Why
Publication 502 lists teeth whitening among the expenses you can't include: "You can't include in medical expenses amounts paid to whiten teeth." It points to the cosmetic surgery rule, which rules out any procedure directed at improving appearance that doesn't meaningfully promote the proper function of the body or prevent or treat illness or disease.
Revenue Ruling 2003-57 is where the IRS worked through it. A taxpayer's teeth were discolored by age and a dentist whitened them. The IRS said the procedure didn't treat a disease or promote the proper function of the body, so it wasn't medical care.
The wording is about the purpose, not who does the whitening. Strips, trays, gels and in-office bleaching are all amounts paid to whiten teeth.
The 2020 change that lets an HSA pay for over-the-counter medicine doesn't help. It removed the prescription requirement for medicines and drugs. It didn't turn a cosmetic treatment into medical care.
What to keep
- Nothing for the whitening itself, since it can't be reimbursed.
- If a dental bill mixes whitening with eligible work, an itemized statement showing each charge, so you reimburse only the eligible lines.
Watch out for
- The ruling's example was discoloration from age, and it noted the discoloration wasn't a deformity or caused by a disfiguring disease or treatment. Publication 502's whitening entry states no exception of its own, but it points to the cosmetic surgery rule, which allows a procedure needed to improve a deformity from a congenital abnormality, an accident or a disfiguring disease. The IRS hasn't said whether staining from an illness or a medication fits, so that's an untested argument.
- Whitening toothpaste doesn't count either. Ordinary toothpaste is the IRS's own example of a personal expense.
- If whitening was paid from your HSA, that amount counts as income, with an additional 20% tax unless you're 65 or older or disabled.