HSAs and DPC after the 2026 rule change

Starting January 1, 2026, a DPC membership no longer keeps someone from contributing to a health savings account, and members can pay qualifying fees from their HSA. There are limits on the monthly fee and on what the membership can include, so check your plans against them with your attorney or CPA.

What changed

Before 2026, many people were told a DPC membership could cost them their HSA eligibility, and that HSA money couldn't pay the fee. The 2025 federal tax law changed that, effective January 1, 2026. A qualifying DPC arrangement doesn't disqualify someone from contributing to an HSA, and the membership fee counts as a medical expense the HSA can pay.

The limits

• The fee can't be more than $150 a month for an individual.
• The fee can't be more than $300 a month for a family.
• The membership has to be for primary care, not specialty, emergency or hospital care.
• Prescription drugs other than vaccines are left out of what the arrangement can cover.

There are more details in the law and in IRS guidance, including how the limits may change in later years. Your healthcare attorney or CPA can confirm how your plans line up.

What it means for your pricing

If your individual tier is $150 or less and your family tier is $300 or less, HSA holders can likely use their accounts for it, subject to the other rules. If a tier sits above the limit, that's worth a conversation before you change anything. Some practices may look at their tiers. Others will decide the limit doesn't matter for their members.

I'd look at your own numbers first. In a made-up example, a practice has 300 members, and 40 of them are on a $175 family tier that covers two people. Before touching that price, know what the tier brings in and run the math on any price change the same way you would for an increase.

What it means for your books

An HSA card payment comes in through your payment processor like any other card payment. You don't need a separate revenue account for it. A few things are worth setting up:

• Keep membership revenue by tier, so you can see what each tier brings in.
• Record meds, labs and other add-ons on their own lines, not mixed into membership. Here's why that helps.
• Expect more members asking for receipts or statements for their HSA records. Make sure your membership platform can produce them.

What I'd do this week

• List your membership tiers with their monthly prices.
• Mark any tier above $150 for an individual or $300 for a family.
• Ask your attorney or CPA whether your plans fit the rules, and how to word them.

Common questions

Do I have to do anything to accept HSA cards?
HSA cards usually run like debit cards through your normal processor. Check with your membership platform or processor that they work.

Does an employer-paid membership count toward the limits?
That depends on how the arrangement is set up. Ask your CPA or healthcare attorney before you sign an employer contract that relies on HSAs.

Should I lower my price to fit under the limit?
Not without running the numbers. Know what the change does to your monthly revenue first, then decide.