The DPC Fee Caps Took Effect in January. A New House Bill Would Scrap Them.

Legislation by DPC Insider
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Sources: GOP hopes to make an employer health package part of Reconciliation 3.0 deal · 27 GOP Health Care Affordability Wins Nobody's Talking About

The $150-per-month cap on DPC fees paid through HSAs hasn’t finished its first year. A House bill filed in April would remove it, and its sponsor pitched it again this week.

Rep. Eric Burlison of Missouri introduced the Great American Healthcare Plan (H.R. 8324) on April 16, and it had drawn eight Republican cosponsors by the time this published, aiming to fold health benefits provisions into a potential third reconciliation package. One of those provisions: eliminate the monthly DPC fee caps that the One Big Beautiful Bill Act created in July 2025, effective this January.

What Would Change

Under the current rules, HSA holders can spend up to $150 per month per individual or $300 per family on DPC membership fees with pre-tax dollars. Exceed those limits and the arrangement stops being a qualifying DPC service arrangement altogether, which can put the HSA itself at risk rather than merely disallowing the excess dollars.

Burlison’s bill would erase those caps. Any DPC membership fee would be HSA-eligible regardless of the monthly amount.

Most DPC practices aren’t bumping against the limits today. Individual memberships typically run $70 to $100 per month, according to DPCA and DPC Frontier data. Family memberships sit closer to the ceiling but usually clear it.

The practices most affected would be those with comprehensive family plans or concierge-adjacent pricing above $300 per month. Cap removal would also prevent the limits from becoming a constraint as the market evolves.

Who’s Behind It

Eight Republican cosponsors had signed on by late June, starting with Rep. Tom Barrett of Michigan on the day of introduction and including Rep. Tom McClintock of California, Rep. Warren Davidson of Ohio and Rep. Elijah Crane of Arizona. No Democrats.

An organized coalition is backing the bill: the HSA Coalition, ERISA Industry Committee, Americans for Tax Reform, Heritage Foundation, Council for Affordable Health Coverage and Health Equity.

The coalition is organized around HSA expansion and consumer-directed care, not DPC specifically. DPC provisions are riding along with a larger tax reform agenda. Americans for Prosperity already counted the OBBBA’s DPC-HSA provisions among 27 healthcare policy wins. Cap removal is the next step.

Burlison described the plan as getting “bureaucrats and middlemen out of the way” and putting “Americans in control of their health care dollars.”

Beyond DPC Caps

The DPC provision is one piece of a broader employer health benefits package. Other provisions would:

  • Let employers satisfy ACA coverage requirements by contributing to employee HSAs instead of offering traditional group plans
  • Create “health marketplace pools” where small employers band together for group purchasing
  • Give HSA assets the same bankruptcy protections as retirement accounts
  • Allow charities to contribute directly to individual HSAs

The employer-HSA provision is the one that could touch DPC indirectly. If more employers route benefits through HSAs rather than traditional group coverage, employees get more control over where those pre-tax dollars go. More HSA dollars in circulation means a larger pool of patients who can pay for DPC memberships without reaching into after-tax income.

What This Means

The fee caps aren’t blocking most DPC practices from marketing HSA compatibility right now. A $90-per-month individual membership fits under the $150 limit with room to spare.

The signal is political. Two years ago, DPC was a legislative footnote. The OBBBA made DPC-HSA compatibility real. Congress wrote inflation indexing into the caps, and the IRS publishes each year’s figure, and the first adjustment was $0. Six months in, a new bill wants to scrap the caps altogether.

Each round of legislation treats DPC fees a little more like any other medical expense in the tax code: office visits, lab work, prescriptions. The line between “DPC membership fee” and “medical expense” keeps narrowing.

This bill still has to clear committee, floor votes and reconciliation. But DPC keeps showing up in major healthcare bills with named sponsors and organized coalition support. Two years ago the DPC-HSA bills were narrower, standalone vehicles rather than planks in a broad reform package.