This guide will help you understand the recent changes introduced by the One Big Beautiful Bill (OBBB), how they affect Health Savings Accounts (HSAs), and what you should do next. Whether you're an individual, employer, or benefits consultant, this guide is written to give you clear, actionable information.
What is the One Big Beautiful Bill?
The One Big Beautiful Bill (OBBB) is a federal law passed in 2025 that updates who can open and use a Health Savings Account, or HSA. An HSA is a special savings account that lets people set aside money for healthcare expenses, including dental and vision. The money goes in tax-free, grows without being taxed, and can be spent on approved health costs without taxes.
One key change in the law is that it expands HSA access to people who have certain Affordable Care Act (ACA) health plans, specifically Bronze and Catastrophic tier plans. The ACA is a federal law that helps people get health insurance, often through online marketplaces. Bronze plans are one of the most basic options and usually have lower monthly payments but higher out-of-pocket costs. Catastrophic plans are designed mainly for people under 30 or with special hardship situations and offer very low monthly premiums with very high deductibles.
The OBBB also makes some types of care, like telehealth and direct primary care (up to certain dollar thresholds), permanently eligible for HSA use. Telehealth is healthcare delivered through phone or video visits. Direct primary care is a type of care where you pay your doctor a monthly fee for regular visits instead of using insurance. Additionally, telehealth and direct primary care arrangements (defined as arrangements costing up to $150/month for individuals and $300/month for families) no longer disqualify you from contributing to an HSA bringing more flexibility to employers.
These updates aim to modernize how people access care and manage out-of-pocket costs. More people can now open HSAs and use them for everyday health services that fit their lifestyle and budget.
What's Changing for Health Savings Accounts?
The One Big Beautiful Bill (OBBB) introduces several major updates to Health Savings Account (HSA) rules—expanding both who can use them and how they can be used:
Expanded eligibility: Starting in 2026, individuals enrolled in Bronze or Catastrophic Affordable Care Act (ACA) plans will be able to open and contribute to an HSA. These lower-premium, higher-deductible plans were previously excluded due to HSA rules but will now qualify.
Also starting in 2026, Direct Primary Care (DPC) arrangements (defined as arrangements costing up to $150/month for individuals and $300/month for families) are now recognized as qualified medical expenses under HSA rules—even if paid outside of a traditional insurance claim. Additionally, having a DPC arrangement no longer disqualifies you from funding an HSA.
Telehealth flexibility made permanent: For plan years beginning after December 31, 2024, high-deductible health plans (HDHPs) that offer first-dollar coverage for telehealth will no longer be disqualified from HSA compatibility. This makes virtual care access a permanent, HSA-compatible benefit.
These changes represent the most significant HSA expansion in nearly two decades. Individuals, employers, and brokers should start planning during the 2025 open enrollment period to take full advantage of the new rules.
Who is now eligible for an HSA under the OBBB?
Under the OBBB, the eligibility criteria for opening and contributing to a Health Savings Account has changed. As of January 1, 2026, more individuals will qualify based on their health plan type. If you are enrolled in a Bronze or Catastrophic Affordable Care Act (ACA) health plan, you will meet the primary coverage requirement for HSA eligibility under the new law.
Bronze ACA plans are commonly used by individuals who buy insurance on their own through the ACA marketplace. These plans typically offer lower monthly premiums but come with higher deductibles, meaning you pay more out of pocket before insurance begins to cover costs.
Catastrophic ACA plans are designed for people under age 30 or those who qualify for a hardship exemption. These plans have very low monthly premiums and very high deductibles and are meant to protect you from worst-case medical costs.
To qualify for an HSA, you must also meet the following eligibility criteria.
These rules ensure that the HSA is being used in combination with high-deductible insurance, which is how it provides the most benefit.
Eligibility by Plan Type
Plan Type | Eligible for HSA Under OBBB? | Details |
Bronze ACA Plan | Yes | Low monthly premium, high deductible. Common ACA marketplace plan. |
Catastrophic ACA Plan | Yes | Designed for people under 30 or those with a hardship exemption. |
Silver, Gold, or Platinum ACA Plans | No | These plans do not meet HSA requirements under the new rules. |
Medicare (Part A or full) | No | Having full Medicare disqualifies you from contributing to an HSA. |
When Do These Changes Take Effect?
The HSA-related provisions in the OBBB take effect on January 1, 2026, except for the telehealth provision which will apply to all plans after December 31, 2024. This would allow individuals who become eligible under the new rules to open and contribute to an HSA starting with the 2026 plan year.
