Maximizing Revenue in Direct Primary Care: Strategic Billing and Pricing Optimization for 2025
By: Drew Duffy, MHA, FACHE, Founder & Managing Director, CleaarPath Compliance
The direct primary care (DPC) model continues to evolve rapidly, with significant regulatory changes on the horizon and growing market demand across the Midwest. For practices serving patients in Minnesota, Wisconsin, and Iowa, understanding the nuances of billing optimization and revenue strategy has never been more critical—especially with the upcoming 2026 HSA compatibility changes that will reshape the landscape.
The Current DPC Revenue Landscape
Direct primary care operates on a fundamentally different financial model than traditional fee-for-service medicine. Instead of the complex web of insurance billing and reimbursements, DPC practices rely on predictable monthly membership fees that typically range from $55 to $150 for individual patients. Recent industry data shows that the median individual membership price has stabilized at around $80 per month as of 2022, reflecting gradual inflation adjustments from the $75 median observed in 2018.
This subscription-based approach offers several advantages for revenue optimization:
Predictable monthly income allows for better cash flow management and strategic planning.
Elimination of insurance billing reduces administrative overhead significantly, with practices reporting dramatic reductions in billing-related staff costs and claim processing delays.
Minnesota's Regulatory Landscape: Opportunities and Challenges
Minnesota presents a unique regulatory environment for DPC practices. Currently, Minnesota has no specific DPC legislation, which creates both opportunities and challenges for revenue optimization. Without explicit regulatory frameworks defining DPC as distinct from insurance, practices must navigate existing Minnesota Insurance Statutes carefully when structuring their billing models.
This regulatory ambiguity requires Minnesota DPC practices to be particularly strategic about their billing approaches. Practices should consider billing in arrears to protect against potential regulatory challenges, as recommended by industry experts who note that "the laws governing DPC practices in many states remain unclear."
Interestingly, Minnesota has previously explored innovative DPC models, including proposals for DPC Medicaid pilots with membership fees capped at "a weighted average of seventy dollars per month across all eligibility categories." While these initiatives haven't yet been implemented, they signal potential future opportunities for practices to expand their patient base through government partnerships.
Strategic Membership Fee Optimization
The most critical decision affecting DPC revenue is membership fee structure. Current market data reveals several key pricing strategies:
Tiered Membership Models: Many successful practices offer age-based pricing tiers. Adult memberships typically range from $75-$150 monthly, pediatric memberships often cost $25-$50, and family packages can reach $200-$300 monthly. This approach maximizes revenue per household while remaining competitive.
Value-Based Pricing: The most successful DPC practices align their pricing with the comprehensive value they provide. This includes unlimited office visits, direct physician communication, extended appointment times, basic lab work, and preventive care services. Practices should calculate the cost-equivalent of these services in traditional healthcare settings to justify their membership fees.
Geographic Considerations: For practices in Minnesota, Wisconsin, and Iowa, demographic and economic factors influence optimal pricing. Rural areas may require lower entry-point pricing, while suburban markets can often support premium pricing for enhanced services.
In addition, investing in patient retention tactics—such as personalized communication, flexible scheduling, and member engagement programs—can reduce churn and increase lifetime value per member, further strengthening revenue stability.
The 2026 HSA Game-Changer
Perhaps the most significant development for DPC revenue optimization is the upcoming HSA compatibility legislation taking effect in 2026. This bipartisan Primary Care Enhancement Act will allow patients with HSA-qualified high-deductible health plans to contribute to HSAs while maintaining DPC memberships, provided the monthly DPC fee doesn't exceed $150 for individuals or $300 for families.
This change presents enormous revenue opportunities. With 61 million Americans currently using HSA-qualified plans, the potential patient pool for DPC practices will expand dramatically. Practices should begin preparing now by:
Ensuring membership fees fall within HSA-compatible limits
Developing marketing strategies targeting HSA users
Training staff on HSA regulations and patient education
Preparing documentation systems for HSA-eligible services
Revenue Diversification Strategies
Beyond membership fees, successful DPC practices optimize revenue through complementary services:
Laboratory Services: Negotiating direct pricing with lab vendors allows practices to offer discounted testing to members while generating additional revenue. Many practices mark up lab costs modestly while still providing significant savings compared to traditional healthcare pricing.
