Wyoming's Direct Primary Care Law Never Says 'Physician.' In July a Nurse Practitioner in Sheridan Opened a Direct Primary Care Clinic.

Legislation by DPC Insider — Policy Desk
#wyoming#dpc-laws#nurse-practitioners#scope-of-practice#hsa
Sources: New clinic expands Sheridan's direct primary care · Wyoming Senate File 0049 (2016) — Enrolled Act No. 4, Senate · Wyoming State Board of Nursing — Practice · Direct Primary Care Rules for HSA Plans Under the OBBBA · Federal Changes Allow Payment for Direct Primary Care Via Health Savings Accounts · DPC Frontier Mapper · AANP State Practice Environment

Wyoming’s direct primary care statute defines the agreement as a contract between a patient and “a health care provider.” The word physician never appears in it. On July 20 a family nurse practitioner in Sheridan opened a direct primary care clinic of her own.

Nina Beach launched Wyo Roots Health after a career in oncology and urgent care, according to the Sheridan Press. She first heard about the model while working as a fill-in provider in Cody.

“You don’t need all those middle people… there’s so much lost in translation, so it’s cutting out all that red tape. You can really care for people efficiently,” Beach told the paper.

The Sheridan Press reports Wyo Roots charges $95 a month per adult, $85 for a second adult on the plan, and $55 for a child with a paying adult, capped at $300 a month for a family. Costs vary by practice and location.

What Senate File 49 Actually Did

The Wyoming Legislature passed Senate File 49 during the 2016 budget session, where it became Enrolled Act No. 4 of the Senate. The enrolled text is short. It amends W.S. 26-1-104(a) with a new paragraph (vi) stating that the insurance code does not apply to a direct primary care agreement, and adds a matching exception to W.S. 26-22-301 so prepaid health service plan rules don’t sweep these contracts back in.

Then it defines the agreement, and the definition is where the work happens. The contract has to be in writing between a patient or their legal representative and a health care provider. Either side can end it in writing with no penalty and no termination fee, on notice of no more than 60 days. It has to describe the services covered by the periodic fee, state that fee and any additional charges, and bar the provider from collecting extra compensation for anything already inside the fee. It has to say conspicuously that it isn’t health insurance and doesn’t satisfy any federal individual mandate.

Subparagraph (E) is the one most readers skip. It permits the periodic fee and any additional fees to be paid by a third party. The statute never says who that third party might be.

The word physician appears nowhere in any of it.

Dr. Dean Bartholomew is a provider at 307 Health in Powell, one of the state’s first direct primary care facilities. It launched 10 years ago, and he told the Sheridan Press that before that, Wyoming didn’t yet have the legislation for these types of clinics to run effectively.

The Second Law Nobody Counts

Senate File 49 sits entirely inside the insurance code. It settles how a membership practice is regulated and says nothing at all about who is allowed to practice without a physician’s signature above them. In Wyoming that question has its own answer, in a different body of law.

The Wyoming State Board of Nursing describes the state as “a full independent scope of practice state, following the national APRN Consensus Model of Regulation since its adoption in 2007.” Supervision or collaboration agreements with any other provider are not required under Wyoming law.

So one body of Wyoming law imposes no physician requirement on a direct primary care agreement, and the other imposes no supervision requirement on an APRN. The membership isn’t a full exit from claims, though. The Sheridan Press notes that primary care providers can still bill a patient’s insurance for referred specialist services.

Not every state is arranged this way. The American Association of Nurse Practitioners sorts every state into full, reduced or restricted practice. A restricted state requires career-long supervision, delegation or team management by another health provider. A reduced state either requires a career-long collaborative agreement with one, or limits the settings where an NP can practice. Wyoming’s DPC act, confined to the insurance code, is silent on the subject. If you might be reading this from a restricted-practice state, the two laws you need are separate bills with separate sponsors.

The Federal Layer Landed in January

Since January 1, 2026, health savings account funds can pay a DPC membership fee. The One Big Beautiful Bill Act capped the qualifying fee at $150 a month for an individual and $300 for a family, indexed for inflation.

To qualify, the arrangement has to consist solely of primary care services delivered by primary care practitioners, compensated by a fixed periodic fee with no per-visit charges. Congress defined “primary care practitioner” by cross-reference to section 1833(x)(2)(A) of the Social Security Act, which counts nurse practitioners, clinical nurse specialists and physician assistants alongside physicians in family medicine, internal medicine, geriatrics and pediatrics.

Federal law reached the same conclusion Wyoming reached in 2016, through a completely different route.

Beach’s pricing sits inside those caps almost exactly. Her individual fee runs well under the $150 line, and her family cap matches the federal family cap dollar for dollar. Whether that alignment was designed isn’t something the Sheridan Press reports.

The federal definition also excludes prescription drugs other than vaccines from primary care services. Separately, the Sheridan Press notes that medications at Wyo Roots aren’t included in the membership fee. Beach described stocking common antibiotics on site and dispensing a course for $3. Dispensing regulations vary by state, and physicians and other prescribers are responsible for verifying their own state’s requirements.

What Changes Tomorrow

For a nurse practitioner in Wyoming, nothing. The DPC exemption passed in 2016, the Board of Nursing already requires no supervision or collaboration agreement, and the federal HSA provision has been live since January.

For a nurse practitioner in a state that requires physician involvement, a DPC statute won’t help. The bill that would change your situation is a scope of practice bill, and those move on a different calendar against different opposition.

The lag is the real lesson here. Wyoming lifted the insurance-code barrier in 2016. Ten years later, the city of Sheridan has two of these clinics, Gannett Health and Wyo Roots, in a county of roughly 33,000 residents, and DPC Frontier’s mapper counted 3,172 practices nationally across all 50 states and the District of Columbia as of September 7, 2026. Removing a legal obstacle sets a floor. It doesn’t set a schedule.