Three New Ways to Qualify for an HSA, and a Shorter Window to Use Them
A 58-year-old leaves a corporate job in Overland Park at the end of the year and buys a bronze plan on healthcare.gov. She asks whether she can keep funding the health savings account she has been building since her forties. For years the answer was no. Bronze plans almost never met the federal definition of a qualifying high deductible plan, so the account stopped receiving contributions the day her employer coverage ended.
As of January 1, 2026, the answer is yes. The 2025 tax law rewrote three separate pieces of the eligibility rules, and the IRS filled in the details in December. Most of the people this helps do not know it, and the window closes two weeks earlier this year than it used to.
What used to disqualify a bronze plan
A health savings account, or HSA, is the only account in the tax code that gives you a deduction going in, tax-free growth along the way, and tax-free withdrawals for medical costs. You can only fund one while you are covered by a qualifying high deductible health plan, and that qualification test is where most people get stopped.
Before 2026, qualifying meant meeting two federal tests: a deductible at or above a set minimum, and out-of-pocket exposure at or below a set maximum. For 2026 those figures are a $1,700 minimum deductible and an $8,500 out-of-pocket ceiling for self-only coverage, and $3,400 and $17,000 for family coverage, per Rev. Proc. 2025-19. Bronze plans usually cleared the deductible test and but exceeded the ceiling. Their out-of-pocket maximums ran above the federal limit. Catastrophic plans failed automatically, because they are required to cover three primary care visits before the deductible is met.
For months beginning after December 31, 2025, any bronze or catastrophic plan available as individual coverage through an exchange is treated as a qualifying high deductible plan, whether or not it meets the deductible and out-of-pocket tests.
IRS Notice 2026-5, issued December 9, 2025, answered the questions the statute left open. Buying the same plan off-exchange still qualifies, as long as that plan is available as individual coverage through an exchange. And buying the coverage with money from an employer's individual coverage health reimbursement arrangement, an arrangement where a business gives employees a fixed amount to buy their own individual policies rather than sponsoring a group plan, does not break eligibility either.
That last point is the one business owners should read twice. A small employer in Johnson County that moved to individual coverage reimbursement to control what health benefits cost can now pair it with bronze plans, and the employees can fund HSAs on top.
A direct primary care membership no longer locks you out
Direct primary care is an arrangement where you pay a family medicine practice a flat monthly amount for visits, basic labs, and routine care, outside of insurance. Before 2026, that membership counted as a second health plan and disqualified you from contributing to an HSA.
Under the new rules, a direct primary care arrangement is not treated as a health plan, provided the total monthly amount stays at or below $150 for one person, or $300 for an arrangement covering more than one. Those thresholds hold at $150 and $300 for 2027 as well, per Rev. Proc. 2026-24. You can also pay the membership out of the HSA itself.
The definition is narrow. The care has to come from a primary care practitioner, meaning a physician in family, internal, geriatric, or pediatric medicine, or a nurse practitioner, clinical nurse specialist, or physician assistant. Procedures requiring general anesthesia, prescription drugs other than vaccines, and lab work not typically done in a primary care office are all excluded. The flat periodic amount has to be the only compensation the practice receives for that care, so a practice that also bills you or your insurer separately for covered services is not a qualifying arrangement. Billing quarterly or annually is fine as long as it annualizes under the cap, which the IRS illustrates as $1,800 a year for one person.
If the membership costs more than the monthly limit, you are disqualified from contributing while enrolled, even though you can still reimburse the cost from an HSA you already have.
Telehealth before the deductible is now permanent
The pandemic-era rule allowing a high deductible plan to cover telehealth with no deductible, without breaking HSA eligibility, expired at the end of 2024 and was reinstated permanently by the same law, retroactive to plan years beginning after December 31, 2024. If your employer's plan added first-dollar telehealth and you stopped contributing out of caution, that caution is no longer necessary. The safe harbor tracks the list of telehealth services Medicare publishes each year, and it does not extend to in-person services, equipment, or drugs furnished in connection with a telehealth visit.
