Short answer: Yes, starting in 2026, certain qualifying Direct Primary Care arrangements do not disqualify you from contributing to an HSA, as long as you otherwise meet HSA eligibility rules.
Direct Primary Care (DPC) is an arrangement where you pay a flat monthly fee directly to a primary care provider for routine services, rather than using traditional insurance.
Historically, DPC arrangements created uncertainty for HSA eligibility because they could be viewed as providing medical benefits before an HDHP deductible was met. However, recent federal legislation and IRS guidance changed this treatment.
Beginning in 2026, a qualifying DPC arrangement is not treated as disqualifying other coverage for HSA purposes. This allows individuals enrolled in an HSA-qualified high-deductible health plan to also use a qualifying DPC arrangement and remain eligible to contribute to an HSA.
To avoid disqualifying HSA eligibility, the DPC arrangement must meet specific requirements set out in federal law and IRS guidance. In general, it must be limited to primary care services and structured as a fixed-fee service arrangement rather than insurance.
Even with a qualifying DPC arrangement, you must still meet all other HSA eligibility rules, including enrollment in an HSA-qualified HDHP.
Sources
- IRS Notice 2026-05 (clarifying expanded HSA eligibility and treatment of Direct Primary Care Service Arrangements): https://www.irs.gov/pub/irs-drop/n-26-05.pdf :contentReference[oaicite:4]{index=4}
- IRS News Release on expanded HSA eligibility under the One Big Beautiful Bill Act: https://www.irs.gov/newsroom/treasury-irs-provide-guidance-on-new-tax-benefits-for-health-savings-account-participants-under-the-one-big-beautiful-bill
Content history
Originally published: March 27, 2025
Last reviewed: January 27, 2026