A plan year is the 12-month period your health insurance plan covers, typically running from January 1 through December 31. Employers, brokers, and individuals should begin preparing during open enrollment in 2025.
How These Changes Could Impact You
With the One Big Beautiful Bill (OBBB) now passed into law, the new rules will affect individuals, employers, and brokers in important ways. Here's what you need to know:
Individuals
If you are enrolled in a Bronze or Catastrophic Affordable Care Act (ACA) plan, you can have access to a Health Savings Account (HSA) starting January 1, 2026. An HSA is a tax-advantaged savings account used for qualified medical expenses. These changes allow you to:
Open an HSA for the first time
Use HSA funds for eligible services like telehealth visits, or direct care from doctors who do not bill insurance (up to $150/month for individuals and $300/month for families).
Learn more about health savings accounts.
Employers
Employers can now offer a wider variety of health plan options and employee benefits plan designs while maintaining HSA eligibility. This includes:
Expanding HSA-compatible benefits to more employees
Including virtual-first or hybrid plan options in your benefits package
Partnering with a platform like Lively to simplify integration, onboarding, and support
A hybrid health plan is a health insurance model that includes both in-person care and virtual healthcare services under a single plan design.
Explore the easiest solution for flexible employee benefits.
Brokers and Consultants
Brokers and consultants now have new opportunities to help clients adapt to the expanded HSA rules. You can:
Recommend HSA-eligible Bronze and Catastrophic ACA plans to more individuals and small groups
Support the adoption of direct primary care and telehealth services within benefit offerings
Use Lively’s platform and resources to streamline plan design and administration
Learn more about flexible employee solutions clients will love.
How to open an HSA Under the New Rules
If you’re newly eligible because of the OBBB, opening an HSA might be your first experience with this kind of account. Here’s how to get started:
Confirm your plan: Make sure you're enrolled in a Bronze or Catastrophic ACA health plan for 2026.
Check eligibility: Confirm you meet all the requirements.
Choose an HSA provider: Compare providers based on fees, investment options, and digital tools.
Open your account: You can typically apply online in minutes.
Start contributing: For 2026, contribution limits will follow IRS guidance. Contributions are tax-deductible.
Once your account is open, you can begin saving and using funds for eligible health expenses.
Using Your HSA Under OBBB: What’s Newly Covered
The OBBB permanently expanded what you can pay for using your Health Savings Account. Two important services are now fully HSA-qualified:
Telehealth services: These include virtual visits with a doctor, therapist, or other licensed provider. Under the OBBB, plans that cover telehealth before the deductible will remain HSA-compatible for plan years beginning after December 31, 2024, making virtual care a permanent, flexible option for HSA users.
Direct Primary Care (DPC): In this care model, you pay a flat monthly fee directly to your primary care provider for routine services, without involving insurance. This model is now fully eligible for HSA reimbursement (up to $150/month for individuals and $300/month for families).
These changes help make healthcare more accessible and affordable for people who want flexible care options.
What the OBBB Signals About the Future of Health Benefits
The One Big Beautiful Bill is part of ongoing efforts to update how health benefits are structured in the United States. It introduces new options for individuals and employers, especially around who can access a Health Savings Account and how funds can be used.
Some consumers are interested in consumer-directed healthcare, which allows them to manage their healthcare spending through savings tools like HSAs.
Employers are exploring virtual-first and hybrid care models as part of their benefits strategy.
Policy makers have introduced measures that aim to expand access to healthcare services and support different ways for individuals to manage their care.
These developments may shape how health benefits are designed in the future. We will continue to update this guide as additional information becomes available.
Next Steps for Navigating the New HSA Rules
The One Big Beautiful Bill introduces several changes to Health Savings Accounts that affect individuals, employers, and brokers. As the 2026 plan year approaches, it’s important to understand how these updates apply to your situation and how to prepare.
If you’re an individual, now is the time to review your current health coverage. If you qualify for a Bronze or Catastrophic ACA plan, you may be newly eligible to open an HSA starting in 2026. An HSA can help you save money on medical expenses and build a financial cushion for future healthcare needs.
Employers should evaluate whether their current health benefits align with the updated HSA rules. Adding virtual-first or hybrid health plans could expand access for employees while maintaining tax advantages. If you’re considering changes, it may help to plan implementation early.
Brokers and consultants can use this moment to support clients in adapting to the new legislation. By staying up to date on eligibility and benefit design changes, you can help employers navigate options more confidently.
If you’d like to learn more about your options or need help getting started, contact our team to speak with someone directly.