Yes. Starting January 1, 2026, you can generally use an HSA to pay a qualifying direct primary care membership and still keep contributing to your HSA, under the 2025 federal tax law and IRS Notice 2026-05. The membership must meet IRS conditions, including fee caps of $150 a month for one person and $300 for a family.
This is general information, not tax or legal advice. The rules are new, and your plan documents, your HSA administrator and your tax professional have the final word on your situation.
What changed for HSAs and direct primary care
Direct primary care (DPC) is a membership model. You pay a fixed periodic fee directly to a primary care practice, and the practice does not bill insurance for the services that fee covers. For years, DPC sat in a gray zone for HSA owners. An HSA requires a qualifying high-deductible health plan (HDHP) and, with limited exceptions, no other health coverage. Many tax advisers worried that a DPC membership could be treated as that kind of disqualifying coverage.
The 2025 federal tax law commonly called the One Big Beautiful Bill Act addressed this directly, and the IRS explained how the changes work in Notice 2026-05, released in December 2025. Beginning January 1, 2026:
- Being enrolled in a qualifying DPC arrangement does not, by itself, make you ineligible to contribute to an HSA.
- Qualifying DPC fees count as medical expenses that can be paid from an HSA tax-free.
- Bronze and catastrophic plans offered as individual coverage are treated as HSA-compatible.
- HDHPs can permanently cover telehealth before the deductible without affecting HSA eligibility.
What makes a DPC membership qualifying
Not every membership-style practice automatically fits. Under the law and IRS guidance, a qualifying arrangement generally must meet these conditions:
- Primary care only. Services must come from primary care practitioners. That group includes physicians in family, internal, geriatric or pediatric medicine, as well as nurse practitioners, clinical nurse specialists and physician assistants.
- A fixed periodic fee. The membership is paid as a set fee for a period of time, not billed to insurance or charged visit by visit.
- Certain services left out. The membership cannot include prescription drugs (vaccines are an exception), procedures that require general anesthesia, or lab services beyond those typically done in an outpatient primary care setting.
- Fees under the cap. More on that below.
Some practices also offer services outside the membership for a separate charge. Ask how those are billed, and check with your HSA administrator about whether they are treated as eligible medical expenses. If a practice charges a one-time enrollment or registration fee, ask your tax professional how that fits the fixed-periodic-fee requirement.
The $150 and $300 monthly caps
For 2026, the combined monthly fees for your DPC arrangements cannot exceed $150 for one person, or $300 for an arrangement that covers more than one person. The law adjusts these amounts for inflation in years after 2026.
Timing matters. Most Richmond-area employer open enrollment periods this fall, and the HealthCare.gov window that typically opens November 1, are choosing coverage for the 2027 plan year. The 2027 caps may differ from the 2026 figures, so look up the IRS’s current numbers rather than relying on an article, including this one, or a social media post.
For families
The family cap is where people most often get tripped up. If several people in your household have memberships, total up what you would pay in a typical month. Ask the practice how family memberships are billed (monthly, quarterly or in advance), and ask your HSA administrator how they apply the monthly cap when fees are paid for several months at once.
Bronze and catastrophic plans now count
This is a meaningful change for individual-market buyers in Midlothian, Chesterfield, Powhatan and Moseley, and for self-employed people buying their own coverage. Starting in 2026, bronze and catastrophic plans available as individual coverage are treated as HSA-compatible even if they don’t meet the traditional HDHP deductible and out-of-pocket rules. According to IRS guidance, the plan generally doesn’t have to be purchased through the Marketplace itself, but confirm with the insurer that your specific plan qualifies.
Two cautions. First, this provision applies to individual coverage. An employer plan with a bronze-level label is not automatically HSA-compatible, so read your benefits materials. Second, catastrophic plans have their own eligibility rules (generally people under 30 or those with a hardship or affordability exemption), and lower premiums come with higher out-of-pocket costs if you need hospital or specialist care.
HSA and FSA are not the same thing
Some practices describe memberships as HSA/FSA compatible in one breath. These accounts follow different rules:
- The 2026 changes were written for HSAs. Whether a health FSA will reimburse a DPC membership depends on your employer’s plan and its administrator. Ask before you assume.
- A general-purpose health FSA, including one through a spouse’s employer, is usually considered other coverage that blocks HSA contributions. A limited-purpose FSA for dental and vision generally does not. If your employer offers both, read the fine print before enrolling in both.
How DPC fits with a high-deductible plan
The pairing is logical: the membership handles routine primary care for a predictable fee, while an HDHP or bronze plan protects you against large bills from hospital stays, surgery, specialists, advanced imaging and emergencies. Direct primary care does not replace health insurance; it is designed to sit alongside it.
