Clinic Memberships and HSA Payments: What U.S. Practices Need to Distinguish in 2026

Start with three separate decisions

General HSA contribution eligibility includes qualifying coverage and other conditions; membership in a qualifying DPC arrangement does not remove those separate tests. Publication 969 also distinguishes qualified-expense distributions from contributions. This guide addresses the clinic's payment planning rather than determining any patient's tax position. Internal Revenue Service: Publication 969 (2025): Health Savings Accounts and Other Tax-Favored Health Plans

Train the team answering payment questions to preserve that distinction. 'Our account can process this card' is narrower than 'every charge under this membership is HSA-eligible.' Neither statement should be inferred from a payment terminal accepting a test transaction.

Read the membership terms before using the DPC label

Public Law 119-21, section 71308, defines the relevant arrangement around medical care consisting solely of primary care by statutorily defined primary-care practitioners, compensated by a fixed periodic fee. Excluded services include procedures requiring general anesthesia, prescription drugs other than vaccines, and laboratory services not typically administered in ambulatory primary care. These changes apply to months after December 31, 2025. U.S. Government Publishing Office: Public Law 119-21, section 71308: Treatment of direct primary care service arrangements

A concierge, wellness, telehealth or clinic membership label does not settle that definition. Have the actual agreement reviewed: what is included, who provides it and whether the charge is the sole compensation for that care. Do not describe a package of unrelated services as DPC because it uses monthly billing.

IRS Notice 2026-05 distinguishes included care billed separately from services outside the arrangement available to members and non-members. It also says an arrangement does not qualify merely because a patient declines to use a service in the package that falls outside the DPC definition. Review the terms, not just the patient's expected use. Internal Revenue Service and U.S. Treasury: Notice 2026-05: Expanded Availability of Health Savings Accounts, especially Q&A 11-20

• List included services and any separately billed services in plain language.
• Identify the charging entity and practitioner roles without sending patient information.
• Record the fixed fee, covered people, coverage period and cancellation terms.
• Flag drugs, laboratory services or other bundled benefits for the appropriate professional review.

Apply the 2026 dollar test to the correct question

For the DPC exception relevant to HSA contribution eligibility, the 2026 aggregate monthly fee threshold is $150 for an individual, or $300 where the applicable arrangement covers more than one individual. It concerns all relevant DPC arrangements for that person, not merely the amount charged by one clinic. Inflation adjustments begin after 2026. These amounts are not the annual HSA contribution limits. U.S. Government Publishing Office: Public Law 119-21, section 71308: Treatment of direct primary care service arrangements

The reimbursement rule differs. Notice 2026-05, Q&A-20, says a substantively qualifying DPC arrangement has no corresponding specific fee ceiling for HSA reimbursement. Exceeding the contribution threshold can therefore affect new contributions without making the qualifying DPC fee inherently unreimbursable. Internal Revenue Service and U.S. Treasury: Notice 2026-05: Expanded Availability of Health Savings Accounts, especially Q&A 11-20

That distinction should shape your patient-facing explanation. Avoid advertising either '$150 is all an HSA can ever pay' or 'our fee allows every patient to contribute.' Both skip facts outside a payment processor's approval decision. When the clinic changes a package or fee, refresh the review instead of relying on an old marketing label.

Use examples that reveal the question, not promise a tax result

These original fictional examples assume the services and practitioners otherwise satisfy the applicable DPC definition. They do not establish any actual patient's eligibility, available HSA balance or tax treatment. All fees are invented; the 2026 thresholds are statutory. U.S. Government Publishing Office: Public Law 119-21, section 71308: Treatment of direct primary care service arrangements

The table separates a fee calculation from the conclusion the clinic must not make for the patient. In the $180 example, the clinic should not invent a $150 eligible portion and a $30 ineligible portion solely from that threshold. The contribution and reimbursement questions need their own assessment. Internal Revenue Service and U.S. Treasury: Notice 2026-05: Expanded Availability of Health Savings Accounts, especially Q&A 11-20

If billing quarterly or annually, describe the actual period and obtain advice on the applicable periodic-fee rules. A $375 charge for three months is not the same commercial proposition as a $375 charge every month. Make dates explicit on receipts and in the recurring-payment authorization.

Design payment handling around the actual service agreement

Give a prospective payment provider a business-only description: a licensed clinic, the membership service, the charging entity, operating locations, billing frequency and the payment methods you want evaluated. Ask whether the proposed configuration supports the actual arrangement, including any HSA-card capability and recurring use. A general healthcare account does not answer every configuration question.

• Confirm how the merchant account is categorized for the services actually provided.
• Distinguish a one-time patient-authorized payment from permission for future recurring charges.
• Plan how the patient can change the payment method without emailing card details.
• Define the response to a decline, insufficient funds or a payment needing customer action.
• Keep the cancellation and refund flow consistent with the service agreement.
• Ensure receipts identify the real service period and fee without unnecessary clinical detail.

Do not repeatedly retry a declined HSA card without understanding the provider's instructions, or relabel a service to obtain authorization. Offer an appropriate alternative payment process where permitted and leave reimbursement questions with the patient and their advisers. An ordinary card receipt should not be presented as a certification of tax eligibility.

Make the records useful without sending patient data into a processing review

IRS recordkeeping guidance requires evidence that HSA distributions paid qualified expenses, were not already reimbursed elsewhere and were not also taken as an itemized deduction. A clear receipt and service agreement can support the patient's records, while the patient's tax responsibilities remain separate from merchant processing. Internal Revenue Service: Publication 969 (2025): Health Savings Accounts and Other Tax-Favored Health Plans

Employer-paid DPC fees, including the salary-reduction arrangement addressed in Notice 2026-05, are not expenses of the HSA beneficiary available for a second HSA reimbursement. Avoid building a payment workflow that assumes every fee can be reimbursed twice. Internal Revenue Service and U.S. Treasury: Notice 2026-05: Expanded Availability of Health Savings Accounts, especially Q&A 11-20

For MerchantBridge's initial inquiry, use the clinic's own contact and business details. Do not send patient names, diagnoses, visit notes, patient invoices, benefit-account information or card data. A fictional fee schedule and a description of the charging entity can explain the proposed model without disclosing a patient record. MerchantBridge Advisors: Payment Processing for U.S. Clinics & Telehealth Providers

Bring the payment question and the qualification question to the right reviewers

A practical opening could be: 'Our licensed U.S. clinic is evaluating recurring payments for a defined primary-care membership. We want to discuss processing support, including HSA-card acceptance if available. Our advisers are reviewing the service agreement separately. The first-stage discussion can use our business model and billing schedule without patient information.' This is illustrative wording, not a description of a real practice.

MerchantBridge can explore relevant payment relationships and identify the operational questions a potential partner needs answered. It does not certify DPC qualification, determine a patient's HSA eligibility or promise a treatment category, state, integration or card-approval outcome. Keep those decisions explicit as the project moves forward. MerchantBridge Advisors: Payment Processing for U.S. Clinics & Telehealth Providers

Questions & answers