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Many primary care physicians are dissatisfied and approaching burnout due to high-volume practices and impersonal "assembly line" care that is not fullfilling or sustainable. The American Academy of Family Physicians is promoting "Direct Patient Care" - i.e. charging extra "Non-Covered Benefit Fees" or a monthly membership premium to augment practice income and allow for lower volumes and smaller patient panel sizes. However, these types of payment models seem fraught with the potential to violate existing insurance contracts or Medicare CMS statutes, and these products may even be interpreted as "health insurance" - subject to all the oversight, requirements, and regulation applicable to insurance products. Are these valid concerns?