Are Microcurrent Devices FSA or HSA Eligible

Medically reviewed by

4 independent reviewers

Andrew Conrad Barile, PT, DPT

Andrew Conrad Barile, PT, DPT

Doctor of Physical Therapy (DPT) | Licensed Physical Therapist (PT) | CEO and Founder, Xtreem Pulse LLC

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Dr. Andrew Conrad Barile is a Doctor of Physical Therapy and the CEO and Founder of Xtreem Pulse LLC, the engineering company behind PureLift. He earned his Doctorate in Physical Therapy from Daemen College and is a licensed physical therapist.

He brings over two decades of clinical and entrepreneurial experience across physical therapy, craniosacral therapy and medical device innovation, built on a working knowledge of human anatomy and muscle physiology.

For PureLift LAB he reviews how current is delivered across all ten levels, from sub-sensory nanocurrent and skin-level microcurrent to motor-level EMS, and how the Infuse pass fits into the same ten-minute routine.

Bertica M. Rubio, M.D.

Bertica M. Rubio, M.D.

Board-Certified Physician, Dartmouth Medical School | Medical Director, Antiaging Regenerative Medicine Clinic

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Dr. Bertica M. Rubio is a board-certified physician and Medical Director of the Antiaging Regenerative Medicine Clinic in Redlands, California. She earned her Doctor of Medicine from Dartmouth Medical School and completed her pediatrics residency at UC Irvine Medical Center.

With decades of clinical experience, she specialises in age management medicine, regenerative medicine, wound healing and growth factor therapies, and her practice integrates evidence-based medical science with advanced aesthetic treatment.

For PureLift LAB she reviews articles for medical accuracy across the whole dial, from the gentle nanocurrent and microcurrent settings through to muscle-level EMS and the Infuse pass.

Daniel Grinberg, MD, FACS

Daniel Grinberg, MD, FACS

Board-Certified Otolaryngologist | Head and Neck Surgeon | Fellow, American College of Surgeons | Mount Sinai

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Daniel Grinberg, MD, FACS is a board-certified otolaryngologist and head and neck surgeon at ENT and Allergy Associates in West Nyack, New York. He earned his medical degree from Columbia University College of Physicians and Surgeons.

He completed his otolaryngology residency at New York University Medical Center, serves as Assistant Clinical Professor at Mount Sinai School of Medicine, and is a Fellow of both the American College of Surgeons and the American Academy of Otolaryngology.

For PureLift LAB he brings a wider clinical lens, connecting at-home facial stimulation from microcurrent to EMS to the anatomy underneath, with the same rigour we apply to every device specification.

Prof. Dr. med. Ivo Buschmann

Prof. Dr. med. Ivo Buschmann

Chair of Angiology, Medizinische Hochschule Brandenburg | Clinic Director, University Clinic for Angiology

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Prof. Dr. med. Ivo Buschmann is Chair of Angiology at the Medizinische Hochschule Brandenburg Theodor Fontane and Clinic Director of the University Clinic for Angiology at the Brandenburg University Hospital.

He trained at the University of Hamburg, was a Max Planck Society Fellow at the Max Planck Institute for Heart and Lung Research, and held senior consultant posts at the Charite Universitatsmedizin Berlin before his appointment as Chair in 2016.

One of Europe's leading authorities on arteriogenesis, with over 150 peer-reviewed publications and US and EU patents, he reviews for PureLift LAB how the evidence on electrical stimulation is read and where its limits lie.

What's This About:

Facial toning devices are cleared for cosmetic use, and cosmetic expenses generally fall outside FSA and HSA eligibility, so the answer for almost everyone is no.

This article sets out what to check before you start, such as:

- why the clearance wording decides this

- what the rules say about cosmetic expenses

- the narrow exception involving a prescription

- why a Letter of Medical Necessity is not a loophole

- who to ask instead of a brand

and many more!

We are not tax advisers, and your plan administrator is the only party who can answer this for your plan.

Key Points:

Our devices are cleared under K190269, K230506, K221443 and K243587 for cosmetic facial stimulation, and that wording is what an administrator looks at.

US tax rules generally exclude cosmetic procedures and products from eligible medical expenses unless they treat a deformity from congenital abnormality, injury or disease.

The narrow exception involves a device prescribed by a clinician to treat a diagnosed medical condition, which is not what a facial toning device is.

A Letter of Medical Necessity does not convert a cosmetic purchase into an eligible one; it documents a medical purpose that has to exist first.

Your plan administrator and your tax adviser are the people to ask, and a brand page is not a substitute for either.

Why the clearance wording decides it

Every device in this category carries an FDA clearance with an indication for use, and ours read, in substance, facial stimulation for over-the-counter cosmetic use.

That is the sentence a plan administrator will land on, because eligibility turns on medical purpose rather than on the technology inside the housing.

The same technology can be eligible in one form and not in another: a TENS unit prescribed for pain and a facial toning device sit on opposite sides of that line despite both delivering current through skin.

We set out how to read a clearance yourself in our article on 510(k) filings.

What the rules say

US guidance on eligible medical expenses excludes cosmetic surgery and cosmetic procedures, defined as those directed at improving appearance rather than at meaningfully treating or preventing illness or correcting a deformity.

A device marketed and cleared for appearance falls on the excluded side of that definition by design.

There is an exception for correcting a deformity arising from a congenital abnormality, a personal injury from an accident or trauma, or a disfiguring disease, and that exception is narrow and clinician-driven.

We are describing the general shape of the rules here rather than advising you, because we are a device company and not tax advisers.

The prescription exception

Electrical stimulation devices prescribed by a clinician for a diagnosed condition, such as a TENS unit for chronic pain or an NMES device for muscle rehabilitation, are a different category with a different eligibility picture.

If a clinician has prescribed stimulation as part of treating a condition, the device they prescribed is the one to ask about, and it will usually not be a facial toning device.

Facial rehabilitation after nerve injury is managed with clinical equipment under supervision, not with a consumer device bought from a beauty site.

So the exception exists and it almost never covers a purchase like ours.

Why an LMN is not a loophole

A Letter of Medical Necessity documents that a clinician considers an item necessary to treat a specific condition, and plans do accept them for items that are otherwise ambiguous.

What it cannot do is create a medical purpose where none exists, and asking a clinician to write one for a cosmetic purchase puts them in a position they should not be in.

Administrators also audit, and a reimbursement that is reversed later leaves you with a tax problem on top of the original cost.

We would rather you paid for a device out of pocket than used a letter in a way that creates trouble for you.

Who to actually ask

Your plan administrator, because FSA and HSA plans vary in how they interpret and document eligibility, and they are the party who approves or denies the claim.

Your tax adviser, if the amount is significant enough to matter.

Most administrators run an eligible-expense search tool, and searching for the specific device category there takes a minute and settles it.

Any brand telling you its facial device is FSA eligible without pointing you at your administrator is making a claim it is not in a position to make.

What we will say about our own devices

Our devices run from $499 to $999, they are cleared for cosmetic facial stimulation, and we have never positioned them as medical equipment.

We do not make an FSA or HSA eligibility claim, and if you see one attached to our products anywhere, it did not come from us.

If the price is the obstacle, the honest conversation is about which device you need rather than about how to pay with pre-tax money, and we set out the arithmetic in our cost benefit article.

The full picture of what each of our devices carries is in our category overview.

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