Our attorneys have seen a significant uptick in the number of providers breaking away from large health systems to establish their own concierge medicine practices. Providers and patients alike are increasingly frustrated with the constraints of large health systems and the complexities associated with health insurance. These challenges, among others, have prompted many providers to explore concierge medicine as an alternative practice model.
The term “concierge medicine” encompasses a variety of practice structures. In our attorneys’ experience, one of the most common models involves maintaining a limited patient panel whose members pay a monthly or annual fee in exchange for defined services and enhanced access to care. This model—and other concierge structures—raises important compliance considerations involving commercial insurance, Medicare assignment, and the distinction between covered and non-covered services.
The interplay between membership fees and a patient’s insurance benefits can be complex, making it critical for providers to structure these arrangements properly from the outset. In a worst-case scenario, a violation of Medicare assignment rules can create significant legal and financial challenges for a physician seeking to establish or operate a concierge practice. Our attorneys are well versed in the regulatory framework governing concierge medicine and represent providers who are both launching and operating these practices.
If you are considering starting a concierge practice or have compliance-related questions regarding an existing practice, contact our attorneys to discuss your options and develop a strategy tailored to your goals.
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