The IRS recently issued guidance on significant changes to Health Savings Account (HSA) rules under the One Big Beautiful Bill Act (OBBBA), expanding eligibility and providing new tax benefits for HSA participants. If you're a small business owner or individual looking to maximize your healthcare savings, here's what you need to know.
What Changed?
Starting January 1, 2026, the OBBBA introduced several important expansions to HSA eligibility and usage that could benefit you and your employees.[1][2] These include:
- Direct Primary Care (DPC) is Now Compatible with HSAs
- Bronze Plans Now Qualify as High-Deductible Health Plans
- Enhanced Telehealth Benefits
1. Direct Primary Care (DPC) is Now Compatible with HSAs
The most significant change allows individuals enrolled in Direct Primary Care (DPC) service arrangements to contribute to an HSA, even though DPC arrangements were previously considered disqualifying coverage.
What this means for you:
- If you're enrolled in a qualifying DPC arrangement and otherwise eligible (such as having a high-deductible health plan), you can now make tax-deductible HSA contributions
- You can use your HSA funds tax-free to pay periodic DPC membership fees
- This opens up a popular healthcare model to HSA participants who previously had to choose between DPC and HSA benefits
2. Bronze Plans Now Qualify as High-Deductible Health Plans
The guidance clarifies that bronze-level ACA plans with an actuarial value of 60% are now treated as high-deductible health plans (HDHPs) for HSA purposes.
This change makes HSAs accessible to more individuals shopping on the health insurance marketplace.
3. Enhanced Telehealth Benefits
While telehealth flexibilities were already in place, the OBBBA includes provisions for telehealth services that are retroactively effective to January 1, 2025.
HSA Basics for 2026
As a reminder, to be eligible for an HSA in 2026, you need to meet the following requirements:
- Maintain coverage under a high-deductible health plan
- Maintain no disqualifying coverage (including bot being enrolled in Medicare)
- Not be claimed as a dependent on someone else's tax return
Why This Matters for Small Businesses
For small business owners offering health benefits:
- Expanded options: You can now offer HDHP/HSA combinations alongside DPC arrangements, giving employees more flexibility in how they access primary care.
- Competitive benefits: HSAs remain one of the most tax-advantaged savings vehicles available, with triple tax benefits (tax-deductible contributions, tax-free growth, and tax-free withdrawals for qualified medical expenses).
- Employee attraction and retention: These expanded rules make HSAs accessible to more employees, which can be a valuable part of your benefits package.
What's Next?
The IRS and Treasury Department are accepting public comments on this guidance until March 6, 2026. Additional regulatory guidance is expected over the coming months as these provisions are implemented.
Navigating health insurance options and maximizing tax benefits can be complex. If you're a small business owner wondering how these HSA changes might benefit your company and employees, or an individual looking to make the most of your health savings strategy, we're here to help.
