Can You Use Your HSA for Direct Primary Care?
Seems like a simple question. The short answer is yes. But the full answer is more nuanced than most people realize.
Recent IRS guidance has made it possible to use Health Savings Account (HSA) funds for direct primary care (DPC) memberships. As a result, many articles and headlines simplify this to a straightforward yes.
However, the reality is more specific. The IRS allows HSA use for certain direct primary care arrangements, and that single word carries important implications for how these memberships must be structured, what they can include, and how they may affect your ability to contribute to an HSA.
In this article, we will break down what the IRS actually says, how these rules work in practice, and the key details most people overlook when deciding whether to use HSA funds for direct primary care.
Health Savings Accounts are most commonly used by individuals enrolled in high-deductible health plans, often through employer-sponsored coverage or self-employment. These individuals tend to be more engaged in how they spend healthcare dollars, making decisions based not only on cost, but also on access, convenience, and overall value.
What Changed with HSAs and Direct Primary Care
For years, the rules around Health Savings Accounts (HSAs) and direct primary care (DPC) existed in a gray area. While HSAs could be used for many qualified medical expenses, it was unclear whether a recurring DPC membership fee met that definition. As a result, some HSA administrators allowed these payments, while others did not.
That changed with new federal guidance issued by the Treasury Department and Internal Revenue Service (IRS) in late 2025 under Notice 2026-05. This guidance clarified two important points.
First, enrolling in a qualifying direct primary care arrangement no longer disqualifies an individual from contributing to an HSA. Second, certain DPC membership fees can now be treated as qualified medical expenses and paid for using HSA funds.
The key detail, however, is in that word “certain.”
Under the updated guidance, not every direct primary care model automatically qualifies. To be considered eligible, the arrangement must meet specific criteria related to how it is structured, what services are included, and how those services are billed.
In general, qualifying arrangements involve a fixed monthly fee that covers primary care services without additional billing for those included services. There are also limits on how these arrangements are defined and how they interact with broader HSA rules.
This means that while many patients can now use pre-tax HSA dollars toward direct primary care, eligibility ultimately depends on the details of the specific practice model and the patient’s overall health plan.
How It Works in Practice
Using your Health Savings Account (HSA) for direct primary care (DPC) is generally straightforward, provided the membership meets the criteria outlined in recent IRS guidance.
In most cases, patients can pay their monthly membership fee using an HSA debit card, similar to how it would be used for other qualified medical expenses. If the practice does not accept HSA cards directly, patients can pay out of pocket and reimburse themselves from their HSA. Keeping clear documentation, such as receipts or itemized statements, is important.
However, the guidance applies specifically to periodic membership fees that meet the definition of a qualifying arrangement. It does not extend to all healthcare models.
For example, concierge medicine practices that charge large upfront retainers or arrangements that bill separately for included services may not meet the same criteria. Similarly, services outside of the membership, such as imaging or external lab work, may require separate evaluation for HSA eligibility. Thought typically they are not included in the membership to begin with.
In practice, this means that while many patients can now use pre-tax HSA funds for direct primary care, the details of how a practice structures its services and billing still matter.
What “Eligible” Really Means
While recent IRS guidance allows HSA funds to be used for direct primary care memberships, eligibility depends on how the arrangement is structured.
This is where many explanations fall short.
A qualifying direct primary care arrangement is not simply any membership-based practice. To meet IRS criteria, the model must follow a specific framework related to how care is delivered and how it is paid for.
In general, eligible arrangements include:
- A fixed, periodic fee (typically monthly)
- Coverage limited to primary care services
- No additional billing for services included within the membership
These requirements are what distinguish qualifying direct primary care from other healthcare models.
There are also important limitations to understand. Certain types of services, such as procedures requiring general anesthesia, most prescription medications, and more advanced testing outside of a typical primary care setting, are not considered part of a qualifying arrangement under these rules.
Another key detail is how these arrangements interact with broader HSA rules. In some cases, a membership may still be reimbursable using HSA funds, but could affect a patient’s ability to continue making HSA contributions, depending on how it is structured.
For patients, the takeaway is simple: while many direct primary care memberships now qualify, the details matter. Understanding how a specific practice is structured is essential to determining how your HSA can be used.
What Does This Look Like at Pearl Primary Care in Colorado Springs?
Understanding the rules is one thing. Seeing how they apply in a real practice is a little more helpful.
At Pearl Primary Care, the direct primary care model is structured to align closely with the IRS definition of a qualifying arrangement. This allows patients to better understand how their membership may interact with HSA eligibility.
To make this easier to understand, here is how these requirements translate in practice:
| Requirement for HSA Eligibility | Pearl Primary Care |
|---|---|
| Fixed periodic (monthly) fee | Yes |
| Monthly fee within IRS guidelines | Yes |
| Covers primary care services | Yes |
| Services included without additional billing | Yes |
| No insurance billing for covered services | Yes |
| Procedures requiring general anesthesia included | Not applicable |
| Prescription medications included in membership | Handled outside membership (prescriptions are prescribed and filled through pharmacies) |
| Advanced lab services included in membership | Not applicable |
This structure reflects a straightforward, membership-based healthcare model. Patients pay a consistent monthly fee for access to comprehensive primary care, while prescriptions, imaging, or outside services are handled separately as needed.
