Is a Direct Primary Care Fee HSA-Eligible?
Yes — as of January 1, 2026, a qualifying direct primary care (DPC) fee is an HSA-qualified expense. Before 2026 it generally wasn’t, and a DPC membership could even disqualify your HSA contributions. The One Big Beautiful Bill, with IRS guidance issued in December 2025, changed both.
But “qualifying” is doing real work in that sentence. Here are the conditions.
The four conditions
To be a qualifying direct primary care service arrangement, the arrangement generally must:
- Provide solely primary care services. Primary care — not specialty or hospital care.
- Be delivered by a primary care practitioner. A real, ongoing clinical relationship.
- Treat the periodic fee as the compensation for those primary care services.
- Not bundle disqualifying items into the fee — specifically, no procedures requiring general anesthesia, no prescription drugs other than vaccines, and no lab services that aren’t typically provided in an ambulatory primary-care setting.
What “no prescription drugs” really means
This trips people up. It does not mean your DPC doctor can’t prescribe medication — prescribing during a visit is ordinary primary care. It means the drug itself can’t be bundled into the membership fee. You get the prescription, then fill it separately (at a pharmacy, or from an in-house dispensary) as its own transaction. The familiar DPC pitch — “your membership covers the visits; medications are billed separately” — is exactly the compliant structure.
The dollar limits
Even a perfectly qualifying arrangement is only HSA-eligible up to the caps: $150/month for an individual, $300/month for a family ($1,800 / $3,600 annualized). Pay more than that and the excess simply isn’t HSA-qualified — it doesn’t void the rest.
And it has to be your money
The fee must come from your own HSA. If an employer pays it — including through a pre-tax salary-reduction (Section 125) plan — it’s not HSA-reimbursable.
For the full picture, see the 2026 pillar guide. Wondering whether joining affects your contributions? See does a DPC membership disqualify my HSA contributions?
Frequently asked questions
Is a DPC membership fee a qualified HSA expense?
Yes, as of January 1, 2026 — if it's a qualifying direct primary care arrangement and the fee is within the caps ($150/month individual, $300/month family). The fee must be for solely primary care from a primary care practitioner and paid from your own HSA.
What disqualifies a DPC arrangement?
Bundling services outside primary care into the fee — procedures requiring general anesthesia, prescription drugs other than vaccines, or lab services not typically provided in an ambulatory primary-care setting — can push an arrangement outside the qualifying definition.