The One Big Beautiful Bill Act (OBBBA), signed into law on July 4, 2025, made significant changes to HSA rules. Here's what you need to know.
1. Bronze and Catastrophic Plans Now Qualify
Effective January 1, 2026
Previously, only plans meeting strict HDHP requirements allowed HSA contributions. Now, many Bronze and Catastrophic health plans may qualify as HSA-compatible, subject to IRS rules and individual plan design.
What this means for you:
- More health plan choices while keeping HSA eligibility
- Lower premiums may be available
- Check if your marketplace plan now qualifies
2. Direct Primary Care (DPC) Is Now HSA-Compatible
Effective January 1, 2026
Direct Primary Care memberships—where you pay a monthly fee directly to a doctor for unlimited primary care—are now fully HSA-compatible.
Key details:
- Monthly fee limits: Up to $150/month (individual) or $300/month (family)
- These limits will adjust annually for inflation
- You can pay DPC fees with HSA funds tax-free
- Having a DPC arrangement no longer disqualifies you from contributing to an HSA
What is DPC? You pay a flat monthly fee (typically $50-$150) to a primary care doctor. In return, you get unlimited visits, same-day appointments, and direct access—no insurance billing involved.
Why it matters: You can now pair an HDHP + HSA with a DPC membership for the best of both worlds: low premiums, tax-advantaged savings, AND convenient primary care access.
3. Telehealth Exemption Is Now Permanent
Effective for plan years beginning January 1, 2025+
During COVID, the government temporarily allowed telehealth services before meeting your HDHP deductible without losing HSA eligibility. This is now permanent.
What this means:
- Your health plan can offer free or low-cost telehealth visits
- You don't have to meet your deductible first
- Your HSA contribution eligibility is unaffected
- Applies to telehealth, telemedicine, and other remote care
4. Updated Contribution Limits
| 2025 | 2026 | Change | |
|---|---|---|---|
| Individual limit | $4,300 | $4,400 | +$100 |
| Family limit | $8,550 | $8,750 | +$200 |
| Catch-up (55+) | $1,000 | $1,000 | No change |
5. HDHP Requirements for 2026
| 2025 | 2026 | |
|---|---|---|
| Minimum deductible (individual) | $1,650 | $1,700 |
| Minimum deductible (family) | $3,300 | $3,400 |
| Max out-of-pocket (individual) | $8,300 | $8,500 |
| Max out-of-pocket (family) | $16,600 | $17,000 |
Action Items for 2026
- Review your health plan: Does your marketplace plan now qualify for HSA contributions?
- Consider DPC: If you value convenient primary care, explore DPC memberships in your area
- Update contributions: Increase your payroll deductions to the new 2026 limits
- Check telehealth: Confirm your plan offers pre-deductible telehealth (most now do)
These updates reflect IRS guidance effective for plan years beginning January 1, 2026. Employer plan designs may vary.
Sources: IRS Revenue Procedure 2025-19 (2026 contribution limits and HDHP thresholds), One Big Beautiful Bill Act — Section 110301–110303 (Bronze/Catastrophic plan eligibility, DPC compatibility, telehealth permanence).