The Biggest HSA Changes in 20 Years: What Employers Need to Know for Now and 2027

If you offer a health savings account, or you have been thinking about it, the rules just changed more than they have in two decades. A federal law signed in July 2025, the One Big Beautiful Bill Act, reworked how HSAs interact with telehealth, primary care, and marketplace plans, and the IRS has since issued guidance and released the 2027 limits. Most of what you read about HSAs in prior years is now partly out of date. Here is what actually changed and what it means for you as an employer.

Change one: the telehealth trap is finally closed for good

For years there was a quiet problem. If your health plan let employees use telehealth before they met the deductible, that convenience could technically disqualify them from contributing to an HSA. Congress kept patching it with temporary fixes that expired and had to be renewed, which left employers guessing year to year.

That is over. The new law made the telehealth safe harbor permanent, so a plan can cover virtual visits before the deductible without breaking anyone’s HSA eligibility, and the fix applies to plan years beginning on or after January 1, 2025. If you were ever nervous about pairing telehealth with an HSA-qualified plan, you no longer have to be. One note worth knowing: the protection generally covers the virtual visit itself, not the drugs or equipment that come out of it.

Change two: direct primary care now works with an HSA

This one opens a door that used to be shut. Direct primary care is an arrangement where an employee pays a flat monthly fee to a primary care practice for unlimited access, no copays and no claims. Under the old rules, that monthly fee counted as separate coverage, which meant an employee in a direct primary care arrangement could not contribute to an HSA at all.

Starting in 2026, that changed. An otherwise eligible employee can now stay in a direct primary care arrangement and keep contributing to an HSA, and can even use HSA dollars to pay the monthly fee, as long as the fee stays within the limits, which the IRS set at $150 a month for an individual and $300 for a family for 2027. For a workforce that values simple, predictable access to a doctor, this is a genuinely new option to put on the table.

Change three: bronze and catastrophic marketplace plans now qualify

The flashiest headline of the new law is that bronze and catastrophic plans bought through the ACA marketplace are now treated as HSA compatible as of January 1, 2026, even if they would not have met the traditional definition before.

Here is the honest read for an employer. This change mostly helps people buying their own coverage on the individual market, not businesses offering a group plan. Where it matters for your world is owner operators and self employed folks in the trades who buy their own insurance. If that describes people you work with, it is worth knowing. For your group plan decisions, the first two changes matter far more.

The 2027 numbers, straight from the IRS

The IRS released the 2027 figures in Revenue Procedure 2026-24. Here is what you and your employees are working with:

• HSA contribution limit: $4,500 for self-only coverage and $9,000 for family, up from $4,400 and $8,750 in 2026
• Catch-up contribution: an extra $1,000 for anyone age 55 or older, unchanged
• HDHP minimum deductible: $1,750 self-only and $3,500 family
• HDHP out-of-pocket maximum: $8,700 self-only and $17,400 family

That last pair matters more than it looks. To stay HSA qualified, your high deductible plan has to fall inside those thresholds. A plan that qualified in 2026 is not automatically compliant in 2027, so it is worth confirming your plan design still lines up before open enrollment, not after.

Why this matters to you, not just your employees

An HSA is one of the few benefits that helps the employer and the worker at the same time. Pairing a qualified high deductible plan with an HSA usually carries a lower premium than a richer plan, which takes pressure off your budget. And the money an employee puts in is theirs, grows tax free, and rolls over every year, which makes it a real recruiting and retention tool rather than a use it or lose it perk.

The move a lot of smart employers make is to take part of what they save on premium and put it directly into employees’ HSAs. That seeded dollar tends to land better than buying down everyone’s deductible, because the employee keeps it, sees it, and builds on it. If you have never modeled that tradeoff, it is worth running the numbers before you set your 2027 contributions, and we will do that with you at no cost.

Setting it up right

The changes above widen what an HSA-qualified plan can do, but they also add a few things to get right, plan design that meets the new thresholds, contribution strategy, and clear communication so employees actually use the account. That is the kind of thing an association is built to help with. NARFA offers HSA-qualified health plans through an open access PPO with a national network, and helps members structure and fund them in a way that fits the business.

If you want to look at whether an HSA-qualified plan makes sense for your team in 2027, let’s run the numbers together before renewal season closes in.

Get started at narfa.com or call 800-258-5318.