Short answer: Yes. Healthcare FSA funds may be used for eligible expenses for your spouse or dependents even if they are not enrolled in your health plan, as long as they meet IRS eligibility rules.
Healthcare Flexible Spending Accounts (FSAs) may reimburse eligible medical expenses incurred by an employee’s spouse or dependents, even if those individuals are not covered under the employee’s group health insurance plan. FSA eligibility is based on federal tax rules, not on who is enrolled in the health plan.
Under Internal Revenue Service rules, eligible individuals generally include a legally married spouse and dependents who meet the IRS definition, such as dependent children under age 26 and certain other qualifying dependents who rely on the employee for support. The individual does not need to be listed on the employee’s medical plan for their expenses to be eligible for FSA reimbursement.
This allows employees to use FSA funds for out-of-pocket expenses, such as copays or prescriptions, even when a spouse or dependent has coverage through a different health plan.
However, there is an important interaction with Health Savings Accounts (HSAs). If a spouse is covered by or has access to a general-purpose healthcare FSA that can reimburse their medical expenses, that coverage may make the spouse ineligible to contribute to an HSA. This rule applies even if the spouse does not actually use the FSA funds.
Employees should confirm both expense eligibility and any potential impact on HSA eligibility before using FSA funds for family members.
Sources
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Internal Revenue Service, Publication 969, Health Savings Accounts and Other Tax-Favored Health Plans
https://www.irs.gov/publications/p969 -
Internal Revenue Code, Sections 125 and 223
Content history
Originally published: March 25, 2025
Last reviewed: January 25, 2026