Budget separately for:
- Prescription medications, which are excluded from a qualifying membership fee.
- Lab work beyond routine primary care testing, often processed by an outside lab.
- Specialist visits, imaging, and urgent or emergency care, which generally go through your insurance.
Many of these costs may still be payable from your HSA as qualified medical expenses. Keep in mind that DPC membership fees generally don’t count toward your insurance deductible, because the insurer is never billed for them. Our page on whether direct primary care is worth it if you already have insurance walks through that trade-off.
Who still can’t contribute to an HSA
DPC eligibility doesn’t override the basic HSA rules. You generally cannot contribute if you:
- Are enrolled in Medicare Part A or Part B. (Venture Wellness’s DPC membership is not available to Medicare Part A or B enrollees.)
- Have other disqualifying health coverage, such as a general-purpose FSA or HRA.
- Can be claimed as a dependent on someone else’s tax return.
Even if you can’t contribute right now, money already in your HSA can generally still be spent on qualified medical expenses.
What to check before open enrollment
- Confirm your 2027 health plan is HSA-compatible: a qualifying HDHP, or an individual bronze or catastrophic plan.
- Ask the DPC practice for a written description of what the membership includes, what is billed separately and how fees are charged.
- Compare the monthly membership cost for your household with the IRS cap for the year you’re enrolling in.
- Check for any general-purpose FSA or HRA, including through a spouse’s employer.
- Ask your HSA administrator what documentation they need to reimburse DPC fees, and keep your receipts.
- Look up the current year’s HSA contribution limits on the IRS website.
- If you’re self-employed or own a small business, talk with your tax professional about how to set up DPC for yourself or your team. Our page on direct primary care for employers in the Richmond area is a good starting point.
What this means at Venture Wellness
Our DPC membership is nurse practitioner-led, and nurse practitioners are among the practitioners the law names. Whether any specific membership qualifies, though, depends on how all of its terms line up with the IRS rules and how your HSA administrator applies them. Current membership costs are listed on our DPC pricing page, so you can compare them with the caps for the year you’re enrolling in. We’re glad to explain what the membership includes and how it is billed; questions about how it affects your taxes belong with your tax professional or HSA administrator.
If you’re weighing a high-deductible or bronze plan for 2027 and want a primary care home in Midlothian, Chester, Brandermill or greater Richmond, see how our direct primary care membership works or call (804) 601-8625 before your enrollment deadline.
Frequently asked questions
Can I contribute to an HSA if I have direct primary care?
Starting January 1, 2026, generally yes, as long as the DPC arrangement meets IRS requirements and you otherwise qualify for an HSA (for example, you have an HSA-compatible health plan, are not enrolled in Medicare and have no other disqualifying coverage). This is general information, not tax advice; confirm with your HSA administrator or tax professional.
Is the $150 DPC limit per person or per family?
For 2026, the cap is $150 per month for an arrangement covering one person and $300 per month for an arrangement covering more than one person, combined across your DPC arrangements. The amounts are scheduled for inflation adjustments after 2026, so check the IRS figures for the year you’re enrolling in.
Can I use my FSA to pay for direct primary care?
It depends on your employer’s FSA plan. The 2026 changes were written for HSAs, not FSAs. Also note that a general-purpose health FSA, including a spouse’s, usually prevents you from contributing to an HSA, while a limited-purpose dental and vision FSA generally does not.
Do DPC membership fees count toward my insurance deductible?
Generally no. Because the practice does not bill your insurer for membership services, those fees usually don’t apply to your deductible or out-of-pocket maximum. Check your plan documents to be sure.
Are bronze plans HSA eligible in 2026?
Bronze and catastrophic plans available as individual coverage are treated as HSA-compatible starting in 2026. An employer plan labeled bronze is not automatically HSA-compatible, so confirm with your benefits administrator or insurer.
References
- Notice 2026-05: Health Savings Account Provisions of the One Big Beautiful Bill Act. Internal Revenue Service. 2025. www.irs.gov/pub/irs-drop/n-26-05.pdf
- H.R.1 – One Big Beautiful Bill Act (Public Law 119-21). Congress.gov. 2025. www.congress.gov/bill/119th-congress/house-bill/1
- Publication 969: Health Savings Accounts and Other Tax-Favored Health Plans. Internal Revenue Service. 2025. www.irs.gov/publications/p969
- Catastrophic Health Plans. HealthCare.gov (Centers for Medicare & Medicaid Services). n.d.. www.healthcare.gov/choose-a-plan/catastrophic-health-plans/
This article is for general education and is not a substitute for individual medical advice. Talk with a licensed clinician about your own situation.
