HSA and FSA for Concierge Care: 2026 Rules

HSA and FSA dollars can pay for lab work, prescribed medicines and diagnosed care at a South Carolina concierge practice. Only the FSA carries a year-end risk. HSA money has no spending deadline. So can you use an HSA for concierge medicine? For those costs, yes. For the membership fee, the answer turns on how the membership is written, under a new IRS rule that took effect January 1, 2026 ^[1].

By Ashley Harwyn, PA-C, ABAAHP | Published November 10, 2026 | Last updated November 10, 2026

A smiling woman in a coral linen shirt reviews a benefits booklet at a round marble table, with white plantation shutters, a rattan chair and trailing pothos behind her.

The deadline belongs to the FSA. Not the HSA. On HSA reimbursements, the IRS says "there is no time limit on when the distribution must occur." The expense must have been incurred after you opened the HSA, and you need records showing it was a qualified medical expense that was not already paid or reimbursed from another source and was not taken as an itemized deduction ^[2]. A health FSA works differently. Unused amounts are forfeited at the end of the plan year unless your plan offers a grace period or a carryover ^[3]. A plan can offer one of those, not both ^[4].

December 31: a calendar-year plan ends
Grace period: up to 2 1/2 months more
or
Carryover: up to $680 rolls over

That difference reaches a lot of workers. In 2026, 47% of private industry workers had access to a health FSA ^[5]. Among workers with employer coverage, 29% were enrolled in an HSA-qualified plan ^[6].

This guide reflects IRS rules as of November 2026. The 2027 limits are already published; check back in January 2027 for the updated figures.

Which account pays for this?

Shows the IRS rule for each cost. It is not tax advice and does not check your plan.

Pick your account, then the cost

HSA

Lab fees, physical, prescribed medicines: Usually eligible under IRS Publication 502. Keep the itemized receipt. No spending deadline. ^[10]^[12]^[11]^[2]
Membership fee: Eligible if the arrangement is direct primary care under IRS Notice 2026-5. At or under $150 a month you keep contributing; above it you cannot contribute while enrolled. ^[8]^[9]
Supplements or weight program: Supplements only when a medical practitioner recommends them for a condition diagnosed by a physician; weight programs only when they treat a disease diagnosed by a physician (IRS nutrition FAQ). ^[11]
Cosmetic treatment: Generally not eligible (IRS Publication 502). ^[20]

FSA with a grace period

Any eligible cost: Spend by the end of the grace period, up to 2 1/2 months after the plan year (IRS Publication 969). ^[4]

FSA with a carryover

Any eligible cost: Up to $680 of 2026 money carries into 2027, less if your plan sets a lower limit; the rest is forfeited (Rev. Proc. 2025-32, Notice 2013-71). ^[7]^[3]

FSA with neither

Any eligible cost: Unused money is forfeited at the end of the plan year (IRS Notice 2013-71). ^[3]

General information from IRS documents read November 2026. Your plan document and tax adviser decide. Solcara does not represent that its memberships are direct primary care arrangements.

Key takeaways

HSA money has no spending deadline. The IRS says "there is no time limit on when the distribution must occur" ^[2].
FSA money is use-or-lose at the end of the plan year, softened only by a grace period of up to 2 1/2 months or a carryover of up to $680 in 2026, never both ^[7] ^[4].
Since January 1, 2026, you can pay a direct primary care membership from an HSA and keep contributing, if the fee stays at or under $150 a month ($300 for more than one person) and the arrangement meets the IRS definition ^[1] ^[8]. Above the cap, the fee is still reimbursable, but you lose the right to contribute while enrolled ^[9].
Lab fees, physical exams and prescribed medicines billed by a practice are qualified medical expenses ^[10] ^[11] ^[12].
The line-by-line table below applies IRS Notice 2026-5 to each kind of practice cost, so you can see which rule decides each one before you spend.

Section 01 / The 2026 rule

What changed for HSAs on January 1, 2026: the direct primary care rule

Starting January 1, 2026, a person enrolled in a qualifying direct primary care arrangement can keep contributing to an HSA and can pay the membership fee from it. The IRS says these members "may use their HSA funds tax-free to pay periodic DPC fees" ^[1]. The arrangement qualifies only if its fee stays at or under $150 a month for one person, or $300 a month if it covers more than one person ^[8].

