What Qualifies as an HDHP: 2026 Thresholds, Telehealth, and DPC

A health plan qualifies as a High Deductible Health Plan (HDHP) when it meets two IRS dollar tests and limits what it pays for before you hit the deductible. For 2026, that means an annual deductible of at least $1,700 for self-only coverage or $3,400 for family coverage, with total in-network out-of-pocket costs capped at $8,500 or $17,000 respectively.¹ Starting January 1, 2026, all bronze and catastrophic marketplace plans also count as HDHPs automatically, even if their cost-sharing doesn’t hit those numbers.² Qualifying matters because HDHP coverage is the gateway to a Health Savings Account.

The 2026 Dollar Thresholds

The IRS updates HDHP thresholds each year for inflation. A plan has to clear both the deductible floor and stay under the out-of-pocket ceiling:¹

Self-only coverage: minimum deductible of $1,700; maximum out-of-pocket of $8,500.
Family coverage: minimum deductible of $3,400; maximum out-of-pocket of $17,000.

Out-of-pocket expenses include the deductible, copays, and coinsurance for covered in-network services. Premiums don’t count. If the deductible falls below the floor or the out-of-pocket cap sits above the ceiling, the plan isn’t an HDHP no matter what the insurer calls it.

For network plans, the out-of-pocket cap only has to hold for in-network care. A plan doesn’t lose HDHP status because its out-of-network cost limits run higher.³ Out-of-network deductible amounts also don’t count toward the annual limits used to figure HSA contributions.

For comparison, 2025 thresholds were $1,650 and $8,300 for self-only, and $3,300 and $16,600 for family coverage.⁴ A plan that barely qualified last year should be re-checked against the 2026 numbers.

What a Qualifying Plan Can Pay for Before the Deductible

The structural feature that defines an HDHP, beyond the dollar amounts, is that it can’t pay for covered benefits before you meet the annual deductible. Preventive care is the exception. A plan can cover preventive services with no deductible and still qualify.³

What counts as preventive is set by IRS guidance, not the insurer’s marketing. The list covers annual physicals and routine exams, childhood and adult immunizations, prenatal and well-child care, tobacco cessation and obesity programs, and various screening services.⁵

In 2019 the IRS expanded that list to include certain treatments for chronic conditions where the goal is preventing the condition from worsening. Examples include insulin and glucose-lowering agents for diabetes, statins for heart disease, blood pressure monitors for hypertension, inhaled corticosteroids for asthma, and SSRIs for depression.⁶ A plan covering these before the deductible still counts as an HDHP.⁷

Plans also keep their HDHP status when they cover services required under federal surprise billing protections before the deductible is met.³ Anything else paid before the deductible breaks qualification.

What Changed for 2026

The One, Big, Beautiful Bill Act (OBBBA) made three changes that expand what qualifies, effective January 1, 2026.

Bronze and Catastrophic Plans Qualify Automatically

Any bronze-level or catastrophic health plan now counts as an HDHP for HSA purposes, whether or not its cost-sharing hits the standard thresholds.² Many bronze plans previously missed HDHP qualification because their deductibles or out-of-pocket structures didn’t line up with the IRS numbers. IRS Notice 2026-5 confirms this applies to bronze and catastrophic plans purchased outside the marketplace as well, even though the statute references Exchange-purchased plans.⁸

Direct Primary Care Arrangements No Longer Disqualify You

Before 2026, a direct primary care (DPC) membership could be treated as separate health coverage that killed HSA eligibility. Starting January 1, 2026, a DPC arrangement is disregarded as long as it covers only primary care services for a fixed periodic fee.⁸ HSA funds can also be used tax-free to pay the DPC fees.²

Telehealth Before the Deductible Is Permanent

The OBBBA made permanent the rule that a plan can cover telehealth or other remote care before the deductible without losing HDHP status. This was a temporary provision Congress kept extending. It now applies for all plan years beginning on or after January 1, 2025.²

Why HDHP Coverage Alone Isn’t Enough

HDHP enrollment is the plan-side test. To actually contribute to an HSA, you also have to meet the person-side conditions on the first day of each month you contribute:³

Covered by a qualifying HDHP.
No other disqualifying health coverage.
Not enrolled in any part of Medicare.
Not claimed as a dependent on someone else’s tax return.

Contribution limits are prorated by month. Gaining eligibility mid-year, or losing it partway through, reduces the amount you can put in.

Coverage That Disqualifies You and Coverage That Doesn’t

Most eligibility problems come from a second layer of coverage that pays for the same benefits the HDHP covers, before the HDHP deductible is met.

FSAs and HRAs

A general-purpose Flexible Spending Account or Health Reimbursement Arrangement reimburses medical expenses from the first dollar, which functions as non-HDHP coverage alongside your HDHP and blocks HSA contributions. A limited-purpose FSA or HRA that’s restricted to dental, vision, or post-deductible expenses doesn’t cause this problem.³ Confirm which version an employer offers before enrolling.

A Spouse’s Non-HDHP Plan

If a spouse has a traditional plan that also covers you, you aren’t HSA-eligible even with your own HDHP. The spouse’s plan pays benefits before your HDHP deductible, which counts as disqualifying coverage.

VA Medical Benefits

Veterans who receive non-preventive medical services or prescription drugs through the VA lose HSA eligibility for the following three months. A routine physical to maintain VA enrollment doesn’t trigger the restriction.⁹

What the Statute Disregards

Several types of coverage are specifically excluded from the disqualification rule. You can hold any of these alongside an HDHP: standalone dental or vision plans, accident insurance, disability insurance, long-term care insurance, and workers’ compensation.³ As of 2026, qualifying direct primary care arrangements and pre-deductible telehealth are also disregarded.

How to Confirm a Specific Plan Qualifies

Insurance carriers indicate whether a plan is HSA-eligible in the Summary of Benefits and Coverage document. Don’t assume a plan qualifies just because the deductible is high. Check three things: the deductible meets the annual floor, the in-network out-of-pocket maximum sits at or below the ceiling, and the plan doesn’t pay for anything except preventive care (and, where applicable, telehealth and surprise-billing services) before you meet the deductible. If any of those pieces is off, the plan isn’t an HDHP for HSA purposes, whatever it’s marketed as.

1
Internal Revenue Service. Revenue Procedure 2025-19
2
Internal Revenue Service. Treasury, IRS Provide Guidance on New Tax Benefits for Health Savings Account Participants Under the One, Big, Beautiful Bill
3
Office of the Law Revision Counsel. 26 USC 223 – Health Savings Accounts
4
Internal Revenue Service. Revenue Procedure 2024-25
5
Internal Revenue Service. IRS Notice 2004-23
6
Internal Revenue Service. IRS Notice 2019-45 – Preventive Care for Specified Conditions
7
Internal Revenue Service. IRS Expands List of Preventive Care for HSA Participants to Include Certain Care for Chronic Conditions
8
Internal Revenue Service. IRS Notice 2026-5 – Expanded Availability of Health Savings Accounts Under the OBBBA
9
U.S. Office of Personnel Management. Health Savings Accounts