Guide · Buying
Usually yes, conditionally. A massage gun or a set of compression boots can be a qualified medical expense when you are buying it to treat a diagnosed condition — and is not one when you are buying it for general fitness. The product does not decide it. Your reason does.
The governing test
IRC §213(d)
IRS guidance naming these devices
None
Hyperice says eligible
All products
Therabody tags as eligible
6 products
The rule
One test governs every FSA, HSA, HRA and Archer MSA purchase. Internal Revenue Code §213(d)(1)(A) defines medical care as amounts paid “for the diagnosis, cure, mitigation, treatment, or prevention of disease, or for the purpose of affecting any structure or function of the body.” HSA rules in §223(d)(2)(A) point straight back at that definition, so it is the same test either way.
IRS Publication 502 adds the sentence that does the real work: “Medical care expenses must be primarily to alleviate or prevent a physical or mental disability or illness. They don’t include expenses that are merely beneficial to general health.”
That word — primarily — is the whole question. A Theragun bought to manage pain from a diagnosed condition is being bought primarily to treat an illness. The same Theragun bought because training left you sore is being bought for general health. Same box, same price, different answer.
Corrections
Misconception 01
It did not. Section 3702 struck the sentence that required a prescription for a medicine or drug. Devices were never covered by that sentence — they have always been judged on the §213(d) purpose test alone. The IRS news release describing the change used the looser phrase “over-the-counter products and medications,” which is where the confusion started. Read the statute, not the press release.
Misconception 02
The eligibility test contains no FDA criterion. Not §213(d), not Publication 502, not the IRS wellness FAQ. Normatec and JetBoots PRO Plus hold 510(k) clearances because 21 CFR 890.5650 makes powered inflatable tube massagers Class II. Massage guns fall under 21 CFR 890.5660, which is Class I and exempt from premarket notification — so no Theragun or Hypervolt has a clearance because none is required. The missing number is a regulatory pathway, not a verdict on the device.
Misconception 03
In its March 2023 FAQ the IRS was asked whether exercise for general health qualifies. The answer: “No, because the exercise, even if recommended by a doctor, is only for the improvement of general health.” A recommendation does not convert a general-health purchase. There has to be a specific diagnosed condition behind it.
Misconception 04
A manufacturer does not decide what your plan reimburses. Your plan administrator does, inside the IRS rules — and employer-sponsored FSAs can narrow eligibility further than the IRS does. Therabody says this on its own help page. Hyperice does not say it anywhere.
The brands
Both manufacturers publish an FSA/HSA page. They do not say remotely the same thing, and the difference is worth knowing before you swipe a benefits card.
| What the page claims | Therabody: a specific list of tagged products | Hyperice: “All Hyperice products are eligible” |
| Products tagged eligible | TheraFace Mask Glo, Theragun PRO Plus, JetBoots PRO Plus, ThermBack LED, Theragun Prime Plus, Theragun Mini G3 | Stated as the whole catalogue |
| Substantiation partner | Flex — pay with an HSA/FSA card at checkout, or get an itemised receipt | None published |
| Letter of Medical Necessity offered | Yes, issued at checkout via telehealth for certain products | Not mentioned |
| Warns that your plan may be narrower | Yes — “extremely important to check prior to purchase” | No qualifier published |
Hyperice’s blanket sentence is the brand’s own claim, not a determination by anyone who administers benefits. No administrator eligibility list we found treats an entire catalogue as eligible regardless of purpose, and it does not square with the “primarily” test in Publication 502. Therabody’s narrower page, with its warning that employer plans can be stricter, is the more accurate description of how this actually works.
Substantiation
An LMN is a note from a licensed clinician saying that a specific item is being used to treat a specific diagnosed condition. It appears nowhere in §213(d) or Publication 502 — it is an administrator convention built on top of the tax rule, and it is evidence rather than permission. It does not make an ineligible purchase eligible. It documents that the purchase met the test, for the day someone asks.
HealthEquity, one of the larger administrators, lists what one has to contain: the patient’s name, a specific diagnosis, the treatment the provider recommends, how long the treatment is for, and a licensed practitioner’s signature. It caps validity at twelve months, and it will not accept a purchase dated before the letter was approved. Buy first and paper it later is exactly the sequence that fails.
Truemed, one of the substantiation services in this space, draws the same line the IRS does: “General health goals, like wanting to lose weight, get stronger, or sleep better without a specific underlying condition, do not meet the IRS threshold.”
