Blueberry Pediatrics HSA/FSA Eligibility: How to Pay for Your Telehealth Membership With Pre-Tax Dollars

Bottom line up front: This tax treatment matters more to a multi-child household than the headline number suggests, because of how Blueberry's fee is structured: it's one flat membership covering every child in the household, not a per-child charge. That means the pre-tax savings covered in this guide apply to a fee that's already doing double or triple duty across your kids — the same $52/year in illustrative tax savings this guide walks through effectively costs less per child in a two-kid household than the identical savings would represent for a family with one child paying the same flat fee. As of January 1, 2026, Blueberry Pediatrics memberships are HSA-eligible under a real, statutory change in federal tax law — the Primary Care Enhancement Act's provisions within the broader 2025 tax legislation reclassified qualifying Direct Primary Care service arrangements so they no longer disqualify a person from HSA eligibility, and their membership fees now count as qualified medical expenses. Blueberry states its memberships are FSA-eligible as well, though FSA administration is plan-specific in a way HSA administration generally isn't, so that side needs a direct confirmation from your plan administrator rather than an assumption. None of this is a "loophole" in the sense of an exploited gap — it's a straightforward application of a tax rule that took effect this year, and treating it as anything shadier than that would misrepresent both the law and what you're actually doing when you pay a medical membership fee with pre-tax dollars you were always entitled to use for qualified medical care.

This guide is a factual walkthrough of the current rule, the actual dollar mechanics, and the documentation process — not tax or legal advice. HSA and FSA administration varies by plan and employer, and a family with specific questions about their own account should confirm details with their plan administrator or a tax professional before assuming any detail below applies exactly to their situation.

Related in this series: This guide covers the tax-payment mechanics only. For the underlying cost-versus-urgent-care math this pre-tax treatment applies to, see our full Blueberry Pediatrics cost matrix. The same HSA/FSA eligibility logic for genuinely diagnostic medical devices also applies to the Owlet Dream Sock, covered in our baby monitor comparison. For how this tax treatment affects total household spending, see our full budget breakdown. For a real-world contrast in how this tax treatment plays out, see our Blueberry vs. Summer Health comparison — Summer Health's own policy currently excludes subscription billing from HSA/FSA eligibility entirely.

What Actually Changed in 2026, and Why It Matters Here

For years, Direct Primary Care arrangements — flat monthly-fee memberships covering ongoing primary care access, structurally similar to what Blueberry Pediatrics offers for pediatric telehealth — sat in an awkward tax position. The IRS's longstanding position, rooted in Notice 2004-23, treated a DPC-style membership as more like a health insurance premium than a payment for a discrete medical service, since the arrangement pays for the right to access future care rather than a specific, itemized visit. That classification had two consequences: DPC fees generally weren't reimbursable as qualified medical expenses, and in some interpretations, simply being enrolled in a DPC arrangement could jeopardize a person's eligibility to contribute to an HSA at all, since HSA rules restrict contributions for anyone with certain other forms of "coverage."

The One Big Beautiful Bill Act (OBBBA), enacted in 2025, changed this directly through what's commonly referred to as the Primary Care Enhancement Act provisions. The Treasury Department and IRS followed with Notice 2026-05, issued in December 2025, clarifying the mechanics. Effective for plan years and fees incurred on or after January 1, 2026, a qualifying Direct Primary Care Service Arrangement (DPCSA) is no longer treated as a health plan for HSA-eligibility purposes, and periodic DPCSA fees are treated as HSA-reimbursable qualified medical expenses in their own right.

This is the specific legal mechanism Blueberry Pediatrics is relying on when it states its memberships are HSA-eligible: Blueberry's own materials describe its financial structure as similar to the DPC model, and state that the federal legislative clarification effective January 1, 2026 is what makes the membership fee a qualified medical expense. This is a real, verifiable claim tied to an actual change in the tax code — not marketing language stretching an unrelated rule to fit.

