Aug. 13, 2025
New Rules Reshape Health Savings Accounts
Applies to Individual & Family Markets
Updated on Aug. 20, 2025: This communication is intended to provide an overview of the law, not of Blue Cross and Blue Shield of Montana’s business decisions. We are still evaluating the bill’s impact on our plans and will share those specific details as soon as they’re available.
The One Big Beautiful Bill Act (H.R. 1) 
was signed into law on July 4, 2025, and implements several important updates to Health Savings Account rules that will open the door for more clients.
Big news for HSA fans: Starting Jan. 1, 2026, all Marketplace Bronze and Catastrophic plans will be considered HSA-compatible. This is a significant change because in the past only select Bronze plans were eligible and limited who could open or contribute to an HSA. Now, Marketplace enrollees will have broader access to tax-advantaged savings for health care expenses. (Sec. 71307).
But that’s not all: Direct Primary Care (DPC) arrangements are now HSA-friendly. Individuals can pay a fixed periodic fee of up to $150 per month, or $300 for families, for enrollment in a primary care arrangement without losing their eligibility to contribute to an HSA. The fees paid for a DPC arrangement are treated as medical expenses. Note: This change impacts HSA rules only. Access to and enrollment in a DPC arrangement is not a covered benefit. (Sec. 71308).
A Win for telehealth: The “Safe Harbor” rule for telehealth is now permanent. This means High Deductible Health Plans can provide benefits for telehealth visits before your deductible is met, and you’ll still qualify for an HSA. The law allows for plans to apply the safe harbor rule retroactively to plan years beginning after Dec. 31, 2024, if they so choose. The law does not require plans to apply the safe harbor rule retroactively or at all. (Sec. 71306).
What’s not changing: We are still evaluating the impact of the bill on our plans.
As a trusted advisor, this is a great time to start conversations with clients about how this update might benefit them. Don’t forget, 2026 HSA contribution limits are $4,400 for individuals and $8,750 for families.
