Discount Plan Organization (DPO): What is it and why should we know?

A “Discount Medical Plan Organization” was created in 2004 and is now simply called a “Discount Plan Organization (DPO).”

What is it and why should we know?

It is like a concierge medical agreement where a patient pays a fee, for example, $1,500/year to get quick access to a specific doctor.  Usually, the DPO is the only way to access specific practitioners.  It does little more than grant access, some prophylactic treatment, and the practitioners are usually the patients’ primary care physician.  You may see these organizations providing post-accident services.

Let’s make sure we are not also paying for the DPO in disguise through administrative CPT’s. Click here for the Bill Analysis.

Summary:

Discount Medical Plan Organizations (DMPOs) offer discount medical plans, in exchange for fees, dues, charges, or other consideration, which provide access for plan members to providers of medical services and the right to receive medical services from those providers at a discount. The Legislature established the regulatory scheme for DMPOs in 2004, which includes licensure, forms and rate filings and approval, disclosure requirements, and penalties.

CS/HB 577 renames a “Discount Medical Plan” and a “Discount Medical Plan Organization” as a “Discount Plan” and a “Discount Plan Organization” (DPO), and makes extensive conforming changes to part II of ch. 636, F.S., to reflect the new names. The bill clarifies the definition of a “Discount Plan” to exclude any plan that does not charge a fee to members. The bill removes all rate and form filing and approval requirements for DPOs. To increase flexibility in marketing and reduce administrative barriers for DPOs, the bill:

• Defines “first page”, upon which certain disclosures must appear, to mean the first page of any marketing material that first includes information describing benefits;
• Allows DPOs to delegate functions to marketers and binds DPOs to the actions of those marketers within the scope of the delegation; and
• Allows marketers and DPOs to commingle certain information on forms, advertisements, marketing materials, or brochures.

To maintain consumer protections for members and potential members of Discount Plans, the bill:

• Changes the disclosure requirements by requiring acknowledgement and acceptance of the disclosures before enrollment and creating visibility and follow up requirements for disclosures made by electronic means or telephone;
• Establishes new cancellation and reimbursement requirements for DPOs to disallow any charges beyond the effective cancellation date;
• Requires pro rata reimbursement of charges paid by a member for the months beyond the effective cancellation date; and
• Requires pro rata reimbursement for members who cancel during an open enrollment period, upon return of his or her discount card.

The bill does not have a fiscal impact on state or local government.

The bill became law on June 14, 2017, and is now Chapter 2017-112, Laws of Florida.

If you have any questions or would like to discuss this issue in greater detail, please feel free to contact Dennis LaRosa (dlarosa@roiglawyers.com/850-264-6389) or any ROIG Lawyers attorney of your choice.