Three HSA changes took effect in 2026 — all ACA bronze and catastrophic plans now qualify, direct primary care no longer disqualifies you, and telehealth is permanent.
Three changes to HSA rules took effect in 2026. Together they are the largest expansion of who can open an HSA in the account's history, and almost nobody enrolled in a marketplace plan has heard about them.
All three come from the One Big Beautiful Bill Act, signed 4 July 2025, and were implemented through IRS Notice 2026-05.
If you have ever been told you could not have an HSA because your marketplace plan did not qualify, that answer may now be out of date.
This is the big one.
Before 2026, a plan qualified as an HDHP only if it met the IRS minimum deductible and maximum out-of-pocket thresholds. Plenty of ACA bronze plans have high deductibles but were not designed as HSA-qualified plans, so they failed the test on a technicality and their enrollees were locked out.
From 1 January 2026, all individual-market bronze and catastrophic plans are treated as HDHPs — even where the plan does not meet the minimum annual deductible requirement.
Read that twice, because it inverts the advice that has been correct for twenty years. The rule used to be "a high deductible does not make a plan HSA-qualified; it has to be built as one." For bronze and catastrophic marketplace plans specifically, that is no longer how it works.
Roughly 7.3 million marketplace enrollees became eligible to open and fund an HSA the day this took effect.
What to do about it: if you are on a bronze or catastrophic plan and do not have an HSA, you can almost certainly open one now. Nobody is going to write to tell you — HSA custodians do not know what plan you are on, and marketplace enrolment screens have been slow to reflect the change.
The other three eligibility conditions still apply in full, and they disqualify more people than the plan question does. They are covered in who can open an HSA.
Direct primary care is the arrangement where you pay a doctor or clinic a flat monthly fee for access, outside of insurance. It has been growing steadily, and it used to create an ugly problem: because the DPC arrangement counted as its own form of coverage, having one could disqualify you from contributing to an HSA at all.
That is fixed, and in both directions:
So an arrangement that used to be a trap is now something you can pay for with pre-tax dollars.
Two honest caveats. The dollar figures above are the thresholds as legislated; whether they index with inflation is not something to assume. And a DPC membership is not health insurance — it typically covers primary care access, not hospitalisation, so it usually sits alongside a plan rather than replacing one.
For several years, HDHPs were allowed to cover telehealth before you met your deductible without breaking HSA eligibility — under a pandemic-era rule that kept expiring and getting extended, sometimes with gaps in between.
It is now permanent, for plan years starting after 31 December 2024.
This is the least dramatic of the three and the most quietly useful. It means a plan can offer no-cost virtual visits without putting your HSA contributions at risk, and you no longer have to check whether the safe harbor happens to be in force this year.
Open enrolment for 2027 coverage happens this autumn. That is when you choose a plan, and it is the one moment each year when the plan question is actually decidable.
If you have been picking a silver plan because you assumed bronze meant no HSA, that trade-off has changed. A bronze plan now potentially comes with a triple-tax-advantaged account attached — and the triple tax advantage is the reason the HSA is worth structuring a decision around in the first place.
The 2027 numbers you will need for that paperwork are in HSA contribution limits for 2027: $4,500 self-only, $9,000 family, plus the same $1,000 catch-up at 55 and over.
Worth stating plainly, because expansions like this generate a lot of wrong confidence:
If you are on an ACA bronze or catastrophic plan, you are now HSA-eligible on the plan test, and you probably do not know it. If you pay for direct primary care, it no longer costs you your HSA. And telehealth before the deductible is finally settled law rather than an annual cliffhanger.
Check your plan type before open enrolment closes. It is the cheapest tax decision available to most people on the marketplace, and the rule that used to stop them changed quietly nine months ago.
General information, not tax or medical advice. Plan-specific eligibility should be confirmed with your plan documents or your HSA custodian.