OTC Reimbursement Charts

The following is a listing of drugs by type (and name brand example). We have separated these OTC drugs into the following categories:

Primarily Medical Care: This chart identifies drugs that typically fall into the category of medical care. The participant does not need a diagnosis of a specific condition and recommendation to take the OTC from a health care provider in order to receive reimbursement.
Dual Purpose: This chart identifies drugs that typically serve a dual purpose-general health of the individual and/or to treat a specific medical condition. Participants must have a diagnosis of a specific condition and a recommendation to take the OTC by a health care provider in order to receive reimbursement.

General Health/Cosmetic: This chart identifies drugs that are typically for the general health of the individual and/or cosmetic drugs and toiletries. These are typically not reimbursable under any circumstance.
The “Your Guess is as Good as Mine” List: This chart identifies drugs over which reasonable minds can differ. Many of the drugs in this list potentially have a medical purpose but such purpose may be de minimis. Consequently; the OTC drug may not be reimbursable at all or it could fall in the “dual purpose” list. Likewise, some OTC drugs’ primary purpose (and intended purpose) is for medical care; however, common usage has expanded into non-medical purposes. Does this make an otherwise “primarily medical” OTC drug a “dual purpose” OTC drug? Additional IRS guidance would be welcome to help determine in which category these OTC drugs belong.
OTC Medical Devices and Products. This chart identifies common OTC medical devices and products other than drugs and indicates whether they would fall in the primarily medical list, dual-purpose list or general well-being list.

These lists are not intended to be exhaustive. Other drugs not listed may fall into one the categories described below.

1. OTC Drugs Used Primarily for Medical Care

These typically reimbursable with only a proper receipt. No recommendation from a health care provider is needed.
Type of Drug	Examples[1]
Allergy Prevention & Treatment	Benadryl, Sudafed, Actifed, Chlora Trimaton, and Nasalcrom
Antacids and Acid Reducers	Gas-X, Maalox, Mylanta, Tums, AXID AR, Pepcid AC, Prilosec OTC, Tagamet HB, and Zantac 75AXID AR, Pepcid AC, Prilosec OTC, Tagamet HB, and Zantac 75;
Anticandial	Femstat 3, Gyne-Lotrimin, Mycelrx-7, Monistat 3, 7, and Vagistat-1
Antihistamines	Actidil Syrup and Capsules, Actifed, Allerest, Benadryl, Claritin, Chlor-Trimeton, Contac, Dimetane, Drixoral, Nyquil, Sudafed, Tavist-1, and Triaminic
Antidiarraheal and Laxatives	Ex-Lax, Pepto-Bismol, Immodium A.D. and Kaopectate
Anti-fungal	Lamisil AT, Lotramin AF, and Micatin,
Anti-itch Lotions and Creams (e.g., for athletes foot, jock itch, bug bites, poison ivy)	Bactine, Caldecort, Cortaid, Hydrocortisone, and Lanacort, Calamine Lotion, Benadryl Cream, Caladryl, Cortaid, Lamisil AT, Lotramin AF, and Micatin
Cold Sore/Fever Blister	Abreva Cream
Cough Suppressants	Robitussin, Vicks 44, Chloraseptic
Decongestant/ Nasal Decongestant and Cold Remedies	Advil Cold and Sinus, Afrin, Afrinol, Aleve Cold and Synus, Children’s Advil Cold, Duration, Dristan Long Lasting, Neo-Synephrine- 12 Hour, Orrivin, Sudafed, Tavist-D, Tylenol Cold and Flue, Thera-flu, Alka Seltzer Cold and Flu, Nyquil, Actidil Syrup and Capsules, Actifed, Allerest, Benadryl, Claritin, Chlor-Trimeton, Contac, Dimetane, Drixoral, Sudafed, Tavist-1, and Triaminic
Diaper Rash Ointments	Balmax and Desitin
Eye Drops for Allergy/Cold Relief	Ocu Hist
Hemorrhoid Treatments	Preparation H, Hemorid, and Tronolane
Internal Analgesic/antipyretic	Advil, Aleve, Children’s Motrin, Nuprin, Excedrin, Tylenol, Bayer,
Menstrual Cycle Medications	Midol, Pamprin, and Premysyn PMS
Migraine	Advil Migraine Liqui-gels, Excedrin Migraine, Motrin Migraine Pain,
Motion Sickness Medication	Dramamine and Marizine
Nicotine Gum or Patches and Smoking Cessation Aids	Nicorette, Nicotrol, and Nicodin
Pediculicide (head lice)	Nix
Poison Ivy Protection	Ivy Block
Smoking Cessation	Commit, Nicoderm CQ, Nicorette, Nicotrol,
Toothache and teething pain relievers	Orajel

2. Dual Purpose OTC Drugs

Permissible with Health Care Provider’s Note Listing Diagnosis of a Medical Condition and Recommendation of OTC Drug

Anti-baldness/hair loss/ hair replacement/ such as Rogaine, but only if to replace hair loss due to a medical condition and not for balding due to age

Medicated shampoo to treat a specific medical condition like psoriasis and only the amount in excess of the cost of normal shampoo. Many plan sponsors may exclude completely to avoid having to determine whether the cost of a medicated shampoo exceeds the cost of regular shampoo.

