Is Red Light Therapy FSA/HSA Eligible?

One of the most common practical questions about red light therapy — particularly from US-based readers — is whether the cost of devices can be covered by a Flexible Spending Account (FSA) or Health Savings Account (HSA). The answer is more nuanced than the simple “yes” or “no” that most red light therapy companies put on their product pages.

This guide covers FSA/HSA eligibility in the United States, the equivalent situation in the UK (where the picture is very different), insurance coverage, and practical steps for maximising your chances of reimbursement.

What Are FSA and HSA Accounts?

For UK readers unfamiliar with the US healthcare system, a brief explanation:

Flexible Spending Account (FSA)

An employer-sponsored benefit in the US that allows employees to set aside pre-tax income for qualified medical expenses
Contributions are tax-free — effectively giving a 22–37% discount on eligible purchases depending on tax bracket
Annual contribution limit: $3,300 (2025) for healthcare FSAs
Use-it-or-lose-it — funds generally must be spent within the plan year (some employers offer a small grace period or carryover of up to $640)
Common at medium-to-large US employers

Health Savings Account (HSA)

Available to individuals enrolled in high-deductible health plans (HDHPs) in the US
Contributions are tax-free, growth is tax-free, and withdrawals for qualified medical expenses are tax-free (triple tax advantage)
Annual contribution limit: $4,300 (individual) or $8,550 (family) for 2025
Funds roll over indefinitely — unlike FSAs, HSA balances carry forward year to year
Can be invested and used as a retirement savings vehicle

Both accounts can be used to purchase qualifying medical devices and treatments. The key question is whether red light therapy devices qualify.

Does Red Light Therapy Qualify as a Medical Expense?

The IRS Standard

The Internal Revenue Service (IRS) defines a qualified medical expense as one that is “primarily for the prevention or alleviation of a physical or mental defect or illness.” Publication 502 provides detailed guidance, but the general principles are:

Medical devices that treat a diagnosed medical condition are eligible
General health and wellness products are not eligible (even if they happen to have health benefits)
FDA clearance as a medical device strengthens (but does not guarantee) eligibility
A letter of medical necessity (LMN) from a licensed healthcare provider significantly improves eligibility

Where Red Light Therapy Falls

Red light therapy devices exist in a grey area:

Arguments for eligibility:

Several red light therapy devices are FDA-cleared as Class II medical devices (for conditions including wrinkle reduction, acne, pain, and hair loss)
PBM/LLLT is recognised in CPT coding (more on this below), indicating it is an accepted medical procedure
When purchased to treat a specific diagnosed condition (chronic pain, wound healing, hair loss), the device serves a medical purpose

Arguments against eligibility:

Many red light therapy devices are marketed as general wellness or beauty products
The same device can be used for cosmetic purposes (anti-ageing) or medical purposes (pain management) — making the “primary purpose” determination ambiguous
Not all devices are FDA-cleared; those sold as “wellness” products without medical claims have a weaker case

The Practical Reality

Many FSA/HSA administrators will approve red light therapy devices, particularly if:

The device is FDA-cleared as a medical device
You have a letter of medical necessity from your doctor specifying the condition being treated
The device is purchased from a retailer that specifically lists FSA/HSA eligibility
You pay using your FSA/HSA debit card at checkout

Some major red light therapy brands (Joovv, MitoRED, PlatinumLED) explicitly market their products as FSA/HSA eligible and have processes in place to facilitate claims. However, individual plan administrators can interpret IRS guidelines differently, and approval is not guaranteed.

How to Maximise Your Chances of FSA/HSA Approval

Step 1: Get a Letter of Medical Necessity

This is the single most important step. Ask your doctor, physiotherapist, or other licensed healthcare provider to write a letter stating:

Your diagnosed medical condition (e.g., chronic lower back pain, osteoarthritis, androgenetic alopecia, post-surgical wound healing)
That photobiomodulation/red light therapy is a medically appropriate treatment for your condition
The specific device recommended (or at minimum, the type of device — e.g., “FDA-cleared LED photobiomodulation device”)
The treatment protocol (frequency, duration)

Most providers familiar with PBM will write this letter. Some may not be aware of the evidence — in that case, bringing published clinical data relevant to your condition can help.

Step 2: Choose an FDA-Cleared Device

While an FDA-cleared device is not strictly required for FSA/HSA eligibility, it significantly strengthens your case. Look for devices that hold:

FDA 510(k) clearance as a Class II medical device
Clearance for a specific medical indication (pain relief, acne treatment, hair restoration)

Devices marketed purely as “wellness” or “beauty” products without FDA clearance have a much weaker claim to medical expense status.

Step 3: Purchase Through an FSA/HSA-Friendly Retailer

Several options:

Brand websites — many red light therapy companies accept FSA/HSA cards directly
FSA Store / HSA Store — dedicated online retailers for FSA/HSA-eligible products. If a product is listed here, it has been pre-vetted for eligibility
Amazon — some Amazon listings are tagged as FSA/HSA eligible, though this varies by seller and product

Step 4: Keep All Documentation

Retain:

The letter of medical necessity
The purchase receipt
The device’s FDA clearance documentation (usually available on the manufacturer’s website)
Any correspondence with your FSA/HSA administrator

If your claim is initially denied, having this documentation allows you to appeal.

