Trulicity HSA/FSA Eligibility and Submission: A Complete 2026 Guide

Is Trulicity an HSA/FSA-Eligible Expense?

Trulicity is an HSA- and FSA-eligible expense. The IRS defines qualified medical expenses in Publication 502 as amounts paid for the diagnosis, cure, mitigation, treatment, or prevention of disease. Because Trulicity is an FDA-approved prescription drug, it clears that standard automatically. Any prescription drug dispensed by a licensed pharmacist with a valid prescription qualifies.

The IRS Rule That Covers Prescription Drugs

IRS Publication 502 states: "You can include in medical expenses amounts you pay for prescribed medicines or drugs. A prescribed drug is one that requires a prescription by a doctor for its use by an individual." Trulicity requires a prescription in all 50 states, so no additional documentation is needed to establish eligibility itself. The IRS has published this rule consistently since the Affordable Care Act tightened over-the-counter drug standards in 2011, though the CARES Act of 2020 later restored OTC eligibility for certain items. Prescription drugs like dulaglutide were never affected by those changes.

The FDA approved dulaglutide (NDA 125469) in September 2014 for glycemic control in adults with type 2 diabetes, and in 2020 the label was updated to include cardiovascular risk reduction based on REWIND trial data. Both indications are medical, not cosmetic, which satisfies the IRS treatment-or-prevention standard without any gray area.

IRS Publication 502, Medical and Dental Expenses FDA NDA approval record for dulaglutide

HSA vs. FSA: Key Differences That Affect Trulicity Purchases

Both account types cover the same IRS-qualified expenses, but they work differently.

HSA (Health Savings Account): Funds roll over indefinitely. You must be enrolled in a qualifying high-deductible health plan (HDHP) to contribute. The 2026 contribution limits are $4,300 for self-only coverage and $8,550 for family coverage (IRS Rev. Proc. 2025-19). Unused balances grow tax-free and can be invested.

FSA (Flexible Spending Account): Offered through employers. The 2026 contribution limit is $3,300. Funds generally expire at plan-year end, though many plans include a 2.5-month grace period or allow up to $640 in rollover. If you have a large Trulicity co-pay, front-loading FSA contributions early in the plan year can fully fund several months of medication.

One practical note: if your employer offers a Limited-Purpose FSA alongside an HSA, that FSA is restricted to dental and vision expenses. Trulicity would not be reimbursable from a Limited-Purpose FSA.

IRS Rev. Proc. 2025-19 to 2026 HSA contribution limits

How to Submit a Trulicity Claim Step by Step

Submitting an HSA or FSA claim for Trulicity is straightforward. Most pharmacies generate a detailed receipt automatically, and most plan administrators accept digital uploads.

Step 1: Obtain the Correct Receipt

Ask your pharmacy for an itemized receipt that shows all of the following:

• Patient name
• Drug name (dulaglutide or Trulicity)
• Prescription number
• Date dispensed
• Amount you paid (your actual out-of-pocket, not the insurance-billed amount)
• Pharmacy name and address

Mail-order pharmacies (CVS Caremark, Express Scripts, OptumRx) typically email a PDF receipt that includes all required fields. Retail pharmacies sometimes need a separate "itemized receipt" request at the counter because the standard register tape may omit the Rx number.

Step 2: Pay with Your HSA/FSA Debit Card or Submit for Reimbursement

Debit card method: Swipe your HSA or FSA debit card at the pharmacy counter. The transaction codes at most major pharmacies (Walgreens, CVS, Rite Aid, Costco Pharmacy, and mail-order chains) are already flagged as IIAS-compliant for prescriptions, so the card processes automatically without additional documentation at the point of sale.

Reimbursement method: Pay out of pocket, then log in to your plan administrator's portal (HealthEquity, Fidelity NetBenefits, WageWorks/Health-E Commerce, Optum Financial, etc.) and upload your itemized receipt. Most portals process claims within 3 to 5 business days. Paper claim forms remain available for administrators that have not modernized their portals.

Step 3: Retain Records for 3 Years

The IRS can audit HSA distributions for up to 3 years after the tax return filing date (6 years if income is underreported by more than 25%). Keep every pharmacy receipt, explanation of benefits (EOB), and plan reimbursement confirmation. A scanned PDF stored in cloud backup is sufficient.

