Direct Primary Care + HSA in 2026: What Changed

Direct primary care and an HSA can work together in 2026 in a way they generally could not before. Starting January 1, 2026, you can use HSA funds to pay for qualifying DPC memberships as well as continue contributing towards your HSA. I'll unpack the word qualifying below.

There are two separate rules to understand:

1. Can you keep putting new money into your HSA while you have DPC?
2. Can you use HSA money to pay your DPC membership fee?

They sound like the same question. Under the new IRS rules, they are not.

What changed for direct primary care and HSAs in 2026?

Before 2026, a typical DPC membership could prevent you from contributing to an HSA because it gave you access to non-preventive medical care before you met your health plan deductible. Starting in 2026, Congress created an exception for qualifying DPC arrangements.

The change came from Public Law 119-21, enacted in 2025, and applicable starting January 1, 2026. The IRS explains how it works in Notice 2026-05.

In practical terms, the law changed two things:

• A qualifying DPC arrangement can coexist with HSA contribution eligibility if its fees stay within the applicable monthly limit.
• Qualifying DPC membership fees can be treated as medical expenses that you can pay or reimburse from an HSA.

It does not mean that every doctor membership now qualifies, or that having DPC by itself makes you eligible for an HSA.

Do you still need an HSA-eligible health plan?

Yes. DPC does not replace the underlying coverage requirement for contributing to an HSA. You still need qualifying HSA-compatible health coverage and cannot have other disqualifying coverage.

For 2026, an HSA-eligible person can include someone enrolled in a traditional qualifying high-deductible health plan. A separate 2026 change also treats qualifying individual-market Bronze and Catastrophic plans as high-deductible health plans for HSA purposes. The IRS covers that change in the same Notice 2026-05, and HealthCare.gov now identifies 2026 Bronze and Catastrophic plans as HSA-compatible.

So think of DPC as a layer of primary care access that may sit alongside your insurance — not as the thing that creates your HSA eligibility.

What counts as a qualifying direct primary care arrangement?

The IRS definition is narrower than “a doctor charges me a membership fee.” A qualifying arrangement must provide primary care services for a fixed periodic fee $150/$300 per month and meet specific limits on what can be bundled into that membership.

Under IRS Notice 2026-05, the arrangement must consist solely of primary care services provided by qualifying primary care practitioners, with the fixed periodic fee serving as the sole compensation for the care included in the arrangement.

The IRS specifically excludes these services from the DPC definition:

• Procedures requiring general anesthesia
• Prescription drugs other than vaccines
• Laboratory services not typically administered in an ambulatory primary care setting

There is another easy-to-miss rule: the IRS looks at what the membership contract includes, not which services you personally use.

If a membership bundles services that fall outside the permitted definition, you cannot make it qualify simply by deciding not to use those services.

And if the practice says certain care is part of the membership but then separately bills you or your insurance for that same included care, the arrangement does not meet the IRS's definition. The practice can still offer separate services outside the membership, but those services must genuinely be outside the DPC arrangement.

What is the $150/$300 DPC limit for 2026?

For 2026, the monthly fee limit is $150 for an arrangement covering one person and $300 if the arrangement covers more than one person. Staying within that limit matters if you want to keep contributing new money to your HSA.

The limit applies to the aggregate fees for all DPC arrangements covering you during the month.

The IRS also allows a qualifying practice to bill quarterly, semiannually or annually. It looks at the fee on an annualized basis. For example, the IRS says a 2026 individual membership could charge $1,800 for the year, $900 for six months or $450 for three months and still stay within the $150-per-month limit.

What happens if your DPC membership costs more than $150 a month?

A DPC fee above $150 a month for one person can make you ineligible to contribute to your HSA while you are enrolled — even though you may still be allowed to use HSA money to pay that DPC fee.

Suppose you are single and have otherwise HSA-compatible health coverage:

• Your DPC membership costs $120 a month. If the membership fits the IRS definition described above, it can generally coexist with your eligibility to make new HSA contributions.
• Your DPC membership costs $175 a month. That exceeds the 2026 $150 monthly limit, so the membership can disqualify you from making HSA contributions for the months you are enrolled.

But the IRS draws a different line for spending money already in your HSA.

Notice 2026-05 says there is no specific dollar cap on the fixed periodic DPC fee for purposes of HSA reimbursement. That means the $175 fee in the second example may still be payable from your HSA if the arrangement otherwise meets the IRS definition of DPC for reimbursement purposes.

The $150/$300 limit determines whether the DPC membership can coexist with new HSA contributions. It is not a cap on how much of a qualifying DPC fee can be paid from HSA funds.

