Two things changed for HSA eligibility rules in 2026 under the OBBBA. The contribution limits moved up modestly. The eligibility rules, thanks to the One, Big, Beautiful Bill Act (OBBBA), changed in ways that matter a lot more for return preparation.
IRS Revenue Procedure 2025-19 covers the limit adjustments. The OBBBA, signed July 4, 2025, amended IRC Section 223 in three specific ways, and the IRS addressed those changes in Notice 2026-5, published December 9, 2025.
For CPAs preparing 2026 returns, the key question around HSA eligibility 2026 OBBBA isn’t whether a client has an HSA — it’s whether their coverage arrangement actually qualifies under the updated rules, and whether contributions made in 2026 are defensible.
2026 HSA Contribution Limits
Per Revenue Procedure 2025-19, self-only coverage increased by $100 and family coverage by $200. The catch-up contribution for participants age 55 and older remains $1,000, unchanged since 2009 by statute.
| Coverage Type | 2025 Limit | 2026 Limit | Change |
|---|---|---|---|
| Self-only | $4,300 | $4,400 | +$100 |
| Family | $8,550 | $8,750 | +$200 |
| Catch-up (age 55+) | $1,000 | $1,000 | No change |
Both employee and employer contributions count toward these limits. Where both spouses are 55 or older and not yet enrolled in Medicare, each may make a $1,000 catch-up contribution in separate HSAs.
The contribution deadline for a given tax year extends through April 15 of the following year under the last-month rule in Section 223(b). Contributions for 2026 can be made through April 15, 2027.
2026 HDHP Thresholds and HSA Eligibility 2026
HSA eligibility 2026 OBBBA requires enrollment in a qualifying high-deductible health plan. Both the minimum deductible and out-of-pocket maximums increased for 2026.
| HDHP Requirement | Self-Only Coverage | Family Coverage |
|---|---|---|
| Minimum annual deductible | $1,700 (up from $1,650) | $3,400 (up from $3,300) |
| Maximum out-of-pocket | $8,500 (up from $8,300) | $17,000 (up from $16,600) |
Plans failing to meet both thresholds generally don’t qualify. The OBBBA created two exceptions to that general rule, covered in the next section.
Three OBBBA Changes to HSA Eligibility 2026
Notice 2026-5 walks through the OBBBA’s HSA provisions in Q&A format. Three changes are directly relevant to whether a client’s contributions are valid under the HSA eligibility 2026 OBBBA framework.
1. HSA Eligibility 2026: Telehealth Safe Harbor Now Permanent
The CARES Act (2020) created a temporary safe harbor allowing HDHPs to cover telehealth services before the minimum deductible without disqualifying participants from HSA contributions. That provision lapsed for plan years beginning on or after January 1, 2025, creating a gap year for calendar-year plans.
The OBBBA made the safe harbor permanent and applied it retroactively to plan years beginning after December 31, 2024. Participants whose HDHPs provided pre-deductible telehealth coverage in 2025 remain eligible to have contributed to their HSAs for that year, including those enrolled before the July 4 enactment date.
Per Notice 2026-5, the safe harbor covers remote services defined by the Medicare list under Social Security Act Section 1834(m)(4)(F). It doesn’t extend to in-person services, medical equipment, or pharmaceuticals dispensed in connection with a telehealth visit, unless those items independently qualify under separate guidance.
2. OBBBA 2026: Bronze and Catastrophic Plans Now HSA-Compatible
Effective for months beginning after December 31, 2025, Exchange-based bronze and catastrophic plans are treated as qualifying HDHPs under Section 223(c)(2)(H), regardless of whether they meet the standard HDHP deductible and out-of-pocket thresholds. This is a significant expansion of HSA eligibility 2026 OBBBA created.
Before the OBBBA, most bronze plans failed HSA qualification because their out-of-pocket maximums exceeded HDHP statutory limits or because they covered certain services pre-deductible. Catastrophic plans had two structural problems: required coverage of three primary care visits pre-deductible, and OOP maximums above the HDHP ceiling. Both are now HSA-compatible.
One boundary to note: a bronze or catastrophic plan purchased off-Exchange qualifies only if the same plan is also offered through an Exchange.
3. OBBBA HSA Eligibility 2026: Direct Primary Care Service Arrangements
This is the most technically complex of the three HSA eligibility 2026 OBBBA changes. The OBBBA amended Sections 223(c)(1) and 223(d)(2)(C) to address DPCSAs: arrangements where individuals pay a fixed periodic fee to a primary care provider for a defined set of primary care services. Two changes apply for months beginning after December 31, 2025:
- DPCSAs no longer constitute disqualifying coverage. Individuals enrolled in both a qualifying HDHP and a DPCSA can still contribute to an HSA.
- HSA funds can pay DPCSA fees tax-free. Previously those fees risked treatment as insurance premiums, which are generally not qualified medical expenses.
To qualify, a DPCSA has to provide only primary care services from primary care practitioners, and charge a fixed periodic fee with no separate billing for covered services. The 2026 fee cap is $150 per month for individuals and $300 per month for family coverage, with annual inflation adjustments beginning in 2027.
Two employer-side details matter. Employer-paid DPCSA fees, including through salary reduction in a cafeteria plan, are excludable under Section 106 and can’t be treated as the employee’s qualified medical expenses for HSA purposes. Notice 2026-5 also clarifies that DPCSA services don’t include procedures requiring general anesthesia, prescription drugs other than vaccines, or lab services not typically administered in ambulatory primary care settings.
The Tax Structure: Three Benefits, One Account
The mechanics of HSA tax treatment haven’t changed. Payroll contributions reduce taxable income dollar-for-dollar. Direct contributions made outside payroll are deductible above-the-line under Section 62, regardless of whether the account holder itemizes. Employer contributions are excluded from gross income entirely.
Earnings accumulate without current tax. Withdrawals for qualified medical expenses under Section 213(d) carry no federal income tax, and there’s no use-it-or-lose-it rule. After age 65, HSA funds used for non-medical purposes are subject to ordinary income tax but no additional penalty, similar to traditional IRA treatment.
Medicare Part B and D premiums, and eligible long-term care insurance premiums up to the age-based limits under Section 213(d)(10), qualify as HSA expenses after 65.
Stay Current on HSA Eligibility 2026 OBBBA Changes
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