Before 2026, a monthly primary care membership could cost you HSA eligibility. A July 2025 law, commonly known as the One, Big, Beautiful Bill Act, and IRS Notice 2026-5 changed that for one narrow kind of arrangement ^[8]. It must provide only primary care services. Primary care practitioners must deliver them. And a fixed periodic fee must be the only payment for that care. Physician assistants and nurse practitioners count as primary care practitioners under the notice ^[8].

The cap is monthly, but billing does not have to be. A practice can bill for up to a year at a time if the fee stays within the cap on an annualized basis. For 2026, that means a single person's fee could be $1,800 a year, $900 for six months or $450 for three months ^[13]. The cap does not rise for 2027 ^[14]. Rev. Proc. 2026-24 keeps it at $150 a month ($300 for more than one person) and raises the 2027 HSA contribution limit to $4,500 for self-only coverage and $9,000 for family coverage ^[14].

Two details trip people up. First, the fee has to be your own expense. If your employer pays the membership, you cannot also reimburse it from your HSA. That includes pre-tax salary reduction through a cafeteria plan ^[15]. Second, you still need an HSA-qualified health plan to contribute at all. For 2026, the contribution limits are $4,400 for self-only coverage and $8,750 for family coverage ^[16].

HSA and FSA limits, 2026 and 2027
Limit	2026	2027	IRS source
HSA contribution limit, self-only coverage	$4,400	$4,500	^[16]^[14]
HSA contribution limit, family coverage	$8,750	$9,000	^[16]^[14]
Health FSA limit	$3,400	$3,500	^[7]^[25]
Health FSA maximum carryover	$680	$700	^[7]^[25]
Direct primary care fee cap, one person, per month	$150	$150	^[8]^[14]
Direct primary care fee cap, more than one person, per month	$300	$300	^[8]^[14]
Health FSA grace period	Up to 2 1/2 months		^[4]

HSA and FSA limits, 2026 and 2027IRS limits for 2026 and 2027, read November 9, 2026

Annual limits

HSA contribution limit, self-only coverage

2026$4,4002027$4,500

HSA contribution limit, family coverage

2026$8,7502027$9,000

Health FSA limit

2026$3,4002027$3,500

Health FSA maximum carryover

2026$6802027$700

Direct primary care fee cap, per month

Direct primary care fee cap, one person, per month

2026$1502027$150

Direct primary care fee cap, more than one person, per month

2026$3002027$300

The cap does not rise for 2027.

Your plan can set a lower carryover limit, or allow no carryover at all. ^[3]

Source: IRS Rev. Proc. 2025-19, Rev. Proc. 2025-32, Rev. Proc. 2026-24, Rev. Proc. 2026-35, Notice 2026-5 and Publication 969. Date range: 2026 to 2027 plan years. 11 published limits. ^[16]^[7]^[14]^[25]^[8]^[4]

Section 02 / Memberships

Which concierge and functional memberships fall outside that rule

A concierge or functional medicine membership falls outside the new HSA rule when it covers more than primary care, when its fee is over the cap, or when the practice also bills insurance or charges separately for the same services the fee covers ^[8] ^[9] ^[17]. The test is the written terms. In the IRS's words, qualification "depends on the terms of the arrangement, not the services used by an individual" ^[18].

That point changes how you should read any membership. You cannot join a broad membership, skip the extras and call it a DPC arrangement. If the membership includes services beyond primary care, it is judged as a whole ^[18].

Some care is excluded from DPC primary care outright. The notice excludes prescription drugs other than vaccines ^[8]. It also excludes procedures that require general anesthesia, and laboratory services not typically given in an ambulatory primary care setting ^[19]. A membership that bundles specialty hormone panels, aesthetic treatments or compounded prescriptions into its fee is built differently from the arrangement the rule describes.

Separate billing needs care. A membership that bills you separately for the same services its fee is supposed to cover is not a DPC arrangement ^[17]. But providers in an arrangement that otherwise qualifies may still bill members and non-members separately for services offered outside the arrangement ^[17].

