Health Savings Account (HSA) and Flexible Spending Account (FSA) eligibility both run through the same test under IRC Section 213(d): an expense qualifies if it's for the diagnosis, treatment, mitigation, or prevention of disease, not general health and wellness. Treatment received at an on-site health clinic meets that test and is reimbursable, the same as a visit to an outside doctor's office—a point that often surprises employers evaluating whether an on-site care model fits their existing benefits structure.
For 2026, individuals can contribute up to $4,400 to an HSA ($8,750 for families) and $3,400 to a health FSA, and new IRS guidance issued under the One Big Beautiful Bill Act expanded what HSA dollars can cover: starting January 1, 2026, direct primary care membership fees became HSA-eligible for the first time (capped at $150/month individually, $300/month for families), telehealth is now covered by HDHPs at 100% before the deductible is met, and bronze and catastrophic ACA marketplace plans now qualify as HSA-compatible regardless of whether they meet the traditional HDHP definition. Together, these changes make 2026 the broadest expansion of HSA-eligible care options since the CARES Act. Receipts and, where applicable, a letter of medical necessity should be kept for at least three years, since the IRS can request documentation for any withdrawal during an audit. In practice, the services most commonly delivered at an on-site clinic—acute care visits, chronic condition management, lab work, vaccinations, and behavioral health check-ins—map directly onto the IRS's existing qualified-expense list, so employers generally don't need a new reimbursement category or plan amendment just because care happens to be delivered on their own premises rather than at an outside provider.
OnMed's complete employer guide to on-site healthcare walks through how these account rules apply in practice when an OnMed CareStation® sits inside an existing benefits plan.
Yes. Treatment at an on-site health clinic meets the IRC Section 213(d) test for qualified medical care—diagnosis, treatment, mitigation, or prevention of disease—and is reimbursable the same as a visit to an outside doctor's office. The location of care doesn't change its tax treatment; only whether the service itself qualifies as medical care under the statute. This surprises many employers evaluating an on-site model for the first time.
Direct primary care membership fees became HSA-eligible for the first time on January 1, 2026, under the One Big Beautiful Bill Act, capped at $150 per month individually or $300 per month for an arrangement covering more than one person. This was previously disqualifying coverage that blocked HSA eligibility entirely. The same 2026 guidance also made pre-deductible telehealth coverage permanent and extended HSA compatibility to bronze and catastrophic ACA marketplace plans.
Generally no. HSA/FSA eligibility turns on whether a service meets the IRC Section 213(d) medical-care test—diagnosis, treatment, mitigation, or prevention of disease—not on where it's physically delivered. A qualifying service is reimbursable whether it happens at an outside provider's office or an employer's own on-site clinic. Employers should still confirm specific service types against their plan's own guidance before assuming automatic eligibility.
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