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Can your contracts handle regulatory scrutiny?
Direct Primary Care is revolutionizing healthcare; however, compliance guardrails can stunt growth opportunities. Without the right contractual structure, providers often find themselves trapped, sacrificing revenue to stay safe or limiting negotiation power to avoid regulatory scrutiny. You shouldn’t have to choose between growth and compliance.
Your Mission is Our Passion
Direct Primary Care is solving the issue of affordability and access traditional healthcare has created.
State and federal compliance regulations puts this mission at risk. The DPC model needs to navigate these regulatory pitfalls to succeed.
Patient Options is dedicated to creating a “Safe Harbor” environment for DPC to thrive and grow.
Audit Your Risk, Before THEY Do!!
Our experts can help you find the chinks in the armor that are exposing you to unnecessary risks. The audit includes the following:
✔ Comprehensive review of the contract
✔ Expose the vulnerabilities
✔ Outline solutions that allow you to grow compliantly
Is Your Growth Stunted by Compliance Guardrails?
Regulation stifles innovation. Your DPC success depends on your ability to navigate regulations seamlessly!
Florida Statute Example
Statutes that are Stalling DPC Growth in Florida
Patient Brokering Act
“It is unlawful for any person… to offer or pay a commission, benefit, bonus, rebate, kickback, or bribe, directly or indirectly, in cash or in kind, or engage in any split-fee arrangement, in any form whatsoever, to induce the referral of a patient…” (FL. Stat. § 817.505(1))
- This restricts a provider from negotiating a volume discount on the membership fee with a large employer.
- Any “free” services bundled under the membership outside the provider’s time could be seen as an illegal inducement
- The statutory penalties scale based on the number of affected patients
- Tier 1 (1-9 patients)
- 3rd degree felony: up to 5 years in prison
- Mandatory $50,000 fine
- Tier 2 (10-19 patients)
- 3rd degree felony: up to 5 years in prison
- Mandatory $100,000 fine
- Tier 3 (20+ patients)
- 1st degree felony: up to 30 years in prison
- Mandatory $500,000 fine
- Tier 1 (1-9 patients)
Patient Self-Referral Act
“A health care provider may not refer a patient for the provision of designated health services or any other health care items or services to an entity in which the health care provider is an investor or has an investment interest… unless an exception applies.” (FL. Stat. § 456.053)
There are a handful of scenerios a DPC clinic need to be awar of:
The “One-Stop Shop” Model: For example, the way “free in-house labs” are offered as part of the membership could be a violation. Because you own the lab equipment, the state views the membership fee as an “investment interest” that induces the referral.
Outside Referrals: If you accept a patient from a different DPC for an ultrasound, you are limited to only 15% of your total imaging volume coming from “outside referrals.” If you exceed 15%, you lose your status and every internal referral becomes illegal.
Penalties:
Civil Money Penalties: Up to $15,000 per individual service (e.g., if you performed 50 labs under a non-compliant group structure, the fine could be $750,000).
Circumvention Schemes: If the state finds you created a “membership model” specifically to hide self-referrals, the fine is $100,000 per scheme.
License Revocation: A violation of this act is considered professional misconduct, which triggers a mandatory report to regulatory boards and agencies and potential loss of your license, fines, and penalties.
Your Freedom Through Our Framework
The true threat to your Direct Primary Care model is that it is being squeezed into a regulatory framework built for insurance-based medicine. State and federal regulators often view a “flat-fee” membership through the same lens as a high-risk insurance product.
You shouldn’t need a law degree to grow your practice. Patient Options provides the Safe Harbor Architecture that turns your ‘Risk‘ into ‘Protected Network Activity‘ automatically.
The Contracting Infrastructure for the Future
Patient Options is leading the course for compliant DPC scalability. Our services protect without the inherent risks. Whether you are managing a pure DPC model, transitioning through a hybrid insurance-based practice, or looking to offer competitive add-on service, your growth shouldn’t be limited by rigid fee schedules.
Preferred Provider Organization for Cash-Pay Healthcare
Contracted Partners with Patient Options are safe from accusations by authorities of arbitrarily offering discounts. These Partners are legally offering contractual discounts within our network, through the activation of our Safe Harbor Designation.
Get FREE DPC Contract Legal Risk Review
Do you think your DPC contract is immune to legal scrutiny?
Don’t wait for a Board complaint to find the ‘chinks in your armor.’ Claim your technical risk assessment below.
Educational & Informational Purpose Only Disclaimer: This presentation and all associated materials are provided for educational and informational purposes only. The information discussed—including interpretations of Florida-specific statutes (such as the PBA and Self-Referral Act) and federal frameworks—does not constitute legal, financial, or medical advice.