With the signing of H.R. 1 in the 119th Congress on 07/04/25 the HSA question has been simplified and will change in 2026 to a simple “yes” in 2026. I have gone into detail and included all the language related to DPC and HSA treatment from the “Big Beautiful Bill” on the revised tax page of DPC Frontier.

Here is the shortest summary I can provide. Even as of 2025 there were already clunky routes to decrease theoretical HSA audit risk for patients in DPC practices, but as of 2026 those clunky solutions are no longer needed if the practice 1) charges less than $150 per month and 2) is staff by specialists with training in family medicine, internal medicine, geriatric medicine, or pediatric medicine.

Also of note: In 2025 Oregon passed HB 2540 and it included the following language which allows DPC monthly fees to be applied toward an out of network deductible. See the Oregon page for details.

Hopefully I will run into many of you at the DPC Summit in a few weeks!