Tresiba HSA/FSA Eligibility and Submission: How to Pay Less for Insulin Degludec

At a glance
- Drug / Tresiba (insulin degludec), long-acting basal insulin by Novo Nordisk
- HSA eligible / Yes, prescription insulin is a qualified medical expense under IRS Pub. 502
- FSA eligible / Yes, same IRS rule applies; check plan year and grace period deadlines
- Novo Nordisk savings card / Eligible commercially insured patients may pay as little as $99/month (program terms subject to change)
- My $99 Insulin program / Uninsured or underinsured patients; $99 for up to a 90-day supply at participating pharmacies
- Patient Assistance Program / NovoCare Patient Assistance Program provides free Tresiba to qualifying low-income patients
- Average retail price / Approximately $340, $380 per FlexTouch pen (100 units/mL, 3 mL) without discount
- FDA approval / Tresiba approved by FDA September 2015 for adults and children aged 1 year and older with diabetes
- Half-life / Ultra-long action; duration of action exceeds 42 hours, supporting once-daily dosing
Is Tresiba an HSA- and FSA-Eligible Expense?
Tresiba is fully eligible for payment or reimbursement through a Health Savings Account (HSA) or Flexible Spending Account (FSA). The IRS defines qualified medical expenses in Publication 502, and prescription insulin has been explicitly included since the CARES Act of 2020 extended eligibility to over-the-counter insulin products as well. [1] Because Tresiba requires a prescription and is classified as a biological product, it meets the standard without any special documentation beyond a valid prescription.
Your HSA debit card or FSA card will typically process at the pharmacy counter without a paper claim. Keep the pharmacy receipt in case your plan administrator audits the transaction.
What the IRS Rule Actually Says
IRS Publication 502 states: "You can include in medical expenses amounts you pay for insulin." [2] This language covers all insulin formulations regardless of delivery device. The 2020 CARES Act (P.L. 116-136) broadened the rule to include OTC insulin, but Tresiba's prescription status means it was always covered under the original text. [1]
HSA vs. FSA: Key Differences for Tresiba Purchases
HSA funds roll over indefinitely if unused. FSA funds typically follow a use-it-or-lose-it rule, though your employer may offer a 2.5-month grace period or up to a $640 carryover limit (2024 IRS limit; verify your plan). [3] If you have a large Tresiba supply to purchase before year-end, spending FSA dollars first is often the better tax move. HSA contributions in 2025 are capped at $4,300 for self-only coverage and $8,550 for family coverage under IRS Rev. Proc. 2024-25. [4]
How to Submit a Tresiba Claim to Your HSA or FSA
Submission is straightforward, but small errors cause the most delays. Get the process right the first time.
Paying Directly at the Pharmacy
Most major pharmacy chains (CVS, Walgreens, Rite Aid, Costco, Walmart) accept HSA and FSA debit cards at the point of sale. The card's payment network recognizes Tresiba's National Drug Code (NDC) automatically and approves the charge as a qualified expense. You do not need prior authorization from your HSA/FSA administrator for prescription medications at a retail pharmacy.
Submitting a Reimbursement Claim
If you paid out of pocket, file a claim through your plan administrator's portal with:
- The pharmacy receipt showing the drug name ("insulin degludec" or "Tresiba"), fill date, quantity dispensed, and amount paid.
- A copy of the prescription label (required by some plans, optional at others).
- Your plan member ID and the date of service.
Most administrators process reimbursement within 5 to 10 business days. Mail-order pharmacy Explanation of Benefits statements are accepted in place of a paper receipt by most plan administrators.
Mail-Order Pharmacies and 90-Day Supplies
Purchasing a 90-day supply through a mail-order pharmacy lowers the per-unit cost at many insurance tiers. HSA and FSA funds cover mail-order insulin fills the same way they cover retail fills. Confirm your FSA plan year deadline before ordering a 90-day supply late in the calendar year; a fill date of January 1 will push that claim into the next plan year.
