HSA & DPC: What's New for 2026

Dr. Katherine Welch
Dec 30, 2025
4 min read

There are good changes coming up regarding how you can use your HSA funds! The following is lifted directly from the Atlas.MD blog. Made my job a lot easier to paste the explanations here with a link to the original. Hope this helps you!

For years, DPC doctors and patients have faced an unnecessary hurdle: federal rules created uncertainty around whether a DPC membership could be combined with a Health Savings Account (HSA), and many people avoided doing so.

That’s changing.

Since the passing of the “One Big Beautiful Bill Act”, DPC will finally be recognized for what it is: a direct medical service. Patients will be able to pair DPC memberships with high-deductible health plans (HDHPs) and use their HSAs to pay for DPC, all without jeopardizing their HSA eligibility.

This guide will give you everything you need to know about HSAs, what’s changing, how these changes affect your patients, employers, and DPC as a whole, and how to communicate these changes effectively.

Let’s break it down.

What Is an HSA?

An HSA is a tax-advantaged account available to patients with an HDHP. Patients contribute pre-tax dollars, let that money grow tax-free, and withdraw funds tax-free for qualified medical expenses. It is like a kind of “tax-free health wallet.” You put money in before taxes, and when you spend it on medical care, you don’t owe taxes on it at all.

For 2025, the IRS has set contribution limits at $4,300 for individuals and $8,550 for families, with an additional $1,000 “catch-up” allowance for those age 55 and older.

Unlike a flexible spending account (FSA), the money in an HSA rolls over year after year; there’s no “use it or lose it.”

The account is portable, meaning it belongs to the patient rather than their employer, and it also offers retirement flexibility. After age 65, funds can be withdrawn for non-medical expenses and are taxed the same as ordinary retirement income.

Together, these features make an HSA much more than a short-term spending tool. For many patients, it functions as both a healthcare fund and a long-term savings vehicle.

How HSAs Work in Practice

Most patients use their HSA for everyday qualified expenses, such as office visits, prescriptions, lab tests, mental health care, and medical devices. HSAs function almost like a debit card, except with the bonus of tax-free spending.

There’s also a retirement twist: once a patient turns 65, HSA withdrawals for non-medical expenses are simply taxed like regular retirement income. That means an HSA acts like a hybrid: part health fund, part retirement account.

For everyday care, though, the main value is straightforward: patients use pre-tax dollars to pay for the care they need, when they need it.

What’s Changing

For years, many patients wanted to know if they could use their HSA to pay for their DPC membership. They could use HSAs for labs, imaging, or prescriptions ordered through their DPC doctor, but not the membership fee itself.

However, DPC will soon be formally recognized as a qualified medical expense under federal law. In practical terms, this means patients will be able to use HSA funds to pay for their monthly DPC memberships, just as they would for any other direct healthcare service.

On top of that, patients enrolled in DPC who also have a qualified high-deductible health plan will be allowed to contribute to an HSA. This means they’ll be able to enjoy the simplicity of direct care and the tax advantages of an HSA.

The law also sets clear financial and scope limits for qualifying DPC arrangements:

Patients can use HSA dollars for up to $150 per month for individuals or $300 per month for families, indexed for inflation.
The membership must provide primary care services by a primary care practitioner, paid via a fixed periodic fee, not per-visit billing.

The legislation also expands access in a few key ways:

Bronze and Catastrophic marketplace plans will automatically qualify as HSA-eligible HDHPs, giving more patients access to the DPC + HDHP + HSA combination. This change applies to individual marketplace plans, not the Small Business Health Options Program or small-group exchanges.
The telehealth safe harbor is now permanent, allowing patients to use telehealth services— including DPC virtual visits—before meeting their deductible without affecting HSA eligibility.
The Dependent Care FSA limit increases from $5,000 to $7,500 per household (or $3,750 if married filing separately) and is not indexed for inflation. This gives employers more flexibility when designing benefits.

The IRS will issue additional guidance in the coming months to clarify documentation standards and reimbursement procedures. We expect to see specifics on: