What changed
For years, paying a DPC membership disqualified you from contributing to an HSA. The IRS treated DPC as a separate health plan. That made no sense for the patient and held the DPC movement back.
Federal legislation passed in 2025 changed that, and the change takes effect for plan months beginning in 2026. Under it, a Direct Primary Care arrangement is no longer treated as disqualifying coverage, within monthly fee limits set by the law.
What this means for you
If you have an HSA-eligible high-deductible health plan, this means you may be able to pair it with a Gem MD membership. Whether your specific plan and membership qualify depends on your circumstances, so confirm with your HSA administrator or tax advisor before you rely on it.
How to set it up
Most HSAs allow direct payment from the account or reimbursement against receipts. Talk to your HSA administrator about which workflow they support. We can provide itemized receipts. We are not tax advisors, and nothing here is tax advice.
If you have questions about whether DPC plus an HDHP is the right setup for your family, book a free meet-and-greet.