President Trump’s signing of the “One Big Beautiful Bill Act” on July 4, 2025, was a big win for concierge medicine practices, often called direct primary care (DPC). The new law allows favorable treatment for DPC arrangements under many Health Savings Accounts (HSAs). Many people enrolled in HSA plans who also participate in DPC programs can take advantage of using their HSA funds for DPC services under the new law. This is a big step forward for DPC plans, allowing many more individuals to participate in personalized primary care models.
The law specifies that the DPC arrangement must solely provide “primary care services” by “primary care practitioners” who bill their members a fixed, periodic fee. These fees cannot exceed $150 per month for individuals and $300 per month for families currently.
Previously, an individual was disqualified from contributing to an HSA if they paid a DPC fee because it was viewed as a health plan. Now, a DPC service arrangement shall not be considered a health plan under the new law for purposes of the high deductible health plan (HDHP) requirement. These fees will be considered qualified medical expenses and will not be considered insurance, so individuals can remain in an HDHP and still participate in a HSA plan.
However, it is important to note that the Act requires that these fees be paid only for primary care services, which specifically excludes procedures that require the use of general anesthesia, prescription drugs other than vaccines, and laboratory services not typically administered in an ambulatory primary care setting.
While not all HSA plans will cover these DPC plans, the law allows that HSA plans can now cover these eligible DPC arrangements, which was not previously the case. This legislation will increase access to DPC care models for many individuals who can now use their HSA funds to pay for their DPC services.
With the new law to be effective after December 31, 2025, the time is right to consider how this new legislation may affect your healthcare practice.
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