Procedure Add-ons: Minor procedures, injections, and specialized services can generate additional revenue while providing convenience to patients. Practices should develop transparent pricing for these services that reflects their value proposition.
Corporate and Employer Partnerships: Establishing relationships with local employers can provide steady revenue streams through group memberships. Employers increasingly recognize DPC as a cost-effective employee benefit, particularly in markets like Minnesota where healthcare costs are a significant concern.
Telemedicine Integration: Incorporating telemedicine capabilities enhances member value while allowing practices to serve larger patient panels efficiently. This is particularly valuable for serving rural patients across Minnesota, Wisconsin, and Iowa.
Administrative Optimization for Maximum Efficiency
Revenue optimization in DPC isn't just about increasing fees—it's equally about reducing overhead and maximizing efficiency. Automated billing and invoicing systems reduce administrative burden while improving revenue cycle management. Modern DPC-specific practice management software can streamline membership management, automate renewals, and provide detailed financial analytics.
Examples of tools that support these goals include:
Practice management platforms designed specifically for DPC workflows
Automated membership billing and renewal systems
Financial dashboards tracking key performance indicators (KPIs)
Practices should monitor metrics such as:
Monthly recurring revenue (MRR) growth
Patient acquisition cost
Lifetime value per member
Churn rates and retention analytics
Average revenue per user (ARPU)
Marketing Investment for Sustainable Growth
Successful revenue optimization requires consistent patient acquisition. Digital marketing strategies specifically tailored to DPC practices have shown strong returns on investment. Search engine optimization, social media marketing, and content marketing help educate potential patients about DPC benefits while establishing practice credibility through patient testimonials and online reviews.
For practices in the Midwest market, local community engagement and physician referral relationships remain crucial for sustainable growth. Many successful practices report that word-of-mouth referrals from satisfied patients generate the highest-quality new members.
Looking Ahead: Positioning for Growth
As the DPC model continues to mature, practices that optimize their revenue strategies today will be best positioned for future growth. The combination of HSA compatibility, growing consumer awareness of DPC benefits, and increasing dissatisfaction with traditional insurance-based care creates unprecedented opportunities.
For Minnesota, Wisconsin, and Iowa practices, the key to successful revenue optimization lies in balancing competitive pricing with comprehensive value delivery, maintaining regulatory compliance in evolving legal environments, and building sustainable systems that can scale with growth.
The practices that thrive in this environment will be those that view billing and revenue optimization not as one-time decisions, but as ongoing strategic processes that adapt to changing market conditions while consistently delivering exceptional patient value.
By implementing these strategies while staying attuned to regulatory developments and market trends, DPC practices can build financially sustainable models that serve both their business objectives and their commitment to providing accessible, high-quality primary care.
How ClearPath Compliance Can Help Your DPC Practice Thrive
Navigating the evolving DPC revenue landscape and complex regulatory environment can be challenging. That’s where ClearPath Compliance steps in as your trusted partner. We specialize in helping Midwest direct primary care practices optimize billing and pricing strategies, ensuring compliance with current and upcoming regulations—including the critical 2026 HSA changes. Our tailored consulting services, practice management guidance, and compliance toolkits empower your clinic to streamline operations, maximize revenue, and deliver exceptional patient value. With ClearPath Compliance, you gain more than just expert advice—you gain a committed ally focused on helping your practice grow sustainably and confidently in today’s competitive healthcare market. Reach out to us today to learn how we can support your direct primary care journey. Reach us at info@clearpathcompliance.org or give us a call at 1-888—996-8376.
About the Author
Drew Duffy, MD, MHA, CPCO, CRCMP, CHCO, CIPP/M, FACHE, is Founder & Managing Director of ClearPath Compliance. With over 20 years in healthcare operations and compliance, Drew draws on his clinical background and extensive expertise, supported by a network of experienced healthcare leaders—to deliver practical, ethical solutions for providers navigating today’s complex regulatory landscape.
Why the New HSA Rule Matters — and What It Means for Your Practice
By: Drew Duffy, MHA, FACHE, Founder & Managing Director, ClearPath Compliance
On July 31, 2025, a new federal tax and spending bill was enacted that permits patients with high-deductible health plans (HDHPs) to use Health Savings Accounts (HSAs) to pay for Direct Primary Care (DPC) and concierge membership fees. This is a pivotal policy change: until now, IRS interpretations effectively prohibited using HSA funds for retainer-based care models.