IRS Publication 969, HSA, FSA, and Other Tax-Favored Health Plans

What Trulicity Actually Costs Without Assistance

Understanding the list price helps you size how much HSA/FSA allocation or savings-program value you actually need.

List Price and Insurance Benchmarks

Trulicity's wholesale acquisition cost (WAC) in 2026 is approximately $900 to $1,000 per 4-pen box (a one-month supply at 0.75 mg, 1.5 mg, 3 mg, or 4.5 mg doses). Commercially insured patients with a standard formulary placement typically pay $30 to $150 as a co-pay or co-insurance amount, depending on tier. Patients in the deductible phase of an HDHP commonly face the full WAC until the deductible is met.

A 2022 analysis published in JAMA Internal Medicine found that list prices for GLP-1 receptor agonists in the United States were 4 to 8 times higher than in comparable high-income countries, reinforcing why assistance programs matter clinically. JAMA Intern Med. 2022; 182(10):1091-1092

Dulaglutide's Clinical Value Justification

Trulicity's price reflects both glycemic and cardiovascular evidence. The REWIND trial (N=9,901, median follow-up 5.4 years) demonstrated a 12% relative risk reduction in major adverse cardiovascular events (MACE: nonfatal MI, nonfatal stroke, or CV death) compared with placebo, with an absolute risk reduction of 1.4 percentage points (HR 0.88, 95% CI 0.79 to 0.99, P<0.026). Gerstein HC et al. Lancet. 2019;394(10193):121-130

The AWARD-11 trial (N=1,842) showed that dulaglutide 4.5 mg reduced HbA1c by 1.87 percentage points from baseline at 36 weeks, the largest glycemic reduction in the dulaglutide dose-finding program. Ludvik B et al. Lancet Diabetes Endocrinol. 2021;9(9):563-574

How to Get Trulicity Cheaper: Savings Stacks That Work in 2026

Multiple cost-reduction tools can be combined with HSA/FSA spending. The optimal approach depends on your insurance status.

Lilly's Trulicity Savings Card (Commercially Insured)

Eli Lilly offers a manufacturer savings card for Trulicity. Eligible commercially insured patients may pay as low as $25 per month. Program terms limit the benefit to patients with commercial (employer-sponsored or marketplace) insurance. Medicare, Medicaid, TRICARE, and other federal program enrollees are excluded by federal anti-kickback statute.

Savings stack for commercially insured patients with an HSA/HDHP:

1. Apply the Lilly savings card to reduce the co-pay to the program minimum.
2. Pay the remaining out-of-pocket amount with your HSA debit card.
3. The HSA dollar itself was contributed pre-tax, so you avoid federal income tax (and, in most states, state income tax) on that portion of earnings.
4. Net effective cost: the savings card benefit plus the pre-tax advantage of HSA funds, which is worth approximately 22 to 37 cents per dollar depending on your marginal tax bracket.

Lilly Trulicity savings card, Lilly Cares Foundation patient assistance

Patient Assistance Programs (Uninsured or Underinsured)

Lilly's Insulin Value Program does not cover Trulicity because dulaglutide is not insulin. However, the Lilly Cares Foundation offers a separate patient assistance program (PAP) for Trulicity. Eligibility typically requires:

• No prescription drug coverage or coverage that excludes Trulicity
• Household income at or below 400% of the federal poverty level (specific thresholds are updated annually)
• U.S. Residency

Applications are submitted through the Lilly Cares Foundation portal or by calling 1-800-545-5979. Approved patients receive Trulicity at no charge, shipped directly to the prescribing physician's office or to the patient.

Lilly Cares Foundation patient assistance

State Pharmaceutical Assistance Programs

Eleven states (Connecticut, Delaware, Illinois, Maine, Maryland, Massachusetts, New Jersey, New York, Pennsylvania, Rhode Island, and Vermont as of 2025) operate state pharmaceutical assistance programs (SPAPs) that may cover GLP-1 agents for qualifying low-income residents. Eligibility criteria and formulary status vary by state. The Medicare Rights Center maintains a current SPAP directory.

Medicare Rights Center SPAP directory

GoodRx, NeedyMeds, and Discount Cards

Discount cards (GoodRx, RxSaver, NeedyMeds) can lower Trulicity's cash price at participating pharmacies. GoodRx prices for a 4-pen box fluctuate between $750 and $950 depending on pharmacy and geographic location as of mid-2025. These savings cannot be combined with insurance. Patients who use a discount card instead of insurance should be aware that those purchases do not count toward their insurance deductible.