CPT Codes for Photobiomodulation

For those seeking insurance coverage or professional treatment reimbursement, PBM has recognised CPT (Current Procedural Terminology) codes:

CPT 97811 — Photobiomodulation, mechanistic/cell function alteration; first 15 minutes. This is the primary billing code for PBM/LLLT administered by a healthcare provider
CPT 97812 — Each additional 15 minutes of photobiomodulation

These codes were introduced in 2023, reflecting growing recognition of PBM as a legitimate therapeutic modality. However, having a CPT code does not guarantee insurance coverage — it simply means the procedure can be billed using standard medical coding.

Insurance Coverage in the US

Coverage of PBM by private health insurance varies widely:

Workers’ compensation — PBM is covered in some states for workplace injuries, particularly chronic pain and wound healing
Veterans Affairs (VA) — the VA has used PBM in some facilities, particularly for traumatic brain injury and wound care
Private insurance — most major insurers do not routinely cover PBM. Coverage decisions are made on a case-by-case basis, often requiring prior authorisation and documented failure of conventional treatments
Medicare/Medicaid — PBM is not currently covered under Medicare or Medicaid for most indications

The introduction of CPT codes is an important step toward broader insurance coverage, but routine reimbursement remains the exception rather than the rule.

The UK Situation

For UK-based readers, the equivalent question is: can you get red light therapy on the NHS or through private health insurance?

NHS

The NHS does not provide red light therapy (PBM) as a standard treatment for any condition, with one notable exception:

Photodynamic therapy (PDT) — which uses red light in combination with a photosensitising agent — is a NICE-approved treatment for certain skin conditions (actinic keratosis, superficial basal cell carcinoma). This is a different treatment from PBM, though it does involve red light. See our actinic keratosis page for details

The NHS may provide LLLT in some specialist settings — certain physiotherapy departments and wound care clinics use low-level laser therapy — but this is not widely available and is typically at the discretion of individual trusts and clinicians.

Private Health Insurance (UK)

UK private health insurance (Bupa, AXA Health, Aviva, Vitality) generally does not cover PBM devices or treatments. Some policies cover physiotherapy that may include LLLT as part of a treatment plan, but standalone PBM device purchases are not typically reimbursable.

Tax Relief (UK)

Unlike the US FSA/HSA system, the UK does not have a general mechanism for tax-free purchase of medical devices. There is no direct UK equivalent. The VAT situation is also straightforward — consumer LED devices are subject to standard 20% VAT regardless of their medical purpose.

If you are self-employed and purchase a red light therapy device for the treatment of a condition that affects your ability to work, there may be a case for claiming it as a business expense, but this would require professional tax advice and is not straightforward.

Which Devices Are Most Likely to Qualify?

Strong FSA/HSA Case

FDA-cleared devices with medical indications (pain, acne, hair loss)
Devices from brands that explicitly support FSA/HSA purchasing (Joovv, MitoRED, PlatinumLED)
Devices purchased with a letter of medical necessity for a diagnosed condition

Weaker FSA/HSA Case

Devices marketed purely for cosmetic/wellness purposes (anti-ageing, “biohacking”)
Devices without FDA clearance
LED face masks marketed as beauty products (even if they use therapeutic wavelengths)
Purchases made without a letter of medical necessity

Not FSA/HSA Eligible

Red light therapy sessions at tanning salons or wellness spas (unless prescribed)
Sauna sessions that include red light (general wellness, not medical)
Accessories (stands, goggles, timers) — though these may qualify as part of a medically necessary device setup

Frequently Asked Questions

Can I use my FSA to buy a red light therapy mask?

Potentially, if the mask is FDA-cleared and you have a letter of medical necessity for a condition it treats (e.g., acne). A mask marketed purely as a beauty product is less likely to be approved.

What if my FSA/HSA claim is denied?

You can appeal the denial. Submit your letter of medical necessity, the device’s FDA clearance documentation, and any relevant clinical literature. Many initial denials are overturned on appeal.

Can I buy a device at the end of the year to use up my FSA balance?

Yes — this is actually one of the most common FSA purchases for red light therapy devices. The “use-it-or-lose-it” deadline motivates many FSA holders to purchase devices they have been considering. Just ensure you have the supporting documentation in place.

Is there a spending limit?

FSA/HSA funds can be used for any amount up to your account balance. There is no per-item limit for qualifying medical expenses.

Do I need a prescription?

Not in the strict sense. FSA/HSA eligibility requires that the expense be for a medical purpose, which is typically established through a letter of medical necessity rather than a formal prescription. However, some FSA administrators may ask for a prescription — check with your plan.

The Bottom Line

In the US, red light therapy devices can be FSA/HSA eligible, particularly when:

The device is FDA-cleared
You have a letter of medical necessity from a healthcare provider
The purchase is for a diagnosed medical condition rather than general wellness

The process is not automatic, and approval varies by FSA/HSA administrator. Taking the steps outlined above — especially obtaining a letter of medical necessity — significantly improves your chances.

In the UK, there is no direct equivalent. Red light therapy devices are an out-of-pocket expense, and neither NHS nor private insurance coverage is available for consumer PBM devices.

This article provides general guidance on FSA/HSA eligibility and should not be considered tax or financial advice. FSA/HSA rules change annually, and individual plan terms vary. Consult your FSA/HSA plan administrator and a tax professional for advice specific to your situation.