Does your organization sponsor Health Savings Accounts (HSAs) for its employees? Or are you considering a high-deductible health plan (HDHP) with HSAs for your 2026 benefits package? Either way, the recent enactment of the One, Big, Beautiful Bill Act (OBBBA) brings some interesting news.
In short, the OBBBA expands eligibility for HSAs beginning in 2026. This development could mean that more of your employees can become HSA participants or that the HDHP+HSAs model will be more viable for your organization.
Multiple objectives
HSAs can help employers and employees accomplish multiple objectives. They allow participants, who own their accounts, to save money on a tax-advantaged basis for qualified medical expenses. Their contributions, generally made through pretax compensation deferrals, are tax-free as funds enter, grow within and exit their accounts.
Also, employer-sponsors may set up HSAs as investment vehicles. This way, participants can amass funds throughout their working lives for retirement and estate planning purposes.
The accounts can support your organization’s strategic goals as well. They may help lower overall health care benefits costs because HDHPs are generally less expensive for employers than other plan types. Additionally, HSAs encourage more informed medical spending and saving among participants, potentially resulting in fewer high-cost claims.
Under the requirements, an employer must sponsor an HDHP to also sponsor HSAs. And participants can’t have any other disqualifying coverage, such as a spouse’s non-HDHP or Medicare.
OBBBA changes
As mentioned, starting in 2026, the OBBBA broadens eligibility for HSA participation. It does so by loosening some restrictions that previously disqualified certain individuals from contributing to an HSA.
For example, under previous rules, many people enrolled in HDHPs who bought from a Health Insurance Marketplace (commonly known as an “exchange”) were ineligible to contribute to HSAs. Beginning in 2026, however, enrollees in Bronze or Catastrophic plans can participate in HSAs.
The new law also paves the way for individuals enrolled in direct primary care arrangements to generally qualify for HSA contributions. This assumes that other conditions are met, such as being covered by a qualifying HDHP and not receiving other disqualifying benefits.
The direct primary care arrangement in question must have a monthly fee of $150 or less, or $300 or less if it covers more than one person. Those dollar amounts will be annually adjusted for inflation.
Another pertinent OBBBA change is that the law restores the “telehealth coverage exception.” Introduced under the Coronavirus Aid, Relief, and Economic Security Act in 2020, it temporarily allowed HDHPs to provide telehealth services without requiring participants to first meet their deductibles. The exception disappeared under previous rules but will return permanently in 2026 and won’t impede applicable HDHP participants from contributing to HSAs.
By clarifying these aspects of HSA participation, the OBBBA allows employers to sponsor these accounts with less confusion about who is and isn’t eligible. The law’s positive impact may be especially felt by employers whose workforces have diverse or nontraditional health care needs — such as gig workers, part-time staff members and employees in rural areas.
The path forward
With 2026 fast approaching, now’s a good time to review your organization’s health care benefits. If you already sponsor an HDHP with HSAs, evaluate how the OBBBA’s changes affect your plan. And if eligibility concerns have kept you from considering HSAs in the past, the path forward may be clearer now. Contact us for help deciding whether expanding or adding an HDHP with HSAs makes sense for your organization.
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