The Statutory Definition, and Why Blueberry's Pediatricians Fit It Cleanly

The reclassification isn't a blanket exemption for any subscription-style health service — it applies to a specifically defined category, and walking through the actual statutory language matters here rather than taking eligibility on faith, since this is exactly the kind of detail that separates a genuinely qualifying arrangement from one that merely resembles one.

A DPCSA, per the statutory language enacted through the OBBBA and detailed in IRS Notice 2026-05, is an arrangement providing medical care consisting solely of primary care services, delivered by a primary care practitioner, for a sole, fixed periodic fee — with three explicit carve-outs from what counts as "primary care services": procedures requiring general anesthesia, prescription drugs other than vaccines, and laboratory services not typically administered in an ambulatory primary care setting.

The "primary care practitioner" definition, borrowed from Social Security Act Section 1833(x)(2)(A), specifically includes physicians whose primary specialty designation is family medicine, internal medicine, geriatric medicine, or pediatric medicine — along with nurse practitioners, clinical nurse specialists, and physician assistants for whom primary care accounts for at least 60% of their practice. Blueberry Pediatrics' service is delivered by board-certified pediatricians treating common childhood illness, which places it squarely inside the "pediatric medicine" category the statute explicitly names — this isn't a stretch interpretation applied to a service that happens to look similar; pediatric primary care is one of the four physician specialties Congress wrote directly into the definition.

The three exclusions also line up informatively with how Blueberry's actual clinical workflow is structured. The requirement that lab services not typically found in an ambulatory primary care setting fall outside the flat fee — and be billed separately — matches Blueberry's own described handling of suspected UTIs, where a urine culture is ordered as a separate lab test with its own (discounted) cost rather than folded into the membership price. Whether that structural alignment was designed with this specific tax provision in mind or is simply how outsourced lab work has to function logistically for a telehealth company, the practical result is the same: the arrangement's actual operation doesn't bundle excluded service categories into the flat fee, which is precisely what the statute requires for DPCSA status to hold.

A Provision Nearly a Decade in the Making

This isn't a rule that appeared out of nowhere in 2026. Versions of the underlying legislation — titled the Primary Care Enhancement Act — were introduced in Congress repeatedly and failed to pass for years before finally becoming law: a 2021 version (S.128, 117th Congress), a 2023 version (S.628, 118th Congress), and a 2025 version (H.R.1026, 119th Congress) all proposed substantially the same core change, with nearly identical statutory language about excluded services across every version. The eventual enactment came through inclusion in the broader One Big Beautiful Bill Act in July 2025, with the IRS's implementing guidance (Notice 2026-05) following in December 2025. The multi-year, bipartisan-sponsored history of this specific provision is worth knowing because it distinguishes this change from a temporary administrative concession that could be reversed by the next guidance update — it reflects a considered statutory change to the Internal Revenue Code itself, not an informal IRS accommodation.

The FSA Complication the Marketing Doesn't Emphasize

Here's a detail that meaningfully sharpens the HSA/FSA distinction raised earlier, easy to miss in a quick read of the new rule: the DPCSA provision's qualified-medical-expense treatment specifically does not extend to fees paid by an individual's employer, including through salary reduction under an IRC Section 125 cafeteria plan — which is exactly the mechanism that funds most employer-sponsored FSAs. In plainer terms, the new statutory language creating HSA-reimbursable treatment for DPCSA fees appears to carve out the employer-funded, cafeteria-plan pathway that FSAs typically run through, even as it clearly opens the door for HSA reimbursement, since HSAs are individually funded and owned rather than run through an employer's Section 125 plan in the same way.

This is a technical statutory nuance, and it's the most likely explanation for why Blueberry's own materials hedge on the FSA side specifically ("final approval depends on your plan administrator") rather than stating FSA eligibility with the same confidence as the HSA claim. It does not necessarily mean FSA reimbursement is impossible — FSA plans have some latitude in how they classify expenses, and an individual plan administrator may still choose to treat the membership as reimbursable under the general Section 213(d) medical-care definition rather than specifically as a DPCSA fee — but it does mean the clean statutory pathway Congress built primarily addresses HSA treatment, not FSA treatment, and a household relying on FSA reimbursement for this expense should treat that outcome as administrator-dependent rather than statutorily guaranteed, exactly as Blueberry's own caveat suggests.

