Pennsylvania

Does the state have a law defining DPC as outside insurance regulation?

No statute. A bill is pending.

House Bill 2096 of the 2025-2026 Regular Session, sponsored by Representative Seth Grove, would provide for direct primary care and medical service agreements. It was referred to the House Insurance Committee on December 9, 2025. An earlier version, House Bill 886 of 2023-2024, was referred to the same committee on April 10, 2023 and did not advance.

Checked September 17, 2026

Any bulletin or ruling on memberships where no statute exists

None found.

We found no Insurance Department notice or bulletin on whether a membership agreement is insurance. Until a statute passes, the general test for the business of insurance applies to your agreement as written.

Checked September 17, 2026

Whether the state follows the federal HSA rules for DPC

Follows the federal rules for health savings account contributions.

The Department of Revenue's Personal Income Tax Guide says "Pennsylvania follows federal rules for contributions to Medical Savings Accounts and Health Savings Accounts" and that the deduction "cannot exceed the federal limits." That chapter was last revised in September 2018, before the federal health savings account changes for direct primary care that apply from 2026, so confirm the treatment of fees with a tax professional.

Checked September 17, 2026