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New for 2026

Direct Primary Care is now HSA-eligible.

A 2025 law change fixed a long-standing conflict. Here's what it means — and why it makes the Choice model even stronger.

For years, there was a frustrating catch: if you had a Direct Primary Care membership, the IRS treated it as "other coverage" that disqualified you from contributing to a Health Savings Account. As of the 2025 law, that conflict is gone — and starting January 1, 2026, DPC and HSAs officially work together.

$150
Max monthly DPC fee, individual (HSA-compatible)
$300
Max monthly DPC fee, family
Jan 1, 2026
Effective date of the change

What changed

The tax-and-spending law signed on July 4, 2025 included a fix that benefits advocates had wanted for years. Effective January 1, 2026, a Direct Primary Care arrangement is no longer treated as disqualifying coverage for HSA purposes — as long as the membership fee stays within $150/month for an individual or $300/month for a family. Those caps are indexed to inflation going forward.

The two things this unlocks

  • You can keep DPC and still fund an HSA. Pair a DPC membership with an HSA-eligible high-deductible plan and keep making tax-advantaged HSA contributions — something that wasn't allowed before.
  • DPC fees are now a qualified medical expense. Within those monthly limits, DPC membership costs can be paid or reimbursed from HSA funds — pre-tax dollars for the primary care people use most.

Why this matters for the Choice modelWe already embed unlimited Direct Primary Care in every plan we build. This change means an employee on an HSA-eligible plan can now get that unlimited primary care and keep building tax-free HSA savings — no trade-off. It's a cleaner, more tax-efficient benefit than a traditional group plan can offer.

Why DPC belongs in the picture at all

Most of what people actually use health care for is primary care — checkups, sick visits, chronic-condition management, quick questions. DPC covers all of that for a flat monthly fee: unlimited visits, longer appointments, and direct access to a physician, with no per-visit copays. Insurance is still there for the big, unpredictable things; DPC handles the everyday. Pairing the two is simply a better-designed benefit.

What it means for you

  • Employers: a more valuable, more tax-efficient offer to recruit and retain — without adding cost complexity.
  • Employees: unlimited primary care plus the ability to keep saving in an HSA, pre-tax.
  • Brokers: a genuine 2026 differentiator to bring to renewal conversations that group plans can't replicate.

See how we build it on the ICHRA + DPC page, or ask us how it applies to your plan.

General information, not tax or legal advice. Confirm specifics with your advisor; monthly limits are inflation-adjusted after 2026.

The best of both

Unlimited primary care, plus HSA savings.

Choice embeds Direct Primary Care in every plan — now fully compatible with HSAs.

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