As part of a major step forward for patient-centered care, new federal legislation as a result of the “One Big Beautiful Bill” (OBBB), is set to significantly expand the accessibility and affordability of Direct Primary Care (DPC) across the U.S. Starting January 1, 2026, key policy changes will unlock both individual and employer opportunities to engage with DPC models in ways previously restricted by federal rules.

These changes represent the culmination of years of advocacy by DPC leaders, bipartisan lawmakers, and health reform advocates who believe in a future where personalized, relationship-based care is available to all. While the details are still evolving and open to further interpretation, two major impacts of this new legislation stand out today.

1. Individuals Can Now Use HSA Funds for DPC

Under the new policy changes, Direct Primary Care will now be considered a qualified medical expense, allowing patients to use Health Savings Account (HSA) dollars to pay for their DPC subscriptions.

This reclassification validates the role of Direct Primary Care within the broader healthcare system and strengthens its position as a practical, front-line solution for both prevention and chronic disease management.

Why This Matters: For individuals with HSA-eligible plans, including HDHPs as well as Bronze and Catastrophic ACA plans, Direct Primary Care offers a more accessible and affordable way to receive routine care. Instead of navigating high out-of-pocket costs and delayed coverage, patients can build ongoing relationships with their physicians, access care when they need it, and avoid financial strain, all through a predictable, membership-based model.

By allowing HSA funds to cover DPC subscriptions, the policy change delivers a meaningful benefit:

• Tax-advantaged access to personalized, proactive primary care
• A new funding source that makes DPC a viable option for more families

This opens up this powerful model of care to a broader population than ever before.

2. Employers Can Now Pair DPC With HSA-Eligible HDHPs

Before the OBBB, the IRS viewed Direct Primary Care subscriptions as a potential “second health plan,” which made it legally risky for employers to offer DPC alongside high-deductible health plans paired with HSAs. This limitation forced many employers to avoid the pairing altogether, even if it was in the best interest of their workforce.

That barrier is now gone. With the new guidance making it clear that Direct Primary Care is not a health insurance plan and removing regulatory hurdles, employers now have the green light to offer DPC as a benefit alongside HDHP + HSA.

Why This Matters:

Employers can now integrate DPC into their health plans with greater confidence, knowing it aligns with federal guidelines. As a result, they can offer employees a more personalized and accessible healthcare experience that supports long-term health while managing costs.

However, it’s important to note:

• Other expenses incurred at the DPC clinic, such as labs and medications, are subject to zero-dollar coverage rules and cannot be paid by the employer.
•  The HDHP cannot pay DPC membership fees on behalf of employees or provide DPC membership until the minimum deductible is met. DPC must be structured as a separate, standalone benefit outside the health plan. 
• The OBBB also introduces price ceilings for DPC under its official definitions, which may influence how practices structure their offerings. The caps are:
  • Up to $150 per month for an individual DPC subscription
  • Up to $300 per month for family coverage
    
    

Still, this marks a pivotal turning point for employers who believe in the value of DPC but were previously held back by compliance concerns.

What’s Next?

While these provisions take effect January 1, 2026, it’s crucial for patients, practices, and employers to start preparing now. As the implementation details evolve, Hint is committed to providing up-to-date guidance and support for our partners across the DPC ecosystem.

These changes represent more than just policy shifts; they’re a validation of the DPC model and its long-standing promise: accessible, affordable, human-centered care for all.

This is just the beginning.

Ready to Build a DPC-Centered Health Plan?

Whether you're looking to integrate Direct Primary Care alongside HDHPs or explore a complete DPC-first benefits strategy, our team at Hint Connect is here to help.

Visit connect.hint.com to schedule a call with our experts and explore how to design a compliant, cost-effective, and patient-first health plan.

Let’s reimagine healthcare together.

Disclaimer: This article reflects early interpretations of the OBBB legislation. The regulatory landscape is still developing, and we expect further clarification from federal agencies in the coming months. We’ll continue to monitor changes closely and share updates as they emerge.

 Editor's Note: This article was updated on 03/10/2026 to correct an earlier claim that DPC fees count toward HDHP deductibles and out-of-pocket maximums. Per IRS guidance, DPC fees do not count toward these accumulators.