DPC Fee Caps Are Now Inflation-Indexed. The First Adjustment Was $0.

Your DPC fee caps aren’t changing for 2027.

The IRS published Revenue Procedure 2026-24 on May 29. It sets the 2027 inflation-adjusted amounts for HSAs, HDHPs, and direct primary care service arrangements. For DPC practices, the numbers are straightforward: the individual fee cap stays at $150 per month and the multi-person cap stays at $300. No adjustment applied.

That flatness is worth understanding, because it’s not random.

This Is the First Time the Indexing Formula Has Run on DPC Caps

The One Big Beautiful Bill Act, passed in July 2025, did two things for DPC fee caps. It made qualifying arrangements compatible with HSA eligibility. And it indexed those fee caps to inflation, so they’d adjust automatically each December for the following year.

Before the OBBBA, the caps were fixed in statute. If Congress didn’t act, they didn’t move. The inflation-indexing provision changed the mechanism. DPC fee caps now go through the same annual IRS review process that governs HSA contribution limits.

But indexing to inflation and rising every year aren’t the same thing. The IRS uses a rounding formula. For a cap to increase, the underlying CPI adjustment needs to be large enough to clear the rounding threshold. For 2027, the math on $150 produced a fractional result that rounded back down to $150. The cap didn’t cross the bar.

This is how HSA limits work too. Individual contributions didn’t go from $4,400 to $4,500-point-something. They went to exactly $4,500 because that’s what the statutory formula produced after rounding. DPC caps follow the same logic. For 2027, the adjustment was zero.

What the Full 2027 Picture Looks Like

The DPC caps stayed flat while the surrounding HSA framework got more generous.

HSA contribution limits went up. Individual coverage: $4,500 annually, up from $4,400. Family coverage: $9,000, up from $8,750. HDHP minimum deductibles increased to $1,750 for self-only and $3,500 for family coverage. Out-of-pocket maximums moved up across the board.

The DPC caps: $150 and $300. Unchanged.

That gap has a practical consequence worth tracking. As patients can contribute more to their HSAs each year while DPC monthly fees hold steady, those fees consume a smaller share of available HSA capacity. A patient contributing $4,500 annually to an HSA and paying $1,200 per year in DPC fees is using 27% of their contribution room for primary care. As HSA limits continue rising in future years while caps stay flat, that fraction keeps shrinking.

For the DPC+HSA pairing, this is a quiet structural improvement. Patients who pair a qualifying HDHP with a DPC membership have more tax-advantaged capacity each year. Their DPC fees don’t take up more of it.

What This Means for Your Practice

If your individual fees run under $150 per month, nothing changes operationally for 2027. Your patients can maintain a qualifying HDHP, keep contributing to their HSA, and use those funds for your membership fee. The same rules that took effect in January 2026 carry over unchanged.

If you’re priced at exactly $150, you’re at the limit. If you’re below it, you have room before the cap becomes relevant to your patients’ contribution eligibility.

Two things to keep clear when explaining this to patients. The DPC fee cap governs whether patients can make new HSA contributions while enrolled in your practice alongside an HDHP. A patient enrolled in a practice charging over $150 per month loses the ability to add new money to their HSA. But they can still use funds already in their HSA to pay your monthly fee as a qualified medical expense. The contribution question and the spending question are separate.

If a patient came to you this year with $5,000 already in their HSA and signed up at a $175 monthly fee, they can pay you from that account. They just can’t add new dollars to it until they drop below the cap threshold or drop the HDHP.

What This Means

Revenue Procedure 2026-24 doesn’t change the rules for DPC practices. What it confirms is that the inflation-indexing framework the OBBBA created is now operational, and that DPC fee caps won’t automatically tick upward every year. They move when CPI is large enough to clear the rounding formula. For 2027, it wasn’t.

For most DPC practices, 2027 looks identical to 2026 on the HSA front. Patients who were eligible last year are eligible under the same terms.

If you’ve already updated your patient-facing materials to explain HSA compatibility since January, you don’t need to revise them for 2027. The rules held. The message holds with them.