Can patients use HSA funds for direct primary care memberships in 2026?
Yes. Starting January 1, 2026, patients can use HSA funds to pay for direct primary care memberships. Having a DPC membership also no longer knocks them out of HSA eligibility. The change comes from Section 71307 of the One Big Beautiful Bill Act, and it fixes a problem DPC practices have dealt with for years.
Before this law, many DPC arrangements were treated as a form of health coverage. A patient with a high-deductible health plan who also paid for a DPC membership risked losing the ability to contribute to their HSA. A lot of patients ended up choosing one or the other. Under the new rule, a qualifying DPC arrangement isn’t treated as a health plan for HSA purposes, and the membership fee counts as a medical expense the HSA can pay.
There are limits. The membership fee can’t exceed $150 per month for an individual or $300 per month for an arrangement covering more than one person, such as a family membership. Those amounts will be adjusted for inflation after 2026. The arrangement also has to be for primary care services provided for a fixed periodic fee. If your fee is above the cap, the arrangement may not meet the definition at all, which puts your patients’ HSA eligibility back at risk. Check your pricing before you finalize 2026 membership rates.
Patients still need an HSA-qualified high-deductible health plan to contribute to an HSA. The new rule removes the DPC barrier. It doesn’t change the other requirements.
For owners of direct primary care practices, how you structure and document memberships matters more now than it did before. A few things are worth getting right.
Keep the membership fee fixed and in writing. Each patient agreement should state the monthly amount, what the membership covers, and who is covered. A fee that moves up and down based on visits or services starts to look less like a fixed periodic fee.
Bill add-on services separately. Labs, in-office procedures, dispensed medications, and anything outside of primary care should go on their own invoice or line item. Don’t fold them into the membership fee. Patients may still be able to pay for some of those from their HSA as regular medical expenses, but they shouldn’t be bundled into the DPC fee that’s subject to the monthly limit.
Give patients clear receipts. HSA administrators can ask account holders to prove what a withdrawal paid for. A statement showing the membership period, the fee, and the covered members saves your patients trouble and saves your front desk from repeat phone calls. If patients prepay several months or a full year, show which months the payment covers so it lines up with the monthly limit.
Your books should mirror all of this. In QuickBooks, set up separate income accounts for membership revenue and add-on services. That makes it easy to confirm your charges match your patient agreements and to pull records quickly if a patient’s HSA claim gets questioned. It also gives you a clearer picture of how much of your revenue actually comes from memberships.
The IRS may issue more guidance on the finer details, so watch for updates during the year. If you’re opening a DPC practice or adjusting membership pricing for 2026, our healthcare bookkeeping services can set up your books so membership and add-on revenue stay separate from the start.
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