Can you use HSA money to pay your DPC membership?

Yes. Beginning in 2026, qualifying DPC membership fees can be paid or reimbursed from an HSA as qualified medical expenses.

The IRS also allows reimbursement timing that can accommodate practices charging in advance. A qualifying DPC expense can generally be treated as incurred on a monthly pro-rata basis, on the first day of the coverage period or on the date the fee is paid.

One limitation: if your employer paid the DPC fee, you cannot also reimburse yourself for that same fee from your HSA. The IRS says an employer-paid fee is not your expense.

Do DPC membership fees count toward your insurance deductible?

No. Paying your DPC membership does not move you closer to meeting your health insurance deductible or out-of-pocket maximum.

The IRS addressed this directly in Notice 2026-05. If you are enrolled in both a DPC arrangement and a high-deductible health plan, the DPC membership fee is not an amount you paid for an item or service covered by the HDHP. Your health plan therefore cannot count that membership fee toward its annual deductible or out-of-pocket maximum.

For example, if you pay $120 a month for DPC, that is $1,440 over a year. You may be able to pay that $1,440 from your HSA, but your insurance deductible generally remains exactly where it was.

HSA-eligible does not mean deductible-eligible.

Is direct primary care a replacement for insurance?

Usually not. DPC is designed around primary care, while health insurance protects against a much broader set of medical expenses.

A DPC practice may offer routine visits, preventive care, urgent primary care, basic testing or easier access to a clinician, depending on the membership. But hospital care, surgery, emergency care, specialists, advanced imaging and many prescription drugs can fall outside the arrangement.

That is why the more useful comparison is often not DPC versus insurance. It is:

What does my insurance cost + what does DPC cost + what medical expenses remain outside both?

The goal is not to assume cash, insurance or a membership model is automatically better. It is to make the pieces visible enough that you can compare them.

How can you check whether a DPC membership works with your HSA?

Ask for the actual membership terms before signing up. A practice calling itself “HSA eligible” is not enough to tell you whether you can keep contributing to your HSA.

The best question to ask is:

“Does this membership qualify as a direct primary care service arrangement under the federal HSA rules, and can I keep contributing to my HSA while I’m enrolled?”

Then confirm these details:

1. What is the fixed membership fee? For 2026, compare it with the $150 individual or $300 multi-person monthly limit.
2. Does the membership itself qualify as DPC under the IRS definition? Ask whether the services bundled into the membership stay within the types of primary care the IRS permits.
3. What services are included in the fee? Look for bundled prescriptions, procedures or labs that could fall outside the IRS definition.
4. Are any membership services billed separately to me or my insurance? Included care generally must be compensated solely through the fixed periodic fee.
5. Does the membership cover one person or more than one person? That determines which 2026 dollar limit applies.
6. Will my employer pay any part of the DPC fee? Employer-paid fees cannot also be reimbursed to you from your HSA.

If possible, ask the practice to confirm its answer in writing or point you to the relevant language in the membership agreement.

Don’t just ask, “Is this HSA eligible?” Ask: “Does this membership qualify under IRC Section 223, and can I continue contributing to my HSA while enrolled?”

You still need to be otherwise eligible to contribute to an HSA; DPC does not override the other HSA eligibility rules. Save the membership agreement and your payment records.

What happens to the DPC limits after 2026?

The law provides for inflation adjustments after 2026, but the first adjustment does not increase the limit: the IRS has set the 2027 amounts at the same $150 and $300 levels.

The bottom line

The 2026 change makes direct primary care and HSAs much easier to combine, but the details of the membership still matter.

If you are considering DPC, separate the decision into three checks:

• Does the membership qualify as DPC under the IRS definition?
• Is the fee low enough for you to remain eligible to make HSA contributions?
• Does the total cost of DPC plus your health plan make sense for the care and access you expect to use?

The biggest trap is assuming that “I can pay this with my HSA” automatically means “I can keep contributing to my HSA.” In 2026, those are different definitions.

Unblind Health provides general healthcare pricing and coverage information for educational purposes. Eligibility, tax treatment, plan benefits and individual costs can vary. This is not medical, legal, insurance or tax advice.

Sources

• IRS Notice 2026-05 — Expanded Availability of Health Savings Accounts — checked August 28, 2026
• IRS — Treasury and IRS guidance on new HSA benefits — checked August 28, 2026
• IRS Revenue Procedure 2026-24 — 2027 HSA and DPC inflation-adjusted amounts — checked August 28, 2026
• HealthCare.gov — Health Savings Account-eligible plans — checked August 28, 2026