On-Site Clinic Tax Rule Changes Starting 2026: What It Means for Your Health Coverage Status

The newly proposed Employee Access to Worksite Health Services Act is a technical bill that deals with one specific question: When your employer offers a health clinic right where you work, does using that clinic count as having health insurance? Starting in tax years after 2025, the answer, according to this bill, is generally no—at least for certain tax purposes.

The Tax Loophole Fix

This bill’s main move is decoupling on-site health services from standard group health coverage rules in the tax code (Sec. 2). Why does this matter? For years, offering certain benefits could accidentally disqualify employees from accessing tax credits or other benefits tied to not having comprehensive coverage. This Act clarifies that if you are eligible for, or use, a qualified on-site clinic, that access won't automatically disqualify you from other tax benefits. Essentially, it gives employers the green light to offer basic, convenient care without tripping up their employees’ tax filings.

What Services Are Covered (and What’s Not)

Before you ditch your primary care doctor, understand the limits. The bill specifies a narrow list of “qualified items and services” that get this special tax treatment. We’re talking about basic stuff: physical exams, immunizations, care for workplace injuries, hearing and vision screenings, and drug testing (Sec. 2). Crucially, the bill explicitly excludes most prescription drugs that fall under the standard tax code definition. It also includes preventive care for chronic conditions, but that definition leans on an existing, somewhat complex IRS Notice (2019-45), which can be updated by the Secretary. This reliance on external guidance means the exact scope of chronic care covered could shift over time.

The Real-World Impact on Your Coverage

For employers, this is a clear win. It provides certainty and flexibility to offer convenient, low-cost services without the administrative headache of linking them to a full group health plan. Imagine a large warehouse or factory where employees can get a flu shot or minor injury care right on site—that’s the benefit.

However, for employees, this change needs a closer look. While the intent is good, the provision that on-site clinic access won’t count as standard coverage for tax purposes creates a potential double-edged sword. If an employer decides to rely heavily on this provision and offers a less comprehensive (and cheaper) main health plan—or perhaps none at all, assuming employees can use the clinic for basics—employees could be left in a tricky spot. They might lose access to certain tax credits or subsidies designed for people without insurance, even though they technically have access to some care at work. The bill essentially creates a new, separate class of basic health access, and we need to ensure this doesn't become a loophole for employers to water down their comprehensive health offerings.

Finally, the bill clarifies that if a company has several related businesses (as defined under specific tax code sections), they must treat all those entities as one single employer when determining if their clinic qualifies as “on-site” (Sec. 2). This prevents large, linked corporations from trying to game the system by splitting up their operations to meet the eligibility requirements. The whole thing goes into effect for tax years starting after December 31, 2025.