Is Direct Primary Care Membership HSA-Eligible? (2026)
Starting in 2026, qualifying direct primary care arrangement fees can be HSA-eligible, with separate contribution-eligibility rules.
Typical Cost
Fixed periodic fee; contribution-eligibility thresholds are year-specific
Details
IRS Notice 2026-5 explains that fees for a qualifying direct primary care service arrangement can be treated as qualified medical expenses. The arrangement must provide only primary care services from qualifying practitioners for a fixed periodic fee. A fee can still be reimbursable even if it exceeds the monthly amount that preserves HSA contribution eligibility, so reimbursement eligibility and contribution eligibility must be checked separately.
What to do next
Confirm that the arrangement meets the federal DPC definition, identify who paid the fee, and keep the agreement and payment record. Employer-paid fees are not your expense. Separately verify whether monthly fees preserve your eligibility to contribute.
Decision record and source basis
This ruling has a source packet that directly addresses the item or rule below. A product or retailer label does not override the expense purpose, eligibility conditions, or documentation requirement shown above.
Search coverage (5 product and plain-English terms)
dpc arrangement, dpc membership, direct care membership, direct primary care fee, primary care subscription.
- IRS Notice 2026-5: Direct Primary Care Service Arrangements
Notice 2026-5 defines qualifying DPC arrangements, explains HSA reimbursement of fees, distinguishes employer-paid fees, and separates reimbursement from contribution eligibility.
Source reviewed
- IRS Publication 969: HSA qualified medical expenses
HSA distributions are tax-free only for uncompensated qualified medical expenses incurred after the HSA was established, with supporting records retained.
Source reviewed
Frequently Asked Questions
Can I use my HSA for a direct primary care membership in 2026?
A qualifying DPC arrangement fee can be reimbursable. Separately verify whether the arrangement and monthly fee preserve your eligibility to contribute to the HSA.
Do employer-paid DPC fees qualify for my HSA reimbursement?
No. Notice 2026-5 says employer-paid fees, including salary-reduction payments, are not expenses of the HSA beneficiary.
Can you reimburse direct primary care membership years later?
Compare timing assumptions, investment risk, and the records needed to support a later distribution.
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