Yes. Beginning January 1, 2026, HSA funds can be used to pay or reimburse fees for qualifying Direct Primary Care service arrangements. The new federal rules also allow certain people enrolled in qualifying Direct Primary Care arrangements to remain eligible to make HSA contributions.
There is one detail that can cause confusion, though. The rule for using HSA money to pay Direct Primary Care fees is not exactly the same as the rule for remaining eligible to contribute new money to an HSA.
That difference matters if you use a Health Savings Account, have a high-deductible health plan, or are considering Direct Primary Care in Arizona.
What Changed for Direct Primary Care and HSAs in 2026?
Before 2026, enrolling in many Direct Primary Care arrangements could interfere with HSA contribution eligibility because the DPC arrangement could be treated as additional health coverage.
Federal law changed that treatment.
For months beginning after December 31, 2025, certain qualifying Direct Primary Care Service Arrangements, or DPCSAs, are no longer treated as disqualifying health plans for HSA contribution purposes, as long as the applicable requirements are met. The law also allows qualifying DPC fees to receive HSA treatment.
This means Direct Primary Care and an HSA can now work together in situations where they previously could not.
For readers who are still comparing care models, Saguaro Direct Care also explains the differences between Direct Primary Care and traditional primary care.
But there are limits and definitions to understand.
Two HSA Rules You Should Not Confuse
The easiest way to understand the 2026 change is to separate HSA spending from HSA contribution eligibility.
| Question | 2026 Federal Rule |
| Can HSA funds pay qualifying DPC fees? | Yes |
| Can qualifying DPC members remain eligible to contribute to an HSA? | Yes, if applicable requirements are met |
| 2026 DPC limit for one individual for contribution eligibility | $150 per month |
| Limit when a DPC arrangement covers more than one individual | $300 per month |
| Is that same $150/$300 cap a strict limit on HSA reimbursement? | No |
| Do DPC membership fees count toward an HDHP deductible? | No |
The $150 and $300 figures relate to whether the arrangement is disregarded as disqualifying health coverage for purposes of making HSA contributions in 2026.
For HSA reimbursement, IRS Notice 2026-05 makes an important distinction. The IRS says there is no specific fixed-fee dollar limit like the one used for contribution eligibility. A qualifying DPC fee above the monthly contribution threshold may still be reimbursable from the HSA. However, that arrangement can make the person ineligible to make new HSA contributions while enrolled.
That distinction is easy to miss.
Paying DPC Fees With Existing HSA Money
If the arrangement meets the federal requirements for a DPCSA, its qualifying fees can be treated as medical expenses that may be paid or reimbursed from an HSA.
Continuing to Make HSA Contributions
To prevent a DPC arrangement from becoming disqualifying coverage, aggregate fees in 2026 generally cannot exceed:
- $150 per month for one individual
- $300 per month if an arrangement covers more than one individual
The limits apply to the aggregate fees for applicable DPC arrangements, not simply the name or advertised price of one membership.
What Makes a Direct Primary Care Arrangement Qualify?
Not every healthcare membership automatically becomes HSA-compatible simply because it uses the words “Direct Primary Care.”
Under IRS guidance, a qualifying DPCSA generally involves medical care consisting solely of primary care services provided by qualifying primary care practitioners, with a fixed periodic fee as the sole compensation for the care included in the arrangement.
For this federal definition, certain services are excluded from primary care services, including:
- Procedures requiring general anesthesia
- Prescription drugs other than vaccines
- Laboratory services not typically administered in an ambulatory primary care setting
The terms of the membership agreement matter. A patient cannot simply decline a nonqualifying included service and make the agreement qualify.
Readers who want to see how a membership-based model works in practice can review Saguaro Direct Care’s Direct Primary Care service.
A practice may still offer separately billed services outside its DPC arrangement. The key issue is whether those services are separate from the fixed-fee qualifying arrangement.
What If Your DPC Membership Costs More Than $150 Per Month?
This is where the two-rule distinction becomes useful.
Consider three simple examples.
Example 1: A $109 Monthly Individual Membership
Assume a qualifying individual DPC arrangement costs $109 per month.
The fee is below the 2026 $150 individual threshold. If the person also satisfies the other HSA rules, the DPC arrangement would not exceed the monthly DPC fee limit used for contribution eligibility.
Saguaro Direct Care currently lists its own Direct Primary Care membership pricing at $109 per month.
Example 2: A $175 Monthly Individual Membership
Assume a qualifying DPC arrangement costs $175 per month.
The fee may still qualify for reimbursement from existing HSA funds. However, because it exceeds the $150 contribution-eligibility threshold, the individual may lose eligibility to make HSA contributions while enrolled in that arrangement.
Example 3: A Low-Cost Membership With Nonqualifying Terms
Suppose a membership costs only $100 but bundles services that fall outside the federal DPCSA requirements.
The low price does not make it qualifying.
Price is only one part of the test. The services, payment structure, practitioner, and membership terms also matter.
Do You Still Need an HDHP to Contribute to an HSA?
In general, you still need to satisfy federal requirements for HSA contribution eligibility. A Direct Primary Care membership does not create HSA eligibility by itself.
For 2026, the general HSA limits are:
- $4,400 maximum annual contribution for self-only coverage
- $8,750 maximum annual contribution for family coverage
- $1,700 minimum HDHP deductible for self-only coverage
- $3,400 minimum HDHP deductible for family coverage
- $8,500 maximum HDHP out-of-pocket expenses for self-only coverage
- $17,000 maximum for family coverage
DPC and health insurance can also serve different purposes. Direct Primary Care may cover routine access to primary care, while insurance may still be used for hospitalization, emergencies, specialists, surgery, and other larger medical expenses.
