Guides · HSA and FSA

Can you use an HSA for direct primary care?

Yes. Since January 1, 2026, you can pay qualifying direct primary care (DPC) fees from an HSA, and a qualifying arrangement that costs $150 a month or less for one person ($300 for more than one) no longer stops you from contributing. The change comes from the One, Big, Beautiful Bill Act, explained in IRS Notice 2026-5.

The arrangement must be primary care only, paid only by a fixed periodic fee. If the fees go over the cap, you can still pay them from your HSA, but you can't contribute to the HSA while you're enrolled. Check with your plan administrator or a tax advisor.

Updated · Facts checked against the sources listed below

What changed in 2026

Before 2026, being in a DPC arrangement generally meant you couldn't contribute to an HSA, because the IRS treated it as other health coverage. The One, Big, Beautiful Bill Act (July 4, 2025) changed that for months starting after December 31, 2025. The IRS announced its guidance on December 9, 2025 (IR-2025-119).

  • Contributions: a qualifying DPC arrangement is not treated as a health plan, so it doesn't stop an otherwise eligible person from contributing.
  • Paying fees: DPC fees can be reimbursed from an HSA tax-free.
  • Timing: an HSA can reimburse a fee monthly, at the start of the coverage period, or on the day you pay it.

What counts as a qualifying DPC arrangement

Notice 2026-5 sets these conditions:

  • Primary care only, from primary care practitioners: physicians in family, internal, geriatric or pediatric medicine, or nurse practitioners, clinical nurse specialists and physician assistants.
  • A fixed periodic fee is the only payment. An arrangement that gives members items or services and bills for them separately, through insurance or otherwise, doesn't qualify (Q-11).
  • Excluded services: procedures that need general anesthesia, prescription drugs (with one narrow exception), and lab services not typical in a primary care office.
  • Fee cap: all your DPC fees together must be $150 a month or less for one person, or $300 if the arrangement covers more than one person. Yearly billing works if it stays within the cap, for example $1,800 a year for one person.
  • Terms decide, not your use. You can't skip the extra services to make an arrangement qualify (Q-14).

The IRS kept the $150 and $300 limits the same for 2027 (Rev. Proc. 2026-24).

If your DPC fees are over the cap

Fees above $150 ($300 for more than one person) can still be paid from your HSA as a medical expense. But the arrangement then counts as other coverage, so you can't make HSA contributions while you're enrolled (Notice 2026-5, Q-20).

If your employer pays your DPC fee, including through a cafeteria plan, you can't also reimburse it from your HSA (Q-18). And DPC fees don't count toward your high deductible health plan's deductible (Q-16).

What to check before you pay

  1. Get the agreement in writing. Confirm the monthly fee, who provides care, and what the fee covers.
  2. Ask whether anything is billed separately. Separate billing for members can disqualify the arrangement.
  3. Add up every DPC fee you pay. The cap applies to all your arrangements combined.
  4. Confirm you're HSA-eligible otherwise. You still need an HSA-eligible high deductible health plan. All Bronze and Catastrophic Marketplace plans work with an HSA, says HealthCare.gov.
  5. Ask your plan administrator or a tax advisor before you count on it.

Gabriel membership and your HSA

With Gabriel Core or Plus, the clinical portion of membership may be HSA/FSA eligible ($39 of Core's $49 monthly price, or $69 of Plus's $89); the wellness and concierge portion is not. Gabriel can provide an itemized statement.

Paying with HSA money is different from being allowed to contribute. Gabriel membership includes benefits beyond primary care, such as member pricing and urgent care, so it may not fit the DPC rules in Notice 2026-5 and could affect whether you can keep contributing. Ask a tax advisor before you contribute to an HSA while you're a member.

Common questions

Can I use my HSA to pay for direct primary care?

Yes, since January 1, 2026, qualifying DPC fees can be paid from an HSA. Check with your plan administrator or a tax advisor about your arrangement.

What is the HSA limit for direct primary care?

To keep contributing, all your DPC fees must total $150 a month or less for one person, or $300 if the arrangement covers more than one person. The IRS kept those amounts for 2027.

Can I still contribute to an HSA if I have direct primary care?

Yes, if the arrangement qualifies under IRS rules and stays within the fee cap, and you're otherwise eligible. If the fees are over the cap, you can't contribute while enrolled.

Do direct primary care fees count toward my HDHP deductible?

No. The IRS says DPC fees aren't out-of-pocket costs for services your high deductible health plan covers, so they don't count toward its deductible or out-of-pocket maximum.

Can my health plan pay my direct primary care fee before the deductible?

No. Notice 2026-5 says a high deductible health plan can't pay DPC fees or provide DPC membership before the deductible is met.

Sources

  1. Notice 2026-5: direct primary care service arrangements and HSAs Internal Revenue Service
  2. Treasury, IRS provide guidance on new tax benefits for health savings account participants Internal Revenue Service
  3. Revenue Procedure 2026-24: 2027 HSA and DPC inflation adjusted amounts Internal Revenue Service
  4. High Deductible Health Plan (HDHP) HealthCare.gov

This guide is general information, not medical advice. It does not replace a visit with a licensed clinician. Gabriel membership is not health insurance.