Health Savings Accounts Under H.R. 1: Expanded Access and Eligibility in Plain Language

Published December 16, 2025

Why This HSA Update Matters for Consumers and Employers

Starting January 1, 2026, important shifts take effect that will impact plan eligibility, telehealth access, and the ways HSA funds can be used. The IRS clarified these provisions in Notice 2026‑05.

HSAs have long helped people save on healthcare costs while reducing taxable income. These clarifications extend that benefit to a broader group of people, including those enrolled in plans that were previously ineligible.

Bronze & Catastrophic Plans Now HSA‑Compatible

Why These Plans Were Previously Ineligible

Previously, only High‑Deductible Health Plans (HDHPs) qualified for HSA eligibility. Bronze and catastrophic plans, common choices for lower premiums on the ACA marketplace, did not meet the IRS’s HDHP criteria.

What H.R. 1 Changes Mean for Consumers

Under H.R. 1, bronze and catastrophic plans will be treated as HSA‑compatible beginning in 2026, meaning more individuals and families can open and contribute to HSAs while enrolled in these lower‑cost plans.

Permanent Expansion of Telehealth Coverage

Background on Temporary Telehealth Rules

During the COVID‑19 pandemic, the IRS allowed telehealth services to be covered pre‑deductible without affecting HSA eligibility. That temporary rule is now permanent for plan years beginning January 1, 2025, as clarified by the IRS guidance.

Benefits of Pre‑Deductible Telehealth Access

Making telehealth pre‑deductible permanently helps patients access care earlier, particularly in mental health and rural areas where in‑person care may be limited.

Direct Primary Care (DPC) Arrangements Now Qualify

What Is DPC and Why It Matters

Direct Primary Care is a model where patients pay a flat monthly fee directly to a primary care provider for comprehensive services. It removes traditional insurance as the middleman and focuses on preventive care.

IRS Greenlight for HSA Use with DPC

Beginning in 2026, certain DPC arrangements will qualify for HSA contributions and tax‑free withdrawals to cover ongoing membership fees. This change makes personalized care more affordable with tax‑advantaged savings.

What the IRS is Asking for Now

The IRS’s Notice 2026‑05 opens the door for public comment through March 6, 2026. The agency is inviting feedback from employers, tax professionals, insurers, and individuals on how these changes should be implemented.

Key Takeaways for Employers and Individuals

• Review health plan options for 2026 — Bronze and catastrophic plans may now be HSA compatible.
• Update benefits communications — HR teams and advisors should explain these changes to employees.
• Explore telehealth and DPC integration — These options are now permanently compatible with HSA usage.
• Plan ahead tax strategy — Individuals and small business owners should incorporate the new HSA eligibility into year‑end planning.

Conclusion

H.R. 1, supported by IRS Notice 2026‑05, significantly broadens HSA access starting in 2026. With bronze and catastrophic plans becoming eligible, telehealth permanently HSA‑friendly, and DPC arrangements qualifying for tax‑free use, more Americans can benefit from HSA savings.

Now is the time to review your plans, update communications, and maximize your HSA benefits under these new guidelines.