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Reinstatement of Over-the-Counter Medications


Part of the CARES Act (COVID-3 Stimulus Bill), that was passed and signed into law on March 27, 2020, has reinstated the coverage for Over-the-Counter (OTC) medications and drugs for reimbursement from HSAs, FSAs, and Archer MSAs (unless your plan excludes OTC items). These items can be purchased with funds from eligible accounts without needing a prescription.


Additionally, the bill expands OTC items to include menstrual care products.

According to the new law, this change is effective for items purchased on or after January 1, 2020. Merchants* will need to update the list of eligible products and implement that list. This process will likely take place over the next 4-6 weeks with no timeline specifically outline by individual merchants.

The changes may result in some inconsistencies for participants while shopping due to the merchant updates required. For example, individuals may be able to purchase OTC products with one merchant but not another, as the merchants are responsible for marking all products as eligible.


* A merchant represents a person or company that sells goods or services. An eCommerce merchant refers to a party that sells goods or services exclusively through the internet.

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