Connecticut

Quick Facts

Key Provisions

• A DPC agreement is legally defined as a non-insurance contract under C.G.S. § 38a-530a, meaning practices are not subject to regulation by the Connecticut Insurance Commissioner.
• All DPC agreements must be in writing and signed by both the primary care provider and the patient or the patient's employer.
• The contract must explicitly state that it is not a health insurance policy and should advise the patient to obtain and maintain separate coverage for services not included in the agreement, such as hospital care, specialist visits, and major surgery.
• Agreements must clearly describe the scope of primary care services covered by the periodic fee, as well as the amount and payment schedule for that fee.
• Eligible DPC providers are limited to licensed physicians (MDs and DOs), physician assistants (PAs), and advanced practice registered nurses (APRNs).
• The fee structure must be periodic (e.g., monthly, quarterly, or annually) and cannot be based on a per-visit or fee-for-service model. The law does not impose any caps on membership fees.
• Either the provider or the patient may terminate the agreement for any reason by providing 30 days' written notice to the other party.
• If a patient terminates the agreement, the provider is required to issue a pro-rated refund for any fees that were prepaid for a future service period.
• Providers operating a DPC practice must maintain professional liability (malpractice) insurance or an equivalent form of financial security as required by their professional licensing boards.

Medication Dispensing

Connecticut's DPC law, Public Act 17-160, does not contain specific provisions regarding in-office medication dispensing. Therefore, DPC practices must adhere to the state's general regulations for provider dispensing. Under C.G.S. § 20-14c, licensed physicians, physician assistants, and nurse practitioners are permitted to dispense medications directly to their patients. However, this is typically limited to a 72-hour supply for acute conditions or the dispensing of professional samples. To dispense larger quantities or pre-packaged medications on a regular basis, a provider must obtain a specific registration from the Connecticut Department of Consumer Protection (DCP) and comply with regulations similar to those for a pharmacy, including labeling, record-keeping, and storage requirements. The DPC law provides no exemptions from these standard dispensing rules.

Medicaid Provisions

Connecticut's DPC legislation does not include any provisions for integrating DPC memberships with the state's Medicaid program, known as HUSKY Health. The law, codified in C.G.S. § 38a-530a, focuses exclusively on defining the legal status of private DPC agreements between providers and individuals or employers. While Connecticut has explored other primary care payment models, such as the HUSKY Primary Care (PCCM) pilot program, that initiative is a fee-for-service care coordination model and is functionally distinct from the membership-based DPC model. Consequently, DPC practices in Connecticut cannot currently contract with the state to offer memberships to Medicaid beneficiaries as a covered benefit.