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Retail health care vs. employer DPC: Preparing for 2026 policy shifts

Dana Y. Lujan, MBA
Policy
January 16, 2026
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Recent federal policy discussions have introduced a framework that would place health care affordability dollars into individual-controlled accounts rather than routing them through insurers or employer benefit plans. Still at the framework stage and requiring legislative action, the architecture being explored signals a potential shift in how health care purchasing power flows through the system.

Whether or not this specific framework advances, the direction of travel is clear. Health care purchasing power is moving closer to the individual. When control of dollars shifts, markets reorganize. For membership-based practices, the key question is not whether this policy passes. It is whether DPC and concierge practices have been building health care practices or retail businesses.

That distinction now matters.

From third-party payer to retail consumer

For decades, physicians built practices around third-party payer networks, referral relationships, and employer plan design. Patients rarely behaved as direct purchasers of care. That dynamic is already changing. More than half of commercially insured Americans are now enrolled in high-deductible health plans. Health savings account assets exceed $100 billion and continue to grow annually. Cash-pay utilization has expanded steadily over the last decade.

In other words, retail health care behavior is no longer theoretical. It is already here.

If future affordability mechanisms place defined health care dollars directly into individual-controlled accounts, more patients will approach care decisions as household budget allocations. That environment favors models with transparent pricing, predictable monthly costs, and direct access. DPC and concierge practices fit naturally. But retail markets impose different survival rules than traditional health care markets.

Retail membership businesses in other sectors operate with materially higher churn rates than enterprise-contracted services, a dynamic health care has historically been shielded from. Household budget sensitivity introduces a new ceiling on sustainable membership pricing, particularly for middle-income families balancing multiple subscription expenses.

Retail DPC and employer-sponsored DPC are not the same business

Much of the DPC movement has grown in two distinct directions:

  • Retail DPC relies on household discretionary income. Patients decide whether a monthly membership fits within their family budget.
  • Employer-sponsored DPC relies on organizational procurement. Employers purchase memberships as part of workforce benefit strategies, spreading risk and stabilizing revenue.

If health care dollars increasingly flow into individual-controlled accounts, market gravity shifts toward the retail model. That creates opportunity. It also introduces volatility. Household budgets are sensitive to inflation, competing expenses, and perceived value. Churn becomes a structural reality. Patient acquisition becomes continuous rather than episodic.

This is not a clinical challenge. It is a consumer business challenge.

The uncomfortable prediction

In a retail health care marketplace, clinical excellence is necessary but insufficient. Survival favors practices that master consumer marketing, frictionless payment, and brand trust capture. Many physician-owned practices have not built these capabilities. They have built excellent care delivery systems inside a health care distribution model that historically shielded them from retail competition.

If individual-controlled funding accelerates, intermediary platforms will emerge to aggregate, package, and resell access to care. In retail markets, whoever owns enrollment flows, payment rails, and navigation experience owns the customer relationship. Practices that do not control those touchpoints risk becoming interchangeable supply-side participants in someone else’s marketplace.

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This is the commoditization risk DPC advocates rarely discuss. It is not ideological. It is structural.

Designing for consumer decision-making

Practices preparing for a retail-dominant environment should focus on three operating realities:

  • Membership architecture: Pricing must align with realistic household health care budgets. Simplicity converts. Complexity repels.
  • Payment infrastructure: Account-based spending requires seamless transactions, receipts, and documentation. Friction kills retail conversion.
  • Patient acquisition strategy: Referral pipelines will not scale. Brand positioning, digital presence, and local market trust become core competencies.

These are business model decisions, not clinical ones.

Where employer-sponsored DPC still holds an advantage

Employer-sponsored DPC models retain a structural advantage. Organizations pool risk, stabilize revenue, and reduce household budget sensitivity. Even if individual-controlled funding expands, employers remain better positioned to curate care ecosystems, provide navigation support, and subsidize access.

That means the employer-sponsored DPC thesis remains economically stronger and more durable. But retail DPC growth accelerates alongside it. The two models will coexist, with different risk and margin profiles.

Preparing without predicting

It is important to remain precise. The current policy discussions represent a framework, not enacted law. No implementation timeline exists. Legislative processes will determine whether and how such mechanisms materialize.

But strategic planning is not prediction. It is preparation for structural shifts already in motion.

Consumer-directed health care spending continues to expand. Membership-based care models continue to proliferate. Proposed federal frameworks accelerate trends already underway. Practices that build retail-ready operating models today will remain resilient regardless of the final policy outcome.

The bottom line

If patients increasingly control health care wallets, care delivery becomes a consumer marketplace. DPC and concierge practices are well-positioned for that environment. But the practices that succeed will not necessarily be those with the strongest clinical models. They will be those that design retail businesses with health care delivery inside them.

That is the market test now forming.

Dana Y. Lujan is a health care strategist and operator with more than twenty years of experience across payers, providers, and health systems. She is the founder of Wellthlinks, a consulting firm that helps employers and providers redesign care models through concierge and direct primary care, and author of The CEO Physician: Strategic Blueprint for Independent Medicine. Dana has led multi-state network development, payer contracting, financial modeling, and compliance initiatives that strengthen provider sustainability and employer value. She previously served as president of the Nevada chapter of HFMA and is pursuing a JD to expand her expertise in health care law and compliance. She has been featured in Authority Magazine and publishes on KevinMD, MedCity News, and  Medium, where she writes on health care innovation, direct primary care, concierge medicine, employer contracting, and compliance. She has forthcoming BenefitsPRO. Additional professional updates can be found on LinkedIn and Instagram.

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Retail health care vs. employer DPC: Preparing for 2026 policy shifts
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