Where This Intersects With the Separate Telehealth Safe Harbor

One more distinction to draw cleanly, since discussions of "OBBBA and HSAs" often conflate several separate provisions into one: the same legislation also made permanent a different rule — a safe harbor allowing telehealth and remote-care services to be covered before an HDHP's deductible is met, without jeopardizing HSA eligibility, effective for plan years beginning on or after January 1, 2025 (a year earlier than the DPCSA provision's January 1, 2026 effective date). This telehealth safe harbor is a separate mechanism from the DPCSA reclassification discussed throughout this guide — it addresses when an HDHP can cover telehealth pre-deductible, while the DPCSA rule addresses whether a flat-fee membership arrangement itself disqualifies HSA eligibility and whether its fees are separately reimbursable. A household could plausibly benefit from both provisions in different ways depending on their specific HDHP's plan design, but conflating the two — as some consumer content does — risks misstating which rule applies to which part of a family's telehealth spending.

The HSA Mechanics: Caps, Aggregation, and Where Blueberry Sits Relative to Them

The new rule isn't unlimited. To avoid disqualifying someone's HSA contribution eligibility, a DPCSA's fees need to stay within specific monthly caps: $150 per month for an individual, $300 per month for a family, for 2026, with these figures scheduled for annual inflation adjustment in future years. These caps are aggregate — they apply across all DPCSA-type arrangements a person is enrolled in combined, not per arrangement, so a household stacking multiple direct-care memberships would need to sum the fees against the same limit.

The rule also permits billing in blocks longer than a month — quarterly, semi-annually, or annually — as long as the fee remains fixed and periodic and doesn't exceed the monthly cap on an annualized basis. A family paying $1,800 for the year, for instance, stays inside the $150/month individual cap when averaged across twelve months, even though it's billed as one annual charge.

This is where Blueberry's actual pricing makes the entire compliance question close to moot for most households. Blueberry Pediatrics costs $18–$29 per month depending on billing frequency (annual vs. monthly), or $216 per year — covering every child in the household under one flat fee, with no per-child or per-visit charges. Compared against the $300/month family cap, Blueberry's actual cost runs at roughly 6–10% of the ceiling. A household would need to be stacking Blueberry alongside several other, considerably more expensive direct-care-style memberships before this cap became a real constraint. For the vast majority of families using Blueberry as their sole DPC-style arrangement, the monthly-cap question is not a practical risk — it's worth knowing the rule exists, but not worth losing sleep over at this price point.

One nuance worth stating honestly rather than glossing over: publicly available guidance on this new rule notes that if a DPCSA's fees do exceed the monthly cap, the arrangement can still be reimbursed with HSA funds as a qualified medical expense — the cap primarily governs whether the arrangement affects your eligibility to make ongoing HSA contributions, not whether the specific fee itself can be paid or reimbursed with existing HSA funds. The precise interaction between exceeding the cap and contribution eligibility is a highly technical area of the new guidance that a tax professional is better positioned to walk through for a specific household's full set of health-coverage arrangements than a general guide can respons‌ibly summarize — but again, this scenario is unlikely to apply to a Blueberry-only household given how far under the cap its pricing sits.

The FSA Side: A Real Distinction, Not a Minor One

This is a place where a lot of consumer-facing content flattens an important difference, and precision matters here: HSA and FSA eligibility for DPC-style memberships are not automatically the same question, even though they're often discussed in the same breath. HSAs are individually owned accounts governed directly by IRS rules on qualified medical expenses. FSAs are employer-sponsored benefit plans, and while they're built around the same general IRC Section 213(d) definition of qualified medical expense, individual employer plans retain discretion in how they administer and interpret specific categories of reimbursement — general industry guidance on DPC memberships has historically noted that FSA plans are less consistently set up to reimburse ongoing membership-style fees compared to HSAs, even after the same underlying legal reclassification.

