WASHINGTON — The Department of the Treasury and the Internal Revenue Service issued Notice 2026-05 PDF providing guidance on new tax benefits for Health Savings Account participants under the One, Big, Beautiful Bill. These changes expand HSA eligibility, which allows more people to save and to pay for healthcare costs through tax-free HSAs.
Expansion of HSA Eligibility Under the OBBB
The OBBB expands access to HSAs by making the following changes:
- Telehealth and Remote Care Services: 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.
- Bronze and Catastrophic Plans Treated as HDHPs: As of Jan. 1, 2026, bronze and catastrophic plans available through an Exchange are considered HSA-compatible, regardless of whether the plans satisfy the general definition of an HDHP. This expands the ability of people enrolled in these plans to contribute to HSAs, which they generally have not been able to do in the past. Notice 2026-05 clarifies that bronze and catastrophic plans do not have to be purchased through an Exchange to qualify for the new relief.
- Direct Primary Care Service Arrangements: A Direct Primary Care Service Arrangement (“DPCSA”) is an arrangement under which an individual is provided medical care consisting solely of primary care services provided by primary care practitioners, if the sole compensation for such care is a fixed periodic fee, and such care does not include: (1) procedures that require the use of general anesthesia, (2) prescription drugs other than vaccines, or (3) laboratory services not typically administered in an ambulatory primary care setting. Beginning Jan. 1, 2026, an otherwise eligible individual enrolled in certain direct primary care (DPC) service arrangements may contribute to an HSA. In addition, they may use their HSA funds tax-free to pay periodic DPC fees. A bronze or catastrophic plan that is available as individual coverage will not fail to be an HDHP simply because an employer-sponsored Individual Coverage Health Reimbursement Arrangement is used to purchase the coverage.