💌 Revisiting a Tax Thing: A Brief Primer on Health Savings Accounts (HSAs) Program -- and what some changes could mean for You

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_{Educational only. Not investment or tax advice.}

Back in early December, the Department of the Treasury and the Internal Revenue Service issued Notice 2026-05 as implementing guidance for taxpayers to establish and contribute cash toward a health savings account (HSA) for people covered under a high-deductible health plan (HDHP) and have no disqualifying health coverage. The Trump Administration describes this update as an expansion of tax savings for individual health care coverage.

Within this notice, there is a 10-page Q&A section explaining how the One, Big, Beautiful Bill Act (OBBBA) updates provisions for:

·      Telehealth and Remote Care Services

·      Affordable Care Act (ACA) Bronze and Catastrophic Plans Treated as HDHPs

·      Direct Primary Care Service Arrangements

Here a very brief snapshot of some details…as usual, with clarity.

The OBBBA makes permanent a COVID-era safe harbor provision for receiving telehealth and other remote care services before meeting the HDHP deductible.  It makes the safe harbor retroactive for health plan years that started after December 31, 2024.

The statutory minimum annual deductibles and out-of-pocket maximums are adjusted annually for inflation. The minimum annual deductible for 2025 is $1,650 for self-only coverage and $3,300 for family coverage, and the out-of-pocket maximum for 2025 is $8,300 for self-only coverage and $16,600 for family coverage.¹

The allowable tax deduction amounts for contributions to an HSA are based on monthly limitations. You can’t deduct all of it based on a one-time lump sum contribution.  For self-only coverage on the HDHP, the maximum monthly amount is 1/12 of $2,250. The family coverage amount is 1/12 of $4,500. For individuals that reach age 55 during the tax year, an additional $1,000 can be deducted.²

An HSA may be used to pay for medical care under IRC §213(d) of the Code; however, an HSA generally may not be used to pay for insurance, with certain exceptions. Notice 2026-05 addresses the issue of fixed periodic fees that direct primary care service arrangements (DPCSAs) charge for primary care services and items, such as:

·      physical examinations,

·      vaccinations,

·      urgent care,

·      laboratory testing, and

·      diagnosis and treatment of some sicknesses and injuries.³

However, the primary care services definition does not include:

·      procedures that require the use of general anesthesia,

·      prescription drugs other than vaccines (therefore, vaccines are permitted primary care services), and

·      laboratory services not typically administered in an ambulatory primary care setting.⁴

Although this Notice was issued in early December, there’s still time for interested parties to chime in on this. Treasury and IRS invite comments until March 6, 2026 at 11:59 PM Eastern Standard Time. Commenters are encouraged to use the Federal e-Rulemaking portal to submit comments online.  Use “IRS-2025-0335” in the search field.

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There’s the scoop, everyone! 

Thanks for taking time to check out this week’s edition of the Tax Clarity Newsletter. 

Thank you so much!

References (4)

¹ Notice 2026-5, Expanded Availability of Health Savings Accounts under the One, Big, Beautiful Bill Act (OBBBA) (October 23, 2025), last accessed December 12, 2025.

² IRC §223(b)(3)

³ Notice 2026-05

⁴ Ibid.

DISCLAIMER: The information in this newsletter is derived from public information, provided for education purposes. It is not provided as a financial advisory service and should not be relied upon as such. For advice on a specific tax matter, please consult a tax professional.