Direct Primary Care Arrangements Are Now HSA-Compatible

What Changed?

The One Big Beautiful Bill Act (OBBBA) expanded HSA eligibility rules for certain Direct Primary Care service arrangements. Previously, participation in a DPC arrangement could be considered disqualifying coverage for HSA contribution purposes. Effective January 1, 2026, qualifying DPC arrangements no longer prevent an otherwise eligible individual from contributing to an HSA.

What This Means for Employers

For employers evaluating their benefits strategy, this change creates another way to pair HSA-compatible coverage with access to primary care. A qualifying DPC arrangement can be offered alongside an HSA-compatible health plan without automatically affecting an employee's ability to contribute to an HSA.

This may give employers an additional option when considering benefit programs designed to support both access to primary care and employees' ability to save for current and future healthcare expenses through an HSA.

Not Every DPC Arrangement Qualifies

Employers should confirm that a DPC arrangement meets the applicable requirements before presenting it to employees as HSA-compatible.

For 2026, qualifying arrangements are subject to monthly fee limits and restrictions on the types of services included. The IRS guidance sets the monthly limit at $150 for one individual and $300 when the arrangement covers more than one individual, with future amounts subject to inflation adjustments. The definition also excludes certain services, including procedures requiring general anesthesia, most prescription drugs, and certain laboratory services.

Helping Employees Understand the Change

When introducing a qualifying DPC arrangement, employers can help employees understand that they may be able to:

• Continue contributing to their HSA while participating in the qualifying DPC arrangement.
• Use HSA funds tax-free to pay qualifying periodic DPC fees.
• Maintain the long-term savings benefits of their HSA while accessing primary care through the DPC arrangement.

As You Plan Your Benefits Strategy

If Direct Primary Care is part of your benefits discussion, consider how it fits alongside your HSA-compatible health plan and employee HSA education. Before implementation, employers should verify that the specific DPC arrangement meets the requirements for HSA compatibility.