"This footnote indicates that a [direct primary care (DPC)] arrangement funded by an employer, presumably including employee pre-tax contributions, would create a group health plan. The Proposed Regs do not otherwise address what would happen if an employer offered or paid for a DPC arrangement ... [M]any state laws do regulate DPCs as insurance. So, while the Proposed Regs are favorable from a federal tax perspective, there are a myriad of other compliance issues that an administrator or employer would need to address before making this arrangement available to employees."  MORE >>