Are HSA and FSA Rules for Orthotic Products Changing in 2026?

Published on August 4, 2026 by Fulton

If you've been searching to find out whether the rules governing HSA and FSA spending on orthotic products are different this year, you're not alone. With the One Big Beautiful Bill Act signed into law in 2025 and new IRS contribution limits in effect, it's reasonable to wonder what, if anything, has changed for orthotic insoles and foot support products. This guide covers what's actually new in 2026, what has stayed the same for orthotics specifically, and how shoppers can use their pre-tax dollars on Fulton insoles with confidence.

What Are HSA and FSA Accounts, and How Do They Apply to Orthotics?

Flexible Spending Accounts let you set aside pre-tax dollars for qualifying medical expenses. Health Savings Accounts work similarly but are tied to high-deductible health plans and offer the added benefit of funds that roll over year to year. FSAs and HSAs generally reimburse expenses that diagnose, treat, or prevent a medical condition. Orthotics are eligible for reimbursement with flexible spending accounts (FSA), health savings accounts (HSA), and health reimbursement accounts (HRA). Orthoses refer to externally applied devices used to modify the structural and functional characteristics of the neuromuscular and skeletal system. An orthotic can be used to guide or immobilize an extremity, joint, or body segment. Foot orthoses include custom-made inserts or footbeds fitted into a shoe to provide support for the foot by redistributing ground reaction forces while realigning foot joints when standing or walking. Fulton's orthotic insoles are designed with these medical-grade standards in mind, making them a strong candidate for pre-tax benefit spending.

What Actually Changed for HSA and FSA in 2026

The One Big Beautiful Bill Act expands health savings account (HSA) eligibility and what counts as a qualified medical expense. In 2026, more Affordable Care Act marketplace plans will be HSA eligible, and direct primary care fees may qualify as medical expenses. The 2026 FSA contribution limit is $3,400 (per IRS Revenue Procedure 2024-40), with a $660 carryover cap. The One Big Beautiful Bill Act introduced gym memberships as HSA-eligible, up to $500/year for individuals. This applies to HSAs only, not FSAs. The bill also raised the annual contribution limit for dependent care flexible spending accounts from $5,000 to $7,500, effective for plan years starting January 1, 2026. Importantly, the eligibility rules specifically governing orthotic products were not revised by the new legislation, orthotics remain a qualifying category under the same medical necessity framework they have always followed.

Did the Rules for Orthotic Eligibility Change in 2026?

The short answer is no. The criteria that determine whether orthotics qualify for FSA or HSA reimbursement have remained consistent. StatPearls (NLM, 2025) confirms foot orthotics as a recognized medical treatment for multiple foot conditions, supporting their eligibility as a qualified medical expense under FSA/HSA guidelines. The IRS treats orthotics as a medical-care item rather than a general comfort purchase, meaning many insoles are eligible for reimbursement through an FSA, HSA, or HRA. What continues to matter is whether the product is being used to treat a diagnosed medical condition, not simply for everyday comfort. Fulton's insoles are designed to meet that standard, addressing conditions like plantar fasciitis, overpronation, and metatarsalgia.

What Determines Whether an Orthotic Qualifies

Understanding orthotics' eligibility comes down to a few core distinctions that apply in 2026 just as they did before.

Custom vs. Over-the-Counter Orthotics: Custom orthotics prescribed by a provider almost always qualify. Over-the-counter insoles may require a Letter of Medical Necessity (LMN) unless they are clearly marketed for medical treatment.

Medical Purpose vs. General Comfort: There is one thing that never changes: the insoles have to be for a medical reason, not general comfort. An insole bought purely because it feels nice doesn't qualify, no matter how much documentation you provide.

Product Labeling and Marketing: When a product is clearly built and marketed to treat something like plantar fasciitis relief, overpronation control, or diabetic cushioning, many plans will approve it at the register with no documentation required. Many retailers even flag these as HSA/FSA-eligible right on the product page.

The Role of an LMN: Many HSA and FSA administrators require an LMN to approve reimbursement or confirm eligibility, especially when the product could be seen as dual-purpose. An LMN connects the purchase directly to a medical condition and explains how the orthotics support treatment. Having one prepared in advance can make both direct purchases and reimbursement claims smoother.

