
The US Treasury Department and IRS have issued Notice 2026-05, answering numerous questions related to a series of Health Savings Account changes introduced in the One Big Beautiful Bill Act.
These HSA changes increase access to and use of contributions, and this appears to be a part of a larger policy aimed at expanding access to tax-favored healthcare savings. Noted in a release from the IRS are a series of key changes that become effective in 2025 and 2026.
One of the most pressing changes that affect many people currently involves Telehealth. Beginning with plan years on or after Jan. 1, 2025, individuals will be able to continue Telehealth care without meeting their HDHP deductible in order to reman HSA-eligible. This Temporary Rule has been made permanent and has been in use since the pandemic.
Starting from Jan. 1, 2026, Bronze as well as Catastrophic Marketplace Plans will now be HSA-compatible HDHPs. This has opened the door for many members who were not eligible for contributions. This has been clarified in Notice 2026-05 as there was some confusion as to whether it has to be part of an exchange.
This guidance also covers direct primary care contracts. Beginning in 2026, individuals in certain direct primary care arrangement models are eligible to contribute to an HSA and pay their periodic direct primary care payments with HSA funds tax free, subject to other requirements.
The Treasury Department and the IRS are soliciting public comments on all matters contained in this notice until March 6, 2026.