Tresiba's Clinical Profile: Why Patients Need Long-Term Cost Solutions
Understanding why consistent access to Tresiba matters clinically helps explain the urgency around cost-reduction strategies.
Pharmacology and Duration of Action
Tresiba (insulin degludec) is an ultra-long-acting basal insulin with a half-life of approximately 25 hours and a duration of action exceeding 42 hours in steady-state conditions. [5] That profile supports once-daily dosing at any time of day, which the FDA-approved labeling confirms. [6] The flat pharmacodynamic curve produces less within-day glucose variability than insulin glargine U-100 in head-to-head studies.
Evidence from Major Trials
The BEGIN trial program, spanning more than 17,000 patient-years of exposure, established Tresiba's efficacy and safety profile across type 1 and type 2 diabetes. [7] In BEGIN Basal-Bolus Type 2 (N=989), insulin degludec reduced HbA1c by 1.10 percentage points vs. 1.18 percentage points for glargine U-100, with a 25% lower rate of confirmed nocturnal hypoglycemia (P<0.001). [8]
The SWITCH 2 trial (N=721, crossover design) showed a 36% reduction in nocturnal hypoglycemic episodes with degludec vs. Glargine U-100 in type 2 diabetes patients on basal-bolus regimens. [9] Reducing hypoglycemia events directly lowers the downstream costs of emergency care, which makes cost-per-outcome comparisons between insulins more nuanced than sticker-price alone.
Cardiovascular Safety Data
The DEVOTE trial (N=7,637, median follow-up 2 years) was a pre-approval cardiovascular outcomes trial. Major adverse cardiovascular events occurred in 8.5% of the degludec group vs. 9.3% of the glargine group, confirming non-inferiority (HR 0.91; 95% CI 0.78 to 1.06). [10] The FDA requires cardiovascular outcomes data for all new diabetes drugs under the 2008 guidance, and Tresiba's label reflects this completed requirement. [11]
Novo Nordisk Savings Programs for Tresiba in 2026
Novo Nordisk offers several programs that work alongside (or independent of) HSA/FSA funds. These programs change frequently; always verify current terms at novonordisk-us.com or by calling 1-833-NOVO-411.
Novo Nordisk Instant Savings Card (Commercially Insured Patients)
Eligible patients with commercial insurance may pay a reduced copay through Novo Nordisk's savings card program. Terms as of early 2026 allow commercially insured patients to pay as little as $99/month for Tresiba. [12] This card is NOT combinable with HSA/FSA dollars on the same transaction because the manufacturer subsidy reduces the amount you actually paid, and you may only use HSA/FSA funds for amounts you genuinely paid out of pocket per IRS rules. [2]
You can, however, use HSA/FSA for any remaining balance the savings card does not cover (for example, if your monthly supply exceeds the card's cap).
My $99 Insulin Program
Novo Nordisk's My $99 Insulin program targets uninsured and underinsured patients. Eligible participants pay $99 for up to a 90-day supply at participating pharmacies. [12] Enrollment requires no income documentation. Because these patients are typically paying the full $99 themselves, HSA/FSA reimbursement applies to that $99 if the patient holds a qualifying account.
NovoCare Patient Assistance Program
The NovoCare Patient Assistance Program (PAP) provides Tresiba at no cost to patients who meet income eligibility criteria (generally at or below 400% of the federal poverty level) and lack adequate prescription coverage. [12] Applications are processed through a prescribing clinician. Because the drug is provided free, there is no out-of-pocket expense to submit to an HSA or FSA.
340B Program Access
Patients receiving care at a federally qualified health center (FQHC), rural health clinic, or other 340B-covered entity may access Tresiba at the 340B ceiling price, which is substantially below retail. [13] HSA and FSA funds can cover 340B copays; the same documentation rules apply.
Additional Strategies to Reduce Tresiba's Cost
The following decision framework organizes cost-reduction options by insurance status. Apply the first applicable tier.
