By John Fisher, JD, CHC, CCEP

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
