Who Can Open an HSA? HDHP Requirements and Disqualifiers

You can open a Health Savings Account if you’re covered by a qualifying high-deductible health plan, aren’t enrolled in Medicare, and aren’t claimed as a dependent on anyone else’s tax return. Starting January 1, 2026, that pool gets much larger: people enrolled in bronze or catastrophic marketplace plans qualify too, even when those plans don’t meet the traditional HDHP definition.¹

What Counts as a Qualifying High-Deductible Health Plan

The core requirement sits in 26 U.S.C. § 223(c)(2), and the IRS resets the dollar thresholds each year for inflation. For the 2026 calendar year, a qualifying plan has to hit both of these targets:²

Self-only coverage: a minimum annual deductible of $1,700 and a maximum out-of-pocket limit of $8,500 (deductibles, copays, and other expenses, but not premiums).
Family coverage: a minimum annual deductible of $3,400 and a maximum out-of-pocket limit of $17,000.

Both numbers have to line up. A plan with a high enough deductible but an out-of-pocket maximum above the ceiling won’t qualify. Your plan’s summary of benefits and coverage should say whether the plan is HSA-compatible.

One thing that won’t cost you HDHP status: preventive care. Federal law includes a safe harbor allowing plans to cover annual physicals, immunizations, and routine screenings before you meet the deductible without breaking eligibility.³ Using those covered preventive services is fine.

The 2026 Expansion: Bronze, Catastrophic, DPC, and Telehealth

The One, Big, Beautiful Bill Act, signed in 2025, broadened HSA eligibility in three ways starting January 1, 2026:¹

Bronze and catastrophic plans are now treated as HSA-compatible regardless of whether they meet the traditional HDHP deductible and out-of-pocket thresholds. The IRS has clarified that bronze and catastrophic plans bought outside an exchange qualify too.⁴
Paying a periodic fee for a direct primary care membership no longer disqualifies you, and you can use HSA funds tax-free to pay those DPC fees.
Receiving telehealth services before meeting your HDHP deductible won’t jeopardize your eligibility. This rule is now permanent for plan years starting on or after January 1, 2025.

Silver and gold marketplace plans still don’t qualify for HSA contributions unless they independently meet the standard HDHP definition. The expansion covers bronze and catastrophic only.

What Disqualifies You Even With the Right Plan

A qualifying plan gets you most of the way there. Several other conditions can still block contributions.

Medicare Enrollment

Once you’re entitled to Medicare benefits — Part A, Part B, or Part D — your HSA contribution limit drops to zero for that month and every month afterward.³ The OBBBA didn’t change this, and it catches a lot of people: at 65, if you’re receiving Social Security, you’re automatically enrolled in Medicare Part A, which triggers the bar. You can still spend money already in the account on qualified medical expenses. You just can’t add more. To keep contributing past 65, you have to delay both Social Security and Medicare enrollment.

Dependent Status

If someone else can claim you as a dependent on their tax return, you can’t deduct contributions to your own HSA.³ The rule keeps the same person from generating tax benefits on two returns.

Other Health Coverage

You generally can’t have a second health plan that pays benefits before your HDHP deductible is met. Watch for these situations:

A spouse’s general-purpose Flexible Spending Account that can reimburse your medical expenses counts as disqualifying “other coverage.” Switching your spouse to a limited-purpose FSA, which only reimburses dental and vision, preserves your eligibility.
Secondary insurance that covers non-preventive services before your HDHP deductible is met will disqualify you.
Veterans Affairs or TRICARE coverage generally counts as disqualifying, though VA benefits received solely for a service-connected disability may not.

Partial-Year Eligibility and the Last-Month Rule

Eligibility is measured month by month. If you only had HDHP coverage for part of the year, your contribution limit is prorated: divide the number of eligible months by 12, then multiply by the annual limit. Six months of self-only HDHP coverage in 2026 gets you $2,200 (6 ÷ 12 × $4,400).

There’s an exception. Under the last-month rule, if you’re an eligible individual on December 1, the IRS treats you as eligible for the entire year and lets you make the full annual contribution.⁵ The tradeoff is a testing period: you have to stay eligible through December 31 of the following year. Lose eligibility during that window by switching to a non-qualifying plan or enrolling in Medicare, and the amount you contributed above your prorated share becomes taxable income plus a 10 percent additional tax. Death and disability are the only exceptions.

How to Open the Account

Once you qualify, there are two common paths. Many employers partner with a specific HSA custodian and let you enroll through a benefits portal during open enrollment. If you’re self-employed or your employer doesn’t offer an HSA option, you can open one directly at any bank, credit union, or brokerage firm that serves as a qualified HSA trustee. Monthly maintenance fees vary from nothing to a few dollars, so compare before choosing.

To apply, you’ll usually need your Social Security number, a residential address, your HDHP insurer’s name, the coverage effective date from your insurance ID card or member portal, and the names, dates of birth, and Social Security numbers of any beneficiaries. Most institutions activate the account within a few business days and mail a debit card shortly after.

The account is yours, not your employer’s. Change jobs, switch health plans, or retire, and the balance goes with you. If you later lose HDHP coverage and can’t make new contributions, you still have full access to the existing balance for qualified medical expenses, including using it to pay COBRA premiums. Annual contribution limits for 2026 are $4,400 for self-only coverage and $8,750 for family coverage, plus a $1,000 catch-up contribution if you’re 55 or older, and contributions for a given tax year can be made any time before that year’s tax filing deadline.²⁶

1
Internal Revenue Service. One, Big, Beautiful Bill Provisions
2
Internal Revenue Service. Rev. Proc. 2025-19
3
Office of the Law Revision Counsel. 26 USC 223 – Health Savings Accounts
4
Internal Revenue Service. Treasury, IRS Provide Guidance on New Tax Benefits for Health Savings Account Participants Under the One, Big, Beautiful Bill
5
Internal Revenue Service. 2025 Instructions for Form 8889
6
Internal Revenue Service. Instructions for Form 8889