WASHINGTON – The Internal Revenue Service today released proposed regulations addressing the treatment of certain medical care arrangements under section 213 of the Internal Revenue Code.
Section 213 of the Code allows individuals to take an itemized deduction for expenses for medical care, including insurance for medical care, to the extent the expenses exceed 7.5% of adjusted gross income. 
The proposed regulations address direct primary care (DPC) arrangements and health care sharing ministry (HCSM) memberships, and provide the following guidance:

  • Payments for DPC arrangements are expenses for medical care under section 213 of the Code. Because these payments are for medical care, a health reimbursement arrangement (HRA) provided by an employer generally may reimburse an employee for DPC arrangement payments.
  • Payments for membership in a HCSM are expenses for medical care under section 213 of the Code. Because these payments are for medical care, an HRA provided by an employer generally may reimburse an employee for HCSM membership payments.

The proposed regulations respond to Executive Order 13877, which directs the Secretary of the Treasury, to the extent consistent with law, to “propose regulations to treat expenses related to certain types of arrangements, potentially including direct primary care arrangements and healthcare sharing ministries, as eligible medical expenses under Section 213(d)” of the Code.



It appears that the unfavorable legislation we have all been actively opposing has been slipped into the new Senate relief bill for Coronavirus

Please see page 171, Section 4403.  

Any help opposing this addition would be greatly appreciated.  It would be wiser to add Senator Cruz's bill which would expand tax relief for HSA to ALL people, not just those with HDHPs.

DPC Action and all of the independent DPC physicians and their patients across the country appreciate any time and consideration you may be able to provide us.

Feel free to reach out to me or anyone on the board of DPC Action if you would like to have a call about this.

This bill will move fast so i am afraid we don't have much time.

With much appreciation-

Kimberly Legg Corba, D.O.

Green Hills Direct Family Care, Inc.



AID's response - March 20, 2020

On behalf of AID, our position is that while we support the relief efforts Congress is trying to enact with regard to the coronavirus, we resent lawmakers’ attempts to inject their unrelated agendas into a last-minute emergency bills in the hopes they’ll get passed unnoticed. My members in particular take issue with Sec. 4403, beginning on page 171. The proposed bill should not limit the scope (by definition) of who provides primary care, or cap the compensation requirement, or otherwise impede the free-market engagement of patients and their chosen physician providers.

AID concurs with AAPS that Sec. 4403 should be removed from the 3rd coronavirus bill.  “It overregulates innovative direct care arrangements that are increasing patient access to low cost, high quality medical care. Congress needs to allow patients to use Health Savings Accounts for direct care arrangements without unnecessary limits on patients' options.” 

Suggested replacement language, if there is to be any, would be either of these bills:

Original HR 365 bill would be a good replacement: 

Or Sen. Cruz’s bill:


Welcome to AID Direct, gathering place for members who have direct-care or concierge practices, or who offer a cash-pay model, or would like to. Here you can find resources, industry updates, and a network of other members opting out of third-party payer arrangements to deliver health care their way. Created in response to member demand, AID Direct is a free member benefit that fills a gap in the market, and that is open to all specialties. If you are interested in joining this subgroup of AID, please contact us, and we will add you to the online directory, which lists direct-care doctors by state.  Meanwhile, please subscribe to the forum below and join the discussion below, where members can ask and answer questions. 

View the directory of AID Direct doctors here.

This video is one doctor's testimony to the power of direct care.


Through our online forum, members can get advice and information from other members and access non-physician professionals who may assist with starting, converting, or maintaining a direct-care medical practice. Please join the conversation.  



Concierge Medicine Has Boomed During Covid. Here's How to Tell if It's Right for You -Nice to see COVID-19 having positive impact on Concierge Medicine featuring our own, Dr. Thomas LaGrelius.

Jessica Hall - January 16, 2021

Bye-bye health insurance:  How direct primary care can save you money  Bravo!! Doctors (and patients) you can do this!  We're helping our members who want to talk about it and explore the option through our AID Direct forum.