The fee cap has its own consequence. Take an arrangement that meets every condition except the cap, with a fee above $150 a month. The IRS says that fee can still be reimbursed from an HSA. But enrolling disqualifies you from making HSA contributions while you are enrolled ^[9].

So read the contract. Whether a specific membership qualifies is a question about its written terms, and the practice can give you those terms. Then ask your plan administrator or tax adviser before you treat a membership fee as HSA-eligible. Solcara has not represented that its memberships meet the Notice 2026-5 definition, and this article does not say they do.

Not sure what a Solcara membership includes? See what a Solcara membership includes, then take the written terms to your plan administrator or tax adviser.

Section 03 / What usually qualifies

Practice costs your HSA or FSA can usually pay: labs, prescriptions and visits

Lab fees, prescribed medicines, physical exams and diagnostic tests are qualified medical expenses at any practice, concierge or not. IRS Publication 502 lets you include laboratory fees that are part of medical care and prescribed medicines ^[10]. It also covers an annual physical examination and diagnostic tests by a physician, even when you are not ill at the time ^[12]. These are the safest uses of year-end FSA money at a practice.

Lab work, such as annual full-panel labs, is the clearest example. A full panel ordered by your clinician to evaluate symptoms or monitor treatment is a laboratory fee that is part of medical care ^[10]. The IRS also says a physical exam can be paid from an HSA or FSA because the exam provides a diagnosis of whether a disease or illness is present ^[11].

Prescribed medicines qualify under the same publication ^[10]. Publication 502 defines a prescribed drug as one that requires a prescription by a doctor for its use ^[10]. It does not make every product a practice sells eligible. The table shows where the lines fall.

The table applies the IRS documents to each kind of cost a concierge or functional practice is likely to bill. It is general information, not a determination about your plan.

Practice cost	HSA	Health FSA	IRS basis	What to check first
Lab fees ordered as part of medical care	Usually yes	Usually yes	Pub 502, lab fees ^[10]	Itemized receipt with the date of service
Annual physical or diagnostic tests	Usually yes	Usually yes	Pub 502, physical exam ^[12]; IRS nutrition FAQ ^[11]	Receipt showing the visit
Prescribed medicines	Usually yes	Usually yes	Pub 502, medicines and drugs ^[10]	The prescription and pharmacy receipt
Membership fee in a qualifying DPC arrangement, at or under $150 a month	Yes, and you can keep contributing	Ask your plan	Notice 2026-5 ^[1] ^[8]	The written terms of the arrangement
Membership fee over the cap in an otherwise qualifying arrangement	Reimbursable, but no new contributions while enrolled	Ask your plan	Notice 2026-5, Q&A-20 ^[9]	Whether you plan to keep contributing
Broader concierge or functional membership	No IRS rule says yes	Ask your plan	Notice 2026-5, Q&A-11 and Q&A-14 ^[17] ^[18]	Plan administrator or tax adviser
Supplements	Only if a medical practitioner recommends it for a condition diagnosed by a physician	Same	IRS nutrition FAQ ^[11]	Written recommendation tied to a physician's diagnosis
Weight-loss program	Only if it treats a specific disease diagnosed by a physician	Same	IRS nutrition FAQ ^[11]	The physician's diagnosis on record
Cosmetic procedures	Generally no	Generally no	Pub 502, cosmetic surgery ^[20]	Whether it treats a deformity, injury or disease
Gym, health club or spa dues	Generally no; a gym membership only if bought solely to treat a disease diagnosed by a physician or for a prescribed physical therapy plan	Same	Pub 502, health club dues ^[21]; IRS nutrition FAQ ^[11]	A physician's diagnosis, or the prescribed plan the membership serves

Section 04 / What usually does not

Costs that usually do not qualify: supplements, weight programs and aesthetics without a diagnosis

Supplements, weight-loss programs and aesthetic treatments each depend on a diagnosis, or are excluded outright. The IRS allows supplements only when a medical practitioner recommends them to treat a specific medical condition diagnosed by a physician. It allows weight-loss programs only when they treat a specific disease diagnosed by a physician, such as obesity, diabetes, hypertension or heart disease ^[11]. Cosmetic procedures are generally excluded ^[20].

