CCLP testifies against Direct Primary Care cost-shift onto Medicaid patients

CCLP testifies against Direct Primary Care cost-shift onto Medicaid patients

by Bethany Pray, Esq.| Feb 18, 2026

Equity work, Health, Legislative Updates, Public Benefits, Research and Policy Analysis, Testimony

On February 17, 2026, CCLP Chief Legal and Policy Officer Bethany Pray, testified against House Bill 26-1096, Colorado Medicaid Access to Primary Care Services, in the House Health & Human Services Committee. CCLP is in an oppose position for HB26-1096 because it would allow Direct Primary Care providers to charge Medicaid patients hundreds of dollars for services that are otherwise free.

Madame Chair and members of the committee,

Thank you for the opportunity to testify today on HB26-1096. I'm Bethany Pray, Chief Legal and Policy Officer of the Colorado Center on Law and Policy, a statewide antipoverty organization that advocates in the areas of public benefits, income and housing. We have appreciated the sponsors' willingness to talk with us about Direct Primary Care (DPC), but we don't see a way to mitigate the damage this bill would do to the rights of Coloradans and the viability of Medicaid networks.

Medicaid members, whether or not they chose to use DPC, would be harmed by this policy. As DPC gains ground, providers leave traditional networks to become DPC providers. In fact, about 30% of providers who joined a DPC between 2018 and 2023 were leaving traditional networks, according to a recent study in Health Affairs.[1] And every departure matters. Authors of an article in the New England Journal of Medicine write, "a single full-time physician's departure from traditional primary care for a concierge or DPC practice could mean that roughly 2000 patients lose their PCP."[2]

Nearly all Medicaid enrollees struggle to make ends meet. Using updated data from CCLP's Self-Sufficiency Standard for Colorado, done in partnership with the University of Washington, we can see that a typical two-parent, one-child family in Boulder, Mesa or Weld County, who qualifies for Modified Adjusted Gross Income[3] Medicaid, does not make enough to cover even their housing, food and childcare expenses. Colorado is expensive. This bill would invite those families-or I would say, induce them, if providers leave networks-to pay hundreds or thousands of dollars a year for primary care services they should be able to get at no cost.

Medicaid patients who used DPC would also lose access to some vital protections for Medicaid patients. Our Medicaid Regional Accountable Entities[4] would have no basis for assessing who needs help getting to appointments, who is missing well-baby checks, whose high blood pressure is poorly managed, and could not reach out to address those issues. Patients would have no way to challenge service denials or file a Medicaid grievance against a provider.

We fully acknowledge that administrative burdens on providers for billing and record keeping are time-consuming. Primary care physicians are underpaid. So, we need solutions. But this is not the time to undermine patient protections, to undermine Medicaid provider networks, or to shift costs onto patients. I ask that you vote no on the bill and I welcome any questions about my testimony, and about costs, the role of private equity, federal efforts on DPC, or other related issues.

**********

[1] Jane M. Zhu, Trisha Marsh, Daniel Polsky, Aine Huntington, and Zirui Song. Growth in Number of Practices and Clinicians Participating in Concierge and Direct Primary Care, 2018-23. Health Affairs, December 2025. https://www.healthaffairs.org/doi/full/10.1377/hlthaff.2025.00656

[2] Zirui Song, Jane M. Zhu. Primary Care: From Common Good to Free-Market Commodity. New England Journal of Medicine, May 24, 2025. https://pmc.ncbi.nlm.nih.gov/articles/PMC12456663/

[3] Income Definitions for Marketplace and Medicaid Coverage. Beyond the Basics, August 2025. https://www.healthreformbeyondthebasics.org/key-facts-income-definitions-for-marketplace-and-medicaid-coverage/

[4] Health First Colorado Regional Organizations. Health First Colorado. https://www.healthfirstcolorado.com/health-first-colorado-regional-organizations/

Recent articles

Lessons from the Public Health Emergency Unwind in Colorado

Feb 17, 2026

CCLP testifies in support of the Worker Protection Act

Feb 11, 2026

CCLP testifies at the PUC Commissioner Panel

Feb 4, 2026

CCLP statement on federal actions in Minnesota

Feb 3, 2026