New HSA Rule Makes Direct Primary Care a Game Changer

5-minute read

For years, Direct Primary Care has been one of the best-kept secrets in employer-sponsored healthcare. It’s not flashy. It doesn’t promise a magic bullet. But it works.

Employees get unlimited access to their doctor. No co-pays. No insurance runaround. No guessing. Just real, personal, preventive care — early, often, and on their terms.

For employers, the payoff is big: lower claims, fewer ER visits, fewer expensive downstream procedures, and a workforce that’s healthier, happier, and far less frustrated with their health plan.

A new federal rule lets employees use HSA dollars for Direct Primary Care. Here's what that means for your health plan.

The reductions in claims expenses alone are significant. An analysis by Hint Health of over 1 million DPC members in 2023 found that employees enrolled in DPC incurred 12.6% lower overall claims costs compared to those in a traditional health plan.

The problem? It’s never been easy to offer DPC alongside a high-deductible health plan (HDHP) with an HSA.

The tax rules didn’t allow it — until now.

A Quiet Fix That Changes Everything

Buried deep in the One Big Beautiful Bill Act — signed into law in 2025 — is a provision that finally clears the way for HSA-eligible employees to enroll in a DPC membership and keep contributing to their HSA. Even better, starting in January 2026, they can use HSA dollars to pay for that membership directly.

Also read: Transforming Your Company Health Plan: Proven Solutions for Cost Control and Better Care

It’s a long-overdue fix. Under the old rules, DPC was classified as a second health plan, which disqualified employees from using an HSA at all. That left employers in a bind: they could either offer DPC and kill the HSA, or preserve HSA eligibility and leave DPC off the table. Most chose the latter.

The new law removes that tension. And while there are some guardrails — capped monthly fees, a definition of what counts as “primary care,” and provider requirements — they’re reasonable. And they make DPC accessible in ways it simply wasn’t before.

Why Direct Primary Care Works

Here’s what DPC actually solves: access.

Employees don’t delay care because they’re lazy. They delay care because they can’t get in. Or because they’re not sure what it will cost. Or because the last time they tried to navigate the system, it made them feel like a number.

Direct Primary Care bypasses all of that.

Instead of waiting three weeks for a rushed appointment, employees can message or call their DPC provider directly. They can be seen the next day — sometimes the same day. They don’t think twice about seeing their doctor, because there’s no co-pay. They’re not discouraged from asking questions, because their doctor has time.

That kind of relationship with a provider doesn’t just feel better. It actually produces better health outcomes. More screenings. Better chronic condition management. Fewer urgent care visits. And fewer complications that lead to hospitalizations.

How It Fits Into a Self-Funded Strategy

DPC doesn’t replace your health plan — it makes it work smarter.

When offered alongside a self-funded plan, Direct Primary Care becomes a frontline defense against high-cost claims. It catches issues early. It reduces reliance on ERs and urgent care centers. And because DPC providers aren’t incentivized by volume, they’re more likely to steer patients away from unnecessary procedures and toward evidence-based care.

We’ve seen clients use DPC in combination with other tools — like real-time price transparency, cash-pay options, and Centers of Excellence — to fundamentally reset the cost curve of their health plans.

They don’t do it with cost-shifting. They do it by creating systems that make healthcare work better.

What You Can Do Now

If you’re fully insured today, this might be the trigger that gets you thinking about moving to a level-funded or self-funded plan.

If you’re already self-funded, DPC could be your next strategic move — not as a bolt-on gimmick, but as a foundational part of how you deliver care.

We all know healthcare is broken. DPC isn’t the fix for everything — but it’s a fix for a lot.

And now, thanks to the OBBB, it’s not just a good idea. It’s a practical one.

If you’ve dismissed Direct Primary Care before because of the HSA conflict, it’s time to take another look.

Let’s talk about how to make it work — for your plan, your employees, and your bottom line.

The Mahoney Group, based in Chandler, Ariz., is one of the largest independent insurance and employee benefits brokerages in the U.S. For more information, visit our website or call 877-440-3304.


This article is not intended to be exhaustive, nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel or an insurance professional for appropriate advice.

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