The enrollment window closes December 15 this year
For plan year 2027, open enrollment on the federal platform runs November 1 through December 15, under the CMS Marketplace Integrity and Affordability Final Rule. Kansas and Missouri are both federally facilitated marketplace states for 2027, so both sides of State Line Road get the same dates. Coverage begins January 1.
That is roughly two weeks shorter than the window people have gotten used to, and it lands in the same weeks as most employer open enrollment. So if you are deciding whether a bronze plan plus an HSA beats a silver plan without one, the comparison has to happen in early November rather than mid-December.
What the account is worth once you qualify
For 2027, the contribution limits are $4,500 for self-only coverage and $9,000 for family coverage, up from $4,400 and $8,750 in 2026. If you are 55 or older at the end of the year, you can add another $1,000. A couple who are both over 55 need two separate HSAs to use both catch-up amounts, because the extra $1,000 is per person and cannot be doubled inside one account.
At a 32 percent federal rate, a $9,000 family contribution is roughly $2,880 of federal tax you do not pay this year, before any state effect. The money grows untaxed and comes out untaxed for qualified medical expenses, at any age, with no deadline for reimbursing an expense you paid out of pocket years earlier. That last feature is what turns the account into a retirement asset rather than a spending account, which we covered in more depth in The Most Powerful Account You're Probably Using Wrong.
You have until the filing deadline for the year, generally April 15 of the following year, to make the contribution. If your employer offers a high deductible plan and funds part of the account, that employer money counts against the same limit, which is a detail worth checking during open enrollment alongside everything else in your benefits package. We walked through that kind of review for one large local employer in Are You Getting the Most From Your Garmin Benefits?
What still disqualifies you
Medicare enrollment ends HSA contributions. Your limit drops to zero beginning with the first month you are enrolled, and that applies to retroactive coverage, so a delayed Medicare application that gets backdated can turn contributions you already made into excess contributions. Anyone approaching 65 should coordinate the HSA cutoff with the rest of the retirement transition, including the Medicare surcharge review we described in Retired, but Medicare Still Uses Your Old Salary.
A general purpose health flexible spending account also disqualifies you, including your spouse's, if it can reimburse your medical expenses. So does being claimed as a dependent on someone else's return, and so does any other health coverage that pays before your deductible outside the narrow set of exceptions the code allows.
Where this changes an actual decision
Three situations are worth a look before November. Someone retiring before 65 who assumed individual coverage meant the end of HSA contributions. A business owner or self-employed person who priced a bronze plan, concluded it disqualified an HSA, and bought something else. And anyone who joined a direct primary care practice and dropped HSA contributions to do it.
The check itself is short. Confirm the plan is a bronze or catastrophic plan available as individual coverage. Confirm no one in the household has coverage that disqualifies you, the spouse's flexible spending account being the one people miss. If there is a direct primary care membership, confirm the monthly amount and ask the practice what it bills separately, because that answer determines whether the arrangement qualifies. Then set the contribution amount before December 15, when the plan choice locks for the year.
Use the tool below to check eligibility and see what the contribution is worth at your bracket.
2027 Plan Year
Can you fund an HSA, and what is it worth?
Check your eligibility under the rules that took effect January 1, 2026, then see the 2027 contribution limit and what the deduction saves at your bracket.
2027 limits: $4,500 self-only and $9,000 family, plus $1,000 if you are 55 or older at year end. A qualifying plan needs a deductible of at least $1,750 self-only or $3,500 family, with out-of-pocket exposure no higher than $8,700 or $17,400. Bronze and catastrophic plans available as individual coverage are treated as qualifying plans without meeting those two tests.
Partial-year eligibility is prorated by month, which is the conservative approach. A separate rule can allow a full-year contribution if you are eligible on December 1, but it carries a testing period that can undo the benefit, so it is worth reviewing before you rely on it.
Estimated savings apply your marginal federal rate to the contribution. They exclude state income tax, payroll tax, the alternative minimum tax, and any interaction with other deductions. Employer contributions to your account count against the same limit and are not included here. Figures are estimates for illustration.
Sources: IRS Rev. Proc. 2026-24 (2027 amounts), IRS Notice 2026-5 (bronze, catastrophic, direct primary care, and telehealth rules), IRS Publication 969 (catch-up amount, Medicare, and disqualifying coverage).
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