The diagnosis is the dividing line. A supplement your clinician recommends to treat a deficiency diagnosed by a physician can qualify ^[11]. The same supplement bought for general wellness does not. Publication 502 excludes expenses that are merely beneficial to general health, such as vitamins ^[21].

Weight-loss care follows the same logic. A program that treats obesity diagnosed by a physician can qualify ^[11]. A program aimed at general fitness does not. Publication 502 says you cannot include membership dues in a gym, health club or spa as medical expenses ^[21]. The IRS FAQ allows one exception: a gym membership bought for the sole purpose of treating a specific disease diagnosed by a physician, such as obesity, or of affecting a structure or function of the body, such as a prescribed plan for physical therapy to treat an injury ^[11].

Aesthetics is the strictest category. Publication 502 allows cosmetic surgery only when it corrects a deformity from a congenital abnormality, an accident or trauma, or a disfiguring disease. It names face lifts, hair transplants, electrolysis hair removal and liposuction as generally excluded ^[20]. Wrinkle treatments and fillers done for appearance follow the same rule, because they improve appearance rather than treat disease ^[20].

The paperwork is where these claims succeed or fail. A health FSA needs a written statement from an independent third party describing the expense ^[22]. For a supplement or a weight-loss program, the cost qualifies only when it treats a condition diagnosed by a physician ^[11], so keep the clinician's written recommendation and the diagnosis with the receipt. A receipt that says only "wellness program" or "supplement" gives the plan nothing to approve.

My view is simple. If a cost only qualifies with a letter, get the letter before December, not after.

Section 05 / December checklist

A December checklist for spending FSA money on care you actually need

To use FSA money well before the plan year ends, first find out which rule your plan uses, then book care that qualifies and that you already need. A plan can offer a grace period of up to 2 1/2 months or a carryover, not both ^[4]. In 2026 the carryover can be up to $680 ^[7], so anything above that can be forfeited. The steps below follow that order.

Hands slide a folded paper receipt into a kraft folder on a marble tabletop, beside a glass of iced tea, a phone and a trailing pothos leaf in shutter light.

Read your plan document. Find the plan year end date, whether your plan has a grace period or a carryover, and how long the run-out period is. A run-out period lets you submit claims after the plan year for expenses you already incurred; a grace period of up to 2 months and 15 days lets you incur new expenses against last year's balance ^[23].
Check your balance, not your contributions. Under the uniform coverage rule, your full annual election is available at any time during the coverage period, regardless of how much you have contributed so far ^[3] ^[24].
Do the math on what is at risk. Our arithmetic from the 2026 limits: if you elected the $3,400 maximum in a carryover plan and spent nothing, at most $680 carries over, so at least $2,720 is forfeited ^[7] ^[3]. Your plan can set a lower carryover limit, or allow no carryover at all ^[3]. For taxable years beginning in 2027, Rev. Proc. 2026-35 raises the health FSA limit to $3,500 and the maximum carryover to $700 ^[25].
Book care you were already going to need. Labs your clinician has ordered, a physical, or a prescription refill are includible expenses ^[10] ^[11] ^[12].
Keep the paperwork. To be reimbursed, you need a written statement from an independent third party describing the expense and a statement that it has not been paid under another plan ^[22].

If you leave a job, the rule is stricter. Any balance at termination of employment is forfeited unless you elect COBRA for the health FSA ^[3].

Section 06 / Questions

HSA and FSA Questions Answered

Can I use my HSA for a concierge medicine membership?

Yes, if the membership is a direct primary care arrangement as IRS Notice 2026-5 defines it ^[1]. That means primary care only, with a fixed periodic fee as the sole payment ^[8]. At or under $150 a month for one person, you can pay it from your HSA and keep contributing ^[8]. Above the cap, the fee is still reimbursable, but you cannot contribute while enrolled ^[9]. A broader concierge or functional membership does not meet that definition, and no IRS rule says its fee is HSA-eligible ^[17] ^[18]. Take the membership terms to your plan administrator or tax adviser.

