Employers: Prepare for 2026 Benefit Plan Updates Under the One Big Beautiful Bill Act

What employers need to know about 2026 benefit plan updates for dependent care FSA limits and HSA-eligibility under the One Big Beautiful Bill Act.
November 2025
Signed on July 4, 2025, the One Big Beautiful Bill Act (OBBBA) brings several key updates to employee benefit plans starting in 2026. From higher Dependent Care FSA limits to new HSA-eligible primary care options, these changes could affect both employers and employees.
Dependent Care Flexible Spending Account (DCFSA) Limits:
Beginning in 2026, the annual contribution limit will increase to $7,500 (or $3,750 for married individuals filing separately).
While increasing the limit is optional, employers offering a DCFSA who want to take advantage of the increase should update their cafeteria and benefits plan documents and notify employees prior to their 2026 plan year.
Direct Primary Care Service Arrangements:
Beginning in 2026, certain direct primary care service arrangements will be eligible for a Health Savings Account (HSA) and treated as a medical expense. To qualify, the arrangement must cost $150/month or less for individuals or $300/month or less for families. Employees can contribute to and use the HSA to pay the monthly cost of qualifying direct primary care service arrangements.
Looking Ahead
Proactive planning will help employers update their benefit plans to take advantage of these changes.
If you would like assistance reviewing your current benefit plan or updating your plan, our team is here to help.