What changed
- Telehealth: plans can cover telehealth and other remote care before the deductible without breaking HSA eligibility, permanently, for plan years beginning on or after January 1, 2025.
- Bronze and catastrophic plans: from January 1, 2026, these plans are treated as HSA-compatible even if they do not meet the usual high-deductible definition. Notice 2026-05 says they do not have to be bought through an Exchange.
- Direct primary care: from January 1, 2026, people in certain direct primary care arrangements can still contribute to an HSA and can pay the periodic fees from it tax-free.