Minnesota Takes Its First Step Toward a DPC Legal Framework

Legislation by DPC Insider
#minnesota#dpc legislation#state law#hf 1724#service agreements
Sources: Representative Dawn Gillman Legislative Update: March 20, 2026 · HF 1724 Bill Status - Minnesota Legislature · Commerce Finance and Policy Committee Schedule - March 24, 2026 · Minnesota DPC Status - DPC Frontier

Minnesota has no law on the books that defines what a direct primary care agreement is. If HF 1724 keeps moving, that’s about to change.

The bill, authored by Representative Dawn Gillman along with Representatives McDonald and Koznick, would establish direct primary care service agreements in Minnesota statute for the first time. It had its hearing in the House Commerce Finance and Policy Committee on March 24 and was amended and re-referred to the Health Finance and Policy Committee the following day.

What the Bill Does

At its core, HF 1724 does what over 30 other states have already done: it draws a clear line between DPC agreements and health insurance.

Under the proposed language, a direct primary care service agreement would allow patients to pay a monthly fee directly to their provider for routine medical services. Rep. Gillman’s legislative update described the model as “a more straightforward and transparent option for accessing everyday health care,” with monthly fees around $50 for routine care.

The critical legal distinction: the bill would clarify that DPC agreements are not health plans, not accident and sickness insurance policies, not HMO contracts, and not subject to the regulatory framework that governs those products. This matters because without that clarification, physicians who accept monthly membership fees could theoretically face scrutiny under insurance regulations they were never meant to comply with.

Why This Matters for Minnesota

According to DPC Frontier, Minnesota currently has no DPC-specific legislation. Physicians can and do operate DPC practices in the state, but they do so without a statutory framework that explicitly recognizes their business model.

That’s not just a technicality. In states without DPC laws, practices operate in a gray area. Insurance regulators could, in theory, argue that a monthly membership fee looks a lot like an insurance premium. No state has actually shut down a DPC practice on those grounds, but the ambiguity creates risk for physicians considering the transition and for investors evaluating the market.

A statutory framework removes that uncertainty. It tells physicians: you can do this, and here’s what the rules are. It tells regulators: this is not your jurisdiction. And it tells patients: this arrangement is recognized and legitimate under state law.

The Broader Legislative Trend

Minnesota isn’t breaking new ground here. It’s joining a well-established trend. More than 30 states have enacted some form of DPC legislation, most following a similar template: define DPC agreements, clarify they’re not insurance, and set basic consumer protections.

What makes HF 1724 notable is the timing. With the HSA-DPC compatibility provision now in effect since January 2026, allowing patients to use health savings account funds for DPC memberships up to $150 per month, there’s renewed urgency for states to have clear legal frameworks. Patients using HSA dollars for DPC need to know the arrangement they’re paying into is recognized by their state.

The bill also has bipartisan practical appeal. DPC isn’t a partisan issue in most state legislatures. The model appeals to conservatives who favor market-based healthcare and to progressives who want better access to primary care. That’s why similar bills have passed in red, blue, and purple states alike.

What to Watch

HF 1724’s re-referral to Health Finance and Policy isn’t unusual. DPC bills frequently move through both commerce and health committees because they sit at the intersection of insurance regulation and healthcare delivery. The next hearing in Health Finance and Policy will be the key test.

There’s also a related bill, HF 2880, authored by Representatives Engen and Johnson, that similarly seeks to clarify DPC agreements are not insurance. Multiple bills addressing the same issue can signal growing legislative interest, or they can split support. It’s worth watching whether these efforts consolidate.

What This Means

If you’re a physician running or considering a DPC practice in Minnesota, this bill is a signal worth watching. It won’t change your day-to-day operations immediately, but a clear statutory framework makes it easier to explain your model to patients, to banks, and to anyone else who asks whether what you’re doing is legal.

If you’re in a state that already has DPC legislation, Minnesota’s movement is a reminder that the legal landscape continues to evolve. Every state that formalizes DPC makes the model more legitimate nationally.

And if you’re a resident exploring DPC as a career path, pay attention to your state’s legislative status. The DPC Frontier state-by-state tracker is the best resource for understanding where things stand. The legal framework might not be the most exciting part of starting a practice, but it’s one of the most important.