Category Archive
Filter Direct primary care updates.
Filter updates by state, jurisdiction, clinic type, service line, command zone, and impact level.
EnactedHigh Impact
Iowa HF 2434 affects referrals from out-of-network primary care providers
Iowa HF 2434 addresses insurance coverage for health care services provided pursuant to a referral by an out-of-network primary care provider and references direct primary care agreements.
Operator impact: Iowa DPC clinics should review referral language, patient education, coverage expectations, payer interactions, documentation, and how DPC referrals are explained to members with insurance coverage.
Effective Jul 1, 2026
Deadline Jul 1, 2026
ProposedHigh Impact
South Carolina bill would clarify DPC agreements are not insurance
South Carolina H3966 would establish that direct primary care agreements are not insurance contracts and are not regulated as insurance.
Operator impact: South Carolina DPC and cash primary care operators should monitor the bill and prepare contract language, membership disclosures, cancellation terms, refund policies, and employer-facing materials.
ProposedHigh Impact
Wisconsin SB 4 would exempt valid DPC agreements from insurance law
Wisconsin SB 4 would exempt valid direct primary care agreements from the application of insurance law.
Operator impact: Wisconsin DPC operators should monitor whether the bill advances and prepare agreement language, service definitions, membership disclosures, non-insurance notices, cancellation terms, and pricing clarity.
ProposedHigh Impact
Pennsylvania HB 2096 would establish a DPC agreement framework
Pennsylvania HB 2096 would create a statutory framework for direct primary care medical service agreements, insurance treatment, and use of HSA or FSA funds.
Operator impact: Pennsylvania DPC and concierge operators should monitor the bill and prepare membership agreement language, non-insurance disclosures, refund/cancellation terms, scope-of-services definitions, and HSA/FSA FAQs.
EffectiveHigh Impact
IRS guidance expands HSA compatibility for certain DPC arrangements
IRS guidance states that beginning January 1, 2026, eligible individuals enrolled in certain direct primary care arrangements may contribute to HSAs and use HSA funds tax-free for periodic DPC fees.
Operator impact: DPC and cash primary care clinics should update pricing pages, employer-facing materials, FAQs, and onboarding workflows to explain HSA-compatible arrangements without overpromising eligibility.
