HSA + Direct Primary Care: The 2026 Rules and Limits
Here are the 2026 HSA + direct primary care (DPC) rules, laid out point by point. The source is the One Big Beautiful Bill and IRS Notice 2026-05 (issued December 9, 2025).
Effective date
January 1, 2026. The DPC provisions apply for months beginning after December 31, 2025.
Two distinct changes
The 2026 rules do two separate things — it’s worth keeping them apart:
- Eligibility: A qualifying DPC arrangement no longer counts as disqualifying “other coverage,” so it no longer blocks you from contributing to an HSA (you still need a qualifying HDHP).
- Spending: A qualifying DPC fee is now a qualified medical expense, so you can pay it from your HSA tax-free.
The dollar limits
| Monthly cap | Annualized cap | |
|---|---|---|
| Individual | $150 | $1,800 |
| Family | $300 | $3,600 |
- Aggregate: the cap applies across all of a person’s DPC arrangements combined.
- Annualized billing is allowed: a practice can bill quarterly or yearly as long as the fee is fixed, periodic, and stays within the cap on an annualized basis.
- Inflation-adjusted after 2026: expect the caps to rise in later years.
- Over the cap isn’t fatal: if your fee exceeds the cap, only the excess is non-qualified; the rest still counts.
The qualifying conditions
A qualifying direct primary care service arrangement generally must provide solely primary care services from a primary care practitioner for the periodic fee, and must not bundle into that fee:
- procedures requiring general anesthesia,
- prescription drugs other than vaccines, or
- laboratory services not typically provided in an ambulatory primary-care setting.
Prescribing itself is fine — it’s the drug as a bundled product that has to stay separate. (More on that in is a DPC fee HSA-eligible?.)
The employer-pay exclusion
This one catches people: the DPC fee has to be paid from the individual’s own HSA. If an employer pays it — including through a pre-tax salary-reduction (Section 125 cafeteria) plan — it is not reimbursable as a qualified HSA expense. Employer-sponsored DPC can still be a great benefit; it just isn’t the same thing as paying from your own HSA.
Where this comes from
The change is written into federal law: Section 110205, “Treatment of direct primary care service arrangements,” of the One Big Beautiful Bill Act (Public Law 119-21), enacted July 4, 2025. The IRS then issued plain-language guidance (Notice 2026-05). You can read both primary sources directly:
A moving target
Treasury and the IRS invited public comments on this guidance into 2026, and the caps adjust over time. Verify the current rule against the primary sources above before relying on any summary.
Start with the 2026 pillar guide for the overview, or check any unfamiliar term in its plain-English definitions.
Frequently asked questions
When did the HSA-DPC rule take effect?
January 1, 2026. It comes from the One Big Beautiful Bill, with IRS guidance (Notice 2026-05) issued December 9, 2025.
What are the 2026 HSA-DPC dollar limits?
$150 per month for an individual and $300 per month for a family — $1,800 and $3,600 annualized. The caps are aggregate across all DPC arrangements and are inflation-adjusted after 2026.
Can a DPC fee be billed annually instead of monthly?
Yes, as long as the fee is fixed, periodic, and does not exceed the cap on an annualized basis.