Concierge Fees (Up Front): HSA Eligibility

Concierge Fees (Up Front): reimbursement is not eligible with a Health Savings Account (HSA)
Concierge fees to retain a boutique practice doctor are not eligible with a flexible spending account (FSA), health reimbursement arrangement (HRA), limited-purpose flexible spending account (LPFSA) or a dependent care flexible spending account (DCFSA). Concierge fees may be eligible for reimbursement in limited circumstances with a health savings account, if the arrangement meets the requirements for a direct primary care service arrangement. The cost of medical services actually incurred by a concierge doctor are eligible with an FSA, HSA and HRA when billed separately from the upfront fee.

What are concierge fees?

Concierge medicine, also known as a boutique practice, is a type of medical care where patients will pay an out-of-pocket fee to become a patient of a medical professional with a small, established clientele. In most cases, these are physicians who have made the determination that they will no longer accept insurance payments for their services, and as opposed to having their insurance cover the cost of care, patients will instead pay a retainer for the doctor's services. While consumer-driven healthcare accounts do not cover the initial expense of concierge fees, any medical services paid for at these offices would be covered (Concierge Medicine Today).

What are the benefits of concierge medicine?

Concierge medicine has become increasingly popular as a direct result of the structure of the American healthcare system. Doctors are paid to make diagnoses and perform procedures on patients, but they are not paid for the time they spend with patients or for their efforts to coordinate care. Additionally, doctors are forced to employ individuals to process insurance reimbursements, billing and other services, which can be an onerous process and may hurt their financial bottom line overall. While some boutique practices may reimburse through insurance on a limited basis, the vast majority will not work with insurance at all.

As a result, many doctors have opted to embrace concierge fees as a means of simplifying the healthcare process, while in turn offering their patients an improved standard of care (i.e. longer office visits, 24-hour service etc.). However, under this format, doctors are left to determine what exactly their concierge fees will cover. For instance, some concierge doctors will charge an annual fee for their services and patients will also have to pay for in-office visits, while other physicians will have their retainers cover all in-office care as well. It's vital for prospective patients to shop around to find the best combination of services and affordability for the cost of an annual retainer (Signature Medicine).

Direct Primary Care Service Arrangements

Concierge medicine may qualify as a direct primary care (DPC) service arrangement when the concierge fee functions as a flat, periodic payment that covers primary care services and the practice does not bill insurance or Medicare for those services. In a qualifying DPC model, the physician–patient relationship is direct and contractual, the retainer includes most routine primary care (such as office visits, preventive care, and chronic disease management), and any excluded services are clearly identified and separately payable. Critically, the practice must not submit claims to insurers or participate in Medicare for covered primary care services; instead, the membership fee replaces third-party billing. When these conditions are met, a concierge arrangement may be considered DPC in structure, even if it is branded or marketed as concierge medicine. In this instance, the fees may be reimbursable with an HSA after December 31, 2025. (https://www.irs.gov/pub/irs-drop/n-26-05.pdf)

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