Documentation and Receipts: Many plans require a Letter of Medical Necessity that specifies the condition, treatment plan, and duration. Comfort-only inserts usually do not qualify. Fulton encourages shoppers to verify plan rules before purchase, and to keep itemized receipts that clearly describe the product as supportive orthotic inserts rather than general comfort accessories.

How Fulton Insoles Work with Your FSA or HSA

Fulton insoles and orthotics are designed to meet HSA and FSA eligibility requirements. These medical-grade products provide arch support, improve alignment, and address conditions such as plantar fasciitis, overpronation, or foot fatigue. Each insole combines supportive materials, durable construction, and custom-molding designs to help improve foot health.

All three Fulton insole styles are FSA and HSA eligible as of 2026, The Classic Insole, The Athletic Insole, and The Universal Insole. The Athletic Insole provides shock absorption and arch support to reduce joint fatigue and protect alignment, available for direct purchase with your FSA or HSA card, no prescription required. Using pre-tax HSA or FSA funds can save you 20-40% compared to paying out of pocket, making Fulton an even smarter investment in your health.

Fulton also makes the process straightforward. Fulton makes using your HSA/FSA convenient and accessible, just place the insoles in your cart and check out as normal using your HSA/FSA card. Save an itemized receipt that names the product as supportive or orthotic inserts, shows the amount paid, and lists the purchaser. If your plan requires it, retain a Letter of Medical Necessity that includes diagnosis, treatment plan, duration, and provider signature.

Best Practices for Using HSA or FSA Funds on Orthotics

Even though the rules for orthotic eligibility haven't changed, navigating them takes some preparation. Here are practical steps to make your claim as smooth as possible.

Verify Your Plan's Rules Before You Buy: Plans interpret eligibility differently, retailers label products inconsistently, and documentation rules can change by employer. Don't assume that what qualifies under one employer's FSA will automatically qualify under another.

Get a Provider Recommendation When Possible: FSAs and HSAs generally reimburse expenses that diagnose, treat, or prevent a medical condition. Insoles often qualify when prescribed or recommended by a licensed provider for issues like plantar fasciitis, overpronation, or metatarsalgia.

Keep Complete Records: Keep the provider's order, diagnosis details, and itemized receipt with your records. Your receipt should name the product, not just show a card total.

Understand the Use-or-Lose Rule: Health FSAs have a "use-or-lose" rule, meaning that any funds left unused at the end of the year are forfeited to the employer. Two exceptions to this rule permitted by the IRS are rollover and grace period. For plan years beginning on or after January 1, 2026, the contribution limit for health FSAs is $3,400. For those plans that allow a rollover of unused funds, the maximum rollover amount will increase to $680 for 2026.

Watch Out for Misleading "Eligible" Labels: In 2026, the IRS explicitly warned consumers about misleading "FSA Eligible" labels, particularly from companies claiming that general wellness items can be converted into medical expenses through "letters of medical necessity" obtained via online questionnaires. Retailer "FSA eligible" badges are not a legal guarantee of reimbursement.

Plan Purchases Around FSA Deadlines: According to the Employee Benefit Research Institute (EBRI), 48% of FSA holders forfeit funds each year, losing an average of $441. Budgeting for orthotic insoles at the start of a plan year, rather than scrambling at year-end, helps you avoid losing money you've already set aside.

The Bigger Picture: Why More People Can Use HSA Funds in 2026

While orthotics' eligibility rules are unchanged, 2026 does bring more people into the HSA landscape. Starting with the 2026 plan year, Marketplace enrollees with Bronze or Catastrophic plans will be eligible to contribute to a health savings account. Starting with the 2026 plan year, the HDHP definition will expand to include all Marketplace Bronze and Catastrophic plans. The HSA-related provisions in the One Big Beautiful Bill Act took effect on January 1, 2026. This means a significant number of people who previously could not open an HSA now have access to tax-advantaged health spending, including the ability to use those funds on qualifying orthotic products like Fulton insoles.

