HSA Eligibility Expansion Under OBBB Detailed in New IRS Guide
The Department of the Treasury and the Internal Revenue Service today released guidance on new tax benefits for Health Savings Account participants under the One, Big, Beautiful Bill (OBBB), detailing changes that expand HSA eligibility.
Notice 2026-05 addresses each of the changes, including:
- Telehealth and Remote Care Services: The OBBB made permanent the ability to receive telehealth and other remote care services before meeting the high-deductible health plan (HDHP) deductible while remaining eligible to contribute to an HSA, effective for plan years beginning on or after Jan. 1, 2025.
- Bronze and Catastrophic Plans Treated as HDHPs: As of Jan. 1, 2026, bronze and catastrophic plans available through an Exchange are considered HSA-compatible, regardless of whether the plans satisfy the general definition of an HDHP. This expands the ability of people enrolled in these plans to contribute to HSAs, which they generally have not been able to do in the past. Notice 2026-05 clarifies that bronze and catastrophic plans do not have to be purchased through an Exchange to qualify for the new relief.
- Direct Primary Care Service Arrangements: Beginning Jan. 1, 2026, an otherwise eligible individual enrolled in certain direct primary care (DPC) service arrangements may contribute to an HSA. In addition, they may use their HSA funds tax-free to pay periodic DPC fees.
Treasury and IRS invite comments on all aspects of this Notice by March 6, 2026. Commentors are encouraged to use the Federal e-Rulemaking portal to submit comments online (indicate “IRS-2025-0335”).
Back in October, Morningstar reported that assets in HSAs climbed to $146 billion in 2024, with an 18% year-over-year increase. The report noted that notes that the tax benefits associated with HSAs, along with widespread adoption of high-deductible health plans (HDHPs), has accelerated growth among the savings vehicles.
Morningstar also said it expects the OBBB expansion to stretch the number of HSA participants “by three to four million.”
In 2026, the HSA contribution limit for individuals with self-only coverage under a high deductible health plan (HDHP) will have an annual limitation of $4,400, an increase of $100 compared to 2025. Those with family coverage under a HDHP will see an annual limit of $8,750, an increase of $200 compared to 2025 limits.
Individuals who contribute to an HSA must first be enrolled in an HDHP. For 2026, a HDHP is defined by the IRS as a “health plans with an annual deductible that is not less than $1,700 for self-only coverage (a rise from $1,650 in 2025) or $3,400 for family coverage.” Out-of-pocket expenses for HDHPs, such as deductibles, co-payments, and other amounts, cannot exceed $8,500 for self-only coverage or $17,000 for family coverage.
SEE ALSO:
• HSA Assets Reach $146 Billion
• IRS Unveils Modest Growth for 2026 HSA Contribution Limits
• Employees Call for Greater Access to HSAs
Veteran financial services industry journalist Brian Anderson joined 401(k) Specialist as Managing Editor in January 2019. He has led editorial content for a variety of well-known properties including Insurance Forums, Life Insurance Selling, National Underwriter Life & Health, and Senior Market Advisor. He has always maintained a focus on providing readers with timely, useful information intended to help them build their business.