The Big Beautiful Bill: 3 New Reasons to Talk Clinics with Your Clients in Q1 2026

Q1 2026 is a pivotal moment for brokers to revisit on-site and near-site clinic solutions with their employer clients. The landscape changed on January 1, 2026, thanks to the newly enacted One Big Beautiful Bill Act (OBBBA) and ongoing shifts in healthcare economics. This sweeping federal law (signed July 4, 2025) introduced major updates that empower primary care clinics and direct primary care (DPC) arrangements within benefit plans. Combined with rising cost pressures and access challenges, you now have at least three new talking points to bring to your Q1 client meetings about the value of employer-sponsored clinics.

1. HDHPs + Direct Primary Care: A New HSA-Friendly Reality

For years, employers interested in direct primary care or on-site clinics faced a hurdle: strict health savings account (HSA) rules. Under old regulations, offering free or low-cost broad primary care (beyond certain limited services) could disqualify employees from contributing to an HSA. That made many cost-saving clinic programs a non-starter for HSA-based high-deductible health plans (HDHPs). Now, OBBBA has changed the game. Effective January 1, 2026, employees can participate in a DPC arrangement alongside an HSA-qualified HDHP without losing HSA eligibility, as outlined in recent benefits guidance on the bill’s DPC provisions (Risk Strategies analysis). In practical terms, this means your clients can offer a modern primary care membership or on-site/near-site clinic access for a flat fee while employees still contribute to their HSAs. The law also deems certain DPC fees a qualified medical expense, payable tax-free from HSAs, subject to monthly caps and primary-care-only guardrails described in technical summaries of the bill’s HSA changes (Sequoia Financial overview).

Why this is big: Brokers can confidently propose DPC subscriptions or near-site clinic partnerships to HDHP clients in 2026, whereas before you may have held back. Your clients get the best of both worlds: the tax advantages of HSAs plus the enhanced access of a clinic. As one compliance update notes, these provisions “expand HSA eligibility” and let employers offer DPC alongside HDHP plans without HSA penalties (Risk Strategies HSA/DPC summary). In short, the HSA handcuffs are off. If a client has been curious about on-site clinics or direct primary care, you now have a green light to start that conversation in Q1. (It is worth noting that earlier proposals to also exempt comprehensive on-site clinic services from disqualifying HSA coverage did not make it into the final bill, as some legislative recaps point out (Sequoia legislative overview). So truly free, full-scope on-site clinics still require some plan design finesse. But a properly structured DPC or limited clinic benefit is now clearly permissible.)

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2. Telehealth Safe Harbor Is Now Permanent – Integrate Virtual Care

Another cornerstone of OBBBA is making the HDHP telehealth safe harbor permanent. During COVID, employers were temporarily allowed to cover telehealth visits at no cost before the deductible without breaking HSA rules. That relief expired at the end of 2024. Now, the new law permanently restores it for HDHPs, as summarized in multiple benefits briefings on the bill’s telehealth provisions (Risk Strategies telehealth safe harbor discussion). Employers can safely offer first-dollar telehealth and remote care in HDHPs without jeopardizing HSA eligibility. This is more than a compliance footnote; it is a strategic opportunity to weave virtual care into your clients’ primary care strategy.

Telehealth pairs naturally with on-site clinics and DPC programs. Think of a near-site clinic that employees can visit for annual physicals or chronic condition management, combined with 24/7 virtual urgent care for off-hours needs. In 2026, brokers should encourage clients to leverage this new flexibility. Employees have grown accustomed to the convenience of telemedicine, and usage remains high. Recent employer-benefit commentary notes that plan participants “continue to value telehealth for its convenience,” reinforcing the upside of integrating virtual care into plan design (Risk Strategies telehealth insights). With the safe harbor in place, there is no financial barrier to integrating virtual visits alongside an employer clinic. Clients can cover telehealth at 100% (or with minimal cost-sharing) as part of a clinic bundle, improving access and satisfaction. The Big Beautiful Bill essentially tells us: virtual primary care is here to stay, so make it a permanent feature of benefit designs. Brokers who help clients blend in-person clinics with telehealth options will deliver a more resilient, modern care ecosystem. Just be sure to update plan documents to reflect any telehealth changes and communicate the added benefit to employees.

