🏗️ Concept Overview: “Bare-Bones HSA-Compatible Plan”
Let’s call this prototype ClearHealth Basic.
Goal: A portable, fully HSA-eligible, minimal-overhead, direct-pay plan that pairs transparent pricing with a clear member out-of-pocket maximum and program-level stop-loss protection (including prescriptions via Cost Plus Drugs).
This is the key premise: ClearHealth is not supposed to be another employer-owned benefits product. It is coverage built around the member, with an HSA that the member owns and can keep across jobs, employers, and life changes.
🧭 The Four Pillars
| Pillar | Why it matters |
|---|---|
| Portable coverage | The plan is designed to follow the member, not the employer. A job change should not reset the healthcare relationship. |
| HSA-first funding | Eligible members can use pre-tax HSA dollars for routine care. Employers can contribute to the HSA without owning the whole coverage relationship. |
| Member OOP protection | Routine care stays transparent and cash-priced; the plan's out-of-pocket maximum protects members from unlimited covered expenses. |
| Program reinsurance | Stop-loss coverage protects the ClearHealth program from unusually large claims so the model stays financially viable. |
| Reference-based pricing | Providers bill the posted cash price or a published reference rate such as 120% of Medicare, whichever is lower. |
🧮 Step 1: Regulatory Foundation — HSA Compatibility
To qualify as HSA-eligible under IRS rules, your plan must be a High Deductible Health Plan (HDHP) that meets all of these:
| Rule | 2026 Requirement (IRS) |
|---|---|
| Minimum Deductible (Self-Only) | $1,700 |
| Minimum Deductible (Family) | $3,400 |
| Maximum Out-of-Pocket (Self-Only) | $8,500 |
| Maximum Out-of-Pocket (Family) | $17,000 |
| No first-dollar coverage | Except for preventive care (per IRS Notice 2004-23 & 2004-50) |
So your plan:
- Covers preventive care at 100% (annual physicals, vaccines, screenings).
- Everything else (primary care, urgent care, prescriptions, imaging, etc.) is cash-price until the deductible is met.
- Once deductible is met → 100% coverage or 80/20 coinsurance up to OOP max.
- Pairs with a member-owned HSA. Eligible members can contribute directly, and employers can contribute where allowed under IRS rules.
That HSA portability is central. If a member changes employers, starts a company, leaves a job, or decides COBRA is too expensive, the healthcare savings strategy does not have to start over.
💊 Step 2: Prescriptions — Cost Plus Integration
Cost Plus Drugs:
- Sells generic medications at cost + 15% + $3 pharmacy fee + $5 shipping.
- No PBM middlemen, no formularies.
Integration options:
- Direct link: Route all prescription fills to CostPlusDrugs.com — either paid directly by the member (pre-deductible) or reimbursed after deductible.
- API partnership: Pull real-time price data via Cost Plus’ APIs → show users exact out-of-pocket prices in your app.
- Optional concierge layer: let members prepay meds via the plan wallet (HSA-linked debit).
Result:
- No opaque PBM pricing.
- HSA-eligible because all spending pre-deductible is member-paid.
🏥 Step 3: Provider & Network Model
Go network-agnostic:
- Let members use any licensed provider.
- Reimburse at a reference rate (e.g., 120% of Medicare).
- Encourage use of direct primary care or telehealth with transparent cash pricing.
Example:
- Member sees Dr. Smith, who charges $120.
- Medicare rate = $100 → plan reimburses $120 once deductible met.
- Before deductible, member pays directly, ideally through HSA.
You can partner with vendors like:
- Sesame Care or MDsave for cash-priced care.
- Telehealth APIs (Wheel, Teladoc, SteadyMD, etc.) for virtual visits.
📱 Step 4: Member Experience Layer
A simple web + mobile portal:
- Tracks deductible + HSA balance.
- Shows who funded the HSA: member contribution, employer contribution, or both.
- Integrates with Cost Plus and DPC/telehealth APIs.
- Displays transparent procedure pricing.
- Offers digital receipts for HSA reimbursement.
Core tech stack:
- Micronaut backend with FHIR interface.
- PostgreSQL (claims + transactions).
- Cloudflare Workers / API Gateway for routing.
- React or Flutter for app.
💰 Step 5: Example Plan Structure
| Feature | Self-Only | Family |
|---|---|---|
| Deductible | $2,000 | $4,000 |
| Coinsurance (after deductible) | 0% (100% coverage) | 0% |
| OOP Max | $8,000 | $16,000 |
| Preventive care | Covered 100% | Covered 100% |
| Rx (via Cost Plus) | Member pays actual Cost Plus price | same |
| Telehealth visit | $40 flat (applied to deductible) | same |
| Any doctor | Yes, reimbursed 120% of Medicare | same |
| HSA compatible | ✅ | ✅ |
| Employer-tied | No | No |
🧩 Step 6: Launch Strategy
Start as a self-funded plan administrator or MGA (managing general agent):
- Partner with a stop-loss reinsurer for catastrophic claims.
- Build out the PAS + HSA integration.
- Offer to independent workers, families, small employers, freelancers, LLCs, and people facing COBRA or employer-plan disruption.
- Position as “Portable health insurance that plays nice with your HSA.”
✳️ Add-Ons (Optional)
- Direct Primary Care (DPC) membership subsidy.
- Wellness Rebate: HSA bonus contribution for preventive screening.
- Transparent Imaging Add-on: pre-negotiated MRI/CT centers at fixed prices.
