First published: February 17, 2026 / Last updated: February 28, 2026

Are direct primary care (DPC) fees HSA eligible?

If you have a high-deductible health insurance plan (HDHP) or are considering getting one, you may be wondering if you can save money by paying direct primary care fees with the pre-tax funds in your health savings account (HSA).

Here's the clear answer:

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What changed in 2026?

The One Big Beautiful Bill Act of 2026 amended the Internal Revenue Code to clarify two important points:

• Qualifying direct primary care arrangements are not treated as disqualifying coverage for HSA purposes.
• Periodic fees paid for qualifying DPC services can be treated as qualified medical expenses.

Before 2026, DPC memberships could be treated as other health coverage, which risked disqualifying HSA contributions. The 2026 update removed that uncertainty for properly structured arrangements.

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HSA eligibility rules for DPC fees

1. Monthly dollar limits apply

The law imposes a statutory cap on how much of your DPC membership fee may be treated as a qualified medical expense.

• Individual coverage: Up to $150 per month
• Family coverage: Up to $300 per month

2. The arrangement must qualify as primary care

The membership must cover primary care services only. If the arrangement bundles services that resemble comprehensive insurance — such as inpatient hospital care or broad specialist coverage — it may fail to qualify.

Under IRS guidance, primary care services do not include procedures requiring general anesthesia, prescription drugs (other than vaccines), or laboratory services not typically administered in an ambulatory primary care setting.

Qualifying DPC services commonly include:

• Office visits
• Preventive care
• Basic laboratory services
• Chronic condition management
• Telehealth access

3. You must still be HSA eligible

To contribute to an HSA, you must remain enrolled in an HSA-qualified high deductible health plan (HDHP) and have no other disqualifying coverage.

The 2026 update clarified that a qualifying DPC membership does not by itself disqualify HSA eligibility — but only if it meets the statutory requirements.

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How to document DPC fees for your HSA

If you use HSA funds to pay DPC membership fees, maintain documentation showing:

• The membership agreement (to demonstrate the structure of the arrangement)
• Monthly invoices or billing statements
• Proof of payment

If you are ever asked to substantiate an HSA distribution, you must be able to show that:

• The arrangement qualified as direct primary care under the statute.
• The amount reimbursed did not exceed the applicable monthly cap.

For more on documentation standards, see our HSA audit risk and documentation guide.

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Are DPC fees always fully eligible?

Status	When it applies
Fully eligible	The DPC arrangement qualifies and the monthly fee is at or below the statutory cap.
Higher risk/may affect eligibility	The monthly fees exceed the statutory cap. The arrangement may not qualify as a DPC service arrangement for HSA eligibility purposes, which can affect your ability to contribute while enrolled.
Not eligible	The arrangement includes non-primary care services or functions as insurance.

If you are unsure how a membership fits within IRS medical expense rules, review what makes an expense HSA eligible or use the HSA eligibility screener.

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Conclusion

Starting in 2026, qualifying direct primary care membership fees may be paid with HSA funds within strict monthly limits. Confirm that your arrangement meets the statutory definition of primary care and keep complete documentation before reimbursing yourself.

Sources

• H.R.1 (Sec. 71308) - Congress.gov
• Publication 502 - IRS
• Publication 969 - IRS
• Notice 2026-05 - IRS

Disclaimer

This page is for educational purposes only and is not tax or legal advice. Check with your HSA administrator or a qualified tax or legal professional if you have questions about your specific situation.