What happens to unused FSA money on December 31?

On a calendar-year plan with no grace period and no carryover, unused money is forfeited at the end of the plan year ^[3]. If your plan has a carryover, up to $680 of 2026 money can roll into 2027 ^[7]. Your plan can set a lower limit, or allow no carryover at all ^[3]. If it has a grace period, you get up to 2 1/2 more months to spend it ^[4]. A plan can offer one or the other, not both ^[4].

Are blood tests HSA or FSA eligible?

Yes, when they are part of medical care. IRS Publication 502 lets you include laboratory fees that are part of medical care ^[10], and it covers an annual physical examination and diagnostic tests by a physician, even if you are not ill at the time ^[12]. Keep the itemized receipt with the date of service.

Can I use FSA money for supplements?

Only when a medical practitioner recommends the supplement to treat a specific medical condition diagnosed by a physician ^[11]. Supplements bought for general health are not eligible. Publication 502 excludes expenses that are merely beneficial to general health, such as vitamins ^[21].

Does the new direct primary care rule apply to functional medicine?

Only if the arrangement consists solely of primary care services under a fixed fee ^[8]. The notice excludes prescription drugs other than vaccines, and laboratory services not typically given in an ambulatory primary care setting ^[8] ^[19]. A functional medicine membership that includes either of those in its fee is outside the definition. DPC fees also do not count toward the deductible or out-of-pocket maximum of your HSA-qualified health plan ^[26].

Section 07 / Bottom line

Bottom line: match the deadline to the account

The December deadline is an FSA problem. HSA money waits for you, and the IRS says so plainly ^[2]. FSA money does not. So the useful question this month is what qualified care you already need: labs, a physical, a prescription ^[10] ^[11] ^[12].

Start with your plan document. It tells you whether you have a grace period, a carryover or neither, and that one fact sets your real deadline ^[4]. If you have a carryover, only dollars above your plan's carryover limit, at most $680 in 2026, are at risk ^[7] ^[3].

For memberships, the answer sits in the written terms. Under the 2026 rule, a direct primary care arrangement at or under $150 a month can be paid from an HSA while you keep contributing ^[1] ^[8]. Broader memberships are a question for your plan administrator or tax adviser. The right time to ask is before you pay.

Solcara Health sees patients at 496 Bramson Ct in Mount Pleasant and at The Longevity Club, 163 Rutledge Ave in downtown Charleston. If you want to know what concierge medicine costs in Charleston or what a membership includes before you decide, call 843-981-0870 or book online.

