Can You Pay for Direct Primary Care With an HSA in 2026?

For years the honest answer to this question was "it's complicated." A direct primary care membership looked like a health plan to the IRS, and having other coverage disqualifies you from contributing to a health savings account. Many people who wanted both quietly gave up one. That changed on July 4, 2025, when Public Law 119-21 was signed, and the change took effect for months beginning after December 31, 2025.

What the law says

Section 71308 of the law, titled "Treatment of Direct Primary Care Service Arrangements," adds a new paragraph to Internal Revenue Code section 223(c)(1). It says that a direct primary care service arrangement is not treated as a health plan for HSA eligibility purposes, provided:

• the arrangement provides medical care consisting solely of primary care services,
• the sole compensation is a fixed periodic fee, and
• the fee does not exceed $150 a month for an individual or $300 a month for an arrangement covering more than one person.

The same section makes those fees a qualified medical expense, which means you can pay the membership from the HSA itself. The dollar caps are indexed for inflation with 2025 as the base year.

What is excluded

The law defines primary care services narrowly enough that some memberships will not qualify as written. The definition excludes procedures that require general anesthesia, prescription drugs other than vaccines, and laboratory services not typically administered in an ambulatory primary care setting. A practice that bundles in-house medications or specialty labs into the monthly fee needs to unbundle them and bill separately for the arrangement to qualify. Several practices in this directory dispense medications from an in-house pharmacy or fold weight-loss injections into a tier, so this matters in practice, not just in theory.

Which local practices are inside the cap

The national average DPC fee is about $98 a month, comfortably under $150, so most practices qualify on price. In Northeast Florida, every practice with a published adult price is at or under $150 except R&R Collective ($189) and Paradigm Primary Care ($199 to $299). Family arrangements are where the $300 cap bites: two adults and two children at a practice charging $125 per adult and $75 per child comes to $400, which exceeds the family cap. Each listing on this site shows an HSA badge based on the lowest adult tier, and the county pages list every practice's family pricing so you can do that math.

The plan that goes with it

An HSA requires an HSA-qualified high-deductible health plan. For 2026 the minimum deductible is $1,700 for self-only coverage and $3,400 for family, and the contribution limits are $4,400 and $8,750. Starting with the 2026 plan year every Bronze plan on the federal Marketplace is HSA-compatible, and ACA Catastrophic plans, a Marketplace category generally limited to people under 30 or with an exemption, are treated the same way. The combination that a licensed agent will typically build is:

1. A Marketplace HSA-qualified Bronze plan (or an ACA Catastrophic plan if you are under 30 or qualify for an exemption) for the hospital, specialist and surgical risk, priced for your county and income.
2. A DPC membership of $150 a month or less for all your primary care, paid from the HSA.
3. Pre-tax HSA contributions up to the annual limit, which now cover both the membership and any deductible spending.

Whether that stack beats a Silver plan with copays depends on your income, your subsidy, how often you see a doctor and which medications you take. The coverage partner on every county page runs that comparison at no cost to you; when coverage is enrolled, compensation generally comes from the insurance company or coverage organization.

This page describes federal law and IRS guidance in general terms. It is not tax advice. Confirm your own situation with the practice and a tax professional.