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Preparing for 2026: FSA, HSA and Trump Account Changes

Written by Jenny Barnes | Aug 6, 2025 6:44:30 PM

On July 4, 2025, President Trump signed the sweeping “One Big Beautiful Bill Act” (OBBBA) into law. The 875-page tax and spending package includes several provisions that affect employee benefit plans. While much attention has been dedicated to the bill’s tax cuts and healthcare provisions, a key change employers should have on their radar is the increase to the dependent care flexible spending account (FSA) limit, which goes into effect in 2026. 

This long-awaited update brings modest relief to working parents – and new responsibilities for HR and benefits teams planning for the next open enrollment cycle. 

The New Dependent Care FSA Limit: What’s Changing 

Beginning January 1, 2026, the annual contribution limit for dependent care FSAs will increase to $7,500 (or $3,750 for married couples filing separately). This is a significant jump from the current $5,000 cap that has been in place since 1986, aside from a brief increase during the COVID-19 pandemic. 

For working families, this change means more pre-tax dollars can be set aside to cover eligible dependent care expenses, such as daycare, preschool, summer day camps and after-school care for children under 13, as well as care for a disabled spouse or dependent adult. 

While higher limits are a win for working parents, they may exacerbate issues for plans that already struggle to pass the IRS’s non-discrimination rule that prevents dependent care FSA benefits from favoring highly compensated employees (HCEs). 

Other HR Benefit Changes to Watch 

While the dependent care FSA limit increase is one of the most immediately relevant issues for HR teams, the OBBBA includes several other benefits-related provisions that take effect in 2026: 

Telehealth and Health Savings Accounts (HSAs)

The bill permanently extends telehealth relief for high-deductible health plans, allowing employees to access telehealth services before meeting their deductibles without jeopardizing HSA eligibility. This change is retroactive to January 1, 2025, giving employers flexibility in how they manage reimbursements or charges this year. 

Direct Primary Care (DPC) Services

Starting in 2026, direct primary care costs will no longer disqualify employees from contributing to a health savings account. Monthly fees for direct primary care memberships will be considered HSA-qualified expenses, provided they don’t exceed $150 for individuals or $300 for families. 

Tax-Free Student Loan Repayment Assistance

Section 127 of the Internal Revenue Code temporarily allowed employers to contribute $5,250 per year in tax-free educational assistance, including student loan repayment. The OBBBA makes this provision permanent, and the $5,250 annual cap will be indexed for inflation beginning in 2026. 

Trump Accounts

With these new tax-advantaged savings “Trump Accounts” for U.S. children, employers may contribute up to $2,500 tax-free annually to employees’ children’s accounts. Children born between 2025 and 2028 will receive a one-time $1,000 federal credit. Money in the accounts grows tax-deferred, and children can access the funds when they turn 18. 

Employer Next Steps 

Although most OBBBA changes take effect in 2026, employers should prepare now by: 

1. Updating employee benefits guides to reflect: 

  • The new $7,500 dependent care FSA limit. 
  • HSA-qualified DPC services and applicable monthly caps. 
  • Telehealth relief under high-deductible health plans. 

2. Ensuring third-party administrators, payroll providers and benefit platforms: 

  • Update their systems for increased dependent care FSA limits. 
  • Adjust plan materials and reporting for any plan changes. 

3. Evaluating how the dependent care FSA increase might affect Section 129 non-discrimination testing outcomes, especially for employers with highly compensated workforces. 

  • If your plan had testing concerns at the current $5,000 level, those risks may persist – or even grow – if a higher percentage of HCEs take advantage of the new $7,500 limit. Consider discussing plan design options or additional testing strategies with Axcet HR Solutions or your legal advisor. 

4. Educating employees by hosting webinars or Q&A sessions so workers understand how these changes affect their benefit options – especially regarding telehealth, HSA eligibility, and dependent care FSA contributions. 

5. Monitoring guidance, because regulatory details, particularly around Trump Accounts and DPC parameters, may evolve. Employers should consult Axcet’s compliance advisors or legal counsel and stay tuned for further IRS or Treasury guidance. 

RELATED: Missouri Rolls Back Future Minimum Wage Hikes After $15 Target >>

Prepare for 2026 Benefits Changes with Confidence

The One Big Beautiful Bill Act introduces significant updates to employee benefits—changes that demand expert guidance and timely execution. As a certified PEO headquartered in Kansas City, Axcet HR Solutions helps small and mid-sized businesses nationwide stay ahead of HR compliance requirements, streamline open enrollment and deliver Fortune 500-level employee benefits without the burden of doing it all alone.

Get a head start on 2026. Contact Axcet for a free consultation >>