Yes, you can use your HSA or FSA to pay for Direct Primary Care at Fishtown Medicine. The 2025 Primary Care Enhancement Act recognizes DPC membership as a qualified medical expense, so monthly fees, advanced labs, and prescribed wellness tools are eligible for pre-tax dollars.
The gray area is gone. The era of pre-tax primary care is here.
For years, the IRS treated Direct Primary Care (DPC) membership fees as a gray area. Patients had to ask for itemized superbills, jump through hoops, and were sometimes denied reimbursement.
That ended in 2025.
With the passage of the Primary Care Enhancement Act, the federal government officially recognized what we have known all along: preventive, relationship-based primary care is medical care.
The legislation explicitly defines DPC membership fees as "qualified medical expenses" under Section 213(d) of the tax code.
What does this mean for your HSA or FSA?
If you have a Health Savings Account (HSA) or Flexible Spending Account (FSA), your Fishtown Medicine membership is now 100% eligible without superbills, caveats, or complex accounting.
This is effectively a 25% to 35% discount on your healthcare, depending on your tax bracket. By using pre-tax dollars (which would otherwise be taxed at your highest marginal rate), you are paying for premium, concierge-level care with money the government never touched.
How does the new pre-tax stack work?
The new pre-tax stack works in three layers. Here is how our savviest members structure their health investment in 2026.
1. The Membership (100% eligible)
You can set up your HSA or FSA card as the primary payment method for your monthly or annual membership.
- Action: Log in to the member portal and swap your credit card for your HSA card. Done.
2. The Deep Diagnostics (100% eligible)
Advanced testing is fully covered when ordered as part of your medical care.
- ApoB and Advanced Lipids: Covered.
- Fasting Insulin and CGM: Covered.
- DEXA Scans: Covered.
- Hormone Panels: Covered.
- Coronary Calcium and Cleerly Scans: Covered.
3. The Wellness Items (Letter of Medical Necessity)
While the membership is automatically covered, certain wellness items still need a documented diagnosis to be eligible. We handle this with a Letter of Medical Necessity (LMN) during your annual physical.
- Gym Memberships: Eligible when prescribed for hypertension, obesity, or insulin resistance.
- Oura Ring or Whoop: Eligible when prescribed for sleep apnea or stress management.
- Supplements: Eligible when targeting a documented deficiency (for example, vitamin D for confirmed deficiency).
Guidance from the Clinic

Actionable Steps in Philly
Stop letting your HSA sit there earning 0.1% interest. Deploy it.
- Switch Your Payment: Go to your Fishtown Medicine portal today and add your HSA card.
- Max Out the Contribution: For 2026, the HSA contribution limit increased again. Max it out to lower your taxable income.
- Download Your LMN: We provide a Letter of Medical Necessity for prescribed gym memberships and supplements by default. We believe in proactive prevention and provide the documentation to help you pay for it pre-tax.
- Pair With an HDHP: An HSA only stays open with an eligible high-deductible health plan. Confirm your insurance is HSA-compatible during open enrollment.
- Keep Receipts in One Folder: Save digital receipts for membership, labs, and supplements in a single cloud folder so reimbursement (or audit) is painless.
Scientific References
- Internal Revenue Service. Publication 502: Medical and Dental Expenses. (Updated annually.)
- Internal Revenue Service. Publication 969: Health Savings Accounts and Other Tax-Favored Health Plans. (Updated annually.)
- American Academy of Family Physicians. Direct Primary Care: A New Way to Pay for Health Care. Fam Pract Manag. 2018;25(1):16-20.
The Best Investment is Biology.
You now have a meaningful pre-tax discount on advanced primary care in Philadelphia. Let's get started.
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