Because individual health plans and HSA administrators may vary, patients are encouraged to confirm specific eligibility details with their HSA provider. However, models like this are designed to align with current IRS guidance and provide a clear, predictable framework for care.
How Using an HSA Affects Cost
Using a Health Savings Account (HSA) to pay for direct primary care (DPC) membership can change how those costs are experienced, primarily because HSA funds are pre-tax dollars.
When medical expenses are paid through an HSA, those funds are not subject to federal income tax. For individuals in a 22% tax bracket, this means that each dollar spent through an HSA avoids approximately 22 cents in federal taxes, along with applicable payroll taxes.
For example, a $150 monthly membership fee paid with HSA funds may represent a lower effective cost when compared to paying the same amount with after-tax income. The exact impact will vary depending on an individual’s tax situation, but the general principle remains consistent.
For individuals whose employers contribute to their HSA, this effect can be more pronounced. Employer contributions are considered pre-tax funds, and in many cases can offset a portion of ongoing healthcare expenses, including qualifying direct primary care memberships.
It is also important to recognize that HSA use does not change the listed price of a membership. Instead, it changes how those expenses are funded and how they interact with an individual’s overall financial and tax planning.
What If I Already Have Insurance?
This is one of the most common questions when considering direct primary care (DPC) alongside a Health Savings Account (HSA).
For many individuals, especially those enrolled in a high-deductible health plan (HDHP), direct primary care is not a replacement for insurance, but a complement to it.
Insurance remains important for larger, less predictable expenses such as hospitalizations, surgeries, and specialist care. Direct primary care, on the other hand, is designed to cover the day-to-day aspects of healthcare, including preventive care, acute visits, and chronic disease management.
In practice, this creates a layered approach to care. The insurance plan provides financial protection for major medical events, while the DPC membership supports ongoing access to a physician for routine and preventive needs.
For patients using an HSA, this combination can be particularly relevant. The HSA can be used to pay for qualified medical expenses, while the structure of a DPC membership may allow for more consistent access to care.
The result is not a replacement of one system with another, but a different way of organizing care: insurance for high-cost events, and direct primary care for continuous, relationship-based medical care.
What to Look for in a Direct Primary Care Practice for HSA Eligibility
Not all direct primary care (DPC) practices are structured in a way that aligns with HSA eligibility. Understanding a few key elements can help determine whether a membership will qualify under current IRS guidance.
First, look for a fixed monthly fee. Qualifying arrangements are based on a consistent, periodic payment structure, rather than variable or service-based billing.
Second, confirm that primary care services are included without additional charges. Memberships that bundle core services into a single fee are more likely to meet the definition of a qualifying arrangement.
Third, understand how the practice handles services outside the membership. Items such as prescriptions, imaging, or specialty referrals are typically coordinated through the practice but handled separately.
Finally, documentation matters. Practices that provide clear receipts or itemized statements make it easier to use HSA funds appropriately and maintain accurate records.
In Colorado Springs, practices such as Pearl Primary Care are structured with these considerations in mind, offering transparent pricing, clearly defined services, and a model that aligns with current HSA guidance.
The Bottom Line: Can You Use Your HSA for Direct Primary Care?
The short answer is yes. But as current IRS guidance makes clear, the more accurate answer is that HSA funds can be used for certain direct primary care memberships, depending on how those arrangements are structured.
The details matter.
From how a practice defines its membership model, to whether services are included without additional billing, to how the arrangement aligns with broader HSA eligibility rules, each factor plays a role in determining how your healthcare dollars can be used.
For many patients, this creates a practical opportunity. A Health Savings Account (HSA) can support the financial side of care, while a direct primary care (DPC) model supports access, continuity, and a more consistent relationship with a physician.
If you live in the Colorado Springs region and are exploring how to use your HSA more intentionally (and efficiently), it may be helpful to start with a conversation.
Schedule a free 15-minute Meet & Greet with Dr. Rachael Degurse to see if Pearl Primary Care is the right fit for you:
https://pearlprimary.care/membership-health-colorado-springs#membership-form
To learn more or connect professionally, follow Dr. Rachael Degurse on LinkedIn:
https://www.linkedin.com/in/drrachaeldegurse
References
Kaiser Family Foundation. (2023). 2023 employer health benefits survey. https://www.kff.org/health-costs/2023-employer-health-benefits-survey/
U.S. Department of the Treasury & Internal Revenue Service. (2026). Notice 2026-05: Guidance on direct primary care arrangements and Health Savings Accounts. https://www.irs.gov/pub/irs-drop/n-26-05.pdf
U.S. Department of the Treasury & Internal Revenue Service. (2025). Treasury, IRS provide guidance on new tax benefits for Health Savings Account participants under the One Big Beautiful Bill. https://www.irs.gov/newsroom/treasury-irs-provide-guidance-on-new-tax-benefits-for-health-savings-account-participants-under-the-one-big-beautiful-bill
