Concierge Medicine Article Series | The Anti-kickback Statute in Concierge and Cash-based Medical Practices

By John Fisher, JD, CHC, CCEP

Anti-kickback statute in concierge medical practices

The Concierge and Cash-Based Medical Practice Article Series explores the evolving landscape of healthcare delivery models that prioritize patient-centered care, transparency, and direct financial relationships between patients and providers. Through this series, readers will gain insights into the regulatory safe harbors most relevant to concierge and direct primary care (DPC) practices, learn about high-risk arrangements and practical compliance frameworks, and understand the significance of OIG advisory opinions for cash-based practices. Each article is designed to equip both practitioners and stakeholders with actionable knowledge and guidance for navigating compliance, mitigating risk, and optimizing patient outcomes in these innovative practice settings.

By drawing attention to the unique challenges and opportunities within concierge and DPC models, this series aims to foster informed decision-making and encourage the adoption of best practices in the pursuit of sustainable, ethical healthcare delivery. Whether you are new to these practice models or seeking to enhance your current approach, the following articles provide a comprehensive overview of key considerations, legal pathways, and practical recommendations for success.

Concierge Medicine and the Anti-Kickback Statute Articles in Series

THE AKS STATUTE IN PLAIN TERMS

Why Concierge and Cash-Based Practices are not Exempt from the AKS

THE APRIL 2026 OIG FAQ UPDATES

SAFE HARBORS MOST RELEVANT TO CONCIERGE AND DPC PRACTICES

HIGH-RISK ARRANGEMENTS IN CONCIERGE PRACTICE

PRACTICAL COMPLIANCE FRAMEWORK

THE OIG ADVISORY OPINION PATHWAY FOR CONIERGE AND CASH-BASED PRACTICES

CONCLUSIONS ABOUT DIRECT PRIMARY CARE AND CONCIERGE PRACTICES

  

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