The gap
No IRS ruling, revenue procedure or published guidance names a percussion massager or a pneumatic compression system. Not once. Everything downstream of §213(d) — every eligibility list, every brand page, this page included — is interpretation of a general rule, not a determination about these products.
Massage guns at least appear on the big administrator lists. FSA Store and HSA Store both say a massage gun bought primarily for pain relief is eligible with an FSA, HSA or HRA, and that one bought for general well-being or relaxation needs an LMN. Optum, one of the largest HSA custodians, sells a Theragun Relief on its own storefront with an HSA/FSA badge and no documentation flag.
Compression boots are the harder case, and it is worth being straight about it: we could not find a single major administrator eligibility list with an entry for compression boots, pneumatic compression, or a sequential compression device. FSA Store’s compression coverage is about garments — stockings and sleeves, eligible at 30–40+ mmHg. A Normatec is not a garment, and stretching a garment threshold to cover an air-compression system would be inventing a rule that nobody has written. So: no published administrator position either way.
The FDA-cleared indication is the one piece of paper that helps here, not because clearance is required but because it is documentary evidence of medical rather than general-wellness purpose. Normatec 3 is cleared under K220217 as “an air pressure massager intended to temporarily relieve minor muscle aches and/or pains, and to temporarily increase circulation to the treated areas.” That sentence is closer to §213(d) language than any marketing copy will ever be.
In practice
Before you buy
Not the brand, not a blog. Your plan administrator is the party that approves or denies the claim, and an employer FSA can be narrower than the IRS rule. A one-line email naming the product gets you an answer you can keep.
If a condition is involved
The purchase has to be dated after the LMN is approved, and the letter needs a named diagnosis and a treatment duration. Therabody’s checkout can issue one through Flex; your own clinician can write one too.
Either way
An order confirmation is not an itemised receipt. Both brands will email one. Keep it with the LMN if you have one — substantiation is asked for after the fact, not before.
This page describes published rules and what each manufacturer states. It is not tax advice, and we are not tax advisers — a purchase reimbursed in error is your liability, not the brand’s. Confirm with your plan administrator or a tax professional before you rely on any of it.
Sources
Every claim above traces to one of these. Read them yourself if the money matters.
| The definition of medical care | 26 U.S.C. §213(d)(1)(A) |
| HSA qualified expenses | 26 U.S.C. §223(d)(2)(A) |
| The “merely beneficial to general health” limit | IRS Publication 502, Medical and Dental Expenses |
| A doctor’s recommendation is not enough | IRS FAQ on nutrition, wellness and general health, 17 March 2023 |
| What the CARES Act changed | Public Law 116-136 §3702; IRS news release IR-2020-122 |
| Compression boots are Class II | 21 CFR 890.5650, powered inflatable tube massager |
| Massage guns are Class I and 510(k)-exempt | 21 CFR 890.5660, therapeutic massager |
| Normatec 3 cleared indication | FDA 510(k) K220217, 25 February 2022 |
| What an LMN must contain | HealthEquity, Letter of medical necessity |
| Massage gun eligibility by purpose | FSA Store and HSA Store eligibility lists |
| Brand positions | therabody.com HSA/FSA page; hyperice.com FSA/HSA page |
Questions
They are different documents. A prescription is written for a medicine or drug; a letter of medical necessity is a clinician's note tying a specific item to a specific diagnosed condition, and it is an administrator convention rather than anything the tax code requires. Nothing in the published rules asks for a prescription for a massage gun or compression system. Your administrator decides which document, if any, it wants.
Substantiation is usually requested after the fact, so a denial can arrive well after the box does. What happens next is set by your plan, not by the manufacturer: administrators publish their own remedies, which can include supplying more documentation, repaying the amount, or offsetting it against another eligible expense. Ask yours how it handles this before you spend, and take anything tax-related to a professional.
Neither Hyperice nor Therabody publishes a separate eligibility position on attachments, cases or replacement parts, and no administrator list we found names them. The same purpose test would apply to an accessory bought to treat a diagnosed condition, but nobody has written that down for these items specifically. If it matters to your budget, ask your administrator to answer in writing before you order.
Therabody publishes that you can pay with an HSA or FSA card at its own checkout through Flex, or request an itemised receipt. Hyperice publishes no substantiation partner. Either way, a card that clears has not been reviewed by anyone and a decline is not a ruling on the purchase - your plan sets what its card accepts. Keep the itemised receipt regardless of how you paid.