Short answer: Yes. Beginning in 2026, a qualifying Direct Primary Care arrangement no longer disqualifies you from contributing to an HSA, and DPC fees within the monthly limits are themselves HSA-eligible expenses, 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 billing traditional insurance.
Historically, DPC arrangements created uncertainty for HSA eligibility because a DPC membership could be viewed as a second health plan providing medical benefits before the HDHP deductible was met. The One Big Beautiful Bill Act (OBBBA) resolved that uncertainty.
Effective January 1, 2026, a qualifying DPC arrangement is not treated as disqualifying coverage for HSA purposes, as long as the aggregate monthly fee does not exceed $150 for one person or $300 for a family (more than one person). IRS Notice 2026-05 confirms this treatment. Within those caps, DPC fees are also treated as qualified medical expenses that can be paid tax-free from your HSA.
If the monthly DPC fee exceeds the applicable cap, you lose HSA-eligible treatment for any month in which the cap is exceeded. The $150/$300 caps apply for both 2026 and 2027 (inflation indexing does not begin until after 2026).
Even with a qualifying DPC arrangement, you must still meet all other HSA eligibility rules, including enrollment in an HSA-qualified high-deductible health plan and having no other disqualifying coverage.
Sources
- IRS Notice 2026-05 (HSA eligibility and treatment of Direct Primary Care arrangements): https://www.irs.gov/pub/irs-drop/n-26-05.pdf
- Treasury/IRS news release on expanded HSA benefits 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
- One Big Beautiful Bill Act, Pub. L. 119-21, §71308 (IRC §223(c)(1)(E)).
Content history
Originally published: March 27, 2025
Last reviewed: June 16, 2026