Among Firms With 10 or More Workers That Offer Benefits, 39% Now Offer an HSA Plan, Up From 31%. The Share of Workers Enrolled in One Didn't Move.

Thirty-nine percent of employers with 10 or more workers that offer health benefits now offer at least some workers an HSA-qualified plan. A year ago it was 31%. Two years ago, 28%. That’s the jump in KFF’s 2026 Employer Health Benefits Survey, published Oct. 22 and drawn from 1,937 interviews with private and non-federal public firms.

The share of covered workers actually enrolled in those plans didn’t budge. It’s 29%, KFF says, the same as last year.

For direct primary care, this is the edition that matters. 2026 is the first year federal law has said a qualifying DPC membership doesn’t disqualify a patient from contributing to an HSA. For workers with employer coverage, the 29% is the share already in the kind of plan that rule needs.

The rule that took effect in January

Under IRS Notice 2026-5, the 2025 tax law’s direct primary care provision applies to months beginning after Dec. 31, 2025. A direct primary care service arrangement whose aggregate fees stay at or under $150 a month for one person, or $300 for an arrangement covering more than one, no longer disqualifies someone in a high-deductible plan from contributing to an HSA. The same law lets an HSA pay those fees.

That cap adjusts for inflation after 2026. For this year, $150 a month works out to $1,800 a year.

A patient only benefits from the contribution side of that rule if they’re in an HSA-qualified plan to begin with. KFF’s survey is the closest public count of how many employer-covered workers are.

Two numbers that measure different things

The 39% counts firms. The 29% counts workers. Most firms are small, and KFF reports that firms with 200 or more workers are more likely than smaller ones to offer an HSA-qualified plan, 54% to 38%. A wave of small employers adding a plan can move the firm figure a long way while barely touching the worker figure.

KFF doesn’t say why firms added these plans. Nothing in the survey ties the increase to direct primary care, and this post doesn’t either.

There’s one more wrinkle. Starting this year, KFF stopped grouping HSA-qualified plans with high-deductible plans paired with health reimbursement arrangements. HSA-qualified plans are now their own plan type. KFF still reports the year-over-year comparison, and the 31% figure for 2025 comes from the survey itself.

Over a longer window, the worker share has climbed. KFF puts it at 22% five years ago and 19% ten years ago.

What a worker in one of these plans faces

The numbers inside the HSA-qualified group are the ones a practice owner might want to sit down with.

• The average single deductible is $2,912. KFF says 48% of covered workers in these plans have a single deductible of $3,000 or more.
• Employers deposit an average of $713 a year into HSAs for single coverage and $1,346 for family coverage. Those averages include workers who get nothing.
• Sixteen percent of covered workers in these plans receive no employer HSA contribution at all. Among employers offering single coverage through an HSA-qualified plan, 39% make no contribution.

Across all plan types, among workers whose plan has a general annual deductible, the average single deductible is $1,955, and the average copay for a primary care visit is $27, KFF reports.

Run the arithmetic. At the $150 cap, a year of membership is $1,800. The average employer HSA deposit for single coverage, $713, would cover a little under five months of that. The rest comes from the worker’s own contributions, or from somewhere else.

For a patient facing a $2,912 deductible, a flat membership that handles routine visits is a different way to spend that first stretch of the year. That’s the pitch you might hear from a DPC practice in 2026, and the survey shows how many people it applies to.

The Counterargument

The strongest case against reading this survey as good news for DPC goes like this. The share of workers in HSA-qualified plans held flat in the first year of the new rule. Enrollment, not firm counts, is what puts a patient in a position to use the HSA side of a membership. And the people already in these plans carry high deductibles with thin employer deposits. A monthly fee lands on top of a payroll premium that KFF puts at $6,211 a year, on average, for family coverage in an HSA-qualified plan.

Much of that holds. A flat 29% means the share of workers in these plans didn’t grow this year. A $713 average deposit doesn’t fund a membership by itself.

Where the case gets weaker is on what the pool already is. Twenty-nine percent of covered workers is a large group, and it was 19% a decade ago. More firms offering the plan type gives more workers the option at their next open enrollment, even if few took it this year. And for those workers, Notice 2026-5 settles a question that used to hang over every membership. A qualifying one at or under $150 a month doesn’t cost them the ability to contribute.

What the survey can’t show is whether anyone acted on that. It has no measure of DPC enrollment, so the answer will have to come from somewhere else.