Medicare 2026

Using an HSA Before Medicare: What Bronze Plans, Direct Primary Care and the 2027 Rules Mean for You

If you are a few years away from Medicare and still working, self-employed, or buying your own coverage, a Health Savings Account (HSA) can be one of the most useful tools for building a tax-advantaged cushion for later health costs. A 2025 federal law changed several of the rules in ways that matter in 2026 and 2027, especially if you buy a bronze plan through the Marketplace or pay a monthly fee to a primary care practice. Here is a plain-English look at what is changing, what the 2027 numbers are, and how all of this connects to Medicare when the time comes.

Bronze and catastrophic Marketplace plans now qualify

Historically, an HSA required a "high-deductible health plan" that met specific IRS minimums for the deductible and out-of-pocket maximum. Many bronze and catastrophic Marketplace plans came close but did not technically qualify.

Under Public Law 119-21, for months beginning after December 31, 2025, bronze and catastrophic plans offered as individual coverage through a Health Insurance Exchange are treated as HSA-compatible, even if they fall outside the usual deductible and out-of-pocket rules. The IRS has also said that the same plan bought off-Exchange in the individual market qualifies, as long as it is available through an Exchange.

Practically, this means more people in their late 50s and early 60s who buy their own coverage can open and fund an HSA while they wait to become Medicare-eligible.

Direct primary care and HSAs

Direct primary care (DPC) is an arrangement where you pay a primary care practice a flat monthly fee for a defined set of primary care services. Until now, being in a DPC arrangement generally blocked HSA contributions, because the IRS viewed it as separate health coverage.

Beginning January 1, 2026, an otherwise eligible person in certain DPC arrangements may both contribute to an HSA and use HSA money tax-free to pay the periodic fees.

For 2027, the DPC arrangement will not block HSA eligibility if the total monthly fees are no more than $150 for one person, or $300 if the arrangement covers more than one person. "Primary care" for this purpose does not include procedures requiring general anesthesia, prescription drugs other than vaccines, or lab services not typically done in a primary care office. If fees exceed the monthly limits, you can still pay them from an HSA as medical expenses, but you cannot make new HSA contributions while enrolled in that arrangement.

Telehealth without a deductible, made permanent

The same law made permanent a rule that had been expiring and renewing: a high-deductible health plan does not lose its HSA-compatible status just because it covers telehealth and other remote care services before you have met the deductible. This applies to plan years beginning after December 31, 2024.

The 2027 HSA numbers

For 2027:

• Contribution limit: $4,500 for self-only coverage, $9,000 for family coverage.
• Minimum deductible for an HSA-compatible plan: $1,750 self-only, $3,500 family.
• Out-of-pocket maximum for an HSA-compatible plan: no more than $8,700 self-only or $17,400 family.
• Catch-up contribution: $1,000 extra per year if you are 55 or older by year-end. If both spouses are 55 or older and neither is enrolled in Medicare, each can make the $1,000 catch-up to their own HSA.

What changes when Medicare starts

Beginning with the first month you are enrolled in Medicare, your HSA contribution limit is zero. The IRS says this also applies to retroactive Medicare coverage, so contributions made during months later covered by backdated enrollment are treated as excess contributions. If you plan to delay Medicare while contributing to an HSA, be careful about how and when you file for Social Security, since that can trigger automatic Part A enrollment.

The good news: money already in an HSA stays yours. After Medicare starts, you can still withdraw tax-free to pay qualified medical expenses incurred after the account was opened. At age 65 or older, those expenses include most Medicare premiums (for example, Part B and Part D), but not premiums for a Medicare supplemental (Medigap) policy. Non-medical withdrawals are taxable, but the extra 20% tax no longer applies once you reach 65, become disabled, or die.

A few Medicare dates and numbers to keep on your radar

For 2027, the Part D out-of-pocket cap is $2,400 (up from $2,100 in 2026), the maximum Part D deductible any plan may charge is $700, and the Part D base beneficiary premium — used to calculate the late-enrollment penalty — is $41.33. Actual plan premiums are set plan by plan.

Annual Enrollment for 2027 coverage runs October 15 – December 7, 2026, with choices taking effect January 1, 2027. The Social Security Administration announced a 3.6% cost-of-living adjustment for benefits payable beginning January 2027.

The 2027 Part B standard premium and deductible, and the IRMAA income-related surcharge brackets, had not been announced at the time of writing. CMS typically releases them in the fall. Watch Medicare.gov for the official figures.

Original Medicare vs. Medicare Advantage, briefly

When you do move to Medicare, you will generally choose between Original Medicare (often paired with a stand-alone Part D plan and sometimes a Medigap policy) and a Medicare Advantage plan (which usually bundles Part D). Each has trade-offs around provider choice, out-of-pocket structure, extra benefits, and paperwork. Neither is "better" in the abstract — it depends on your health, budget, and preferences.

If you have Medicaid or Extra Help, since 2025 you have a monthly Special Enrollment Period to move to Original Medicare with a stand-alone Part D plan, or to switch stand-alone Part D plans. If you are a full-benefit dual-eligible, you can join an integrated D-SNP in any month.

Where to learn more

For official rules, plan comparisons, and the 2027 figures as CMS releases them, visit Medicare.gov or call 1-800-MEDICARE (1-800-633-4227), TTY 1-877-486-2048. This article is educational and not a recommendation of any specific plan or strategy.