Can You Use an HSA for Direct Primary Care?

If you have an HSA-eligible HDHP and you're weighing a Direct Primary Care membership, you're likely unsure whether you can still contribute to your HSA, and whether you can use HSA funds to pay the DPC membership fee itself. As of January 1, 2026, the answer to both is generally yes, under new IRS guidance issued through the One Big Beautiful Bill Act (OBBBA). This guide walks through exactly what changed, what conditions apply, and what it means for your RAW DPC membership. 

There Are Actually Two Questions Here

Most people type "can you use HSA for direct primary care" looking for a quick yes or no. 

The problem is that phrase bundles two separate questions into one search:

• Can you still contribute to an HSA while enrolled in a DPC membership?
• Can you pay your DPC monthly fee using HSA funds?

These look like the same question, but each is governed by its own set of IRS rules, and those rules changed on January 1, 2026. A lot of the conflicting information you find online predates that change. Let's take them one at a time, starting with what applies now.

Can You Contribute to an HSA if You Have a DPC Membership?

Generally yes, but there is one condition.

To qualify for HSA contributions, the IRS requires that you are enrolled in a High-Deductible Health Plan (HDHP). A DPC membership by itself does not count as an HDHP, so it will not automatically open the door to HSA eligibility on its own.

This is where the pairing strategy comes in, and it is the key to setting up HSA eligible direct primary care. Many DPC members pair their membership with a low-premium HDHP designed to cover catastrophic events, hospitalizations, emergency surgery, and other major unforeseen care. Under this structure, your DPC membership handles everyday primary care for a flat monthly fee, while the HDHP takes care of the big-ticket expenses. Because you are still carrying an HDHP, your eligibility to contribute to an HSA remains intact.

IRS Notice 2026-5, issued in December 2025 under the One Big Beautiful Bill Act, confirmed that DPC arrangements paired with an HDHP maintain HSA eligibility, effective January 1, 2026. A tax advisor can confirm how current IRS guidance applies to your specific plan structure.

For the full technical breakdown of HSA eligibility rules, IRS Publication 969 covers Health Savings Accounts and other tax-favored health plans in detail.

Can You Use HSA Funds to Pay Your DPC Membership Fee? 

The IRS defines qualified medical expenses as costs paid for the "diagnosis, cure, mitigation, treatment, or prevention of disease." A DPC membership fee is a flat monthly access fee, not a per-visit charge, which is why this question sat in a gray area for years.

That gray area closed on January 1, 2026. Under IRS Notice 2026-5, a qualifying direct primary care service arrangement now counts as a qualified medical expense, and HSA funds can be used to pay the fee directly, as long as two conditions are met: the fee is $150 per month or less for individual coverage, or $300 per month or less for family coverage, and the arrangement provides only primary care services for a fixed periodic fee without billing separately for those services.

Because DPC membership pricing varies by practice and by tier, whether a specific fee and structure meet those conditions is worth confirming with a CPA familiar with direct primary care. What has always been on firmer ground, regardless of how the membership fee itself is treated, are the specific clinical services connected to your membership. Wholesale labs, in-office procedures, and other out-of-pocket costs that fit the IRS definition of qualified expenses are a clean fit for health savings account primary care spending. At RAW DPC, members access thousands of lab tests at discounted pricing, and those lab costs remain clearly qualified regardless of how the membership fee itself is classified.

How the HDHP and DPC Pairing Lowers Your Total Healthcare Cost

Even setting the HSA question aside, the financial case for pairing a DPC membership with an HDHP is strong.

Traditional insurance plans layer premiums, deductibles, copays, and variable billing in ways that make it nearly impossible to know what care will actually cost you until after the fact. An HDHP direct primary care setup works differently: when you swap a high-premium plan for a low-premium HDHP and add a flat-rate DPC membership, the math often comes out in your favor, especially for individuals and families who use primary care regularly but rarely need hospital-level services.

At RAW DPC, adult membership starts at $80 per month, with couple coverage at $150 per month and a family max of $240 per month for three or more children. Child memberships are also available at $30 per month when enrolled alongside a primary adult member, and Young Adult (18-24) memberships are available at $40 per month.  That includes same-day and next-day appointments, direct provider access by phone and text, and discounted pricing on labs. Stack that against a lower-premium HDHP, and many members find their total out-of-pocket costs are lower than what they paid under traditional insurance, with better access on top of it.

If you are on a HealthShare plan or exploring one, the same logic applies. Rural Authentic Wellness is one of the few practices in West Central Minnesota helping patients navigate how HealthShare and DPC work together, and it is a niche we understand well. Many families in the region have found that RAW Healthcare (Rural Authentic Wellness clinic membership and our cooperative HealthShare plan) gives them comprehensive coverage at a fraction of traditional insurance costs.

A Note on RAW Healthcare

RAW Healthcare is a cooperative that combines a RAW DPC membership with a health sharing plan. Enrollment happens directly with our team, not through an online process. If you are enrolled in RAW Healthcare, you cannot use HSA funds to pay for it. If HSA use is important to you, talk with our team first so we can help you find the membership option that fits your situation.

