Florida DPC Guide¶

Quick Summary: Florida has explicit DPC legislation (F.S. § 624.27) and permits physician medication dispensing with simple registration. Large population, no state income tax, and a growing DPC community make Florida attractive for DPC practice.

[!CAUTION] Verify Current Law: Always confirm current regulations with the Florida Board of Medicine and review Florida Statutes Chapter 624 for the most current statutory language.

At a Glance¶

DPC Law Status¶

Legislation¶

Statute: Florida Statutes § 624.27

Effective Date: 2017

Florida's DPC legislation provides clear exemption from insurance regulation and establishes the legal framework for DPC practice.

Key provisions: - DPC agreements explicitly not insurance - Primary care services defined - Written agreement required - Disclosure requirements specified - Cannot guarantee health outcomes

What This Means¶

• DPC practices operate outside insurance regulatory framework
• Clear legal standing for membership model
• Standard business regulations apply
• Consumer protection built into statute

Medication Dispensing¶

Regulatory Status¶

Florida permits physician dispensing with simple registration.

Requirements¶

• DEA Registration: Required for controlled substances
• State Registration: Register as a dispensing practitioner with Florida Board of Medicine
• Controlled Substances: Subject to additional restrictions (see below)
• Labeling: Follow Florida labeling requirements
• Record Keeping: Maintain dispensing records per Board requirements

Controlled Substance Considerations¶

Florida has specific regulations regarding controlled substance dispensing: - Schedule II opioids have dispensing limitations - Three-day supply limit for certain Schedule II opioids (exceptions for specific conditions) - PDMP (Prescription Drug Monitoring Program) checking required - Review current Board of Medicine guidance

Registration Process¶

1. Register as dispensing practitioner with Florida Board of Medicine
2. Complete required application
3. Pay applicable fees
4. Maintain compliance with dispensing regulations

Licensing and Registration¶

Medical License¶

Board: Florida Board of Medicine (MD) / Florida Board of Osteopathic Medicine (DO)

Website: flhealthsource.gov

Requirements: - MD or DO degree from accredited school - Completion of accredited residency - Passing examination scores - Good standing in all jurisdictions

Business Registration¶

Entity Registration: Florida Division of Corporations

Website: dos.myflorida.com/sunbiz

Notes: - Register LLC, PLLC, PA, or corporation - Annual report required - Florida has no state personal income tax

DEA Registration¶

Required for: Prescribing and dispensing controlled substances

Website: deadiversion.usdoj.gov

Medicare Considerations¶

Opt-Out Process¶

Florida follows the standard federal Medicare opt-out process.

MAC for Florida: First Coast Service Options (J9 jurisdiction for North Florida) / First Coast Service Options (J9 jurisdiction for South Florida)

See Medicare Opt-Out Guide for detailed process.

Medicare Population¶

Florida has a large Medicare population. Consider: - Medicare opt-out implications for your patient base - Private contract requirements for Medicare beneficiaries - Clear communication about Medicare status

Key Resources¶

State Agencies¶

Professional Organizations¶

DPC Resources¶

• DPC Frontier Florida

State-Specific Considerations¶

Large Population¶

• Third most populous state
• Large potential patient base
• Varied demographics across regions

No State Income Tax¶

Florida has no state personal income tax, improving take-home income.

Regional Variation¶

• South Florida: Dense, competitive, diverse population
• Central Florida: Growing, varied communities
• North Florida: More rural, different character
• Tampa Bay/Gulf Coast: Mix of urban and suburban

Seasonal Residents¶

• Significant "snowbird" population
• Consider seasonal membership options
• Telehealth for patients who travel

Medicare Demographics¶

• High Medicare population (retirees)
• Understand opt-out implications
• Clear communication essential

Malpractice Environment¶

• Florida has had malpractice challenges historically
• Review current malpractice market
• Consider tail coverage needs

Checklist for Starting DPC in Florida¶

• Obtain or verify Florida medical license
• Register business entity with Division of Corporations
• Obtain EIN from IRS
• Register with DEA (if prescribing controlled substances)
• Register as dispensing practitioner (if dispensing medications)
• Review controlled substance dispensing regulations
• Secure malpractice insurance
• Develop membership agreement meeting statutory requirements
• File Medicare opt-out affidavit (if applicable)

Related Guides¶

• Medicare Opt-Out Guide
• Dispensing Medications
• State DPC Laws Overview

[!NOTE] This guide provides general information. Laws and regulations change. Verify current requirements with the Florida Board of Medicine and Board of Pharmacy.

Florida's large population, no income tax, and DPC legislation make it an attractive state for DPC practice, though controlled substance regulations require attention.