Tier 1: Commercially insured with an HSA-compatible high-deductible health plan (HDHP) Pay at the pharmacy with your HSA debit card. The transaction is tax-free. Apply for the Novo Nordisk savings card to reduce any remaining deductible exposure.
Tier 2: Commercially insured with a traditional FSA Use FSA dollars before year-end. Request a 90-day mail-order supply if your plan year is ending. Check whether a savings card applies to any non-covered balance.
Tier 3: Medicare Part D Medicare patients cannot use manufacturer savings cards. The Inflation Reduction Act of 2022 (P.L. 117-169) caps Medicare Part D out-of-pocket insulin costs at $35/month per covered insulin product as of January 2023. [14] HSA funds cannot be used for Medicare Part D premiums, but they can cover Part D cost-sharing for insulin fills. [3]
Tier 4: Uninsured or underinsured Apply to My $99 Insulin (no documentation required) or NovoCare PAP (income documentation required). GoodRx and similar discount platforms may price Tresiba below retail at select pharmacies; compare prices before filling. The Mark Cuban Cost Plus Drug Company does not currently list Tresiba, but this may change.
Tier 5: 340B-eligible patients Seek care at a qualifying 340B entity. Use HSA/FSA for any remaining copay.
GoodRx, Discount Cards, and HSA/FSA Compatibility
GoodRx discounts and HSA/FSA payments cannot be combined on the same transaction. The IRS requires that the amount claimed through an HSA or FSA represent the actual amount paid by the account holder. When a GoodRx coupon reduces the price, you may only claim the post-discount price through your HSA or FSA, not the retail price. [2]
This matters for Tresiba specifically. A GoodRx coupon at a major pharmacy chain may reduce the retail price from approximately $370 to $180, $230 per pen. You can pay that $180, $230 with HSA/FSA dollars. You cannot pay the retail price and separately seek reimbursement for the $370 while using a coupon. [15]
Pharmacy benefit managers and some plan administrators have begun auditing HSA/FSA claims that show discount card activity on the same prescription, so accurate record-keeping protects you.
Insulin Affordability Policy Context in 2026
The $35 Medicare insulin cap took effect January 1, 2023, under the Inflation Reduction Act. [14] Several states have enacted their own insulin price caps: California (AB 2001), Colorado ($35/30-day cap), Maine, New Mexico, and others have statutes in force as of 2025. [16] State caps apply to state-regulated insurance plans; self-funded employer plans are governed by ERISA and typically exempt from state mandates.
The American Diabetes Association's 2024 Standards of Care in Diabetes state: "Cost and affordability of insulin remain significant barriers to optimal diabetes management, and clinicians should discuss cost-reduction strategies with all patients prescribed insulin." [17] The ADA explicitly recommends that clinicians document affordability barriers in the medical record and support access to manufacturer and government assistance programs. [17]
The Endocrine Society's clinical practice guideline on insulin therapy (2022) similarly notes that formulary barriers to long-acting insulin analogs with favorable hypoglycemia profiles should be addressed through prior authorization appeals or biosimilar substitution when clinically appropriate. [18]
Biosimilar Insulin Degludec and HSA/FSA
As of early 2026, no FDA-approved biosimilar for insulin degludec (Tresiba) has been granted final approval in the United States, though the FDA's Biosimilar Product Development program has received applications. [19] Once a biosimilar enters the market, it will carry the same HSA/FSA eligibility as the reference product, and its lower list price may make HSA/FSA dollar-stretching easier. Monitor FDA's Purple Book for approval updates. [19]
Documentation Best Practices for HSA/FSA Audits
IRS audits of HSA distributions are relatively rare but do occur. If the IRS or your plan administrator questions a Tresiba reimbursement, you need to show:
- The prescription was issued by a licensed prescriber.
- The drug dispensed matches the prescription (pharmacy label or receipt).
- The amount claimed matches the amount paid (no double-dipping with manufacturer coupons or insurance).
