IRS Opens HSAs to Bronze, Catastrophic and Direct Primary Care Plans Starting in 2026

The Treasury Department and the IRS on December 9, 2025 issued Notice 2026-5, explaining three changes that widen who can contribute to a health savings account. Starting January 1, 2026, bronze and catastrophic plans count as HSA-compatible, and people in direct primary care arrangements can still contribute. A zero-deductible telehealth option is also now permanent. For families who max out other accounts, the guidance adds another route to the only account that is tax-favored going in, while growing and on the way out for medical costs.

What changed

Bronze and catastrophic plans. Until now, an HSA required a high-deductible health plan meeting set deductible and out-of-pocket limits. Many bronze and catastrophic plans sold through the Affordable Care Act marketplaces missed those limits. From 2026 they qualify regardless, and the notice says they do not have to be bought through an exchange to qualify.

Direct primary care. In a direct primary care arrangement, a patient pays a practice a flat periodic fee for primary care. Such arrangements previously could disqualify a person from contributing to an HSA. From 2026 they no longer do, and the fees can be paid from the HSA tax-free. The arrangement must cover only primary care from primary care practitioners, and the aggregate fee cannot exceed $150 a month for one person or $300 a month for arrangements covering more than one person, with inflation adjustments after 2026.

Telehealth. The ability to receive telehealth and other remote care before meeting the deductible, first allowed during the pandemic, is permanent for plan years beginning on or after January 1, 2025. In-person services and drugs connected to a telehealth visit remain subject to the deductible, according to RSM.

Who is affected

Self-employed owners and early retirees who buy coverage on their own are the clearest beneficiaries, since bronze plans are common among them. Families who pay a concierge-style primary care practice a monthly fee may also find they can now combine that care with an HSA, provided the fees stay under the limits. For 2026, a traditional high-deductible plan still needs a deductible of at least $1,700 for self-only coverage or $3,400 for family coverage, per Rev. Proc. 2025-19.

The after-tax math

The 2026 contribution limits are $4,400 for self-only coverage and $8,750 for family coverage.

Example: a self-employed consultant in the 37% federal bracket buys a family bronze plan in 2026 and contributes the full $8,750. The deduction trims federal income tax by about $3,238. If the family also pays a direct primary care practice $300 a month, the $3,600 of annual fees can come out of the HSA without tax. Whatever is not spent can stay invested, and withdrawals for qualified medical expenses in retirement remain tax-free.

State treatment varies, and the figures above exclude state tax.

Moves to discuss with your advisor

Households choosing 2026 coverage may want to compare a bronze plan plus a funded HSA against richer plans, looking at premiums, expected care and the tax value of contributions. Families already using direct primary care often check whether their practice's fees and services fit the $150 and $300 limits. Those who can pay current medical bills from cash sometimes treat the HSA as a long-term investment account, a strategy worth weighing with a financial planner.

What to watch

Treasury and the IRS are taking comments on the notice through March 6, 2026. Open enrollment decisions made this month will determine who can contribute from January, and insurers and direct primary care practices are likely to adjust their offerings as the new rules take hold.

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