Dental fluoride treatments, special mouthwashes, or treatments for gingivitis

Fiber supplements such as Benefiber and Metamucil

Glucosamine/chondrotin for arthritis or other medical condition (not reimbursable if taken for overall joint health)

Herbal supplements used to treat a specific disease such as St. John’s Wort for depression

Nose strips for proper breathing or other medical conditions

Retin-A and other acne medicines (not reimbursable if used for cosmetic purposes such as wrinkle reduction)

Snoring cessation aids and medications such as Breathe Right Spray, Snorezz

Weight loss/dietary supplements must be for a specific medical condition such as obesity

3. OTC Drugs Primarily Not Reimbursable

OTC Drugs or other products that are not for Medical Care

Deodorants

Face creams, moisturizers, eye creams, and wrinkle reducers

Hair removal treatments and waxes

Mouth washes, antiseptics and oral anesthetics

Teeth Whitening kits, and powders

Toothpaste

Vitamins taken to improve overall-health

4. The “Your Guess is as Good as Mine” List

This list represents OTC drugs that could arguably fall into categories 1-3 but we are not sure which category.
Type of Drug	Comments
Creams for joint and muscle pain such as BenGay and Flexall	Typical and intended use of this product is to alleviate muscle and joint pain/soreness. Some use the product to prevent soreness and stiffness. Is this a dual purpose OTC or primarily for medical care?
Wart removal medications	Is this for cosmetic purposes or is it being used to alleviate a medical condition? Even if the cause of warts is viral, is removal just a cosmetic procedure?
Pedialyte for a child’s dehydration	At one time, this product was available only by prescription. Currently, this OTC product is used as a drinking product for children much in the same way as Gatorade. Is this a food supplement, a dual purpose OTC or primarily for medical care?
Products used solely to treat acne (e.g., Clerasil)	Acne is a medical condition; however, some argue that acne medications are primarily for cosmetic purposes unless it is for chronic acne. Others argue that acne is a medical condition whether chronic or isolated. Is this a dual purpose OTC or primarily for medical care?
Sunscreen	Arguably, sunscreen prevents cancer and “prevention” is one of the core elements of the definition of medical care. However, unless the individual had or has skin cancer, there is likely no imminent probability of disease.
Chapstick	Some would argue that this is cosmetic. However, medicated chapstick is used to treat chapped and broken lips, which is arguably a medical condition. Is this solely for cosmetic purposes or does it fall into the dual purpose drugs?
Cough drops	The intended use is to treat a cough. However, common usage of cough drops have arguably made them more akin to candy. This could fall into primarily medical, dual purpose or not reimbursable under any circumstance.
No Doz (and other sleep prevention drugs)	Is the inability to stay awake a medical condition?
Sleep-Aid	Is the inability to fall asleep a medical condition or are sleep aids only reimbursable if they are recommended by a health care provider to treat a specific medical condition (e.g. sleep apnea)?
Visine	What does Visine really do? Does Visine treat a medical condition or does it simply change the color of your eyes. If the former, then it may be a primarily medical or dual purpose OTC. If only the latter, then Visine would fall into the category of generally well-being or cosmetic and would not be reimbursable under any circumstance.

5. OTC Medical Products and Devices

The following is a list of common OTC products and whether they are for medical care or not.
Product or Device	Medical Care, Dual Purpose or General Well Being	Comments
1. Crutches	Medical Care	Crutches are primarily used when there is a leg or foot injury.
2. Bandages such as Band-Aids, gauze, ace bandages	Likely Medical Care but additional guidance would be helpful	Band-aids and gauze are arguably used to prevent infection where there is an imminent probability of infection. Ace bandages and other similar products are typically used to support bone and/or joint injuries.
3. Condoms and other contraceptive devices	Likely Medical Care but additional guidance would be helpful	These prevent disease and pregnancy where there is imminent probability of either. IRS has informally indicated that these should be reimbursable.
4. Incontinence Supplies	Unclear	Could possibly be for medical care if recommended for someone with a diagnosed incontinence condition; however, there is some question as to whether incontinence supplies actually alleviate, treat or prevent a condition.
5. Feminine Hygiene Products such as tampons and maxi pads	Unclear	May be that analysis similar to that for incontinence applies with respect to feminine hygiene products.

[1] This list is not an exhaustive list and is intended to give examples of some of the most common brand names of OTC drugs.