Concierge bell With interest in concierge care growing amidst the COVID-19 pandemic, the regulations could have a wide-ranging effect for clients interested in concierge care. (Photo: Shutterstock)

In the latest of a series of guidance that generally expands the availability and use of health reimbursement arrangements (HRAs), the IRS recently proposed regulations dealing with direct primary care arrangements. More commonly known as "concierge care," a direct primary care arrangement allows an individual and a primary care physician enter a contract to cover the cost of medical care for a fee (without the involvement of a traditional third-party insurance company).

With interest in concierge care growing amidst the COVID-19 pandemic, the regulations could have a wide-ranging effect for clients interested in concierge care — they affect the medical expense deduction, availability of HRA reimbursements and eligibility for HSA participation.

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Robert Bloink

Robert Bloink, Esq., LL.M., has taught at the Texas A&M University School of Law and the Thomas Jefferson School of Law; in the past decade, Bloink has initiated $2B+ in insurance & alternative asset class portfolios, and previously served as a senior attorney in the IRS Office of Chief Counsel for the Large- and Mid-Sized Business Division. Bloink is also the co-author of Tax Facts, a reference solution that helps to answer critical tax questions and provides the latest tax developments.

William H. Byrnes

William Byrnes, Esq., LL.M., CWM, is an executive professor and associate dean of special projects at the Texas A&M University School of Law. A pioneer of online legal education, he also is the author or co-author of 20 tax books and legal treatises. Byrnes is also the co-author of Tax Facts, a reference solution that helps to answer critical tax questions and provides the latest tax developments.