HSA Eligibility in 2026: Bronze, Catastrophic, DPC

Three eligibility changes took effect on January 1, 2026. Bronze and catastrophic plans count as HSA-compatible¹. Direct primary care arrangements no longer break HSA eligibility². Pre-deductible telehealth does not break HSA eligibility³.

Each of them widens who can contribute, not how much. The HSA contribution limit calculator still needs a month-by-month answer to the eligibility question these rules changed.

Where the changes come from

The statute is P.L. 119-21, the One Big Beautiful Bill. The guidance is IRS Notice 2026-05, announced in news release IR-2025-119 on December 9, 2025.

None of it is a proposal. All three items below are in force for coverage months in 2026.

Bronze and catastrophic plans

IR-2025-119: “As of Jan. 1, 2026, bronze and catastrophic plans available through an Exchange are considered HSA-compatible.”

The release then closes the obvious gap: “bronze and catastrophic plans do not have to be purchased through an Exchange to qualify for the new relief.”

The point is that these plans qualify by their metal tier rather than by clearing the general high-deductible test. From January 1, 2026 they are HSA-compatible regardless of the general HDHP definition.

Direct primary care

IR-2025-119: “Beginning Jan. 1, 2026, an otherwise eligible individual enrolled in certain direct primary care (DPC) service arrangements may contribute to an HSA.” The release adds that participants “may use their HSA funds tax-free to pay periodic DPC fees.”

Two changes in one sentence. The arrangement no longer breaks HSA eligibility, and its periodic fee is now a qualified medical expense payable from the account.

The relief has a ceiling on the monthly fee, added to the tax code as IRC §223(c)(1)(B)(iii) by P.L. 119-21 §71308. Rev. Proc. 2026-24 sets that ceiling for 2027 at $150 per month⁴ where the arrangement covers one individual, and $300 per month⁵ where it covers more than one.

The 2026 ceiling is a gap in the published record. Rev. Proc. 2026-24 states the 2027 amounts; no IRS statement of the 2026 dollar amounts was located on September 7, 2026, so this page does not print one. Confirm the 2026 figure with your DPC provider or a tax professional before relying on it.

Telehealth before the deductible

IR-2025-119: “The OBBB made permanent the ability to receive telehealth and other remote care services before meeting the high-deductible health plan (HDHP) deductible while remaining eligible to contribute to an HSA, effective for plan years beginning on or after Jan. 1, 2025.”

This one is older than the other two and runs on plan years rather than calendar months. A plan year that began in 2024 and ran into 2025 is outside it; a plan year beginning on or after January 1, 2025 is inside it.

Permanent is the operative word. The safe harbor no longer carries an expiry date that has to be checked each year.

What did not change

The four conditions in Publication 969 are untouched. You must be covered by a qualifying high-deductible plan on the first day of the month, have “no other health coverage except what is permitted”, not be enrolled in Medicare, and not be claimable as a dependent on someone else’s return.

The HDHP definition still governs every plan that is not bronze or catastrophic. For 2026 the minimum annual deductible is $1,700⁶ for self-only coverage and $3,400⁷ for family coverage.

A general-purpose health flexible spending arrangement is still disqualifying coverage, and so is Medicare enrollment.

Can I contribute to an HSA with a bronze plan?

Yes, from January 1, 2026. IR-2025-119 states that bronze and catastrophic plans “are considered HSA-compatible” as of that date.

Do bronze and catastrophic plans have to come from the Marketplace?

No. IR-2025-119 says they “do not have to be purchased through an Exchange to qualify for the new relief.”

Does direct primary care disqualify my HSA?

Not from January 1, 2026. IR-2025-119 says an otherwise eligible individual in certain DPC service arrangements “may contribute to an HSA”, within a monthly fee limit.

How much can a direct primary care fee be?

For 2027 Rev. Proc. 2026-24 sets the limit at $150 per month⁴ for one individual and $300 per month⁵ where the arrangement covers more than one. The 2026 amounts are not separately confirmed on this page.

Can I pay DPC fees from my HSA?

Yes. IR-2025-119 says participants “may use their HSA funds tax-free to pay periodic DPC fees” from January 1, 2026.

Is telehealth before the deductible still allowed?

Yes, permanently. IR-2025-119 says the safe harbor was made permanent “effective for plan years beginning on or after Jan. 1, 2025.”

What still disqualifies me from an HSA?

Other health coverage that is not permitted, Medicare enrollment, and being claimable as someone else’s dependent. A general-purpose health flexible spending arrangement remains other coverage.

Do these changes raise my contribution limit?

No. They change who counts as eligible for a month. The dollar limits for the year are unchanged and are listed on the 2026 HSA limits page.