Direct primary care (DPC) arrangements have long presented challenges for HSA compatibility, as their fixed monthly fees typically cover non-preventive services, like office visits for chronic or acute care, before a deductible is met, conflicting with the HSA requirement that no other plan provide such first-dollar coverage.
Starting in 2026, the OBBB resolves this issue by explicitly exempting DPC arrangements from being considered disqualifying coverage, making them compatible with HSA participation. To qualify, DPC fees must not exceed $150 per month for individuals or $300 for families, with these limits indexed for inflation. Additionally, the Act clarifies that DPC fees are considered qualified medical expenses, allowing them to be paid tax-free from an HSA.
