"[Notice 2026-05] links to two websites containing qualifying telehealth services lists ... Employers may need to work with their telehealth provider to determine whether their services are 'consistent with the principles of' Social Security Act section 1834(m).... It is theoretically possible for an employer to structure an onsite clinic offering [direct primary care service arrangements (DPCSA)] membership with items and services provided outside the DPCSA, available to employees who are not DPCSA members, and billed separately.... If a DPCSA arrangement does not meet the Notice requirements, it provides medical care and would be considered disqualifying insurance preventing HSA eligibility."  MORE >>