References

[1] Internal Revenue Service. Treasury, IRS provide guidance on new tax benefits for health savings account participants under the One Big Beautiful Bill (IR-2025-119). December 2025. https://www.irs.gov/newsroom/treasury-irs-provide-guidance-on-new-tax-benefits-for-health-savings-account-participants-under-the-one-big-beautiful-bill
[2] Internal Revenue Service. Notice 2004-50, Q&A-39. 2004. https://www.irs.gov/pub/irs-drop/n-04-50.pdf
[3] Internal Revenue Service. Notice 2013-71, sections II and III (forfeiture, carryover, plan-set lower limit, uniform coverage rule). October 2013. https://www.irs.gov/pub/irs-drop/n-13-71.pdf
[4] Internal Revenue Service. Publication 969 (2025), Health Savings Accounts and Other Tax-Favored Health Plans. Page updated April 30, 2026. https://www.irs.gov/publications/p969
[5] U.S. Bureau of Labor Statistics. Flexible benefits in the workplace (National Compensation Survey). September 25, 2026. https://www.bls.gov/ebs/factsheets/flexible-benefits-in-the-workplace.htm
[6] KFF. 2026 Employer Health Benefits Survey. October 2026. https://www.kff.org/health-costs/2026-employer-health-benefits-survey/
[7] Internal Revenue Service. Rev. Proc. 2025-32 (2026 health FSA limits). October 2025. https://www.irs.gov/pub/irs-drop/rp-25-32.pdf
[8] Internal Revenue Service. Notice 2026-5 (direct primary care service arrangements). December 2025. https://www.irs.gov/pub/irs-drop/n-26-05.pdf
[9] Internal Revenue Service. Notice 2026-5, Q&A-20. December 2025. https://www.irs.gov/pub/irs-drop/n-26-05.pdf
[10] Internal Revenue Service. Publication 502 (2025), Medical and Dental Expenses (laboratory fees; medicines). Page updated April 30, 2026. https://www.irs.gov/publications/p502
[11] Internal Revenue Service. Frequently asked questions about medical expenses related to nutrition, wellness and general health (Q3, Q9, Q10, Q14). Page updated September 23, 2026. https://www.irs.gov/individuals/frequently-asked-questions-about-medical-expenses-related-to-nutrition-wellness-and-general-health
[12] Internal Revenue Service. Publication 502 (2025), Physical Examination. Page updated April 30, 2026. https://www.irs.gov/publications/p502
[13] Internal Revenue Service. Notice 2026-5, Q&A-13. December 2025. https://www.irs.gov/pub/irs-drop/n-26-05.pdf
[14] Internal Revenue Service. Rev. Proc. 2026-24 (2027 HSA and DPC figures). Internal Revenue Bulletin 2026-25, June 15, 2026. https://www.irs.gov/pub/irs-drop/rp-26-24.pdf
[15] Internal Revenue Service. Notice 2026-5, Q&A-18. December 2025. https://www.irs.gov/pub/irs-drop/n-26-05.pdf
[16] Internal Revenue Service. Rev. Proc. 2025-19 (2026 HSA limits). May 2025. https://www.irs.gov/pub/irs-drop/rp-25-19.pdf
[17] Internal Revenue Service. Notice 2026-5, Q&A-11 and Q&A-12. December 2025. https://www.irs.gov/pub/irs-drop/n-26-05.pdf
[18] Internal Revenue Service. Notice 2026-5, Q&A-14. December 2025. https://www.irs.gov/pub/irs-drop/n-26-05.pdf
[19] Internal Revenue Service. Notice 2026-5, Q&A-17. December 2025. https://www.irs.gov/pub/irs-drop/n-26-05.pdf
[20] Internal Revenue Service. Publication 502 (2025), Cosmetic Surgery. Page updated April 30, 2026. https://www.irs.gov/publications/p502
[21] Internal Revenue Service. Publication 502 (2025), What Are Medical Expenses, Health Club Dues and Weight-Loss Program. Page updated April 30, 2026. https://www.irs.gov/publications/p502
[22] Internal Revenue Service. Publication 969 (2025), Health Flexible Spending Arrangements (substantiation). Page updated April 30, 2026. https://www.irs.gov/publications/p969
[23] Internal Revenue Service. Notice 2013-71 (run-out and grace periods). October 2013. https://www.irs.gov/pub/irs-drop/n-13-71.pdf
[24] Internal Revenue Service. Publication 969 (2025), Health Flexible Spending Arrangements (maximum reimbursement available at any time). Page updated April 30, 2026. https://www.irs.gov/publications/p969
[25] Internal Revenue Service. Rev. Proc. 2026-35 (2027 inflation-adjusted items, section .16 cafeteria plans), announced in IR-2026-133 (https://www.irs.gov/newsroom/irs-releases-tax-inflation-adjustments-for-tax-year-2027-taxpayers-continue-to-benefit-from-the-working-families-tax-cuts). November 5, 2026. https://www.irs.gov/pub/irs-drop/rp-26-35.pdf
[26] Internal Revenue Service. Notice 2026-5, Q&A-16. December 2025. https://www.irs.gov/pub/irs-drop/n-26-05.pdf

Ashley Harwyn, PA-C, smiling in front of a woven rattan chair.

About the author

Ashley Harwyn, PA-C, ABAAHP

Full bio

This article is for general education and is not medical, tax or legal advice. It does not create a provider-patient relationship. Your HSA or FSA plan document, your plan administrator and your tax adviser decide what qualifies for you. Solcara Health, 496 Bramson Ct, Ste 120, Mount Pleasant, SC 29464 and 163 Rutledge Ave, Ste 202, Charleston, SC 29403. 843-981-0870.

Using HSA and FSA Money at a South Carolina Concierge Practice Before December 31