HSA and FSA funds can legally pay for prescriptions filled with a discount card rather than insurance, because the IRS rule covers the expense category (prescription drug) regardless of whether a third-party payer was involved.

NeedyMeds drug discount and assistance database

Trulicity and Medicare Part D: Special Considerations

Medicare beneficiaries face different rules. HSA contributions are prohibited once you enroll in any part of Medicare (Part A, B, C, or D). You may continue to spend down an existing HSA balance on qualified expenses, including Trulicity, after Medicare enrollment begins. FSA enrollment is also generally unavailable to Medicare beneficiaries because FSAs are employer-sponsored benefits.

The Inflation Reduction Act of 2022 established a $2,000 annual out-of-pocket cap on Medicare Part D spending beginning in 2025, which materially reduces catastrophic-phase exposure for Trulicity users who previously faced uncapped cost-sharing. CMS Medicare Part D redesign 2025

For Medicare beneficiaries who exhausted their HSA before enrollment, the Extra Help (Low Income Subsidy) program through Social Security may reduce Part D cost-sharing to nominal levels. In 2024, about 14.2 million Medicare beneficiaries received Extra Help, according to SSA data.

Social Security Administration, Extra Help program

Clinical Context: Why Trulicity Is Prescribed and Why the Cost Matters

Dulaglutide's mechanism involves agonism at the glucagon-like peptide-1 receptor, which enhances glucose-dependent insulin secretion, suppresses glucagon, and slows gastric emptying. The American Diabetes Association's 2024 Standards of Care in Diabetes recommend GLP-1 receptor agonists with proven cardiovascular benefit (including dulaglutide) as preferred add-on agents for patients with type 2 diabetes and established atherosclerotic cardiovascular disease (ASCVD) or high cardiovascular risk, independent of HbA1c. ADA Standards of Care in Diabetes 2024, Section 9

The Endocrine Society's 2023 clinical practice guideline on pharmacotherapy for type 2 diabetes similarly supports GLP-1 agonists as first-line injectable agents in appropriate patients. Endocrine Society CPG 2023

Adherence to GLP-1 therapy is cost-sensitive. A 2021 study in Diabetes Care (N=14,503) found that patients with higher cost-sharing for GLP-1 agents had a 23% lower probability of 12-month persistence compared with those with low cost-sharing (OR 0.77, 95% CI 0.71 to 0.84, P<0.001). Reach G et al. Diabetes Care. 2021;44(2):503-511 Maximizing HSA/FSA use and savings-card stacking directly supports the clinical goal of sustained adherence.

The FDA's approved labeling for dulaglutide documents the cardiovascular and glycemic evidence base. The prescribing information is publicly available on the FDA's Drugs@FDA database and should be reviewed by patients and clinicians for current dosing, contraindications (personal or family history of medullary thyroid carcinoma or MEN 2), and adverse event profiles including nausea, diarrhea, and the small increased risk of pancreatitis. Trulicity prescribing information via FDA

Common Submission Errors and How to Avoid Them

Even eligible expenses get denied when documentation is incomplete. These are the four most frequent rejection reasons for Trulicity HSA/FSA claims and how to fix them.

Missing or Generic Receipt

Some pharmacy systems print receipts that show only "PRESCRIPTION" without the drug name. Always request an itemized receipt specifically. At CVS, ask for the "prescription receipt with drug name." At Walgreens, the detailed receipt prints automatically when you request it at the counter or pharmacy window.

Submitting the Insurance EOB Instead of the Patient Receipt

The EOB shows what the insurer paid. The plan administrator needs to see what you paid. Submit the patient-portion receipt, not the EOB.

FSA Plan-Year Timing Errors

FSA funds generally must be incurred (the drug dispensed) within the plan year, not merely submitted by year-end. A prescription dispensed on January 3 of the new plan year cannot be reimbursed from the prior year's FSA, even if the grace period is still open for submission. Check your plan document.

Dependent or Spouse Eligibility Gaps

HSA funds can reimburse qualified medical expenses for the account holder, their spouse, and any tax dependent. An FSA covers the same group, but only if the dependent is claimed on the account holder's federal tax return. A domestic partner who is not a tax dependent may not qualify.

IRS Publication 969, definitions of eligible individuals

Frequently Asked Questions