Concierge medicine and direct primary care (DPC) give you fast, personal access to a primary care doctor for a membership fee, but neither one is health insurance. In Florida, you still need a major medical plan for hospital stays, specialists, surgery, and emergencies. For many healthy, higher-income households, the best pairing is DPC plus a Bronze or HSA-eligible plan, especially now that a 2025 federal law allows qualifying DPC arrangements alongside an HSA.
Key takeaways
- Not insurance: Florida law says direct health care agreements are not insurance and are not regulated by the Florida Insurance Code.
- Keep major medical: DPC does not cover hospitals, specialists, or most expensive care.
- HSA rules changed: Starting in 2026, qualifying DPC arrangements no longer disqualify you from contributing to an HSA. The fee limit is $150 a month for one person or $300 for more than one, and the same limits apply in 2027.
- Bronze plans now qualify: As of 2026, IRS guidance treats bronze and catastrophic plans as HSA-compatible.
- Read the contract: Florida requires a written agreement with a 30-day termination right and a refund of prepaid fees if the practice closes.
Concierge medicine vs. direct primary care
| Feature | Concierge medicine | Direct primary care |
|---|---|---|
| How you pay | Annual or monthly retainer | Flat monthly (or periodic) membership fee |
| Bills your insurance? | Often yes, for visits and services | Typically no, for covered primary care |
| Typical cost | Varies widely; often higher than DPC | Varies by practice and age; often a modest monthly fee |
| What’s included | Extended visits, same-day access, care coordination | Unlimited or frequent primary care visits, messaging, some labs |
| Replaces insurance? | No | No |
Pricing varies a lot from practice to practice in Orlando, Tampa, Jacksonville, and DeLand. Get the fee schedule, the list of included services, and the prices for anything extra, such as labs, imaging, and in-office procedures, in writing. For more background, see Can self-employed people use direct primary care instead of health insurance?
Florida’s DPC law: not insurance
Florida Statute 624.27, broadened in 2019 from “direct primary care” to “direct health care agreements,” says such an agreement “does not constitute insurance and is not subject to the Florida Insurance Code” (Florida Statutes). The agreement must:
- Be in writing and signed by the provider and the patient (or the patient’s employer).
- Let either party cancel with at least 30 days’ written notice.
- List the services covered by the monthly fee and the fees for anything else.
- Refund prepaid fees if the provider stops offering services.
- State that it is not health insurance and does not qualify as minimum essential coverage under the ACA.
Why you still need major medical
A DPC membership will not pay for a hospital stay at AdventHealth or Orlando Health, a cancer workup at Moffitt, or a specialist at Mayo Clinic Jacksonville. An ACA plan covers those costs, caps your 2027 in-network out-of-pocket spending at $12,000 for an individual or $24,000 for a family, and covers pre-existing conditions. Medically underwritten private plans can cost less for healthy applicants, but they may exclude pre-existing conditions and lack ACA protections (see our guide to underwritten private plans).
HSA rules for DPC after the One Big Beautiful Bill Act
The IRS says that “beginning Jan. 1, 2026, an otherwise eligible individual enrolled in certain direct primary care (DPC) service arrangements may contribute to an HSA” and can use HSA funds tax-free to pay periodic DPC fees (IRS). For 2027, Rev. Proc. 2026-24 keeps the limit at aggregate monthly fees of no more than $150, or $300 if the arrangement covers more than one person (IRS Internal Revenue Bulletin 2026-25). Key details from the IRS guidance:
- The arrangement must cover only primary care for a fixed periodic fee. It cannot include procedures that require general anesthesia, prescription drugs (other than vaccines), or most labs not typically done in a primary care office.
- Your HDHP cannot pay for the membership before you meet the deductible, and DPC fees do not count toward the plan’s deductible or out-of-pocket maximum.
- Fees above the cap can still be reimbursed from an HSA, but they make you ineligible to contribute.
- Concierge practices that bill insurance separately for member services may not qualify.
These rules are new, so confirm your setup with a tax advisor. Learn more in our HSA guide for self-employed Floridians.
Pairing DPC with a Bronze or HDHP plan
A common strategy for healthy high earners above the 400% FPL subsidy cliff is to pair DPC with a lower-premium Bronze or HSA-eligible plan. DPC handles routine visits, the health plan covers serious care, and the HSA lets you save for the deductible with pre-tax money. The 2027 HSA limits are $4,500 for self-only coverage and $9,000 for family coverage, plus a $1,000 catch-up at age 55 or older. With Florida’s proposed 2027 rates up 15.3% on average, it is worth running the numbers (see how high earners can lower premiums in 2027). Before you enroll, check that the plan’s network includes the hospitals and specialists your DPC doctor refers to.
Frequently Asked Questions
Is direct primary care insurance in Florida?
No. Florida Statute 624.27 says a direct health care agreement “does not constitute insurance” and is not subject to the Florida Insurance Code. Agreements must state that they are not health insurance and do not count as minimum essential coverage.
Can I contribute to an HSA if I have direct primary care?
Starting Jan. 1, 2026, yes, if the arrangement qualifies. It must cover only primary care for a fixed periodic fee of no more than $150 a month for one person or $300 for more than one (the same limits apply in 2027), and you must otherwise be HSA-eligible. Confirm your situation with a tax advisor.
Can I pay concierge medicine fees from my HSA?
It depends on how the practice is set up. Many concierge practices also bill your insurance for visits, and IRS guidance treats arrangements that bill separately for member services differently from qualifying DPC arrangements. Ask the practice and a tax advisor before you pay.
Do DPC fees count toward my health plan deductible?
No. IRS guidance says an HDHP cannot count DPC membership fees toward its deductible or out-of-pocket maximum.
Pair your DPC membership with the right plan
We can help you find a Bronze, HSA-eligible, or PPO plan that works with your concierge or DPC doctor and your preferred hospitals. Michael McAllister, owner of Choice Health Insurance Brokers in DeLand, is a licensed health insurance broker (NPN 18229135) with 10 years in business. He is appointed with 200 carriers and quotes on- and off-exchange, public and private plans, at no cost to you. Call or text 321-230-9536 or visit choice.healthcare to compare 2027 options before Open Enrollment.