Can we layer Direct Primary Care (DPC) or Virtual Primary Care (VPC) on top of a high-deductible plan?

Yes. Pairing Direct Primary Care (DPC) or Virtual Primary Care (VPC) with a High-Deductible Health Plan (HDHP) is one of the most effective ways to improve access, increase utilization, and control long-term costs. The key is to structure the arrangement correctly to maintain HSA eligibility and IRS compliance.

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Why pairing DPC or VPC with an HDHP works
HDHPs lower premiums but can discourage employees from seeking care due to high upfront costs. Layering DPC or VPC gives employees immediate, affordable access to care before they reach their deductible.

Result: Employees receive early care for preventive, chronic, and everyday needs, while employers experience fewer emergency visits and costly claims.

IRS compliance and HSA eligibility
If your HDHP is HSA-compatible, the DPC or VPC structure must be designed carefully. Under IRS rules, employees can only contribute to an HSA if they have no other coverage that provides medical benefits before meeting the deductible. This means traditional DPC or VPC programs could disqualify HSA contributions unless they are designed as:

• Preventive-only or wellness programs, or
• Employer-paid, non-insurance memberships offered outside the HDHP.

Solution: Design DPC or VPC benefits as preventive or care navigation programs, or offer them separately as an employer-paid benefit to preserve HSA eligibility.

Employer design options for combining HDHP and DPC/VPC

• Option 1: HDHP plus Employer-Funded DPC/VPC (Non-Insurance Model)
  
  • The employer pays for DPC or VPC access outside the health plan.
  • The HDHP covers major medical expenses.
  • Employees retain HSA eligibility if the DPC/VPC model qualifies as non-insurance and preventive.
    Ideal for: Employers who want to maintain tax advantages while improving access to care.
• Option 2: HDHP plus Integrated Primary Care Benefit (Non-HSA Approach)
  
  • The DPC/VPC benefit is integrated directly into the health plan.
  • Employees get $0 access to primary care, mental health, and basic labs from day one.
  • HSA eligibility does not apply, but utilization and satisfaction improve significantly.
    Ideal for: Employers who value accessibility and retention more than HSA tax savings.

Compliance considerations

• IRS Notice 2004-50 limits first-dollar coverage in HSA-qualified plans, but preventive care exceptions apply.
• Confirm with your vendor or legal counsel that your structure preserves HSA eligibility.
• Clearly communicate to employees how this benefit interacts with their deductible.
  Best practice: Document whether your program is considered a “non-insurance membership” or an “embedded benefit” in your plan materials.

Why this approach improves outcomes
Combining DPC or VPC with an HDHP offers both affordability and quality:

• Lower premiums through the HDHP structure.
• Higher engagement due to easy, $0 primary care access.

Reduced claims through prevention and early treatment.Impact: Employees use care proactively, helping employers maintain predictable costs and stable renewals.

Vitable’s primary-care-first model works seamlessly alongside HDHPs. Every member receives $0 access to primary care, mental health, and prescriptions through virtual or in-home visits. Vitable can function as an employer-funded, HSA-compatible add-on or as an integrated benefit in a non-HSA plan. This structure provides meaningful care access without compliance complications.

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You can successfully combine DPC or VPC with a high-deductible plan. The key is proper structure:

• Keep DPC/VPC preventive or employer-paid to preserve HSA eligibility, or
• Integrate it directly if HSA tax advantages are not a priority.
  
  

With Vitable’s $0 primary-care-first model, you can achieve affordability, compliance, and employee satisfaction while keeping your HDHP efficient and easy to manage.

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