Healthcare planning
Expanded HSA eligibility reaches more plans and direct primary care arrangements
The new law permanently protects pre-deductible telehealth access and, beginning in 2026, expands HSA compatibility to certain bronze, catastrophic, and direct primary care arrangements.
The changes may give business owners, employees, and medical-practice patients more HSA options. Eligibility still depends on the full coverage arrangement, contribution months, other disqualifying coverage, and the detailed limits for direct primary care fees.
Telehealth relief is permanent
For plan years beginning on or after January 1, 2025, qualifying telehealth and remote-care services may be provided before the high-deductible health plan deductible is met without automatically preventing HSA contributions.
More marketplace plans can qualify
Beginning January 1, 2026, bronze and catastrophic plans may be treated as HSA-compatible under the expanded rules, whether obtained through an exchange or outside one.
Direct primary care gained limited compatibility
Beginning in 2026, certain direct primary care arrangements may coexist with HSA eligibility, and HSA funds may be used tax-free for qualifying periodic fees, subject to statutory definitions and limits.
Payroll and enrollment records should agree
Employers and individuals should coordinate plan documents, coverage effective dates, HSA payroll deductions, employer contributions, and any other health coverage. Contribution limits can change when eligibility begins or ends during the year.
Do not rely only on a plan’s marketing label. Confirm HSA eligibility from the plan documents and coverage dates, then coordinate payroll and personal contributions with the annual limit.
Apply the guidance to your facts
Discuss the accounting and tax decisions behind the form.
We begin with the records, entity structure, timing, and decisions that apply to your situation.
Schedule a complimentary callThis article provides general educational information and is not individualized accounting, legal, investment, or tax advice. Tax rules and forms change; confirm the current requirements for your facts before acting.