Direct Primary Care memberships became HSA-eligible with a hard monthly cap, telehealth's pre-deductible safe harbor became permanent — and the gym provision died. What actually changed in 2026.
Starting January 1, 2026, individually-paid DPC membership fees are qualified expenses AND holding a DPC membership no longer breaks HSA eligibility — up to $150/month (self) or $300/month (family), inflation-adjusted (OBBB 2026; IRS Notice 2026-05).
The cap is a CLIFF, not a ceiling: pay $151/month and the entire arrangement is disqualifying for that month — not just the extra dollar. And employer-paid DPC never qualifies; only fees you pay yourself count.
Since 2020, a temporary rule let HDHPs cover telehealth before the deductible without costing members their HSA eligibility. OBBB §71306 made that safe harbor permanent. Teladoc-style visits, virtual mental health, and telemedicine prescriptions can be covered first-dollar.
Early drafts included fitness expenses; the final law stripped them. Gym memberships, fitness classes, and exercise equipment remain NOT broadly HSA-eligible in 2026. The only path remains a Letter of Medical Necessity prescribing exercise for a specific diagnosed condition. Any vendor implying blanket gym eligibility is selling risk.
If you use a DPC practice: confirm your fee is under the cap, confirm you (not your employer) pay it, and track it monthly — Candor's DPC tracker warns you before the cliff. If you're choosing an HDHP: telehealth coverage no longer carries HSA risk. If you're hoping to HSA-fund your gym: the LMN path or nothing.
Candor vaults your receipts, tracks your Claimable Balance, and answers eligibility questions with IRS citations — free.
Start your shoebox — freeInformational only — not tax, legal, or medical advice. Consult a qualified tax professional about your situation. Rules version 2026-07-16, last verified July 2026.