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The Evolution of Direct Care Medicine: Beyond Traditional Limitations

Direct Care Medicine Without the Compliance Risks or Corporate Control

Direct care medicine offers the practice experience many healthcare professionals dream of more time with patients, deeper relationships, and better care. However, traditional direct care models often create Medicare compliance concerns, funding limitations, and corporate dependencies that restrict your practice potential. Our approach delivers all the benefits of personalized patient care without the unnecessary risks and limitations.

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The Direct Care Compliance Challenge

Traditional direct care models face several critical challenges that create unnecessary risks and limitations for physicians
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Medicare Compliance Uncertainties

Many practices market non-compliant services in ways that create Medicare compliance risks, particularly around the prohibition on charging for services already covered by Medicare. This creates potential regulatory vulnerability, especially with OIG guidance specifically addressing direct care models.
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HSA/FSA Disqualification

Membership fees are often disqualified from HSA/FSA/HRA funding when structured as “access fees” rather than payment for specific medical services, limiting accessibility for many patients who have these tax-advantaged funds available.
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Corporate Platform Dependence

Many healthcare professionals join large platforms that take substantial percentages of revenue (25-40%) indefinitely, limiting long-term profitability and independence. These ongoing revenue-sharing arrangements significantly impact lifetime practice economics.
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Restrictive Model Requirements

Corporate platforms often dictate practice parameters, fee structures, marketing approaches, and operational details, limiting your ability to create a truly personalized practice that reflects your unique vision and clinical philosophy.

The Routine Exam Approach for Direct Care Practitioners

Our routine exam model delivers all the benefits of direct care medicine while eliminating unnecessary risks and limitations

Full Medicare Compliance

Structure your practice around routine exam services explicitly excluded from Medicare coverage since 1965, creating a solid compliance foundation without opt-out requirements. This approach leverages the same statutory exclusions that have protected executive health programs for decades.

HSA/FSA/HRA Qualification

By properly structuring your services as qualified medical expenses under IRC 213(d), your patients can use pre-tax dollars and employer-funded accounts to pay for your care. This significantly expands accessibility and can be a powerful marketing advantage over traditional concierge practices.

Complete Independence

Retain 100% ownership of your practice model and all future revenue without permanent revenue-sharing arrangements or corporate control. Our flat-fee consulting approach ensures you never pay ongoing percentages that limit your long-term success.

Custom Practice Design

Create a completely personalized practice model tailored to your clinical vision, patient population, and business goals without external constraints. Your practice should reflect your unique approach to medicine, not a corporate template.

Your Path to Direct Care Independence

Transitioning from a traditional model (or creating a new concierge practice) is straightforward with our guidance
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Assessment Phase
(Weeks 1-2)

  • Evaluate your current practice structure and compliance vulnerabilities
  • Analyze patient demographics and financial potential
  • Review any existing corporate agreements and constraints
  • Develop custom practice vision and service framework
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Structuring Phase
(Weeks 3-5)

  • Redefine service offerings as routine exams with proper documentation
  • Develop Medicare-compliant practice framework and agreements
  • Create HSA/FSA-qualified fee structure and documentation
  • Design practice operations and patient experience
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Implementation Phase
(Weeks 6-8)

  • Develop patient communication strategy for smooth transition
  • Create implementation timeline with minimal disruption
  • Prepare staff for new model and documentation requirements
  • Develop enrollment process for current and new patients
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Launch Phase
(Weeks 9-12)

  • Introduce new model to current patients with emphasis on enhanced benefits
  • Begin enrollment process with proper documentation
  • Implement new agreements and compliance framework
  • Monitor and optimize performance metrics
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Whether you’re currently in a corporate concierge model or launching a new practice, our approach provides the path to complete independence with full compliance confidence and optimal practice economics.

Direct Care Models Compared: A Comprehensive Analysis

Feature Traditional Model Corporate Platforms Routine Exam Model
Medicare Compliance Variable compliance risk Platform-dependent approach Full compliance through statutory exclusions
HSA/FSA Eligibility Generally disqualified Typically disqualified Fully eligible when properly structured
Revenue Retention 100% if independent 60-75% after platform fees 100% after one-time consulting fee
Practice Control Variable autonomy Limited by platform requirements Complete independence
Legal Foundation Limited regulatory clarity Platform-dependent approach Based on federal statutes (1965, 1996, 2006)
Fee Structure Often undervalued Platform-dictated Market-appropriate valuation
Setup Process Self-guided or platform-dictated Corporate template Customized implementation
Practice Growth Limited by platform Platform-controlled Unlimited potential
Documentation Variable compliance Platform templates Customized, fully compliant framework
Long-term ROI Limited by ongoing fees Significantly reduced by platform fees Maximized through 100% ownership

Common Questions from Direct Care Practitioners

Yes. We help physicians successfully transition from corporate platforms to independent practice models. This transition typically requires careful review of your current agreement for any non-compete or patient solicitation restrictions. We help navigate these challenges to create a smooth transition that maintains patient relationships while eliminating ongoing revenue sharing.

