothpaste — as “qualified medical expenses.”


In 2020, a new law reinstated FSA/HSA eligibility for OTC medicines and, for the first time, feminine care products. New proposed legislation seeks to build on this momentum by also including certain oral care products as qualified medical expenses.


According to estimates, 60 million consumers already use FSAs and HSAs to save money on eligible healthcare expenses, including OTC medicines and feminine hygiene products.​

HSA plans are used by Americans from every income level, with the average HSA contribution being 2% of household income, according to findings from the Employee Benefits Research Institute. Nearly half of those using HSA/FSA accounts make less than $71,243 per year.

Data shows that FSAs and HSAs are associated with reductions in overall healthcare spending. Promoting access to oral healthcare products for Americans with FSAs or HSAs is better for our healthcare system overall and for taxpayers.

The Proposed Solution: Put More Teeth into FSAs and HSAs

Bipartisan legislation to expand FSA/HSA eligibility to include OTC oral care products would give millions of Americans increased flexibility to improve their oral health. Americans are asking for increased flexibility to use these pre-tax savings for better self-care, including for oral care products. Policymakers should encourage — and empower — individuals to take responsibility for their oral health.

By supporting daily self-care for better oral health, we can improve the wellness of Americans while also reducing the strain on the healthcare system. Expanding FSA/HSA eligibility to include manual and electric toothbrushes, water flossers, anti-cavity toothpaste, and similar oral care products, would give consumers more power to make better oral health decisions.

“Good oral health supports the overall health and wellbeing of individuals, families, communities, and the nation.”

– National Institutes of Health (NIH)