How Fulton Simplifies FSA and HSA Spending on Orthotics

Fulton takes the guesswork out of benefit-eligible foot care. Using HSA or FSA funds for foot health products helps you invest in long-term comfort and support while maximizing your tax benefits. Supportive insoles, orthotics, and other eligible products can relieve pain, correct alignment issues, and reduce the risk of foot-related conditions. By using HSA or FSA dollars, you can make these medical-grade products more affordable, ensuring your feet stay healthy without impacting your regular budget.

Fulton's order confirmations and product descriptions help substantiate that the insert is a supportive device rather than a general comfort accessory. For customers who need additional documentation, Fulton's support team can assist with the paperwork required for reimbursement. The combination of clinically relevant design and straightforward purchasing makes Fulton one of the clearest choices for shoppers looking to spend FSA or HSA funds on foot support.

Key Takeaways and Next Steps

The HSA and FSA rules for orthotic products have not materially changed in 2026. Orthotics remain eligible under the same medical necessity framework they always have. What has changed is the broader benefit landscape: higher FSA contribution limits, expanded HSA eligibility for more plan types, and new eligible expense categories under the One Big Beautiful Bill Act. For anyone with pre-tax benefit funds to spend, now is a good time to act before year-end deadlines approach.

Fulton's full lineup of FSA and HSA eligible orthotic insoles, The Classic, The Athletic, and The Universal, can be purchased directly with your benefits card. Explore Fulton's HSA/FSA eligible insoles and put your pre-tax dollars toward foot health that lasts.

FAQs About HSA and FSA Rules for Orthotic Products

Are Orthotics Still FSA and HSA Eligible in 2026?

Orthotics are eligible for reimbursement with flexible spending accounts (FSA), health savings accounts (HSA), and health reimbursement accounts (HRA). This has not changed in 2026. The key requirement remains medical necessity, the orthotics must be used to treat, prevent, or manage a diagnosed condition, not simply for general comfort. Fulton insoles are designed to meet that standard, addressing conditions like plantar fasciitis, overpronation, and foot fatigue, and are purchasable directly with an FSA or HSA card.

What Is a Letter of Medical Necessity and Do I Need One for Insoles?

A Letter of Medical Necessity (LMN) is a document from a licensed healthcare provider justifying that a specific product, service, or treatment is essential to treat, prevent, or relieve pain from a medical condition. It is required for reimbursement for various HSA/FSA eligible products, including footwear and some gear, to verify that the expense is needed for medical care under IRS guidelines. For clearly labeled orthotic insoles like Fulton's, many plans will approve the purchase without an LMN, but having one on file strengthens your claim if your plan requires additional documentation.

What Are the FSA Contribution Limits for 2026?

The IRS officially announced, under Revenue Procedure 2025-32, the 2026 flexible spending account (FSA) and commuter limits. The health care FSA annual maximum plan contribution limit will increase from $3,300 to $3,400 for plan years beginning on or after January 1, 2026. The health care FSA rollover maximum limit will increase from $660 to $680 for plan years beginning on or after January 1, 2026. These increases give shoppers slightly more pre-tax budget to spend on qualifying products, including Fulton orthotic insoles.

Can I Use My HSA or FSA Card Directly to Buy Fulton Insoles?

You can use your Health Savings Account (HSA) or Flexible Spending Account (FSA) funds to purchase eligible health products, including orthotics like Fulton Insoles. Most HSA/FSA cards work just like a regular debit card at checkout. If you pay out of pocket, you can submit your itemized receipt for reimbursement. Fulton's product descriptions and order confirmations are formatted to help you document the purchase as a supportive orthotic device.

What Conditions Qualify for FSA or HSA Reimbursement of Insoles?

Orthopedic shoes and supportive foot products can qualify for HSA and FSA use when they are tied to a medical need, such as chronic foot pain, joint conditions, diabetes-related complications, or recovery from injury or surgery. Common conditions that support insole eligibility include plantar fasciitis, flat feet, overpronation, metatarsalgia, and heel spurs. Fulton insoles address several of these conditions directly, making them a practical choice for customers managing ongoing foot pain or alignment issues.