Wisconsin has no DPC laws at present, but there are multiple DPC practices in operation and Senate Bill 670 has been proposed to clarify and DPC is not insurance while simultaneously initiating a Medicaid direct primary care pilot program.  

Most of the bill is well written and helpful.  If this passes Wisconsin would be the first state to pass DPC defining "not insurance" language in the same piece of legislation as a more controversial Medicaid pilot.  Typically "not insurance" efforts pass with bipartisan support, but pilot programs are a tougher sell. I have a few detailed thoughts:

Section 1(3)(a) comes dangerously close to the old HMO gatekeeper provision and I am not convinced that the language in Section 1(3)(b) will be easily enforced.  

Section 2(2)(h) is missing important language.  As written this section prohibits employers, Medicaid (the pilot proposed in Section 1) or theoretically the patient's Grandma from paying the monthly DPC fee.  I would propose the following language addition.  "The health care provider and the patient are prohibited from billing an insurer or any other third party on a fee for service basis for the routine health care services provided under the Agreement.  

Section 2(3) is not the ideal scenario.  If this language was what it took to get the insurance commissioner's office to withdraw their objection, then okay.  Ideally this entire section should not be needed.  DPC physicians should be policed by the medical board, not the department of insurance.

Be sure to review the Wisconsin Insurance Code when planning your DPC practice.