Skip to main content
The full inventory of what a practice owner must do: becoming an owner, choosing a revenue model, building the patient payment stack, and the recurring calendar. The launch checklist is the condensed version. Use this page as a pre-launch audit, an operating calendar, and a diagnostic (“what are we not doing?”).

​
Part 1: The universal layer

Applies to every model.

​
Part 2: Choose your revenue model

​
A. Insurance-based (the guide’s default path)

Credentialing → EFT/ERA per payer → test the full cycle → reconciliation habit. Timeline set by the 90-to-180-day credentialing clock.

​
B. Cash-pay / direct pay

No payer machinery, but three obligations cash-pay owners routinely miss:
  • Good Faith Estimates are mandatory. The No Surprises Act requires written GFEs for uninsured and self-pay patients for scheduled services (45 C.F.R. § 149.610; CMS). Build it into scheduling, not billing.
  • Medicare doesn’t vanish because you don’t bill it. Treating Medicare beneficiaries for cash generally requires formally opting out with compliant private contracts (42 U.S.C. § 1395a(b)). Decide your posture explicitly.
  • DPC and membership models are exempt from insurance regulation in many states, but only if the agreement fits the state’s DPC statute. Concierge hybrids that also bill insurance need duplicate-billing review. Publish transparent pricing.
Everything in Part 1 still applies. Cash-pay is a billing model, not a compliance exemption.

​
C. Telehealth-first

  • Licensure where the patient sits. A license or compact privilege (IMLC, PSYPACT, NLC) in every state you serve. Your licensure map is your market map.
  • Prescribing limits. Ryan Haight requires an in-person exam before controlled-substance prescribing, subject to DEA flexibilities currently extended through 2026, with state rules layered on (overview). A model that depends on controlled substances is concentrated regulatory risk.
  • State variation: modality and consent rules, payment parity, Medicare’s shifting telehealth rules. Assign an owner to track them.
  • Platform: HIPAA-compliant video with a BAA, identity verification, EPCS for controlled substances, an emergency plan per patient state.
  • Multi-state means multi-everything: licensure, Medicaid, malpractice territory, tax nexus, and often an early arrival at the MSO structure.

​
D. Hybrid

Insurance base plus cash lines plus telehealth follow-ups. The risks are the seams: keep cash prices consistent with GFE duties, never routinely waive copays on insured services (an inducement/AKS problem), and make sure the PM system segregates the streams so reconciliation stays possible.

​
Part 3: Patient payment stack

  • Card processing: rates, card-on-file, surcharge rules (state law plus payer contracts).
  • Pre-service collection: eligibility → estimate → deposit or card authorization. With high deductibles, this is the difference between 95% and 70% patient collection.
  • Third-party financing (Cherry, Sunbit, CareCredit et al.): practice paid upfront minus a merchant fee; patient repays the financer (landscape). Diligence before signing: merchant fee by plan length, approval rates for your demographics, who services the loan (their collections behavior is your brand), deferred-interest disclosure (regulators are watching medical credit products), and refund/chargeback flow when treatment plans change. Offer financing at treatment-plan presentation, not at collections.
  • Self-carried plans: no merchant fee, your A/R risk. Fine for small balances on card-on-file autopay.
  • Statements, dunning, and the refund loop.

​
Part 4: The recurring calendar

If a task here has no owner in your practice, that’s the finding.