HSA Eligibility Expansion 2026: Bronze Plans, Direct Primary Care, and Telehealth

What changed for HSAs in 2026? The One Big Beautiful Bill Act, signed in July 2025, opened health savings accounts to more people. Starting January 1, 2026, bronze and catastrophic plans count as HSA-eligible health plans, people with a direct primary care membership can still contribute to an HSA, and telehealth before your deductible no longer affects HSA eligibility. The Internal Revenue Service (IRS) explained how the new rules work in Notice 2026-5.

This guide covers each part of the HSA eligibility expansion in 2026, who can contribute now, the 2026 and 2027 HSA contribution limits, and what didn't change.

What Changed for HSAs in 2026?

Before these changes, you could only contribute to an HSA if you had a high deductible health plan (HDHP) and no other disqualifying coverage. Many bronze plans didn't meet the HDHP rules, and a direct primary care membership could count as other coverage. The new rules fix both.

Bronze and Catastrophic Plans Are Now HSA-Eligible

Starting in 2026, bronze and catastrophic plans are treated as HSA-compatible, even if their deductible or out of pocket maximum doesn't match the usual HDHP rules.

• Bronze plans are designed to cover about 60% of the cost of care, with lower premiums and higher out-of-pocket costs.
• Catastrophic plans cover essential health benefits only after you reach the plan's cost-sharing limit. They're available to people under 30 or those with a hardship exemption, and those enrollment limits still apply.

You don't have to buy the plan through an Exchange. According to Notice 2026-5, a bronze or catastrophic plan bought off-Exchange still counts when the same plan is available as individual coverage through an Exchange. An employer can also help you buy one through an individual coverage HRA (ICHRA) without breaking HSA eligibility, as long as the HRA only reimburses premiums.

The other HSA rules still apply. Having a bronze plan doesn't make you eligible if you also have a general-purpose health FSA, are enrolled in Medicare, or can be claimed as a dependent on someone else's tax return.

Direct Primary Care Memberships and HSAs

A direct primary care (DPC) arrangement is a membership with a primary care practice: you pay a fixed periodic fee, often monthly, for primary care services like office visits, check-ups, and basic tests, without billing insurance for each visit. Under the old HSA rules, a DPC membership could count as other health coverage and stop you from contributing to an HSA.

From 2026, an otherwise eligible person enrolled in a qualifying direct primary care arrangement can still contribute to an HSA. You can also use HSA funds to pay the periodic DPC fees tax-free, because the IRS now treats them as qualified medical expenses.

To qualify, the arrangement must meet the statutory definition in Notice 2026-5:

• Care comes from primary care practitioners, and the only payment is a fixed periodic fee.
• The fee can't be more than $150 per month for individual coverage or $300 per month for family coverage in 2026. The IRS adjusts these limits for inflation after 2026.
• It can't include procedures that need general anesthesia, prescription drugs (other than vaccines), or lab services not typically done in a primary care office.

A DPC membership that charges more or covers those excluded services doesn't qualify for the new rule, so check with the practice before you join. Keep your DPC agreement and fee receipts, since the usual HSA documentation requirements still apply.

The Permanent Telehealth Safe Harbor

During the pandemic, Congress let high deductible health plans cover telehealth before the deductible without affecting HSA eligibility. That relief was temporary and was extended several times. The One Big Beautiful Bill Act made it permanent for plan years beginning after December 31, 2024.

Under the permanent telehealth safe harbor, an HDHP can cover telehealth and other remote care services, including virtual care visits on Medicare's telehealth list, with no deductible, and you can still make HSA contributions (Notice 2026-5).

Who Can Contribute to an HSA in 2026?

The HSA eligibility requirements now look like this. To contribute to an HSA for a month, you need to:

1. Be covered by an HSA-eligible health plan: a high deductible health plan (HDHP), or starting in 2026, a bronze or catastrophic plan.
2. Have no other disqualifying coverage, such as a general-purpose health FSA (yours or your spouse's). A limited purpose FSA for dental and vision care is fine, and so is a qualifying DPC membership.
3. Not be enrolled in Medicare. Medicare enrollment, including Part A, ends your ability to contribute.
4. Not be claimed as a dependent on someone else's tax return.

If you become eligible partway through the year, the last month rule may let you contribute the full annual amount, but you have to stay eligible through a 12-month testing period or pay income tax plus a 10% additional tax on the extra amount. For details, see IRS Publication 969.

2026 and 2027 HSA Contribution Limits

HSA contribution limits rise with inflation each year. Your payroll deductions and any employer contributions count toward the same annual contribution limit.

Sources: Rev. Proc. 2025-19 for 2026 and Rev. Proc. 2026-24 for 2027. Read more about the 2027 HSA contribution limits.

If you're married and either spouse has family coverage, you share one family limit, split however you choose. If you're both 55 or older, each spouse can add a $1,000 catch-up contribution, but only to their own HSA.

Excess contributions often happen when employer contributions and your own contributions together go over the limit, or when your coverage changes mid-year. Excess contributions for a tax year are charged a 6% excise tax for each year they stay in the account. To avoid it, withdraw the extra amount, and any earnings on it, before your tax filing deadline for that tax year.

Why the 2026 HSA Changes Matter for Retirement

Health savings accounts are one of the most tax-advantaged ways to pay for healthcare: contributions go in pre-tax, growth is tax free, and withdrawals for qualified expenses are tax free. Many HSA owners invest their balance through their HSA providers and save it for healthcare costs in retirement. After 65, you can withdraw HSA money for any reason and pay only income tax on non-medical withdrawals.

That's why the expansion matters: more people with bronze or catastrophic plans can now get those tax benefits and build savings for retirement.

What Didn't Change

The new rules expanded who can contribute, but most HSA rules stayed the same:

• Gym memberships aren't automatically HSA-eligible. Proposals to let HSAs pay for gym memberships weren't part of the final law. A gym membership still qualifies only with a Letter of Medical Necessity for a specific medical condition. Read more about using an HSA for a gym membership.
• Medicare enrollees still can't contribute, though you can keep spending your HSA balance.
• What counts as a qualified medical expense is still set by IRS Publication 502. See our HSA eligible items list for 200+ examples.
• The triple tax advantage is unchanged: tax-deductible contributions, tax free growth, and tax-free withdrawals for eligible medical expenses.

How to Check if Your Health Plan Is HSA-Eligible

1. Look at the plan name and Summary of Benefits and Coverage. HSA-eligible plans are often labeled "HSA" or "HDHP," and Marketplace plans show their metal level.
2. Check the metal level. From 2026, a bronze or catastrophic plan qualifies even without the HSA label.
3. Ask your insurer or HR team if you're unsure, especially for employer plans.
4. Review your other coverage. A general-purpose FSA, a spouse's FSA, or Medicare can still block HSA contributions.

If you have questions about your own situation, like the last month rule or excess contributions, talk to a tax professional.

Make the Most of Your HSA in 2026

More people can now use an HSA to pay for healthcare costs with pre-tax money and save for retirement. Once you're contributing, your HSA funds can cover everything from doctor visits to over-the-counter medicine and medical devices. If you're deciding between accounts, see our guide to HSA vs FSA.

Shopping for eligible products? The Flex Marketplace lets you pay with your HSA card at checkout, and qualifying customers can get a Letter of Medical Necessity for dual-purpose items right at checkout.