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IRS Clarifies When HSA Funds Can Cover Direct Primary Care Fees — Here’s What Counts in 2026

February 26, 2026 by Drew Blankenship
HSA funds
Image Source: Shutterstock

Direct primary care (DPC) has been a go-to for many Americans to receive predictable monthly costs and easier access to doctors. Until recently, no one could nail down whether HSA funds could legally pay for those fees. Well, the IRS has finally clarified when HSA funds can cover DPC fees. The new guidance spells out exactly which DPC services qualify as medical care and which do not, ending years of confusion and conflicting interpretations.

For seniors, families, and self‑employed workers trying to stretch every healthcare dollar, these rules determine whether DPC is a smart financial move or a costly mistake. So, here’s what the IRS says about this and what can actually be covered.

Monthly Membership Fees Can Be Eligible

The IRS now allows HSA funds to cover DPC membership fees when those fees pay for actual medical care. This includes services like routine visits, chronic disease management, preventive screenings, and basic in‑office procedures. The key requirement is that the fee must directly relate to diagnosing, treating, or preventing a medical condition.

If the membership includes non‑medical perks, such as wellness classes, administrative support, or lifestyle coaching, those portions are not eligible. Patients may need itemized statements from their DPC provider to prove which parts of the fee qualify.

Labs, Imaging, and Procedures Are Eligible When Billed Separately

When a DPC practice offers in‑house labs, X‑rays, or minor procedures, those services can be paid with HSA funds as long as they are itemized. The IRS considers these services traditional medical care, even when provided under a DPC model. Many clinics offer discounted cash‑pay rates for these services, making HSAs a powerful tool for lowering out‑of‑pocket costs.

However, if the clinic bundles these services into a flat membership fee, only the portion tied to medical care is eligible. Patients should request clear breakdowns to avoid IRS issues later.

Preventive Care Services Are Fully Eligible Under the New Rules

The IRS confirmed that preventive care, such as annual physicals, screenings, and routine check‑ups, can be paid for with HSA funds when provided through a DPC practice. This aligns with existing HSA rules that allow tax‑free spending on preventive services even before meeting the deductible.

For patients managing chronic conditions, this clarification is especially helpful because many DPC clinics offer ongoing monitoring and follow‑up visits. These services qualify as medical care as long as they are not bundled with non‑medical perks. The clearer definitions make it easier for patients to use their HSAs confidently and correctly.

A Smarter Way to Use HSAs in a Changing Healthcare Landscape

The IRS’s 2026 clarification finally gives patients a roadmap for using HSA funds responsibly within the direct primary care model. By distinguishing medical services from convenience perks, the rules help consumers avoid costly mistakes and maximize tax‑free benefits. Patients who understand these distinctions can choose DPC practices that align with both their health needs and their financial goals. As more Americans look for alternatives to traditional insurance, HSAs remain one of the most powerful tools for managing out‑of‑pocket costs.

Do you use a direct primary care practice, or are you considering one? Share your experience in the comments. 

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Drew Blankenship headshot
Drew Blankenship

Drew Blankenship is a seasoned automotive professional with over 20 years of hands-on experience as a Porsche technician.  While Drew mostly writes about automotives, he also channels his knowledge into writing about money, technology and relationships. Based in North Carolina, Drew still fuels his passion for motorsport by following Formula 1 and spending weekends under the hood when he can. He lives with his wife and two children, who occasionally remind him to take a break from rebuilding engines.

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