Key implications for your clinic:
Lower financial barrier for patients: Membership fees can now be funded pre‑tax, making your practice more affordable and attractive to cost-conscious patients and employers.
Greater employer adoption expected: Employers can now subsidize memberships as part of their benefit packages, leveraging HSA compatibility to reduce taxable income.
Strategic growth window: Clinics offering membership-based care models are likely to see increased demand, as patients seek more personalized, accessible care—without giving up HSA benefits.
⚖️ State-Level Regulation: The Minnesota Example
While the federal HSA shift is promising, membership medicine remains governed at the state level, and not all states treat Direct Primary Care the same. Understanding your state’s stance is essential for legal compliance.
📍 In Minnesota:
Minnesota does not yet have a specific law that formally exempts DPC practices from insurance regulation. However, the state has historically taken a cautious but permissive stance when DPC contracts are:
Clearly labeled as non-insurance agreements
Paid for in flat monthly or annual fees
Not tied to third-party insurance billing
Minnesota law defines insurance broadly, and if a membership clinic includes services that are traditionally billed per unit or appear risk-bearing (e.g., unlimited services for a flat rate), the state could classify it as engaging in insurance activity—especially if the clinic markets to employer groups.
Key Risks for Minnesota Practices:
Marketing language matters: Avoid phrases like “unlimited care” or “covered benefits.” Instead, describe services as “access to care” or “ongoing primary care engagement.”
No current safe harbor statute: Unlike states like Washington or Idaho, Minnesota does not have a codified legal “safe zone” for DPC. This means that legal compliance hinges on the interpretation of existing insurance laws.
Employer arrangements require caution: Offering DPC memberships to employee groups without formal review could trigger scrutiny under the state’s insurance licensing rules.
Action Steps for Minnesota Clinics:
Work with legal counsel to review your membership agreement annually.
Ensure services provided match the contract exactly—no unlisted or implied care benefits.
Keep documentation that shows your clinic does not assume risk in the same way as an insurer.
Use patient disclosures that clearly explain this is not health insurance.
📲 Telehealth Caution: Multistate Limitations Still Apply
Even if your practice is based in Minnesota, many membership clinics offer virtual care across state lines. However, the post-pandemic relaxation of interstate telemedicine rules is fading, and licensure now matters again.
If your patients live or move out of state:
You must be licensed in the patient’s location at the time of the virtual visit.
You may need to adjust documentation and consent practices for each state’s standards.
You should ensure HIPAA-compliant technology is being used, especially as the Department of Health and Human Services (HHS) rolls out updated 2025 telehealth guidance.
🔍 Summary of Key Compliance Issues for Membership Clinics in 2025
Here are the three most critical compliance areas your practice should monitor:
1. HSA Rule Changes:
Patients with high-deductible health plans can now use Health Savings Accounts (HSAs) to pay for direct primary care and concierge membership fees. This creates a significant opportunity for clinics to expand access and market their services as HSA-compatible. If your clinic hasn’t yet updated patient-facing materials or employer outreach strategies to reflect this change, now is the time.
2. Minnesota State Law on DPC:
Minnesota has not enacted a specific law exempting direct primary care practices from insurance regulation. That means your contracts must be written carefully to avoid being classified as an unlicensed insurance product. Avoid promising “unlimited” care or listing benefits that resemble insurance coverage. Instead, emphasize access to care and transparency. Work with legal counsel to ensure your agreements reflect Minnesota’s current interpretation of insurance statutes.
3. Telehealth Across State Lines:
As federal pandemic-era flexibilities expire, telehealth is once again governed by traditional state licensure rules. If you see patients virtually outside Minnesota, you must be licensed in their state at the time of service. Review where your patients live or travel and adjust your policies accordingly. Failure to do so could lead to disciplinary actions or liability.
🔍 Final Thoughts
Membership medicine is gaining momentum. With expanded HSA eligibility and rising patient demand for personalized care, clinics like yours are uniquely positioned for growth. But that growth must be legally sustainable.
At ClearPath Compliance, we monitor these changes daily—so you don’t have to. We help Minnesota clinics:
Ensure legal alignment for membership agreements,
Stay current with state-level regulations,
Navigate telehealth compliance, and
Structure employer offerings that won’t invite regulatory action.
Need help reviewing your membership contract or marketing language? Let’s make sure your practice is compliant, competitive, and ready for the next chapter in direct care.