Can You Use an HSA for a Direct Primary Care Membership? What the 2026 Law Changed

So, can an HSA be used for Direct Primary Care?

As of January 1, 2026, the answer is often yes, provided the membership arrangement and your individual situation meet the applicable rules.

The 2026 change makes it easier for many people to pair a Direct Primary Care (DPC) membership with an HSA-eligible high-deductible health plan. Federal law now allows certain DPC arrangements to coexist with HSA contributions and permits qualifying periodic DPC fees to be paid or reimbursed from HSA funds.

That can make a predictable monthly primary-care membership more accessible for Southern Oregon families, self-employed people, and small-business owners. The rules still have important details.

What Changed for DPC and HSAs in 2026?

Before 2026, a DPC membership generally counted as other health coverage, which could prevent HSA contributions for someone with an HDHP.

Section 71308 of Public Law 119-21 changed that treatment for months beginning after December 31, 2025. Under the new rule, enrollment in a qualifying DPC service arrangement does not by itself make you ineligible to contribute to an HSA. The law also allows expenses for coverage under a qualifying DPC arrangement to be treated as eligible HSA expenses. IRS Notice 2026-05 explains both changes and the conditions that apply.

In plain English, the updated rule creates two opportunities:

• Keep contributing to an HSA — If you are otherwise HSA-eligible and your DPC arrangement meets the requirements, having the membership no longer automatically disqualifies you.
• Use HSA funds for periodic DPC fees — You may be able to pay or reimburse qualifying membership fees with HSA dollars, rather than paying those fees entirely with post-tax income.

This does not turn DPC into insurance. If you are still deciding how a membership fits alongside coverage for larger medical expenses, review how Direct Primary Care works with insurance.

Who Can Use an HSA for Direct Primary Care?

There are two related but different questions: Can you use money already in an HSA to pay a membership fee? And can you continue contributing new money to the HSA while enrolled in DPC?

For HSA contributions, you must be an “otherwise eligible individual.” In general, that means HSA-compatible coverage, such as a qualifying HDHP, with no other disqualifying health coverage. DPC itself may no longer be the problem, but your broader benefits situation still matters.

The DPC arrangement matters, too. The IRS describes a qualifying arrangement as primary care provided by an eligible primary-care practitioner for a fixed periodic fee. Review the membership terms before assuming every fee, add-on, or specialty service receives the same treatment.

For 2026, the rule uses these monthly thresholds when determining whether a DPC membership avoids disqualifying you from HSA contributions:

These are aggregate monthly limits for all relevant DPC arrangements, not annual HSA contribution limits. The IRS adjusts them for inflation after 2026. Notice 2026-05 explains that quarterly, semiannual, or annual fixed fees can work if they remain within the annualized monthly limit.

An Important Nuance About the $150 and $300 Limits

The monthly thresholds are important, but they do not mean a fee above the threshold can never be paid from an HSA.

According to the IRS, a fixed periodic DPC fee that exceeds the $150 individual or $300 multi-person threshold may still be a qualified medical expense that can be reimbursed from an HSA. However, the member may be disqualified from making HSA contributions while enrolled in that arrangement. That difference between spending existing HSA funds and remaining eligible to contribute new funds is one of the most common points of confusion.

Your plan administrator or tax advisor can help confirm whether your coverage, membership fee, and contribution plans work together. Resolute can explain its membership structure and pricing, but cannot determine your personal tax eligibility.

How to Use HSA Funds for a DPC Membership

Once you have confirmed your situation, the process is usually straightforward:

1. Review the membership. Confirm the fee, what is included, separate add-ons, and whether you are enrolling as an individual or family.
2. Check HSA eligibility. Ask your benefits administrator whether your plan is HSA-compatible and whether other coverage affects contributions.
3. Confirm the arrangement. Request membership documentation, then ask your administrator or tax advisor about reimbursement and continued contribution eligibility.
4. Pay or reimburse the fee. Use an HSA card where accepted, or pay and reimburse yourself. Keep the agreement, invoices, and payment records.
5. Recheck after changes. A change in coverage, tier, family status, or fee can change the analysis.

HSA money can be used tax-free for qualified medical expenses, but the tax result depends on the arrangement and your circumstances.

Common pitfalls to avoid

• Assuming every DPC-related charge qualifies. Do not assume enrollment fees, specialty services, medications, labs, or add-ons receive the same treatment as the fixed membership fee.
• Confusing reimbursement with contribution eligibility. A higher DPC fee may still be reimbursable, but could affect whether you can contribute while enrolled.
• Forgetting the HDHP requirement. The new law removes one DPC-related obstacle, not the broader HSA eligibility rules.
• Double-dipping. If an employer pays a membership fee, do not also seek personal HSA reimbursement for that same amount.
• Treating DPC as catastrophic coverage. Your DPC membership supports everyday primary care. It does not replace insurance coverage for hospitalization, emergency care, or other major medical expenses.
• Assuming HSA and FSA rules are identical. They are not. Some FSA plans may allow DPC-related payments, but you should check your specific plan’s rules before relying on that option.

Also remember that DPC membership fees do not count toward an HDHP deductible or out-of-pocket maximum. They are separate from the amounts your insurance plan applies toward covered care.

Starting in 2026, certain DPC payments may qualify for deductible and annual out-of-pocket credit under Oregon HB 2540. For some Oregon-regulated, non-HMO plans, insurers must offer a way to submit documentation after paying a provider directly and request credit. The care must be medically necessary, covered, and meet the law’s pricing condition. Ask your insurer whether a DPC membership fee or service qualifies and what proof it requires.

Why this change can matter for families and small businesses

For a household, the new rule can make it easier to combine DPC for everyday, relationship-based primary care with an HSA-eligible health plan for larger or unexpected medical expenses. Using qualified HSA funds may lower the membership’s effective out-of-pocket cost, though the actual tax benefit depends on your situation.

For a small-business owner, DPC can bring predictable pricing and direct provider access into the benefits discussion, while an HSA-compatible plan may help employees set aside funds for qualified costs. Employer payment and benefit design have separate tax rules, so businesses should work with a benefits professional or tax advisor before launching a program.

At Resolute Integrative Health, we believe transparent, predictable primary-care pricing should make it easier to understand your options, not harder. You can explore current membership options and pricing and ask how a membership may fit with your household’s or team’s coverage strategy.

Explore whether HSA-funded DPC fits your household or team

If you are considering Direct Primary Care in the Southern Oregon area, contact Resolute Integrative Health to discuss the membership model, current fees, and what is included. Bring questions about your HSA, HDHP, or employer benefits plan, then confirm the tax and plan details with your administrator or advisor.