Short answer. From January 1, 2026, a bronze or catastrophic plan available as individual coverage through an Exchange is treated as a high deductible health plan (HDHP), even if bought off the Exchange, as long as the same plan is offered on it. A direct primary care arrangement with fees of no more than $150 a month ($300 if it covers more than one person) doesn't stop you from contributing, and those fees can be paid from the HSA. The 2026 limits are $4,400 for self-only coverage and $8,750 for family coverage, plus $1,000 at 55 or older; for 2027 they are $4,500 and $9,000.
What changed
- Bronze and catastrophic plans. Notice 2026-5 treats them as HDHPs if the plan is available as individual coverage through an Exchange. A plan bought off the Exchange counts if the same plan is available on it. Small-employer SHOP coverage is not individual coverage and generally doesn't get this treatment.
- Direct primary care. A direct primary care service arrangement (DPC) is one where primary care is paid for only by a fixed periodic fee. It doesn't block HSA contributions if the fees for all your DPC arrangements are $150 a month or less ($300 for one covering more than one person). The 2027 figures, after the inflation adjustment, are the same $150 and $300.
- Telehealth. Covering telehealth before the deductible is now permanently allowed, for plan years beginning after December 31, 2024.
Step by step: check your eligibility month by month
- Identify your plan. Find the metal level and how it is offered on your plan documents or the Marketplace. Bronze or catastrophic individual coverage available through an Exchange counts as an HDHP from 2026. For any other plan, check that it meets the HDHP minimum deductible and out-of-pocket limits: for 2026, a deductible of at least $1,700 (self-only) or $3,400 (family), and out-of-pocket costs of no more than $8,500 or $17,000.
- Check the other conditions. Publication 969 lists them: covered by an HDHP on the first day of the month, no other health coverage except what's permitted, not enrolled in Medicare, and not someone who can be claimed as a dependent on another person's return.
- Check a DPC membership. Confirm the fee is a fixed periodic amount within the limit, and that the services don't include procedures requiring general anesthesia, prescription drugs other than vaccines, or lab services not typically given in an ambulatory primary care setting.
- Count your eligible months. Eligibility is tested on the first day of each month. Under the last-month rule, someone eligible on December 1 can be treated as eligible all year, but must stay eligible through a testing period that ends 12 months later, or the extra contribution is added to income with a 10% additional tax.
- Set the contribution. Use the limit for your coverage type and add $1,000 if you are 55 or older at the end of the year. Publication 969 (2025) says 2025 contributions can be made through April 15, 2026; check the 2026 edition for the date that applies to 2026 contributions.
- Report it. Contributions go on Form 8889, filed with your Form 1040.
Paying DPC fees from the HSA
Notice 2026-5 treats DPC fees as medical expenses that can be reimbursed from an HSA. There's no specific cap on the fee for reimbursement purposes, but a fee over the monthly limit means you can't contribute while you're enrolled in that arrangement. Fees your employer pays can't be reimbursed from your HSA.
A self-employed worker switches plans
A self-employed graphic designer, age 56 at the end of 2026, buys a self-only bronze plan through the Marketplace starting January 1, 2026, and joins a direct primary care practice at $95 a month.
- Plan: bronze individual coverage available through an Exchange, so it's treated as an HDHP from January 2026.
- DPC: $95 a month is within the $150 limit, so it doesn't block contributions.
- 2026 limit: $4,400 + $1,000 (55 or older) = $5,400.
- DPC fees: $95 × 12 = $1,140 for the year, which can be paid from the HSA.
If the practice charged $175 a month instead, the fee would be over $150 and the designer couldn't contribute for the months enrolled, though the fees could still be reimbursed from money already in the HSA.
A friend, age 48, switches to a bronze Marketplace plan on April 1, 2026 and isn't eligible on December 1. Eligible months: April through December, 9 months. Self-only limit: $4,400 × 9 ÷ 12 = $3,300.
Records to keep
Keep your plan's summary showing the metal level or deductible, the DPC agreement and fee receipts, a month-by-month note of coverage, and receipts for anything you pay or reimburse from the HSA.
Official sources
- IRS IR-2025-119: guidance on new tax benefits for health savings account participants (Dec. 9, 2025)
- IRS Notice 2026-5: health savings account changes under Public Law 119-21
- IRS Rev. Proc. 2025-19: 2026 HSA and high deductible health plan amounts
- IRS Rev. Proc. 2026-24: 2027 HSA, high deductible health plan and direct primary care amounts
- IRS Publication 969 (2025), Health Savings Accounts and Other Tax-Favored Health Plans
Checked November 2026 on irs.gov and nj.gov.
Common questions
Does a bronze plan bought outside the Marketplace count as an HDHP?
Notice 2026-5 says yes if the same plan is available as individual coverage through an Exchange.
Does a small-employer SHOP bronze plan count?
Generally no. Notice 2026-5 says SHOP coverage offered by a small employer is not individual coverage.
Can I pay my direct primary care membership from my HSA?
Yes. Notice 2026-5 treats DPC fees as medical expenses reimbursable from an HSA. Fees paid by an employer can't be reimbursed.
What if my DPC fee is more than $150 a month?
You can still reimburse the fee from your HSA, but you can't make HSA contributions while enrolled in that arrangement.
What are the HSA limits for 2027?
$4,500 for self-only coverage and $9,000 for family coverage, per Rev. Proc. 2026-24.
Can I contribute once I'm on Medicare?
No. Publication 969 lists not being enrolled in Medicare as one of the conditions for contributing.
Related guides: Ages 60-63 catch-up and Roth catch-up · Tax documents checklist for 2027