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The Department of Health and Human Services (HHS) proposed rules on affordable health care exchanges on July 15, 2011, which clearly state that: “direct primary care medical homes are not insurance.” The exchange rules (CMS–9989–F) became final without modification on March 12, 2012. Section B, Part 156 (g) §156.245 on the treatment of direct primary care medical homes should clear the way for state insurance regulators to recognize DPC medical homes as a benefit that can be offered within the exchange but is not subject to risk or capitalization requirements of insurers or HMOs. This is an important distinction.


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