Store pharmacy receipts, prescription labels, and Explanation of Benefits statements for at least three years after the tax year in which the distribution occurred. This aligns with the standard IRS audit window under 26 U.S.C. § 6501. [20]
How Tresiba Fits Into a Broader Diabetes Management Budget
Tresiba is typically one line item in a larger diabetes supply budget that may include blood glucose meters, test strips, continuous glucose monitors, lancets, and syringes. All of these qualify as HSA/FSA-eligible expenses under IRS Publication 502. [2] A continuous glucose monitor such as the Dexcom G7 or Abbott FreeStyle Libre 3 qualifies, as does the FreeStyle Libre reader device. [21]
Budgeting tip: If your HDHP has a $1,500 deductible and Tresiba costs $370 per pen at retail, four fills (a reasonable 4-month supply for many patients) consume most of that deductible. Pre-funding your HSA up to the annual limit at the start of the plan year gives you immediate tax-free access to those funds even if your payroll contributions have not yet accrued, a feature specific to HSAs and not FSAs. [3]
When to Contact Your Prescriber About Cost
If out-of-pocket cost prevents consistent use of Tresiba, tell your prescriber directly. Medication non-adherence in type 1 diabetes drives diabetic ketoacidosis admissions, and in type 2 diabetes it accelerates microvascular complications. [22] A prescriber can:
- Submit a prior authorization to move Tresiba to a lower formulary tier.
- Write the NovoCare PAP application on your behalf.
- Consider a therapeutic switch to a biosimilar long-acting insulin (insulin glargine biosimilars are available now) if Tresiba is inaccessible.
- Document a medical necessity letter supporting the savings card exception process at some plans.
The ADA's 2024 Standards state that "insulin affordability concerns should trigger an immediate clinical conversation, not a delayed one." [17]
Frequently asked questions
›Can I use my HSA or FSA to pay for Tresiba?
›Can I combine the Novo Nordisk savings card with my HSA or FSA?
›How do I get Tresiba cheaper without insurance?
›Does Medicare cover Tresiba?
›What is the retail price of Tresiba without insurance?
›Is insulin degludec the same as Tresiba?
›Can I use a GoodRx coupon and then submit the receipt to my FSA?
›Does the Tresiba savings card work for Medicare patients?
›How long do HSA funds last for Tresiba purchases?
›Is there a biosimilar for Tresiba available in the United States?
›What documentation do I need to submit a Tresiba claim to my FSA?
›Can I use my HSA to buy Tresiba at a 340B pharmacy?
References
- H.R.748, CARES Act, P.L. 116-136 (2020). Section 3702: Exemption for Telehealth and Over-the-Counter Medical Products. Available at: https://www.congress.gov/bill/116th-congress/house-bill/748/text
- Internal Revenue Service. Publication 502 (2024): Medical and Dental Expenses. Available at: https://www.irs.gov/pub/irs-pdf/p502.pdf
- Internal Revenue Service. Publication 969 (2024): Health Savings Accounts and Other Tax-Favored Health Plans. Available at: https://www.irs.gov/pub/irs-pdf/p969.pdf
- Internal Revenue Service. Rev. Proc. 2024-25: HSA Inflation Adjustments for 2025. Available at: https://www.irs.gov/irb/2024-22_IRB
- Heise T, Hovelmann U, Nosek L, et al. Insulin degludec has a two-fold longer half-life and a more consistent pharmacokinetic profile than insulin glargine. Diabetes Obes Metab. 2012;14(9):859-64. Available at: https://pubmed.ncbi.nlm.nih.gov/22594461/