3. Cost and Access Pressures Demand New Solutions

Beyond specific legal changes, the broader market context heading into 2026 adds urgency to the clinics conversation. Recent data show the biggest spike in employer health premiums in a decade—a 7% jump to nearly $24,000 for average family coverage—according to the 2023 benchmark KFF Employer Health Benefits Survey. Healthcare trend rates are not expected to slow, so CFOs and HR leaders are hungry for cost containment that actually bends the curve (not just shifts costs to employees). An on-site or near-site clinic can be that curve-bender by catching problems early and steering care to high-value providers. For example, one small employer in Kentucky opened a workplace clinic and “saved money by reducing unnecessary ER use and reducing hospitalizations,” substantially lowering claims while improving access (KFF Health News Laurel Grocery case study). Better primary care access translated into fewer expensive claims—exactly what self-funded employers need.

At the same time, access to care has become a pain point for employees everywhere. The U.S. faces a growing primary care shortage, and patients feel it. Recent survey work by AMN Healthcare and Merritt Hawkins found that the average wait time to schedule a new patient physician appointment in major U.S. cities now exceeds three weeks, with family medicine waits exceeding 20 days on average (AMN Healthcare physician wait time survey). These delays mean deferred care, worsening health, and frustrated workers. Employer clinics (or DPC memberships) directly tackle this issue by offering same-day or next-day care for employees and their families. In fact, employers who provide on-site or near-site clinics report significantly improved access; one mid-sized manufacturer that joined a regional clinic network now gives employees access to multiple health centers around its metro area, often with appointments available within a day rather than weeks (Franklin International clinic case study). That kind of convenience is a morale booster and a differentiator in workforce recruitment. As one benefits leader noted, it is “a good benefit to say you can get free primary care,” and the clinic becomes a powerful talking point in hiring discussions.

Finally, consider the competitive landscape. On-site and near-site clinics are no longer just a Fortune 500 perk—they are spreading into the mid-market. Reporting on employer clinics indicates that roughly one-fifth of employers with 200–999 employees and about one-third of larger firms now offer some form of on-site or near-site clinic services, reflecting adoption beyond the largest corporations (KFF Health News employer clinic adoption). This means your clients might already be hearing success stories from their peers or even losing talent to employers with better healthcare access. By raising the clinic option in Q1 2026, you position yourself as a forward-thinking advisor helping them stay competitive.

Bottom line: The Big Beautiful Bill Act has removed key barriers and added momentum for employer-sponsored clinics and DPC models. Pair those new “legal” reasons with the escalating cost and access challenges, and it is clear why Q1 2026 is the time to bring clinics into the conversation. Brokers who proactively discuss these solutions—backed by data and the latest regulatory insights—will stand out as strategic partners. You can help clients evaluate which model fits (on-site vs. near-site vs. DPC), quantify potential ROI, and map out an implementation path. The result could be a win-win: healthier employees, and happier HR teams that see you not just as a product vendor but as a problem-solver.

Download the Broker Toolkit here for a deeper dive into making clinic initiatives work for your clients in 2026, including compliance checklists and engagement strategies.

Sources

• Risk Strategies. “House Tax & Spending Bill: Noteworthy Employee Benefit Changes.” 2025.
• Sequoia Financial Advisors. “The “One Big Beautiful Bill” Is Now Law.” 2025.
• KFF. “Benchmark Survey: Annual Family Premiums for Employer Coverage Rise 7% to Nearly $24,000 in 2023.” 2023.
• KFF Health News. “Smaller Employers Weigh a Big-Company Fix for Scarce Primary Care: Their Own Clinics.” 2023.
• AMN Healthcare / Merritt Hawkins. “Physician Appointment Wait Times Getting Longer.” 2022.
• Marathon Health. “Franklin International Case Study.” 2023.