"[P]recisely how the [direct primary care arrangement (DPCA)] is designed, and what it pays for impacts the employee's eligibility to make HSA contributions, determines ERISA's applicability to the DPCA, and might trigger [ACA] protections, COBRA and other issues.... [B]ecause the IRS views employee pretax contributions as employer contributions, even an employee-pay-all DPCA fee arrangement might trigger HSA disqualification if the employees' fees are paid with pretax salary reductions via a cafeteria plan."  MORE >>