Although many states have specific rules on direct primary care practices, it is less common that there are state rules governing strictly concierge medicine practices, which are also referred to as retainer-based or boutique medical practices. A forthcoming blog post will discuss compliance risks to consider with concierge medicine practices. This post answers a few preliminary questions about concierge medicine.
What is Concierge Medicine?
Concierge medicine programs essentially offer specific benefits to patients who pay a fee to become a member in the concierge medicine program. In general, the benefit is as follows: Through the concierge fees, concierge medicine programs are able to limit the number of members accepted into the program and/or practice with attendant benefits that flow therefrom, such as prompt appointment scheduling, limited wait times, longer visits, more flexibility, and increased access to care delivered in a format convenient to members. In our forthcoming blog post, we will discuss the risks around a physician accepting a fee in exchange for benefits that are fully or partially covered by commercial and governmental payors, including Medicare, but this explanation is useful to understanding the concept. Importantly, the concierge fee is not health insurance, and no part of the fee goes towards member payments for medical services, medications, or treatments. Members, individually or through insurance, generally remain responsible for paying for all medical services, medications, diagnostic testing, treatments, specialist care, hospitalizations, or other services.
Is the Membership Fee Covered by Insurance?
In the vast majority of cases, insurance does not cover concierge membership fees. However, certain Health Savings Account (HSA) and Flexible Spending Account (FSA) plans may reimburse members for all or part of the concierge membership fee. Those interested in becoming a member in a concierge medicine program should check with their human resources representative or HSA or FSA plan manager to find out.
Do Patients Still Need Insurance?
Concierge medicine programs usually recommend that members retain their traditional health insurance to help pay for any medically necessary services, medications, or treatments. Concierge fees do not cover medical services, medications, or treatments, including services covered by insurance plans. Concierge medicine programs typically also bill to members’ health insurance plans, if applicable, for office visits. Members remain responsible for paying any deductible or co-payment, as dictated by their specific insurance plan, or, if members opt not to have health insurance, they remain responsible for the full cost of all medical services, medications, diagnostic testing, treatments, specialist care, hospitalizations, or other services.
Our firm works with many providers to create forms and other policies to lawfully create concierge medicine practices considering each practice’s unique needs. If you have questions regarding this blog post or wish to discuss the process of migrating to a direct primary care or concierge practice, you may contact us at (404) 685-1662 (Atlanta) or (706) 722-7886 (Augusta), or by email, info@littlehealthlaw.com. You may also learn more about our law firm by visiting www.littlehealthlaw.com.
*Disclaimer: Thoughts shared here do not constitute legal advice.