Saguaro Direct Care covers this distinction in more detail in its guide to using health insurance with Direct Primary Care in Arizona.
How Can You Pay a DPC Membership With an HSA?
If your DPC arrangement qualifies, the practical process can be straightforward.
Before using HSA funds, check these points:
- Confirm the arrangement qualifies. Do not rely only on the words “Direct Primary Care.”
- Review what the fixed membership fee covers.
- Check your HSA contribution eligibility separately.
- Keep records of your DPC payments. Save invoices, receipts, and related documentation.
- Avoid double reimbursement. An expense should not be reimbursed from another source and then claimed again from the HSA.
It is also helpful to understand the membership itself before using HSA funds. Saguaro provides additional information about coverage, services, insurance, and membership questions on its Direct Primary Care FAQ page.
If you are unsure how a specific arrangement affects your taxes, ask your HSA administrator or a qualified tax professional.
Do DPC Fees Count Toward Your Health Insurance Deductible?
No. A separately paid DPC membership fee does not count toward your HDHP deductible or out-of-pocket maximum.
The membership fee and the health plan operate separately.
You could have a DPC membership for routine primary care access while still having a separate deductible, coinsurance, or other costs under your health insurance plan.
This is one reason some patients compare both models together rather than thinking of DPC as a direct replacement for every type of medical coverage. The DPC vs. traditional primary care comparison can help explain where each approach differs.
What Should Saguaro Direct Care Patients Know?
Saguaro Direct Care currently lists its individual Direct Primary Care membership at $109 per month. The practice uses a virtual-first care model for adults in Arizona, with additional local options for patients in Lake Havasu City.
Patients can learn more about how Saguaro’s Direct Primary Care membership works before deciding whether the model fits their needs.
The current $109 monthly price is below the federal $150 individual threshold used for the 2026 DPC contribution-eligibility rule.
However, price alone does not determine federal HSA qualification. The complete membership arrangement and services must satisfy applicable requirements.
Patients who want to compare cost and membership details can also review Saguaro’s current Direct Primary Care pricing.
HSA + Direct Primary Care Checklist for 2026
Before combining an HSA with Direct Primary Care, check:
- Does the arrangement meet the current federal DPCSA definition?
- What exactly does the recurring membership fee cover?
- Are outside services billed separately?
- Is my health coverage compatible with HSA contributions?
- Does my DPC fee stay within the contribution-eligibility limit?
- Am I eligible to contribute to my HSA for each applicable month?
- Have I kept documentation for HSA payments or reimbursements?
This short review can prevent a common mistake: assuming that being allowed to spend HSA funds automatically means being allowed to continue making HSA contributions.
If you are new to this type of membership, Saguaro’s explanation of what Direct Primary Care is and how it works is a useful starting point.
Frequently Asked Questions About HSA and Direct Primary Care
Can I use my HSA to pay for Direct Primary Care in 2026?
Yes, qualifying Direct Primary Care fees can be paid or reimbursed from an HSA beginning in 2026. The arrangement must meet applicable federal requirements for a Direct Primary Care Service Arrangement.
Does joining Direct Primary Care stop me from contributing to my HSA?
Not necessarily. In 2026, certain qualifying DPC arrangements do not prevent an otherwise eligible person from contributing to an HSA if aggregate fees stay within the applicable $150 or $300 monthly threshold and the other HSA rules are met.
Can my HSA pay a DPC membership that costs more than $150 per month?
Potentially, yes. The reimbursement rule does not use the same fixed-dollar limit as the contribution-eligibility rule. However, exceeding the applicable threshold can affect your ability to make new HSA contributions while enrolled.
Do I still need a high-deductible health plan if I have Direct Primary Care?
You still need to independently satisfy HSA eligibility requirements if you want to make HSA contributions. A DPC membership provides primary care services but does not itself establish HSA eligibility.
Does my DPC membership payment count toward my HDHP deductible?
No. Separately paid DPC membership fees do not count toward the HDHP’s annual deductible or out-of-pocket maximum.
Can I reimburse myself from my HSA after paying a DPC fee?
Qualifying DPC expenses may be reimbursable from an HSA when applicable requirements are met. Keep documentation supporting the expense and reimbursement.
Is every Direct Primary Care membership HSA-qualified in 2026?
No. Calling a healthcare membership “Direct Primary Care” does not automatically make it qualify. Federal treatment depends on the services included, practitioner, fixed-fee structure, membership terms, and other applicable requirements.
See If Direct Primary Care Fits Your Healthcare Plan
The 2026 HSA changes give more people a way to combine tax-advantaged healthcare funds with qualifying Direct Primary Care. The key is understanding both sides of the rule: how HSA funds may be spent and whether you remain eligible to make new contributions.
Saguaro Direct Care offers membership-based Direct Primary Care for adults across Arizona. You can review the current membership pricing, learn more about Saguaro’s Direct Primary Care model, or review the practice FAQs before deciding whether the membership fits your healthcare needs.
HSA and tax rules depend on individual circumstances. Saguaro Direct Care can explain its membership and services but does not provide individual tax advice. Confirm your HSA eligibility or tax treatment with your HSA administrator or qualified tax professional.