Your HSA can pay for direct primary care with tax-free dollars, under a federal rule change that took effect January 1, 2026. Two things changed at once. A DPC membership no longer counts against your HSA eligibility, so you can keep both. The membership fee itself also became a qualified medical expense you can pay from the HSA directly, as long as the fee stays within the annual cap.
We have watched patients carry a high-deductible plan for years while paying for primary care out of pocket anyway, because the insurance version of primary care was a rushed visit plus a referral chain plus a surprise bill. The 2026 change finally lets those patients use the account they already fund for the care they actually use.
- Since January 1, 2026, HSA funds can pay DPC membership fees directly as a qualified medical expense.
- A qualifying DPC arrangement does not disqualify you from contributing to an HSA.
- The fee cap is $150 per month for individual coverage and $300 for family coverage ($1,800 and $3,600 per year).
- Our flat $299 monthly fee covers the doctor and the quarterly Biomarker Audit, with medication billed separately by the pharmacy at cost and zero markup.
What the rule change actually says
The change came through the One Big Beautiful Bill Act and was implemented through IRS guidance effective January 1, 2026. A qualifying DPC arrangement is a subscription model where members pay a fixed periodic fee for primary care services. Fees at or below $150 per month for individual coverage (or $300 for family) keep you HSA-eligible and are reimbursable from the HSA. Fees above the cap can still be reimbursed, but the excess portion disqualifies you from contributing during that period.
How this applies to our membership
Our fee is $299 per month, which is above the individual cap, so here is the honest breakdown rather than the marketing version.
| Component | HSA treatment in 2026 |
|---|---|
| First $150 per month of the fee | Qualified medical expense, reimbursable from your HSA |
| The remaining $149 per month | Reimbursable from the HSA, but disqualifies contributions for that period if reimbursed |
| Medication, billed at pharmacy cost | Prescription drugs are qualified medical expenses, reimbursable normally |
| Quarterly Biomarker Audit | Included in the fee, no separate charge |
Two practical notes. If your spouse or family members are also on the membership, family coverage raises the cap to $300 per month, which brings the entire fee inside the qualifying range. And if you are contributing to your HSA aggressively and do not want to interrupt contributions, many members simply pay the fee with after-tax dollars and treat the HSA as the vehicle for the medication and other qualified costs.
We are clinicians and not tax advisors, so confirm the mechanics with your HSA administrator or tax professional before you change how you pay. What we can state plainly is the clinical half: what the fee buys is a physician who reads your full biomarker panel every 90 days and a clinical relationship that does not run through a referral chain.
A real objection, named plainly: 'I already pay for insurance, why would I also pay a membership?' Because you are already paying for primary care twice. The premium buys the plan and the deductible, the referrals and the surprise bills buy the actual care. Our members did the math and decided a known $299 for unlimited clinical access plus quarterly labs beats an unknown annual total for the care they actually use. The membership is HSA-compatible in 2026 and the medication is billed at pharmacy cost with zero markup.
Who this is for
The patients who fit this model best are the ones the industry calls system skippers. You have a high-deductible plan you rarely touch, you fund an HSA, you have been paying cash for care anyway and you want a real clinical relationship instead of an app and a referral. The 2026 rule change finally aligned the tax code with the way you already behave.
The 2026 rule change aligned the tax code with the way high-deductible patients already behave.
Frequently asked questions
Can I use my HSA to pay for a direct primary care membership in 2026?
Yes. Under rules effective January 1, 2026, HSA funds can pay DPC membership fees directly as a qualified medical expense and a qualifying DPC arrangement no longer blocks HSA eligibility. The fee cap is $150 per month for individual coverage and $300 for family coverage, adjusted annually for inflation.
What is the fee cap and what happens above it?
The 2026 cap is $150 per month for individual coverage ($1,800 per year) and $300 for family coverage. Fees above the cap can still be reimbursed from the HSA, but the portion above the cap disqualifies you from making HSA contributions during that coverage period. Our fee is $299 per month, so the first $150 fits inside the individual cap and the remainder is a decision to make with your tax advisor.
Does a DPC membership replace insurance?
No and we never suggest otherwise. A DPC membership is not insurance and does not cover hospitalizations, specialists, imaging or emergencies. Our members keep a high-deductible or catastrophic plan for events and use the membership for the clinical relationship, the quarterly labs and the day-to-day care that insurance was never designed to deliver.
Is the medication covered by the HSA?
Prescription medications are qualified medical expenses and can generally be reimbursed from an HSA, including the branded GLP-1s and hormone therapies our protocols use. The medication is billed directly by the pharmacy at cost, with zero markup, so the HSA reimbursement applies to the actual cost.
Does the membership cover the medicine?
No. The flat $299 monthly fee covers the doctor, the quarterly Biomarker Audit and the clinical protocols. The medicine is billed separately, directly by the pharmacy, at pharmacy cost with zero markup. These are two separate charges by design and the separation is what keeps our clinical advice independent of our income.
What if my HSA administrator says something different?
Follow your administrator's guidance, because implementation details vary and the IRS guidance is new. The federal rule is clear, but administrators are still updating their systems and some have not yet added DPC fees to their eligible-expense lists. We are clinicians, not tax advisors and we would rather you confirm the mechanics with the people who administer your account.
Is this the same as concierge medicine?
Not exactly. Concierge medicine typically bills insurance for visits on top of a membership fee, while direct primary care charges one flat membership fee and does not bill insurance at all. Both offer smaller panels and longer visits and our practice is a direct primary care model scoped to cardiometabolic optimization rather than a general-practice DPC clinic.
Related guides
- Cardiometabolic Optimization: the definitive guide
- What a Biomarker Audit includes
- Direct primary care for cardiometabolic care
- How GLP-1s work and what happens when they stop
External reference: the IRS Notice 2026-5 specifies the DPC fee caps, eligibility rules and qualified-expense treatment described above.
References
- Direct Primary Care: Practice Distribution and Cost Across the Nation (J Am Board Fam Med). 2015. pubmed.ncbi.nlm.nih.gov/26546651/