Expanded Eligibility and Benefits for Health Savings Accounts Under New Legislation
January 18, 2026
Business News

Expanded Eligibility and Benefits for Health Savings Accounts Under New Legislation

The 2025 OBBB Law Broadens Access and Contribution Limits for HSAs, Offering Enhanced Tax Advantages

Summary

The 2025 enactment of the One Big Beautiful Bill (OBBB) brought significant updates to the regulations regarding Health Savings Accounts (HSAs), making these tax-advantaged accounts accessible to a broader group of Americans. Key shifts include expanded eligibility criteria—particularly for ACA marketplace enrollees in high-deductible Bronze and Catastrophic plans—and allowances for those using direct primary care subscriptions to contribute and benefit from HSAs. Additionally, contribution limits have increased for 2026, presenting individuals and families with greater capacity to save pre-tax funds for healthcare expenses.

Key Points

The One Big Beautiful Bill (OBBB) signed into law in July 2025 modifies tax regulations related to Health Savings Accounts, extending eligibility.
From January 1, 2026, individuals enrolled in high-deductible Bronze and Catastrophic plans on the ACA marketplace can contribute to HSAs.
Direct primary care membership holders can now have HSAs if monthly fees are below specified thresholds, and they may use HSA funds to pay these fees.

The passage of the One Big Beautiful Bill (OBBB) into law in July 2025 introduced a range of tax reforms impacting several areas, including the structure and accessibility of Health Savings Accounts (HSAs). These accounts have long been recognized for their distinct tax benefits, and the recent legislative changes notably widen the pool of individuals eligible to open and contribute to an HSA. This shift reflects a significant adjustment in the landscape of consumer-driven healthcare savings.


HSAs offer a comprehensive triple tax advantage that is uncommon among financial accounts. First, contributions made to an HSA are deductible from federal taxable income within the contribution year, effectively reducing an individual's taxable earnings. Second, any assets within the account can appreciate through investments without incurring tax liabilities during the growth phase. Third, withdrawals made for qualified medical expenses are exempt from federal income tax. This unique set of benefits has made HSAs a valuable tool for managing healthcare costs and long-term financial planning.


Historically, eligibility to open and contribute to an HSA was limited to individuals enrolled in a high-deductible health plan (HDHP). These plans are distinguished from traditional preferred provider organization (PPO) plans by their higher annual deductibles and correspondingly lower premiums. For 2025, the Internal Revenue Service defines an HDHP as a plan with a minimum deductible of $1,700 for self-only coverage or $3,400 for family coverage. These thresholds set the parameters for the plans that confer HSA eligibility.


With the enactment of the OBBB, the eligibility criteria expanded to include participants in high-deductible Bronze and Catastrophic plans available through the Affordable Care Act (ACA) marketplace starting January 1, 2026. This means that millions more enrolled in these particular ACA plans can now open and contribute to Health Savings Accounts, thereby accessing the tax advantages previously reserved for HDHP enrollees. It is important to note, however, that individuals enrolled in Medicare are excluded from HSA eligibility under these regulations.


Another notable outcome of the OBBB is its impact on individuals utilizing direct primary care arrangements. Direct primary care involves a membership-style model where patients pay a fixed monthly fee in exchange for a defined set of primary care services, including routine health examinations, consultations, and certain laboratory diagnostics and procedures. Before the OBBB, subscribers to such plans were ineligible for HSAs. The new legislation permits individuals with direct primary care memberships to maintain and contribute to HSAs provided the monthly fee does not exceed $150 for individuals or $300 for families. Moreover, HSA funds can now be used to cover the monthly direct primary care fees, enhancing the flexibility and usefulness of these accounts for subscribers.


In terms of contribution limits, the OBBB sets the 2026 maximum HSA contributions at $4,400 for individuals with self-only coverage and $8,750 for those with family coverage. Additionally, individuals aged 55 years and older are eligible to make an extra $1,000 as a catch-up contribution. Given these thresholds, enrollees should consider contributing as much as possible to maximize their tax savings, though even partial contributions offer the unique triple tax advantage HSAs provide.


In summary, these legislative modifications broaden the accessibility and attractiveness of Health Savings Accounts. By expanding who can contribute and allowing subscription-based healthcare arrangements to coexist with HSAs, the OBBB enhances the toolkit available to Americans striving to manage rising healthcare costs effectively through tax-efficient savings.

Risks
  • Individuals enrolled in Medicare are ineligible to contribute to or maintain HSAs.
  • Only certain healthcare plans, meeting minimum deductible requirements, confer HSA eligibility.
  • There are maximum annual contribution limits that must be adhered to, varying by coverage type and age, which could restrict the amount saved.
Disclosure
This article is for informational purposes only and does not constitute financial advice or recommendations. Individuals should consult a financial advisor or tax professional to determine eligibility and contribution strategies for Health Savings Accounts.
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