Blueberry Pediatrics states directly that its memberships are both HSA and FSA eligible, and explicitly notes — in its own published guidance — that "final approval depends on your plan administrator." That caveat, coming directly from the company making the eligibility claim, is the right level of caution to carry into this decision: treat Blueberry's FSA-eligible claim as generally accurate based on the current legal classification, but confirm actual reimbursement behavior with your specific FSA administrator (common administrators include HealthEquity, Optum Financial, WEX, and Further, among others) before assuming a card swipe or reimbursement claim will process automatically, since FSA plans can and do vary in how proactively they've updated their eligible-expense lists to reflect this year's legislative change.

The Diagnostic Kit's Tax Treatment

Blueberry's at-home kit — the smart otoscope and pulse oximeter shipped to members — sits on more familiar tax ground than the membership fee itself. Diagnostic medical devices used to detect or monitor a health condition have long been treated as qualified medical expenses under standard IRS guidance, in the same general category as home blood pressure monitors or basic first-aid diagnostic tools, without requiring the kind of third-party medical-necessity documentation that general wellness products (supplements, fitness equipment, and similar items marketed as broadly health-supportive rather than diagnostic) typically need. Blueberry's own materials describe the kit's diagnostic devices as typically reimbursable under standard IRS guidance for medical supplies. This is a meaningfully different — and simpler — approval path than what applies to wellness-adjacent purchases that rely on a Letter of Medical Necessity from an independent clinician to become HSA/FSA eligible; a genuinely diagnostic device like a pulse oximeter generally doesn't need that extra layer of documentation to qualify.

Documentation and Reimbursement: The Actual Step-by-Step

Because Blueberry's membership fee is now directly classified as a qualified medical expense under the new DPCSA rule — rather than requiring a case-by-case medical-necessity justification the way general wellness products do — the documentation burden here is lighter than headlines about "HSA tax hacks" sometimes imply. There is no Letter of Medical Necessity requirement in this specific case, because the expense category itself, not an individual's specific health situation, is what establishes eligibility.

Paying directly at checkout: Blueberry allows members to use an HSA or FSA card directly at signup, the same way you'd pay with any debit card. This is the simplest path, since it requires no separate reimbursement claim — the transaction is coded and processed as a qualified medical expense at the point of sale, assuming your card issuer's merchant-category coding recognizes the transaction appropriately, which is the card network's function rather than something the member needs to configure.

Paying another way, then requesting reimbursement: If you've already paid with a regular card, or prefer to keep your HSA/FSA card reserved for other purposes, Blueberry's support team can issue an HSA/FSA-compliant receipt on request via email, using the address associated with your account. From there, the general reimbursement process — consistent with how most HSA/FSA administrators handle any qualified expense — involves:

• Requesting or saving an itemized receipt showing the provider name, service description (membership fee for the relevant billing period), amount, and date.
• Logging into your HSA or FSA administrator's portal (or app) and locating the reimbursement or claims-submission function.
• Uploading the receipt and completing whatever claim form your specific administrator requires — this varies by administrator, but generally asks for the expense category, amount, and date of service.
• For HSA accounts specifically, note that unlike FSAs, HSAs generally don't require pre-approval before you spend the money — the account holder is responsible for retaining documentation in case of an IRS inquiry, rather than submitting every expense for prior authorization. FSAs, by contrast, more commonly require the claim to be submitted and approved by the plan administrator before or as part of the reimbursement.
• Retaining a copy of the receipt independently of the administrator's portal, since audit-response documentation is ultimately the account holder's responsibility for HSAs, and administrators don't guarantee indefinite storage of submitted claim documents.