Our approach maintains the personalized, high-touch aspects of patient care that physicians and patients value, while restructuring the services as routine exams explicitly excluded from Medicare coverage. This creates a solid compliance foundation while qualifying for HSA/FSA funding advantages that other models typically lack.
Not necessarily. While our model often generates higher physician revenue, this comes primarily from increased practice efficiency, better service structure, and elimination of corporate fees—not necessarily from charging patients more. Many practices maintain similar patient fees while improving practice economics through our approach.
Our approach leverages specific statutory exclusions dating back to 1965 that explicitly exclude “routine physical checkups” from Medicare coverage. These exclusions, further clarified in 1996 and 2006, create a clear legal foundation for collecting cash payments for routine exam services, even from Medicare beneficiaries, without requiring opt-out.

Breaking Free from Corporate Platforms

For healthcare professionals currently affiliated with corporate platforms, transitioning to an independent practice model offers significant advantages
Financial Impact Analysis
Revenue Component With Corporate Platform With Routine Exam Model 10-Year Difference
Annual Revenue (300 patients) $750,000 $1,200,000 +$4,500,000
Platform Fees (30%) -$225,000 annually $0 +$2,250,000
Net Annual Revenue $525,000 $1,200,000 +$6,750,000
Consulting Fee $0 -$10,000 (one-time) -$10,000
10-Year Net Revenue $5,250,000 $11,990,000 +$6,740,000

Financial impact will vary based on patient panel size, fee structure, and practice expenses

Transition Process from Corporate Platforms

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Contract
Review

Comprehensive analysis of your current platform agreement, focusing on term, termination, non-compete, and patient communication restrictions

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Strategic
Planning

Development of transition strategy that respects contractual obligations while maximizing patient retention

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Patient
Retention

Communication frameworks that emphasize continuity of care during transition

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Compliance Assurance

Implementation of routine exam model with full Medicare compliance documentation

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Platform Independence

Complete separation from corporate control and ongoing revenue sharing

Create the Concierge Practice You've Always Envisioned

Direct care medicine represents an important step toward more personalized, relationship-based care. Now, the routine exam model offers the next evolution maintaining personalized care while eliminating corporate control, compliance risks, and funding limitations.

Discover how to transform your concierge vision into a fully compliant, financially optimized reality with complete independence and long-term stability.

Schedule Your Concierge-Focused Consultation
Obesity Nutrition
Schedule Your Concierge-Focused Consultation

From Corporate Concierge to Independent Success

Dr. Elizabeth Spencer, Former Corporate Platform Provider Atlanta, Georgia

Before

  • 350 patients at $2,000 annually ($700,000 gross revenue)
  • 30% of revenue to corporate platform ($210,000 annually)
  • Restrictive practice parameters and marketing restrictions
  • Limited ability to customize services based on patient needs
  • Compliance concerns with Medicare patients
  • No HSA/FSA eligibility for patients

After

  • 250 patients at $5,000 annually ($1,250,000 gross revenue)
  • 100% of revenue retained (no ongoing platform fees)
  • Complete practice customization and personalization
  • Fully Medicare-compliant structure with clear documentation
  • HSA/FSA qualification expanding patient accessibility
  • 78% higher net income with reduced patient panel
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“After five years with a corporate concierge platform, I was frustrated by the lack of control and the ongoing revenue sharing that limited my practice’s potential. Jim helped me create a fully independent practice built on the routine exam model. I now have complete freedom to practice my way, full compliance confidence, and significantly higher income—all while providing even better care to my patients. The HSA/FSA qualification has made my services accessible to a broader range of patients than before, including many who use employer-sponsored funds.”
During your consultation, we’ll discuss your specific practice goals, analyze potential improvements or transition strategies, and outline a customized implementation plan that preserves the concierge care model while eliminating unnecessary constraints and costs.

Contact Information:

Jim Eischen
Eischen DPSC LLC
2323 Locust Street
San Diego, CA 92106
619-919-5395
jim@eischenlawoffice.com

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  • Looking to create a DPC practice without Medicare opt-out requirements?
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