Missouri

Quick Facts

Key Provisions

• A Direct Primary Care agreement is explicitly defined as not being insurance and is therefore exempt from regulation under the state's insurance code (Missouri Revised Statutes § 376.1890).
• All DPC agreements must be in writing and clearly outline the scope of primary care services provided, the periodic fee structure, and the terms of the contract.
• The agreement must include a conspicuous disclosure, in writing, stating that the DPC agreement is not a health insurance policy and does not satisfy any individual health insurance mandate.
• Providers are prohibited from billing a patient's insurance plan for any services already covered by the DPC agreement's periodic fee.
• Eligible providers include licensed physicians (MDs and DOs) and physician assistants operating under a physician's supervision, all governed by the Board of Healing Arts.
• Missouri uniquely allows 'assistant physicians'—medical school graduates who have passed board exams but not completed residency—to provide primary care in DPC settings within designated underserved areas under a collaborative practice agreement.
• To qualify as a DPC agreement under the law, the provider cannot assume financial risk for services outside the scope of primary care, such as hospital, emergency, or specialty care.
• The agreement must specify the duration of the contract and the terms for termination by either the patient or the provider.

Medication Dispensing

Missouri DPC practices are permitted to dispense pre-packaged medications directly to their patients, providing a significant source of convenience and cost savings. This activity is regulated by the State Board of Registration for the Healing Arts under rule 20 CSR 2150-5.020 (Nonpharmacy Dispensing). Key requirements include that a licensed physician or physician assistant must be physically present at the practice location when medications are dispensed. Furthermore, practices must inform patients that they have the right to have their prescription filled at an external pharmacy of their choice. Standard labeling, packaging, and record-keeping laws must be strictly followed to ensure patient safety and regulatory compliance.

Medicaid Provisions

Missouri law allows patients enrolled in MO HealthNet (the state's Medicaid program) to privately contract with a DPC provider for services. However, there are important considerations for both patients and providers. While the patient pays the DPC practice directly for membership, for any ancillary services—such as prescriptions, lab work, or imaging—to be covered by MO HealthNet, the DPC provider must be an enrolled Medicaid provider. This enrollment is necessary for the provider to write orders that will be honored and paid for by Medicaid. State regulation 13 CSR 70-4.030 clarifies that Medicaid participants may be held liable for services that are not covered or reimbursable by the program, which includes DPC membership fees.