IRS High-Deductible Health Plan: 2026 Limits and HSA Eligibility

For 2026, the IRS high deductible health plan requirements set a minimum annual deductible of $1,700 for self-only coverage and $3,400 for family coverage, with out-of-pocket maximums capped at $8,500 and $17,000. A plan that hits those numbers and pays nothing toward covered non-preventive care until the deductible is met qualifies as an HDHP, which is what lets you pair it with a Health Savings Account. Miss any of those tests and the plan is not an HDHP, and HSA contributions are off the table.¹

The 2026 Dollar Tests

A qualified HDHP has to clear two financial hurdles the IRS republishes each year. Revenue Procedure 2025-19 sets the 2026 figures.

Self-only coverage:

Minimum annual deductible of $1,700
Maximum annual out-of-pocket expenses of $8,500

Family coverage:

Minimum annual deductible of $3,400
Maximum annual out-of-pocket expenses of $17,000

The out-of-pocket ceiling counts your deductible, copayments, and coinsurance. Premiums don’t count toward it.¹

The other side of the rule is what the plan can pay for before you satisfy the deductible. With narrow exceptions covered below, the answer is nothing. If a plan starts paying for non-preventive services before the deductible is met, it stops being an HDHP and everyone enrolled loses HSA eligibility for that period.²

Embedded Deductibles on Family Plans

Some family HDHPs use an embedded individual deductible, meaning a single family member can trigger plan payments after meeting a lower personal threshold, without waiting for the whole family to hit the aggregate. If your family plan works this way, the embedded individual deductible has to be at least the minimum family deductible, which is $3,400 in 2026. A family plan with a $2,000 embedded individual deductible and a $4,000 family deductible fails the test even though the aggregate is high enough.¹ Check this before assuming a family plan qualifies.

What an HDHP Can Cover Before the Deductible

The general “no payment before the deductible” rule has exceptions, and the list grew for 2026.

Preventive Care

HDHPs may cover preventive services on a first-dollar basis. Preventive care is meant to prevent or detect illness rather than treat an existing condition, and includes things like annual physicals, prenatal and well-child visits, immunizations, and standard screenings.³

Chronic Condition Drugs and Tests

Under Notice 2019-45, the preventive care category also covers specific low-cost treatments for people already diagnosed with certain chronic conditions:

Diabetes: insulin and other glucose-lowering agents
Heart disease and coronary artery disease: statins, ACE inhibitors, beta-blockers, and LDL testing
Congestive heart failure: ACE inhibitors and beta-blockers
Asthma: inhaled corticosteroids

The exception applies only to those listed items used to keep a listed condition from worsening. A prescription that falls outside the notice remains subject to the deductible.⁴

Contraceptives

Notice 2024-75 confirmed that over-the-counter oral contraceptives, emergency contraception, and male condoms count as preventive care for HDHP purposes and can be covered before the deductible with or without a prescription. Male sterilization is not part of that expansion.²

Telehealth

The One Big Beautiful Bill Act (OBBBA), signed in mid-2025, made the telehealth safe harbor permanent. For plan years beginning after December 31, 2024, an HDHP can cover telehealth and other remote care services before the deductible without losing its status.⁵ A telehealth visit on the second day of the plan year, paid entirely by the plan, no longer breaks HSA eligibility.

Direct Primary Care

Starting in 2026, being enrolled in a direct primary care (DPC) arrangement, a monthly-fee membership for primary care, does not disqualify you from HSA eligibility. HSA funds can also pay DPC fees tax-free, as long as the monthly fee is no more than $150 for an individual or $300 for a family.⁵

Bronze and Catastrophic Marketplace Plans

Also starting in 2026, bronze and catastrophic plans available through the Health Insurance Marketplace are automatically treated as HDHPs even when their deductibles or out-of-pocket limits fall outside the standard thresholds. The IRS confirmed the plan need not actually be purchased on an Exchange for this treatment to apply, opening HSA eligibility to a large group of people who were previously shut out on a technicality.⁶

Having an HDHP Isn’t Enough

The HDHP is a plan-side test. There’s also a person-side test. To actually contribute to an HSA, you have to be an “eligible individual” on the first day of the month, which requires all four of these:

You are covered by a qualified HDHP.
You have no disqualifying other coverage. A spouse’s general-purpose FSA or HRA counts as disqualifying. A limited-purpose FSA covering only vision and dental does not. Fixed-indemnity and specific-disease policies are generally fine.
You are not enrolled in Medicare Part A, B, or D. Enrollment drops your contribution limit to zero starting with the first month of coverage, including retroactive months.
You are not claimed as a dependent on someone else’s return.

VA and Indian Health Service Care

Receiving VA care for a service-connected disability does not disqualify you.³ The Indian Health Service rule is tighter: if you received medical services at an IHS facility in the past three months, you generally aren’t eligible, though receiving only dental, vision, or preventive care at an IHS facility doesn’t affect eligibility.⁷

2026 Contribution Limits Tied to the HDHP Tier

Your HDHP tier sets how much you can contribute to the HSA for the year. For 2026:

Self-only HDHP coverage: $4,400
Family HDHP coverage: $8,750

Employer contributions count against these caps, not on top of them. The combined total from all sources can’t exceed the limit.¹ If you’re 55 or older by December 31, you can add a $1,000 catch-up contribution.⁸

Anything over the limit is subject to a 6% excise tax for each year the excess stays in the account, reported on Form 5329. Pulling the excess plus earnings before your filing deadline avoids the penalty.⁹

Partial-Year HDHP Coverage

Lose HDHP coverage midyear and your contribution limit is prorated to the number of full months you were an eligible individual. The “last-month rule” is a workaround: if you’re HDHP-covered on December 1, you can contribute the full annual amount, but you have to stay eligible through the entire following calendar year. Fail that testing period, and the extra contribution gets added back to income and hit with a 10% penalty.³

Contributions for a given tax year can be made up to that year’s federal income tax filing deadline, typically April 15 of the following year.

1
Internal Revenue Service. Revenue Procedure 2025-19
2
Internal Revenue Service. Notice 2024-75, Preventive Care for Purposes of Qualifying as a High Deductible Health Plan
3
Internal Revenue Service. Publication 969, Health Savings Accounts and Other Tax-Favored Health Plans
4
Internal Revenue Service. Notice 2019-45, Preventive Care and Chronic Conditions
5
Internal Revenue Service. Notice 2026-5, Expanded Availability of Health Savings Accounts Under the One Big Beautiful Bill Act
6
Internal Revenue Service. Treasury, IRS Provide Guidance on New Tax Benefits for Health Savings Account Participants Under the One Big Beautiful Bill
7
Internal Revenue Service. Notice 2012-14
8
Internal Revenue Service. HSA Limits on Contributions
9
Internal Revenue Service. Form 5329, Additional Taxes on Qualified Plans and Other Tax-Favored Accounts