IRS Issues Guidance on New HSA Tax Benefits Under OBBBA

Taxes | December 11, 2025

IRS Issues Guidance on New HSA Tax Benefits Under OBBBA

The Treasury Department and the IRS provided guidance in Notice 2026-05 on Dec. 9 on new tax benefits for health savings account participants under this summer's One Big Beautiful Bill Act.

Jason Bramwell

The Treasury Department and the IRS provided guidance in Notice 2026-05 on Dec. 9 on new tax benefits for health savings account participants under this summer’s One Big Beautiful Bill Act.

These changes expand HSA eligibility, which allows more people to save and to pay for healthcare costs through tax-free HSAs.

Specifically, the Trump tax law, which was enacted last July, expands access to HSAs by making the following changes:

  • Telehealth and remote care services: The OBBBA made permanent the ability to receive telehealth and other remote care services before meeting the high-deductible health plan deductible while remaining eligible to contribute to an HSA, effective for plan years beginning on or after Jan. 1, 2025.
  • Bronze and catastrophic plans treated as HDHPs: As of Jan. 1, 2026, bronze and catastrophic plans available through an exchange are considered HSA-compatible, regardless of whether the plans satisfy the general definition of an HDHP. This expands the ability of people enrolled in these plans to contribute to HSAs, which they generally haven’t been able to do in the past. Notice 2026-05 clarifies that bronze and catastrophic plans don’t have to be purchased through an exchange to qualify for the new relief.
  • Direct primary care service arrangements: Beginning Jan. 1, 2026, an otherwise eligible individual enrolled in certain direct primary care service arrangements may contribute to an HSA. In addition, they may use their HSA funds tax-free to pay periodic DPC fees.

For calendar-year 2026 the annual contribution limit for an individual with self-only coverage under a HDHP will be $4,400, up $100 from $4,300 in 2025. Last year, the amount climbed $150 from $4,150 in 2024.

For an individual with family coverage, the amount is $8,750, an increase of $200 from $8,550 in 2025 and $450 from $8,300 in 2024. 

For calendar-year 2026, a “high-deductible health plan” is defined by the IRS as a health plan with an annual deductible no less than $1,700 for self-only coverage or $3,400 for family coverage, and for which the annual out-of-pocket expenses (deductibles, copayments, and other amounts, but not premiums) don’t exceed $8,500 for self-only coverage or $17,000 for family coverage.

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The Treasury Department and IRS is asking the public to comment on all aspects of this notice by March 6, 2026.

Commentors are encouraged to use the Federal e-Rulemaking portal to submit comments online (indicate “IRS-2025-0335”). Paper submissions should be sent to: Internal Revenue Service, CC:PA:01:PR (Notice 2026-05), Room 5503, P.O. Box 7604, Ben Franklin Station, Washington, DC 20044.

Photo credit: Pgiam/iStock

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