- – the unlicensed practice of medicine in states where the “treating” doctor does not have a license (if, for example, the doctor is consulting by email with a patient who has moved his residence)
- – compliance with HIPAA privacy and security rules in a practice that relies more heavily upon electronic communications
- – private payment running afoul of Medicare rules and prohibitions regarding charges to Medicare beneficiaries for services that are covered under Medicare
- – adherence pharmacy and DEA rules concerning prescription refills regulations concerning what tasks can be delegated to non-MD employees
- – merging rules governing the practice of telemedicine and of charging for it
- – the possibility that risk-assumption in providing unlimited visits/consultations for a fixed fee might be deemed an unauthorized insurance operation
- – malpractice and Medical Board concerns over the sufficiency of diagnosing and prescribing treatment if the doctor has not adequately determined the patient’s history or examined the patient
Nevertheless, the proper legal steps to properly set up and operate a direct primary care practice are manageable and, as thousands of doctors are finding, far less onerous than dealing with insurance companies. To be sure, direct primary care/concierge medicine is the wave of the future.
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