Short answer: Usually not. A direct primary care (DPC) fee is paid to the practice and is not an insurance claim, so most plans do not count it toward your deductible, the amount you pay before insurance starts paying. The IRS says the same for HSA-compatible DPC fees. Ask your plan to confirm.
Direct primary care is a membership model. You pay a monthly fee to a doctor's office, and the office does not bill your insurance company for each visit. The Tennessee Department of Commerce and Insurance says such fees will not likely be reported to, or accepted by, a person's health plan. It also says DPC fees will not count toward an insured person's annual deductible or out-of-pocket payments. That is a statement from one state, so a plan in another state could treat things differently. Ask your own plan.
A health savings account (HSA) is a savings account for medical costs that you can have with certain high-deductible health plans (HDHPs). Starting in 2026, a federal law change lets a person in a qualifying direct primary care arrangement still contribute to an HSA. The arrangement must provide only primary care, and the only payment must be a fixed periodic fee. The total fees must be no more than $150 a month for one person or $300 a month for an arrangement that covers more than one person. These limits are adjusted for inflation after 2026. Our page on using an HSA to pay for direct primary care explains these rules in more detail.
In Notice 2026-5, the IRS says fees an individual pays for this kind of membership would not count toward the minimum annual deductible and the out-of-pocket maximum for the high-deductible plan. If your fee is above the limit, you cannot make HSA contributions while you are enrolled. Please check with a tax adviser about your own situation.
In general, what counts toward a deductible is your share of the cost of covered services that your insurance plan processes, such as a hospital stay or a specialist visit. Your plan documents spell out which costs count. A DPC fee is a payment for membership, not for a claim, which is why it is treated differently. If your DPC doctor orders a test or sends you to a specialist, that bill may go through your insurance, and it may count. Ask your plan how it handles each case.
Because the fee probably will not count toward your deductible, treat it as a separate bill on top of your insurance costs. Add up your monthly premium (what you pay to keep the plan), the DPC fee and what you may pay toward the deductible if you need care outside the practice. Then compare that total with what you spend now. A DPC membership is not insurance, so keep coverage for emergencies and hospital care.
To learn more, read what direct primary care is or see what direct primary care costs in each state. You can also find a direct-pay doctor near you.
No. Notice 2026-5 says fees an individual pays for a qualifying DPC membership would not count toward the minimum annual deductible and out-of-pocket maximum of the high-deductible plan.
Starting in 2026, a qualifying arrangement can work with an HSA if it meets the IRS rules, including the $150 a month limit for one person or $300 for a plan covering more than one person. Check with a tax adviser.
Tennessee's insurance department says such fees will not likely be reported to or accepted by a person's health plan. Plans can differ, so ask yours.
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