PolicyBrief
S. 3298
119th CongressDec 2nd 2025
Medicaid Primary Care Improvement Act
IN COMMITTEE

This act clarifies that states can use Medicaid funds for primary care services delivered through direct primary care arrangements.

Marsha Blackburn
R

Marsha Blackburn

Senator

TN

LEGISLATION

New Medicaid Clarity: States Can Now Pay for Primary Care Via Fixed Monthly Fees

The Medicaid Primary Care Improvement Act is about one thing: giving states more flexibility in how they pay for primary care services for Medicaid recipients. Specifically, it clarifies that states can use Medicaid funds to pay for primary care through what’s called a “Direct Primary Care arrangement” (DPC).

If you’re unfamiliar, a DPC arrangement is essentially a subscription model for your doctor. The bill defines it as an arrangement where a patient gets only primary care services from a practitioner, and the only payment for that care is a fixed periodic fee. Think of it like a gym membership for your health: you pay a flat monthly rate, and that covers your visits and basic services, cutting out the complex billing process for those specific services. This bill confirms that states can use this model in their Medicaid programs, often as part of a larger value-based care strategy.

The Subscription Model Hits Medicaid

For years, Medicaid has largely operated on a fee-for-service model, where doctors get paid for every visit, test, or procedure. This bill opens the door for states to experiment with a fixed-fee approach instead. This is a big deal because DPC models are often seen as a way to encourage more preventative care and better patient-doctor relationships, since the doctor isn't constantly focused on billing codes.

For a busy parent or worker on Medicaid, this could mean better access to their primary care doctor without the hassle of co-pays or complex bills for routine check-ups. The idea is that providers get predictable income and patients get predictable access. However, the bill is clear: this DPC arrangement only covers primary care. It doesn't change anything about how hospital stays, specialist visits, or medications are covered—those still fall under the existing Medicaid rules (Title XIX of the Social Security Act).

What the Fine Print Says About Scope

The legislation includes a critical "Rule of Construction" that serves as a guardrail. It explicitly states that this change does not alter existing statutory requirements regarding cost-sharing or the required amount, duration, and scope of medical assistance. In plain English, while the payment method for primary care can change to a fixed fee, the state still has to provide the same level of comprehensive coverage it always has. This is important: it prevents states from using DPC as a way to quietly cut benefits or impose new, prohibitive costs on enrollees.

The Clock is Ticking for HHS

This isn't just a green light for states; it’s also a homework assignment for the federal government. The Secretary of Health and Human Services (HHS) has two deadlines. First, within one year, they must hold open meetings and issue formal guidance to states on how to implement these DPC arrangements within Medicaid. This guidance will be crucial for ensuring consistency and preventing a patchwork of different rules across state lines.

Second, within two years, HHS must report back to Congress on how many states are actually using DPC, and, most importantly, analyze the quality and cost of care provided under these new arrangements. This focus on data collection is key. It means that while states get flexibility now, they will eventually have to prove that this DPC approach is actually improving outcomes and managing costs effectively, especially when implemented through Medicaid managed care organizations.

Who Stands to Gain (and Who Might Grumble)

This bill is a win for independent primary care physicians and practices who want the flexibility of the DPC model without being locked out of the Medicaid patient pool. For Medicaid patients, it could mean more time with their doctor and less bureaucratic friction for routine visits.

On the flip side, some existing Medicaid managed care organizations (MCOs) might feel the pinch. If states start contracting directly with independent DPC practices, it could reduce the necessity of MCOs in managing that part of the primary care network. Also, if a state decides to heavily favor DPC, it could potentially disrupt existing fee-for-service networks, impacting groups that are not set up for the fixed-fee model. This is where the future HHS guidance will need to step in and ensure a smooth transition and a level playing field.