Can I use my HSA for direct primary care?

What an HSA is

HSA stands for health savings account, which is a special savings account for medical costs. You put money in, and you do not pay income tax on it when you use it for health care. The money stays in the account from year to year, so it does not disappear on January 1.

To put new money into an HSA, you generally need a certain kind of health plan, called a high-deductible health plan. If you already have money in an HSA, you can usually spend it on qualified medical costs. These are the costs the IRS counts as health care.

What is a high-deductible health plan?

A deductible is the amount you pay yourself each year before your insurance starts to pay. A high-deductible health plan, or HDHP, is a plan with a deductible above a minimum set by the IRS. In exchange, the monthly premium is often lower. The premium is the amount you pay each month to keep the plan.

Not every plan with a high deductible counts as an HDHP for HSA purposes. Your insurer or your plan papers should say whether yours is "HSA-eligible." If you want to learn more about how high deductibles work, see our guide on high deductibles.

What changed in 2026

Before 2026, direct primary care could cause a problem for HSA owners. In general, you cannot put money into an HSA if you also have other health coverage besides your high-deductible plan. A direct primary care membership could be seen as that kind of extra coverage, which put some people's HSA at risk.

A federal law passed in 2025 changed that. Starting January 1, 2026, a direct primary care arrangement that meets certain rules is not treated as extra health coverage. A person can now have a qualifying direct primary care membership and still put money into an HSA. The law also says the person can use HSA money to pay the monthly fees. A direct primary care membership is not insurance, so it does not pay for the emergency room, a hospital stay or surgery.

The IRS, the federal tax agency, explained how this works in a document called Notice 2026-5. This guide is based on that notice.

What are the $150 and $300 limits?

The new rule puts a cap on the monthly fee. An arrangement fits the rule if the fees are $150 a month or less for one person. If the arrangement covers more than one person, such as a family, the cap is $300 a month. The IRS says these amounts will be adjusted for inflation after 2026, so they may go up in later years.

A practice can bill for longer periods if it wants. The notice says a fee can cover a period of up to a year. The amount just has to work out to the monthly limit or less. For example, in 2026, $1,800 for a year is within the limit for one person.

The limit is mostly about keeping your HSA eligibility. If the fee is above the cap, the arrangement does not count as a qualifying direct primary care arrangement under the new rule. The notice says that would stop you from putting new money into an HSA while you are enrolled.

It also says HSA money can still be used to reimburse those fees as a medical expense. That is a tricky point, so please do not decide on your own. A tax adviser can tell you what it means for you.

Which services are left out?

To fit the rule, the arrangement has to cover only primary care services. The only payment has to be the fixed fee. Primary care means everyday care from a family medicine, internal medicine, geriatric or pediatric doctor. It can also mean care from a nurse practitioner, clinical nurse specialist or physician assistant.

The notice says the care cannot include procedures that need general anesthesia, which is medicine that puts you fully to sleep. It also cannot include prescription drugs, except vaccines. Lab tests that are not usually done in a primary care office are left out as well.

The notice also says the fee has to be the only payment for that care. If a practice bills your insurance on top of the fee for the same kind of care, it may not fit. That means some concierge-style practices may not qualify. You can read more about the differences in our guide to direct primary care and concierge medicine.

Other things to know

• Whether a membership fits is based on its terms, not on what services you end up using.
• If your employer pays the fee for you, you cannot also reimburse that fee from your HSA. This includes a payroll deduction set up through the employer.
• If you want to keep your HSA eligibility, your high-deductible plan cannot pay for your direct primary care membership before you meet your deductible.
• Money you pay for a direct primary care membership does not count toward your plan's deductible.
• Other HSA rules still apply to you, and they depend on your age, your other coverage and your tax situation.

What should I do next?

1. Find out whether your health plan is an HSA-eligible high-deductible plan.
2. Ask any practice you like for its monthly fee, and whether it fits the rule. Our checklist of questions can help.
3. Ask your HSA provider whether it pays direct primary care fees by card or by reimbursement.
4. Keep your receipts and a copy of the membership agreement.
5. Talk to a tax adviser before you rely on any of this. The rule is new, and your situation may be different from the examples here.

To learn what direct primary care is, read our basic guide. To find a practice near you, use the doctor search. If you work for yourself, our guide on health care for the self-employed covers your choices. This is general information and is not tax or legal advice. In an emergency, call 911 or go to the nearest emergency room.