Understanding the New HSA Eligibility Rules for Employers 2026

Is your company currently offering Health Savings Accounts (HSA) to your workforce? Or are you exploring a high-deductible health plan (HDHP) paired with HSAs for your 2026 employee benefits? The recently passed One Big, Beautiful Bill Act (OBBBA) includes essential updates you’ll want to know about.

The bottom line: Starting in 2026, the OBBBA expands eligibility for HSAs. This change could allow additional employees to take advantage of HSA benefits or make the HDHP+HSA combination more attractive for your company.

Why HSAs Matter

HSAs deliver value for both companies and their workers. Employees own their accounts and can set aside funds tax-free for healthcare costs. Money contributed—typically through pre-tax paycheck deductions—enjoys tax advantages when deposited, while invested, and when withdrawn for qualified expenses.

Employers can structure HSAs as investment options, enabling workers to build savings over their careers for both retirement needs and wealth transfer goals.

These accounts align with organizational priorities, too. HDHPs typically cost employers less than traditional health plans, helping control benefits expenses. HSAs also promote smarter healthcare decisions among employees, which can reduce claims costs.

The ground rules require employers to offer an HDHP before sponsoring HSAs. Participants must also avoid certain other coverage types, including a partner’s traditional health plan or Medicare enrollment.

What’s Changed Under OBBBA

Beginning in 2026, the OBBBA removes several barriers that previously prevented certain people from funding an HSA.

Under old regulations, many HDHP enrollees who purchased coverage through a Health Insurance Marketplace (often called an “exchange”) couldn’t contribute to HSAs. From 2026 forward, those with Bronze or Catastrophic marketplace plans will be HSA-eligible.

The legislation also opens HSA access to people participating in direct primary care models, provided they meet other criteria, such as qualifying HDHP coverage and avoiding disqualifying benefits.

Direct primary care memberships must cost $150 or less per month for individuals and $300 or less per month for families. These thresholds will increase with inflation each year.

Additionally, the OBBBA permanently reinstates the “telehealth coverage exception.” Created by the Coronavirus Aid, Relief, and Economic Security Act in 2020, this provision allowed HDHPs to offer telehealth without applying deductibles. While this benefit expired previously, it’s now back for good, starting in 2026 and won’t prevent eligible HDHP members from making HSA contributions.

These clarifications reduce uncertainty around HSA qualification rules. Companies with varied workforce needs—including independent contractors, hourly employees, and team members in less-populated regions—stand to benefit considerably.

Next Steps

As we enter 2026, it’s an ideal moment to assess your company’s healthcare offerings. If you currently provide an HDHP with HSAs, consider how these OBBBA updates impact your program. And if eligibility questions previously discouraged you from exploring HSAs, those concerns may now be resolved. Reach out to us for guidance on whether expanding or implementing an HDHP with HSAs is a good fit for your organization.