Health Savings Accounts and OBBBA

Under OBBBA, changes expanded eligibility for Health Savings Accounts (HSAs), effective January 1, 2026. HSAs are triple tax-advantaged, with tax-deferred contributions, tax-free earnings, and tax-free withdrawals for qualified medical expenses. You can roll over any balance remaining at the end of 2026 into 2027. Nonqualified withdrawals before age 65 are subject to a tax penalty. After age 65, you can take penalty-free withdrawals for any reason, but you must pay income tax on the non-qualified amount. To contribute to an HSA, you must have a high-deductible health plan (HDHP).

EXPANDED BY OBBBA

OBBBA made changes that expand the health plans that qualify as HDHPs. First, it extends the rule allowing plans to be considered HDHPs, despite not having a deductible for telehealth services retroactively to January 1, 2025. Second, OBBBA expands HSA eligibility to include those enrolled in Bronze and Catastrophic plans available on state and federal insurance exchanges under the Affordable Care Act.

This provision takes effect on January 1, 2026. Third, it allows individuals with HDHPs to enroll in Direct Primary Care arrangements (sometimes referred to as “concierge medical care”) while remaining HSA eligible, provided the monthly fee for DPC services doesn’t exceed $150 for individuals or $300 for families (both adjusted for inflation). DPC fees are also considered qualified medical expenses that can be paid with HSA funds.

August 2025 Question and Answer

QUESTION:

Is a gym membership a medical expense that can be paid by an HSA or FSA?

ANSWER:

Yes, but only if the membership was purchased for the sole purpose of affecting a structure or function of the body (such as a prescribed plan for physical therapy to treat an injury) or the sole purpose of treating a specific disease diagnosed by a physician (such as obesity,hypertension, or heart disease).

Otherwise, the cost of a gym membership is for the individual’s general health and is not a medical expense.

Many health insurance policies offer gym membership benefits.

Some Things Get Better with Time

Fine wine, balsamic vinegar, cheese, and certain tax breaks have something in common. They can get better with age. Case in point: consider this sample list.

RETIREMENT PLAN CONTRIBUTIONS

If you’re 50 or older, catch-up contributions allow you to add an additional $1,000 to qualified retirement accounts, such as IRAs and 401(k)s. Contribution limits are based on modified adjusted gross income and begin to phase out at higher income levels.

HIGHER HEALTH SAVINGS ACCOUNT (HSA) LIMITS

Similarly, qualified individuals aged 55 or older may increase deferrals to HSAs by up to $1,000 for an annual contribution of $5,150 (single) or $9,300 (family) versus $4,150 and $8,300 for younger taxpayers with qualified high-deductible medical plans.

NO WITHDRAWAL PENALTIES

At age 59 1/2, you’re no longer subject to the usual 10% early withdrawal penalty on withdrawals from IRAs and 401(k) plans. At 65, you may withdraw HSA funds for non-medical expenses without paying an additional tax penalty. However, ordinary income tax rates apply to unqualified medical expenses.

AN EXTRA STANDARD DEDUCTION

Once you turn 65, you become eligible for an additional standard deduction. The extra deduction reduces taxable income, potentially lowering your overall tax liability. The amount of this extra standard deduction can vary based on filing status and whether you or your spouse are 65 or older. Another factor is whether you or your spouse is blind. Generally, for 2024, the deduction amounts are $1,950 if you’re single or file as head of household and $1,550 each for married, filing jointly or separately. They double for taxpayers 65 and older and blind.

This list isn’t all-encompassing. If you’re unsure whether any tax provision, credit, or deduction applies to you, consult a trusted tax professional.