Michigan

Quick Facts

Key Provisions

• A DPC agreement is legally defined as a non-insurance contract and is explicitly exempt from regulation under the Michigan Insurance Code, as long as it meets statutory requirements (MCL 333.2705).
• All DPC agreements must be in writing, signed by the provider and the patient, and must clearly specify the services covered, the periodic fee, and the contract's duration, which cannot exceed one year but is renewable (MCL 333.2703).
• The agreement must include a conspicuous disclosure stating that it is not a health insurance policy and does not satisfy any individual mandate for health insurance coverage.
• Eligible providers are limited to licensed primary care physicians (MDs and DOs). Nurse Practitioners and Physician Assistants can provide DPC services, but must do so under a collaborative agreement with a physician.
• Providers are prohibited from billing any third-party payer, such as an insurance company, for any services that are covered under the DPC agreement's periodic fee (MCL 333.2709).
• Patients have the right to terminate their DPC agreement with 30 days' written notice. Upon termination, the provider is required to refund a pro-rated amount of any fees paid in advance for the unused portion of the term (MCL 333.2703).
• The fee structure must be based on a periodic payment (e.g., monthly) that is not dependent on the frequency or volume of services the patient receives.
• The scope of services is restricted to primary care. The law does not permit DPC agreements to cover specialty care, emergency room visits, or hospital services.

Medication Dispensing

In Michigan, DPC practices do not have special dispensing laws but must adhere to the general regulations governing physician dispensing under the Michigan Public Health Code (MCL 333.17708). Licensed physicians (MDs and DOs) are permitted to dispense pre-packaged, properly labeled medications directly to their patients from their office. This authority is generally limited to dispensing a 72-hour supply of a medication, although exceptions exist for certain drug categories, such as oral contraceptives. This capability allows DPC providers to offer enhanced convenience and potential cost savings on common generic medications, bypassing the need for a separate trip to a pharmacy for short-term treatments.

Medicaid Provisions

Michigan does not have a permanent program integrating Direct Primary Care into its state Medicaid plan. However, the state legislature authorized a temporary DPC pilot program for Medicaid beneficiaries for the 2017-2018 fiscal year (authorized by Public Acts 158 of 2017 and 207 of 2018). The pilot was a limited-scale initiative designed to test the DPC model with a small number of enrollees through select Medicaid Health Plans. The program was not expanded or made permanent after its conclusion. Consequently, DPC services are generally not a covered benefit for Michigan's Medicaid population.