What Records to Actually Keep

Given that the entire basis for this expense's eligibility rests on its correct classification as a DPCSA fee, the two records to retain longer-term are: an itemized annual or monthly billing statement showing the fee amount and that it's a Blueberry Pediatrics membership charge, and — as inflation adjustments to the monthly caps roll out in future years — awareness of what the current cap is relative to your actual membership cost, simply so you have a documented basis for why the arrangement stayed within the threshold if that specific detail is ever questioned by a plan administrator or during an IRS inquiry.

Running the Actual Pre-Tax Math

The genuine value of paying with HSA or FSA funds isn't abstract — it's the taxes you don't pay on the dollars used. Since HSA and FSA contributions are made pre-tax (avoiding federal income tax, and in most cases FICA/payroll tax as well, and often state income tax depending on the state), the effective cost of a $216 annual Blueberry membership drops meaningfully below its sticker price for anyone paying with pre-tax funds rather than post-tax income.

The table below illustrates this using representative marginal tax rate assumptions — these are examples to demonstrate the mechanism, not a claim about any specific taxpayer's actual bracket, which depends on income, filing status, state of residence, and other factors a tax professional should evaluate directly:

The per-child version of this table is where a two-kid household sees the real advantage. Because Blueberry's $216 covers every child on the account, the effective cost per child at a 24% rate drops to roughly $82 for a two-child household versus $164 for a single child paying the identical fee — the tax treatment doesn't change with child count, but the per-child value of receiving it does. This is the direct multi-child payoff of a flat-fee structure combined with pre-tax treatment: the household isn't getting a bigger tax break for having two kids, it's getting the same fixed break spread across more coverage, which is a materially better deal per child than the same math would produce for a single-child household paying the same flat rate.

The mechanism driving this table: money contributed to an HSA or FSA is deducted from income before taxes are calculated, so a dollar routed through either account effectively goes further than a dollar earned, taxed, and then spent. Applied to a low-cost subscription like Blueberry's, the absolute dollar savings are modest in isolation — tens of dollars annually — but the same mechanism applies to every dollar of qualified medical spending in a household's budget, and stacking a family's full annual medical spending (co-pays, prescriptions, this kind of membership, eligible diagnostic devices) through pre-tax accounts is where the cumulative effect becomes meaningful rather than incidental.

Re-Baselining the True Cost Comparison

This matters directly for the cost analysis in our full Blueberry Pediatrics urgent-care cost-matrix breakdown: every dollar figure in that comparison — the $216/year membership fee, the avoided urgent-care copays — becomes slightly more favorable to the membership once pre-tax treatment is factored in, since the membership side of the ledger can be paid with tax-advantaged dollars while a cash urgent-care visit generally cannot (unless separately submitted for HSA/FSA reimbursement itself, which many families don't bother doing for smaller one-off expenses). The break-even math in that guide holds without this adjustment, but pre-tax payment tilts it slightly further in the membership's favor for any household with HSA or FSA access.

Practical Recommendations

• If you have an HSA: Pay for Blueberry directly with your HSA card at signup. The DPCSA reclassification applies cleanly, your membership cost sits far under the monthly cap, and no special documentation beyond a standard receipt is needed.
• If you have an FSA: Attempt payment with your FSA card first; if the transaction doesn't process automatically, request an itemized receipt from Blueberry and submit a standard reimbursement claim through your FSA administrator's portal, since Blueberry's own materials acknowledge final approval sits with your specific plan.
• If you're stacking multiple direct-care-style memberships across your household: Total their monthly fees against the $150 individual/$300 family cap before assuming full contribution-eligibility protection, and consider a tax professional's input if you're close to or over that threshold.
• Regardless of account type: Keep an independent copy of your annual membership statement, separate from whatever your HSA/FSA administrator's portal retains, since you are the party ultimately responsible for substantiating the expense if it's ever questioned.

