Paying for a One Medical membership with your HSA generally doesn’t work. The IRS treats the annual fee as payment for platform access rather than for medical care, so it isn’t a qualified medical expense. The clinical services you receive through One Medical — office visits, lab work, prescriptions, vaccinations — are qualified and can be paid from your HSA. A new federal rule effective January 1, 2026, opens the door for HSA money to cover certain direct primary care arrangements, but One Medical’s standard consumer membership almost certainly falls outside that definition.
Why the Membership Fee Doesn’t Qualify
One Medical charges $199 per year for non-Amazon Prime members and $99 per year for Prime members.1Amazon News. One Medical Review That fee buys same-day scheduling, 24/7 virtual chat through the app, and access to One Medical’s offices. It doesn’t pay for any specific diagnosis or treatment.
Under Section 213 of the Internal Revenue Code, a qualified medical expense is one paid for the diagnosis, cure, treatment, or prevention of disease, or to affect a structure or function of the body.2Office of the Law Revision Counsel. 26 USC 213 – Medical, Dental, Etc., Expenses Treasury regulations narrow the deduction further, confining it “strictly to expenses incurred primarily for the prevention or alleviation of a physical or mental defect or illness.”3eCFR. 26 CFR 1.213-1 – Medical, Dental, Etc., Expenses IRS Publication 502 adds that qualifying costs must involve legal medical services from licensed practitioners.4Internal Revenue Service. Publication 502 (2025), Medical and Dental Expenses
A subscription that gives you an app and a scheduling tool doesn’t clear that bar. You’re paying for the right to receive care later, not for care itself. The IRS treats this the same way it treats gym memberships and general wellness spending: convenient, health-adjacent, and not deductible.
If you pay the membership fee from your HSA anyway, the withdrawal is a non-qualified distribution. You’ll owe income tax on the amount plus a 20% additional tax.5Internal Revenue Service. Publication 969 (2025), Health Savings Accounts and Other Tax-Favored Health Plans The 20% penalty doesn’t apply if you’re 65 or older, disabled, or the distribution happens in the year of the account holder’s death, but income tax still applies.
The 2026 Direct Primary Care Rule
Starting January 1, 2026, HSA owners can pay for qualifying direct primary care arrangements (DPCAs) with tax-free HSA distributions, and enrolling in a qualifying DPCA no longer disqualifies you from contributing to an HSA. The IRS issued guidance on this change in Notice 2026-05 under the One, Big, Beautiful Bill Act.6Internal Revenue Service. Treasury, IRS Provide Guidance on New Tax Benefits for Health Savings Account Participants Under the One, Big, Beautiful Bill
The definition of a qualifying arrangement is narrow. A DPCA must provide medical care consisting solely of primary care services from primary care practitioners, and the sole compensation for that care must be a fixed periodic fee. The fee is capped at $150 per month for an individual and $300 per month for arrangements covering more than one person. The arrangement cannot provide additional healthcare items or services billed separately on top of the membership.
Why One Medical’s Consumer Membership Likely Doesn’t Fit
One Medical bills health insurance for clinical visits on top of the membership fee. From One Medical’s own FAQ: “for In-Office appointments and scheduled Remote visits, we bill you or your health insurance, and you are responsible for the standard fees, copayment, deductible or coinsurance.”7One Medical. Frequently Asked Questions
That structure breaks the DPCA requirement that the fixed periodic fee be the sole compensation for care. When the provider also collects insurance payments and copays for clinical visits, the membership fee isn’t the only revenue for the care being delivered. Earlier proposed regulations on direct primary care were even more explicit, defining such an arrangement as one where the physician agrees to provide care “without billing a third party.”8Federal Register. Certain Medical Care Arrangements
Some employers offer One Medical through a separate direct primary care benefit that may be structured differently, without insurance billing. If your employer has set up a DPC-specific arrangement, that version could potentially qualify under the new law. The standard $199 or $99 consumer membership almost certainly does not.
One Medical Charges You Can Pay With HSA Funds
The membership fee is off limits. The actual medical care you receive through One Medical is not. Every time you see a provider for a visit, get a flu shot, or have blood drawn, the charge for that specific service qualifies as a medical expense.4Internal Revenue Service. Publication 502 (2025), Medical and Dental Expenses Use your HSA debit card at checkout or reimburse yourself later.
Eligible clinical charges at One Medical include:
- Office visit copays, coinsurance, or the full visit cost if you haven’t met your deductible
- Lab work, blood panels, diagnostic tests, and preventive screenings
- Out-of-pocket costs for prescriptions written during a visit
- Flu shots, travel vaccines, and other immunizations administered by One Medical providers
The distinction is whether you’re paying for a specific service or for membership. An invoice for a strep test is a medical expense. The annual subscription that lets you book the appointment for that strep test is not.
The Amazon Prime Bundle
Amazon Prime members can add One Medical for $99 per year or $9 per month, a $100 discount off the standard rate. Prime members can also add up to five family members at $66 per year each.1Amazon News. One Medical Review
The discount doesn’t change the analysis. Whether you pay $99 or $199, the fee buys platform access rather than medical treatment. Bundling adds another wrinkle: IRS rules require that the medical portion of any bundled payment be separately stated and reasonable in amount.4Internal Revenue Service. Publication 502 (2025), Medical and Dental Expenses Even if the membership component were someday treated as a medical expense, you’d need clear documentation isolating it from the broader Prime bundle.
If You Already Paid the Fee From Your HSA
You may not be stuck with the tax hit. The IRS allows you to repay a mistaken distribution if you reasonably believed the expense was qualified and later learned it wasn’t. The deadline to return the money is the due date of your tax return (without extensions) for the first year you knew or should have known the distribution was a mistake.9Internal Revenue Service. Instructions for Forms 1099-SA and 5498-SA
If you repay within that window, the distribution isn’t included in your gross income, isn’t subject to the 20% additional tax, and the repayment isn’t treated as an excess contribution. Contact your HSA administrator to initiate the return. Not every custodian is required to accept repayments of mistaken distributions, so ask before assuming you can reverse the transaction. If the custodian does accept the return, they should correct any Form 1099-SA that was previously filed.
If the deadline has passed or your custodian won’t accept the repayment, report the non-qualified distribution on Form 8889 with your tax return. You’ll owe income tax on the amount plus the 20% additional tax unless you qualify for an exception.5Internal Revenue Service. Publication 969 (2025), Health Savings Accounts and Other Tax-Favored Health Plans
Keeping Your Records Straight
The most useful habit here is filing membership invoices and clinical receipts separately. A membership invoice shows a subscription period and a flat annual charge. A clinical receipt lists the date of service, the provider’s name, a description of what was done, and the amount charged for that visit. These are different documents, and mixing them up is where people run into trouble at tax time.
For every HSA withdrawal you make for One Medical services, keep an itemized receipt or an Explanation of Benefits from your insurer showing the covered service. The IRS generally requires you to keep records supporting tax return items for three years from the filing date.10Internal Revenue Service. How Long Should I Keep Records? Electronic copies work as long as they’re legible and include the service details. If you’re claiming HSA distributions for clinical visits while paying a separate membership fee to the same provider, organized records are what proves you used the money correctly.