"While [Notice 2026-5] provides some helpful clarification, it points the public to other, not very straightforward, sources for determining which telehealth services may be provided ... [It] permits an individual who does not even purchase a bronze or catastrophic plan available through an Exchange to be HSA-eligible, but again, the guidance points the public to other sources to determine whether the rules are satisfied.... [T]he guidance on direct primary care arrangements ... suggests that, except for a narrowly defined arrangement, an individual cannot participate in a direct primary care arrangement and contribute to an HSA at the same time."  MORE >>