Can You Pay for Direct Primary Care With an HSA? (Yes, the Rules Changed in 2026)

For years, the answer to this question was a frustrating no. People loved the idea of pairing a Direct Primary Care membership with a Health Savings Account, and the IRS would not allow it. That barrier is gone. Starting January 1, 2026, you can pay for a Direct Primary Care membership with HSA funds, and joining a DPC practice no longer disqualifies you from contributing to your HSA.

The change comes from the One Big Beautiful Bill Act, signed into law on July 4, 2025, which formally recognizes Direct Primary Care memberships as qualified medical expenses under federal HSA rules. If you have an HSA, or you have been holding off on DPC because of one, this changes your math. Here is what the new rules say and exactly how they apply at Meadow.

What changed, in plain English

Before 2026, the IRS treated a DPC membership as "other health coverage." That classification meant that simply belonging to a DPC practice made you ineligible to contribute to an HSA, and HSA dollars could not be used to pay membership fees. Patients had to choose between the care model they wanted and the tax-advantaged account they wanted.

The new law creates a category called a Direct Primary Care Service Arrangement and settles both problems at once. A qualifying DPC membership is no longer disqualifying coverage, so you can keep contributing to your HSA while enrolled. And membership fees are now qualified medical expenses, which means you can pay them with pre-tax HSA dollars. The IRS issued implementation guidance in Notice 2026-05 confirming how it works.

The limits that matter

To qualify, the arrangement must provide only primary care services for a fixed, periodic fee, and the fee must fall under federal caps: $150 per month for an individual and $300 per month for an arrangement covering more than one person. Both caps are indexed for inflation going forward. Fees can be billed monthly, quarterly, or annually, as long as the annualized amount stays under the cap.

The fine print worth knowing

Two nuances keep this honest. First, to contribute new money to an HSA at all, you still need to be enrolled in a qualifying High-Deductible Health Plan. The DPC rule change removed one barrier to eligibility, but it did not remove the HDHP requirement, which is why DPC plus an HDHP plus an HSA has become such a popular combination. If you already have that setup, your Meadow membership now slots right in.

Second, if a DPC arrangement's fees exceed the caps, IRS guidance still allows HSA funds to reimburse the fees, but enrollment in that arrangement blocks new HSA contributions. That trade-off will not affect Meadow members, since our fees sit under the caps, but it is worth knowing if you are comparing practices.

How to actually use your HSA at Meadow

It is simple. Pay your membership with your HSA debit card, or pay normally and reimburse yourself from the HSA, keeping your receipts either way. Meadow provides documentation of your membership fees on request. If you also carry a PPO and want to understand out-of-network reimbursement for services, our guide to superbills covers that separately.

For families running the numbers: an adult paying $119 per month from pre-tax HSA dollars is effectively getting a meaningful discount equal to their marginal tax rate, on top of a membership that already replaces copays, urgent care bills, and rushed seven-minute visits. For employers, the same law opens the door to pairing DPC with HDHPs and HSAs as a formal benefits strategy, something we cover in our small business guide.

The bottom line: the last regulatory reason to hesitate on Direct Primary Care disappeared on January 1. Your HSA and your Meadow membership now work together, exactly the way patients always wished they would.