Minnesota

Quick Facts

Key Provisions

• The Minnesota DPC Act (HF 1724) explicitly defines a direct primary care agreement as a service contract, not a health insurance policy. Consequently, DPC practices are not subject to regulation under the state's insurance laws, including Minnesota Statutes chapters 60A through 72A.
• All DPC arrangements must be formalized in a written agreement that is signed by the primary care provider (or their agent) and the patient (or their legal representative).
• The agreement must clearly describe the scope of primary care services covered by the periodic fee, ensuring transparency for the patient.
• The contract must specify the exact amount of the periodic fee, the payment schedule, and any additional fees that may be charged for services not included in the standard membership.
• A mandatory disclosure must be included in the agreement, stating in a clear and conspicuous manner that the DPC agreement is not health insurance and does not satisfy any legal requirement to maintain health insurance coverage.
• The agreement must include a recommendation that the patient secure and maintain a separate health insurance plan to cover services not provided by the DPC practice, such as hospitalizations, specialty care, and emergency services.
• The contract must specify its duration and include provisions allowing either the patient or the provider to terminate the agreement, providing flexibility for both parties.
• Prior to the law's effective date of January 1, 2026, DPC practices in Minnesota operated in a regulatory gray area. This uncertainty created challenges, including the risk of being misclassified as an insurance business and limiting the ability of patients to use Health Savings Accounts (HSAs) for DPC fees.

Medication Dispensing

Minnesota does not have DPC-specific regulations for in-office medication dispensing. Therefore, physicians operating DPC practices must adhere to the general state laws and rules governing all dispensing practitioners, as enforced by the Minnesota Board of Pharmacy and outlined in statutes such as Minnesota Statutes, Chapter 151. This requires compliance with all standard licensing, record-keeping, labeling, and storage requirements. While DPC practices can offer the convenience of dispensing common, non-controlled medications directly to patients, the cost of the actual medications is separate from the monthly membership fee and is typically billed to the patient at or near wholesale cost.