HSA eligibility lives or dies on whether the health plan is a real HDHP. For 2026, that means a deductible of at least $1,700 (self) / $3,400 (family) and an out-of-pocket maximum no higher than $8,500 / $17,000.
The family-plan confusion
Family HDHPs can use aggregate deductibles or embedded individual deductibles — but if the plan uses an embedded individual deductible, that embedded amount generally must be at least the family HDHP minimum ($3,400 for 2026). This is the plot of many “my broker said it was HSA-eligible” disputes.
If a family plan lets one person receive non-preventive benefits after hitting an embedded deductible below $3,400, you may have an HSA problem even if the brochure says “HSA.”
Preventive care still sits outside the deductible
Qualifying preventive care can (and usually should) be covered pre-deductible. Telehealth flexibility is broader than it used to be under the OBBB changes, but “all virtual care forever” is not the same as the preventive-care safe harbor. Keep the categories straight in employee chats.
Quick sponsor actions
- Ask your carrier for a written HSA-eligibility confirmation for each 2026 medical option.
- Align SBC deductible language with what the TPA/custodian shows participants.
- Revisit any employer HRA or FSA layered beside the HDHP — stacking the wrong account breaks eligibility fast.
March is a good time for this audit: early enough to fix midyear communication, late enough that real claims data shows where employees misunderstand the deductible.