of note

DPC, CONSIDERED TO BE A DISTANT RELATIVE YET NOT TO BE CONFUSED WITH ‘BESPOKE’ nOR MORE ‘CONTEMPORARY’ VERSIONS OF CONCIERGE CARE NOR CONSIDERED CONCIERGE-STYLE ‘Personal CARE MODELS’ IN THE MARKETPLACE TODAY

Like a Fourth Generation Iteration (A distant cousin if you will): Not to be confused with bespoke-luxury concierge medicine practice models, nor present-day versions of membership-driven contemporary personal care models (PCMs) nor a contemporary iteration of concierge subscription healthcare practices, DPC is a modern-day, cash-only, no insurance, no Medicare, self-pay, reboot (or budget-friendly) subscription spin on the original 90’s luxury or bespoke concierge medicine subscription model that catered primarily to the affluent clientele years ago.

“In contrast, DPC arose as a response to insurance limitations for lower-income populations, focusing on lobbying for legal changes instead of adapting to existing regulations, often leading to violations. Steer clear of marketing and branding, that, while quite prevalent in the marketplace, is frustrating your patient fees achieving qualified medical expense status. For example, you may dearly love the DPC or concierge [as terms or] brands, but, the IRS is convinced that neither brand’s patient fees are qualified medical expenses. Why debate the IRS? Neither brand is likely to fully explain YOUR medical or healthcare philosophy, and neither brand assists with qualified medical expense status so both brands frustrate HSA/FSA/HRA/MSA funding absent changes in tax laws and IRS regulations.” (Eischen; 2025)

• Update by Concierge Medicine Today (Jan 1, 2026) — “In light of the new 2025 ‘One Big Beautiful Bill’ Act (effective January 2026), federal law now explicitly allows health savings account (HSA) funds to be used for qualifying direct-primary-care (DPC)/concierge membership fees (Source: dlapiper.com) – but only under specific conditions. Under this law, a fixed-fee DPC arrangement covering only core primary-care services can qualify as a medical expense, provided the monthly membership fee stays under the IRS cap (roughly $150 per individual or $300 per family) (Source: irs.gov). Even so, the core warning remains: simply labeling a practice “concierge” or “DPC” still does not by itself guarantee HSA/FSA/HRA eligibility. Physicians should therefore seek guidance and advice from qualified and competent advisors, communicate carefully and transparently – clearly identifying which membership plans qualify under the new rules and which do not – so patients understand the limits on tax-advantaged payments (Source: dlapiper.comirs.gov).”

Typically (but not always which is why industry jargon can be confusing) DPC docs often urge their curious colleagues to ditch Medicare and kick insurance headaches to the curb and offer a more affordable fee. They champion a cash-only subscription model for primary care or family health services and those fees can range (typically, but not always) $50 to $150 per month per patient. This may (but not always) cover services like check-ups and preventive care (Baus, C. (2022). Baird, A. (2021); Peterson, J. (2021); Tew, J. (2020))

As of recent estimates (2025), there are about 1,200 to 1,500 Direct Primary Care (DPC) practices in the U.S., accounting for some closures. DPC is expected to grow at a rate of 10-20% annually, driven by increasing demand for personalized healthcare, excluding concierge medicine programs. ("The Future of Direct Primary Care" by the American Academy of Family Physicians; "Direct Primary Care" by the American College of Physicians; Articles in *Health Affairs* regarding DPC trends.)

Related to HSAs in 2026: "The expansion of HSAs—and the permanent inclusion of Direct Primary Care as an eligible expense—represents meaningful progress FOR patients seeking more flexibility in how they access and pay for care,” says Concierge Medicine Today’s Editor-in-Chief. “It is a positive step, particularly for those who value continuity, access, and a stronger relationship with their physician. At the same time, this moment invites thoughtful reflection within the broader primary care community. For decades, physicians have been trained to view primary care as the center of a patient’s healthcare journey—and for good reason. Strong primary care improves outcomes, enhances coordination, and builds trust over time. That shared foundation is something nearly all models of care agree on. Where Direct Primary Care can continue to mature is not in conviction, but in communication. Patients arrive with different needs, financial realities, and comfort levels. Some will benefit from a membership-based relationship; others may engage primary care through different structures. When DPC is presented as one effective option—rather than the only answer—it becomes easier for patients, employers, and policymakers to understand its role without feeling pressure to adopt a particular model. HSAs may help certain patients participate in DPC, but they are not a universal solution—and they need not be. The larger opportunity remains education: helping patients understand that primary care is fundamentally about relationship, time, and trust, regardless of how it is funded. The mechanism matters less than the experience it enables. The path forward is not louder messaging, but clearer explanation. When physicians lead with calm confidence and respect for patient choice, the value of relationship-based care tends to speak for itself—no megaphone required. (And thankfully, no 40-slide presentation either.)”