HSA and FSA eligibility for CPAP and oxygen (2026)

4 min read By HHZ Editorial Next review

Generally yes. IRS Publication 502 lists 'oxygen and oxygen equipment to relieve breathing problems caused by a medical condition' as a medical expense, and defines medical expenses to include equipment, supplies and diagnostic devices used to diagnose or treat disease. That covers a prescribed oxygen concentrator. A CPAP for diagnosed sleep apnea falls under the same general definition, though Pub 502 doesn't name CPAP. HSA distributions for qualified medical expenses are tax-free; non-qualified ones are taxed and may face an extra 20% tax. Your plan's rules decide FSA claims.

CPAP machines, masks, oxygen concentrators and portable concentrators are expensive and often bought partly out of pocket. They are exactly the kind of purchase a health savings account (HSA) or health flexible spending arrangement (FSA) exists for. This guide sets out what the IRS publications actually say. It is general information, not tax advice. Your plan administrator and tax adviser have the final word on your situation.

What the IRS counts as a medical expense

IRS Publication 502 (2025 edition, for 2025 returns) defines medical expenses as:

the costs of diagnosis, cure, mitigation, treatment, or prevention of disease, and for the purpose of affecting any part or function of the body … They include the costs of equipment, supplies, and diagnostic devices needed for these purposes.

It adds that medical care expenses “must be primarily to alleviate or prevent a physical or mental disability or illness” and excludes things “merely beneficial to general health”.

Oxygen and oxygen equipment: named directly

Pub 502 has a specific entry:

Oxygen. You can include in medical expenses amounts you pay for oxygen and oxygen equipment to relieve breathing problems caused by a medical condition.

That covers a prescribed home or portable oxygen concentrator, oxygen cylinders and refills, and oxygen equipment generally.

CPAP: covered by the general definition

Pub 502 doesn’t list CPAP machines by name, and it says it covers “many common medical expenses but not every possible medical expense”. For anything not listed, it points you back to the general definition. A CPAP prescribed to treat diagnosed obstructive sleep apnea is equipment used to treat a disease. Masks, cushions, tubing and filters are the supplies it needs. A home sleep test is a diagnostic device or service used to diagnose disease.

Many retailers label CPAP products HSA/FSA eligible. cpap.com, for example, labels its home sleep test that way. A retailer’s label isn’t an IRS ruling, though. What matters is that the purchase meets the definition and that you keep the records.

Paying from an HSA

From IRS Publication 969 (2025 edition):

  • What’s tax-free. Distributions used for “qualified medical expenses”, defined as medical care under Code section 213(d) for you, your spouse and your dependents, aren’t taxed.
  • What’s taxed. Distributions for anything else are included in income and “may be subject to an additional 20% tax”. The extra 20% doesn’t apply after you become disabled, reach age 65, or die.
  • Records. You must keep records showing the distributions were exclusively for qualified medical expenses, weren’t already paid or reimbursed from another source, and weren’t taken as an itemized deduction. Don’t send them with your return.
  • Timing. You don’t have to take distributions in the year you pay. Balances carry over from year to year.

2026 contribution limits

Pub 969 gives these limits for 2026:

HDHP coverage2026 HSA limit2026 minimum deductible2026 maximum out-of-pocket
Self-only$4,400$1,700$8,500
Family$8,750$3,400$17,000

The Medicare catch

Pub 969: “Beginning with the first month you are enrolled in Medicare, your contribution limit is zero.” That includes retroactive Medicare coverage, so contributions made during a backdated enrollment period count as excess. You can still spend an existing balance on qualified expenses, including oxygen equipment and CPAP supplies.

Paying from an FSA

For health FSAs, Pub 969 says qualified medical expenses are “those specified in the plan that would generally qualify for the medical and dental expenses deduction”. So the Pub 502 definition is the starting point, but your employer’s plan document decides what it reimburses. Plans can also use a grace period or a carryover, but not both, so check your plan’s deadline before buying a big-ticket item late in the year.

Can you deduct it instead?

If you itemize, Pub 502 lets you deduct only the part of total medical and dental expenses above 7.5% of your adjusted gross income. You can’t deduct anything paid with a tax-free HSA distribution. Pub 502 also says you can’t deduct amounts fully reimbursed by an FSA you funded with pre-tax pay.

What to keep

  1. The prescription for the CPAP or oxygen equipment.
  2. The sleep study or oxygen test result, if you have it.
  3. The itemized receipt, showing what was bought, when and for whom.
  4. For an FSA, whatever substantiation your administrator asks for.

Typical HSA/FSA purchases, with prices

PurchaseExample priceHHZ guide
Home sleep test$99 at cpap.comCPAP without insurance
Auto CPAP$873–$1,004 at cpap.comBest auto CPAP
CPAP mask$105–$167 at ResMed’s shopCPAP masks
5 LPM home concentratorfrom about $738Home oxygen concentrators
Portable oxygen concentratorabout $2,400–$2,800Portable oxygen concentrators

Prices were checked on 13 October 2026. See each guide for its sources.

Verdict

Oxygen equipment is named directly in IRS Pub 502. A prescribed CPAP, its supplies and the sleep test that diagnosed you fit Pub 502’s general definition of medical expenses. Pay from your HSA or FSA, keep the prescription and itemized receipt, and check your FSA plan’s rules and deadlines. If you’re about to join Medicare, stop HSA contributions in time, but keep the balance for future supplies.

Frequently asked questions

Is an oxygen concentrator HSA eligible?
IRS Publication 502 says you can include 'amounts you pay for oxygen and oxygen equipment to relieve breathing problems caused by a medical condition'. An HSA can pay tax-free for medical care as defined in Code section 213(d), the same definition Pub 502 explains. Keep the prescription and receipt.
Is a CPAP machine HSA or FSA eligible?
Pub 502 does not list CPAP by name. It defines medical expenses as costs for the diagnosis, cure, mitigation, treatment or prevention of disease, including the costs of equipment, supplies and diagnostic devices needed for those purposes. A prescribed CPAP for diagnosed obstructive sleep apnea, with its masks and supplies, fits that definition. Your HSA trustee or FSA administrator may ask for documentation.
What is the 2026 HSA contribution limit?
IRS Publication 969 gives $4,400 for self-only HDHP coverage and $8,750 for family coverage for 2026.
Can I use my HSA after I join Medicare?
You can still spend your existing HSA balance on qualified medical expenses. Starting with the first month you're enrolled in Medicare, your HSA contribution limit is zero, per IRS Publication 969, including during any period of retroactive Medicare coverage.