Allison Gormly - March 2, 2020

Interoperability Rules, Price Transparency, Policy Updates 

                                              Michael Tetreault - Februbary 27, 2020

The Business of Better Health Care -  hotel magnate’s efforts to create a quality and cost-saving health system offer lessons for other employers.

Harris Rosen - February 14, 2020

5 things to know about direct primary care

 Seka Palikuca - March 13, 2019

How my life changed: transitioning to direct primary care

Robert Lamberts, MD - August 1, 2018

 How my life changed: transitioning to direct primary care

Robert Lamberts, MD - August 1, 2018

January 14, 2020 - Legislative Update

Currently, bills in both the House and Senate address the tax treatment of Direct Primary Care as it relates to a patient’s ability to pay fees using his or her HSA account, while continuing to fund that HSA account.  Both issues relate to the tax code--IRC 213(d) and IRC 223(c), respectively. The proposed and upcoming rule from the White House’s June 24, 2019, Executive Order on Improving Price and Quality Transparency will fix the 213(d) tax issue, but the 223 (c) tax code requires legislative action. 

As of Jan. 14, 2020, 19 HSA reform-related bills were in Congress. Four are Senate bills; two address the DPC/HSA issue. Fifteen are House bills; five address the HSA/DPC issue. One Senate bill (S.2999) and one House bill (HR3708) are unfavorable to independent, private practice DPC/Direct Care physicians and offices. 

Any legislation clarifying that DPC arrangements are not health insurance under IRC 223 (c) creates an important distinction and will continue to advance the growth of direct care. Neither S2999 nor HR 3708 do that. Our position is that if patients can use HSAs/FSAs/HRAs/MSAs to pay for Direct Care, it will help them get affordable health care that would otherwise cost them far more out-of-pocket costs, especially if they have High Deductible Health Plans.

Dr. Kimberly Corba


July 31, 2019

HR  3708 entitled "To amend the Internal Revenue Code of 1986 to allow individuals with direct primary care service arrangements to remain eligible individuals for purposes of health savings accounts, and for other purposes" is a poorly crafted bill that will impact the market-based strides that Direct Primary Care has worked so hard to establish. This example of needless government control over something that is working is indicative of why we are where we are today in healthcare.

Our coalition stands behind Direct Primary Care as well as other models that provide affordability and accessibility to the American people. We will be signing on to a letter that expresses our displeasure with the bill. I have provided the link to HR 3708 below for all to read. Please feel free to reach out if you have any questions.  

Be encouraged, 

David Balat,

Texas Public Policy Foundation

American College of Private Physicians  
National organization serving active direct practices of all designs

Christian Healthcare Ministries

A faith-based healthcare cost solution for Christians in all 50 states and around the world

Concierge Medicine Today
National trade publication and educational network for the Concierge Medicine and Membership Medicine Marketplace

Healthcare policy think tank created to advance healthcare freedom and empower patients

DPC Action

Dedicated to promoting and advocating for improved access to affordable health care through independent Direct Primary Care practices

Direct Primary Care (DPC) Alliance
ational direct primary care membership organization

Direct Primary Care (DPC) Frontier
edicated to defending direct primary care, expanding the direct primary care movement, lowering barriers to entry into DPC for fellow physicians

Free Market Medical Association
ational association promoting transparency and free market in healthcare

Liberty HealthShare

Offering health-conscious individuals and families an affordable way to share medical care expenses in a like-minded community.  Liberty HealthShare is not insurance. 


The Sedera Health medical cost sharing model boldly challenges the insurance status quo. Through an innovative layering of healthcare services, we enable individuals and families access to high quality healthcare that is affordable, flexible and effective. You share medical funds with like-minded people and receive premium care, through an organization run with compassion.

 not insurance.

Specialdocs Consultants
Concierge consulting firm

Surgery Center of Oklahoma
Multi-specialty, physician owned and operated surgery center providing transparent, direct, package pricing


Pre-adjudication difficulties, courtesy of Patient Rights Advocate

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