Can I Use FSA for Direct Primary Care?

Flexible Spending Accounts operate under a different set of rules than HSAs, and IRS Notice 2026-5 addressed HSA eligibility specifically, not FSA reimbursement. Whether a DPC membership fee qualifies for FSA reimbursement remains a separate question, and the gray area that applied to HSAs before January 2026 may still apply to FSAs. For a full breakdown of what counts as a qualified medical expense, the IRS Publication 502 is the authoritative reference, and a tax advisor can confirm how your specific FSA plan treats DPC fees. 

That said, FSA dollars can still go toward many of the clinical costs that come with your DPC membership. Labs, procedures, and other out-of-pocket medical expenses are generally FSA-eligible, so your FSA is not off the table for the care itself. The access fee and the care it enables are two different things, and only one of them sits in uncertain territory.

What This Means for Your RAW DPC Membership

Rural Authentic Wellness DPC is a flat-fee primary care practice located at 111 S. 10th St. in Olivia, MN, and 1252 E. Bridge St. in Redwood Falls, serving patients across Renville County and the surrounding region. Financial transparency is one of the reasons patients choose us. You will always know what your membership costs and what it covers before you commit to anything.

When patients ask about HSA eligibility, we walk them through the practical side: how the membership works, what pairing it with an HDHP looks like, and where a tax professional fits into that conversation. We are not tax advisors, and we will always be upfront about that. But we can make sure the healthcare side of the picture is completely clear so you are not making decisions based on guesswork.

If you want to see exactly what a RAW DPC membership includes before making any financial decisions, our membership overview page gives you the full picture with no fine print.

Ready to See If DPC Fits Your Budget?

You do not have to decode IRS notices on your own. A short conversation with our team can help you understand what is included, how it pairs with your current coverage, and whether RAW DPC is the right fit for where you are right now.

Meet and Greet or reach us directly at 320-400-3116.

Frequently Asked Questions

1. Is a DPC membership HSA-qualified?

It depends on which question you mean, though as of January 1, 2026 the answer to both is generally yes. Contributing to an HSA while enrolled in a DPC plan is allowed as long as you also carry an HDHP. Using HSA funds to pay the monthly DPC membership fee is now allowed too, under IRS Notice 2026-5, as long as the fee is within IRS monthly limits and the arrangement qualifies as primary-care-only. A tax advisor familiar with DPC arrangements can confirm how these rules apply to your specific membership. 

2. Is direct primary care HSA eligible?

As of January 1, 2026, yes, for arrangements that meet the IRS definition of a qualifying direct primary care service arrangement and fall within the monthly fee limits. Specific clinical services you receive through your membership, such as labs, procedures, and in-office care, have always been on clear ground as health savings account primary care expenses. 

3. What if my DPC membership fee is above the IRS monthly limit? 

If your DPC membership fee exceeds $150 per month for individual coverage or $300 per month for family coverage, the portion above that limit does not qualify as an HSA-eligible expense under Notice 2026-5. A CPA familiar with direct primary care can help you determine how much of your specific membership fee qualifies. 

4. Does HSA cover membership fees in general?

HSA funds are designed for IRS-defined qualified medical expenses. As of January 1, 2026, direct primary care membership fees can qualify, provided the fee falls within the IRS monthly limits and the arrangement meets the definition of a qualifying DPC service arrangement. Confirming your specific membership fee and structure with a tax advisor before applying HSA funds to the monthly fee is still the safest approach. 

5. What happens to my HSA if I cancel my HDHP to switch insurance plans?

Your existing HSA funds stay yours regardless of what happens to your insurance coverage. You can continue using saved HSA dollars for IRS-qualified medical expenses even after your HDHP ends. What stops is your ability to make new contributions. New HSA deposits require active HDHP enrollment, so once you switch to a non-HDHP plan, contributions pause until HDHP coverage is reinstated. Any balance you have already accumulated is yours to use indefinitely.   

Key Takeaways

• To contribute to an HSA, you need to be enrolled in an HDHP. A DPC membership on its own does not qualify you, but pairing DPC with an HDHP keeps your HSA contribution eligibility intact.
• IRS Notice 2026-5, issued under the One Big Beautiful Bill Act, clarified that certain DPC arrangements are compatible with HDHP and HSA participation, removing a long-standing point of confusion for DPC members.
• As of January 1, 2026, HSA funds can be used to pay your monthly DPC membership fee directly, as long as the fee is within IRS monthly limits and the arrangement qualifies as primary-care-only. Check with a tax professional to confirm how this applies to your specific membership.
• HSA and FSA funds can be used for clinical services received through your membership, including labs, procedures, and qualified out-of-pocket care, and the membership fee itself is now generally eligible too under the conditions above. 
• If you are enrolled in RAW Healthcare, HSA funds cannot be used to pay for it.
• Pairing a flat-rate DPC membership with a low-premium HDHP is a practical strategy for lowering total healthcare costs without sacrificing access to primary care.
• Adult membership at RAW DPC starts at $80 per month, with child memberships at $30 per month and a family max of $240 per month for three or more children, making the cost comparison with traditional insurance straightforward to run.