Frequently Asked Questions

Does the HSA-eligibility change apply retroactively to Blueberry membership fees paid before January 1, 2026? No — the Primary Care Enhancement Act provisions and the corresponding IRS guidance apply to fees incurred on or after January 1, 2026; fees paid in prior years under the previous classification aren't affected by this change.

If my employer's FSA plan hasn't updated its eligible-expense list to reflect the new DPC rule, can I still get reimbursed? Possibly, but it depends on your specific plan administrator's current configuration — Blueberry's own guidance notes final approval depends on your plan administrator, so if a direct card payment or claim is initially declined, contacting your FSA administrator directly to ask whether they've incorporated the 2026 DPCSA guidance is the appropriate next step rather than assuming the expense is categorically ineligible.

Do I need a Letter of Medical Necessity from a doctor to make my Blueberry membership HSA/FSA eligible? No — unlike general wellness products that require a Letter of Medical Necessity to qualify, Blueberry's membership fee is eligible based on its classification as a Direct Primary Care Service Arrangement fee under current federal tax law, which doesn't require an individualized medical-necessity determination.

Does paying for Blueberry with HSA funds count against my annual HSA contribution limit? No — the annual HSA contribution limit governs how much you can contribute to the account each year; spending previously contributed funds on a qualified expense like a Blueberry membership doesn't reduce or count against your contribution limit for that year.

If I have both an HSA and an FSA, which one should I use to pay for Blueberry? This depends on your personal financial situation — HSAs roll over indefinitely and are often preferable to preserve for larger future medical expenses, while FSAs are typically use-it-or-lose-it within the plan year, so some households prioritize spending down FSA funds on eligible recurring expenses like this membership first; a financial advisor familiar with your specific accounts can offer a more tailored recommendation.

Is the one-time medical kit fee subject to the same $150/$300 monthly DPCSA cap as the membership fee? The DPCSA monthly cap specifically governs the periodic membership-style fee; a one-time diagnostic-equipment purchase is generally evaluated under the separate, longstanding standard for qualified medical devices rather than the DPCSA periodic-fee cap, though confirming this distinction with a tax professional is reasonable if the combined costs are a significant factor in your household's HSA planning.

Can I use HSA or FSA funds to pay for Blueberry Balance (their adolescent metabolic health program) the same way as the core pediatric membership? Blueberry states its Balance program is also FSA/HSA eligible on its own program page, though as with the core membership, confirming current eligibility and any program-specific documentation requirements directly with Blueberry and your plan administrator is the appropriate step before assuming identical treatment to the primary pediatric membership.

What happens if I use HSA funds for the membership and then get a partial refund from Blueberry for an unused period? Refunded amounts for a previously reimbursed qualified expense generally need to be returned to the HSA or accounted for as taxable income if not returned, consistent with general IRS treatment of reimbursed-then-refunded medical expenses — check with your HSA administrator on the correct process for handling a refund in your specific case.

Why does the pediatric specialty of Blueberry's doctors specifically matter for DPCSA eligibility? The statutory definition of a qualifying "primary care practitioner" explicitly lists pediatric medicine as one of four physician specialties that satisfy the requirement (alongside family medicine, internal medicine, and geriatric medicine), so a service staffed by board-certified pediatricians treating primary-care-level childhood illness fits the definition directly rather than requiring an expansive interpretation.

Is the FSA carve-out for employer-funded, Section 125 cafeteria-plan payments the reason my FSA card might not work automatically at checkout? It's a plausible technical explanation, since the DPCSA provision's clean qualified-medical-expense treatment appears specifically written around HSA-style individual funding rather than employer-funded cafeteria-plan arrangements like most FSAs — if your FSA card doesn't process the charge automatically, this statutory distinction is a likely reason, and confirming with your FSA administrator whether they treat the fee as reimbursable under the general medical-care definition instead is the appropriate next step.

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This guide is a factual explanation of a current tax rule and is not tax or legal advice. HSA and FSA rules can vary by plan, employer, and individual tax situation, and the details above should be confirmed with your plan administrator or a qualified tax professional before making decisions based on them.