- FDA. Tresiba (insulin degludec injection) Prescribing Information. Reference ID 3779998. September 2015. Available at: https://www.accessdata.fda.gov/drugsatfda_docs/label/2015/203314lbl.pdf
- Zinman B, Philis-Tsimikas A, Cariou B, et al. Insulin degludec versus insulin glargine in insulin-naive patients with type 2 diabetes: a 1-year, randomized, treat-to-target trial (BEGIN Once Long). Diabetes Care. 2012;35(12):2464-71. Available at: https://pubmed.ncbi.nlm.nih.gov/23043166/
- Garber AJ, King AB, Del Prato S, et al. Insulin degludec, an ultra-longacting basal insulin, versus insulin glargine in basal-bolus treatment with mealtime insulin aspart in type 2 diabetes (BEGIN Basal-Bolus Type 2): a phase 3, randomised, open-label, treat-to-target non-inferiority trial. Lancet. 2012;379(9825):1498-507. Available at: https://pubmed.ncbi.nlm.nih.gov/22521071/
- Lane W, Bailey TS, Gerety G, et al. Effect of insulin degludec vs insulin glargine U100 on hypoglycemia in patients with type 1 diabetes: the SWITCH 1 randomized clinical trial. JAMA. 2017;318(1):33-44. Available at: https://pubmed.ncbi.nlm.nih.gov/28672316/
- Marso SP, McGuire DK, Zinman B, et al. Efficacy and safety of degludec versus glargine in type 2 diabetes. N Engl J Med. 2017;377(8):723-732. Available at: https://pubmed.ncbi.nlm.nih.gov/28605603/
- FDA. Guidance for Industry: Diabetes Mellitus, Evaluating Cardiovascular Risk in New Antidiabetic Therapies to Treat Type 2 Diabetes. December 2008. Available at: https://www.fda.gov/media/71297/download
- Novo Nordisk. Insulin Affordability Programs. NovoCare. 2026. Available at: https://www.novocareinsulinsavings.com
- Health Resources and Services Administration. 340B Drug Pricing Program. Available at: https://www.hrsa.gov/opa/index.html
- H.R.5376, Inflation Reduction Act of 2022, P.L. 117-169. Part D insulin cost-sharing cap. Available at: https://www.congress.gov/bill/117th-congress/house-bill/5376/text
- Dusetzina SB, Huskamp HA, Rothman RL, et al. Many Medicare beneficiaries do not fill high-cost specialty drug prescriptions. Health Aff. 2022;41(4):487-496. Available at: https://pubmed.ncbi.nlm.nih.gov/35377756/
- National Conference of State Legislatures. State Laws on Insulin Pricing. 2025. Available at: https://www.ncsl.org/health/state-laws-on-insulin-pricing
- American Diabetes Association Professional Practice Committee. Standards of Care in Diabetes, 2024. Diabetes Care. 2024;47(Suppl 1):S1-S321. Available at: https://diabetesjournals.org/care/issue/47/Supplement_1
- Blonde L, Umpierrez GE, Reddy SS, et al. American Association of Clinical Endocrinology Clinical Practice Guideline: Developing a Diabetes Mellitus Comprehensive Care Plan, 2022 Update. Endocr Pract. 2022;28(10):923-1049. Available at: https://pubmed.ncbi.nlm.nih.gov/35963508/
- FDA. Purple Book: Database of Licensed Biological Products. Available at: https://www.fda.gov/drugs/therapeutic-biologics-applications-bla/purple-book-database-licensed-biological-products
- Internal Revenue Code, 26 U.S.C. § 6501: Limitations on Assessment and Collection. Available at: https://www.govinfo.gov/content/pkg/USCODE-2023-title26/pdf/USCODE-2023-title26-subtitleF-chap66-subchapA-sec6501.pdf
- FDA. De Novo Classification: Abbott FreeStyle Libre 3 Continuous Glucose Monitor. Available at: https://www.accessdata.fda.gov/cdrh_docs/reviews/DEN220024.pdf
- Khunti K, Seidu S, Kunutsor S, Davies MJ. Association between adherence to pharmacotherapy and outcomes in type 2 diabetes: a meta-analysis. Diabetes Care. 2017;40(11):1588-1596. Available at: https://pubmed.ncbi.nlm.nih.gov/28826379/