DPC alongside an employer's health plan: how the pieces fit

For an employer, DPC can sit next to its health plan, not in place of it. The membership covers primary care. The health plan covers specialists, hospitals, imaging and emergencies. Knowing how the two fit lets you answer an employer's first questions and send the rest to the right advisor.

What each piece covers

• The DPC membership: primary care for a fixed monthly fee, under the terms of your agreement.
• The health plan: the care a membership doesn't cover, like specialists, hospital stays, surgery and emergencies.

On its own, a DPC membership isn't health insurance. Say so plainly. An employer that drops its health plan and offers only DPC leaves employees without coverage for hospitals, specialists and emergencies. Those rules are a question for the employer's broker and attorney.

DPC with a high-deductible plan

An employer can pair DPC with a high-deductible health plan. Employees get primary care without paying toward the deductible first, and the plan stays in place for large costs.

IRS Notice 2026-5 covers how this works with health savings accounts from 2026:

• A qualifying DPC arrangement doesn't stop someone from contributing to an HSA, if the fee is no more than $150 a month for one person or $300 a month for an arrangement covering more than one person. The limits are adjusted for inflation after 2026.
• The DPC arrangement has to sit outside the high-deductible plan. The plan itself can't pay DPC fees as a benefit.
• DPC fees don't count toward the plan's deductible or out-of-pocket maximum.
• A fee above the limit makes the member ineligible to contribute to an HSA while enrolled.

There's more on what employer payment means for HSAs in this post.

Questions to send to the employer's advisors

Some questions belong to the employer and its advisors, not to you: whether their DPC offering counts as part of a group health plan, what plan documents they need, and whether continuation coverage rules apply. Here's a list you can hand them.

What it means for your contract

Write down exactly what the membership includes and how any extras are billed. If an employer is relying on the HSA rules, have your healthcare attorney confirm your arrangement fits them before you sign.

What I'd do this week

• Write a short paragraph explaining what DPC covers and what the health plan covers.
• Check your per-person and family fees against the $150 and $300 limits.
• Ask your attorney to review how you describe the arrangement to employers.

Common questions

Can an employer offer DPC instead of a health plan?
Some try, but a membership doesn't cover hospitals, specialists or emergencies. The employer should talk to its broker and attorney before dropping a plan.

Do I need to know the employer's plan details?
You need to know the plan type and plan year. The details of their coverage are for their broker.

Who confirms the arrangement fits the HSA rules?
Your healthcare attorney for your side, and the employer's advisors for theirs.