PlainBillCongress, translated.Legislation. Context. Public interest.Referred to the House Committee on Ways and Means.
Congressional Research Service
No official summary is available in the imported record yet.
People & committees
Rep. Smucker, Lloyd [R-PA-11] · R–PA
Legislative record
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Referred to the House Committee on Ways and Means.
Introduced in House
Introduced in House
Primary sources
Text links open the official source. We also preserved the text version used in the PlainBill explanation below.
Source last updated: Oct 7, 2026. Consult Congress.gov for the current record.
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PlainBill explanation
Based on the full Introduced in House · 2025-02-05 text. This explanation has not received human editorial review. This overview describes the proposal’s major provisions; it does not establish what its real-world effects would be.
The proposed Primary Care Enhancement Act of 2025 would change tax treatment for people receiving primary care for a fixed recurring fee. Qualifying arrangements would not count as health plans under a specified tax rule, and their fees would be treated as medical expenses under the amended provision. Fee limits and service exclusions would restrict which arrangements qualify.
This Act may be cited as the Primary Care Enhancement Act of 2025.
A direct primary care service arrangement shall not be treated as a health plan for purposes of subparagraph (A)(ii).
if the sole compensation for such care is a fixed periodic fee.
(b) Direct primary care service arrangement fees treated as medical expenses
such term shall not include any arrangement if the aggregate fees for all direct primary care service arrangements (determined without regard to this subclause) with respect to such individual for such month exceed $150
the term primary care services shall not include— (I) procedures that require the use of general anesthesia, (II) prescription drugs (other than vaccines), and (III) laboratory services not typically administered in an ambulatory primary care setting.
The bill would exclude qualifying direct primary care arrangements from treatment as health plans specifically for Internal Revenue Code section 223(c)(1)(A)(ii). It does not state a general exclusion from all health-plan rules.
Section 223(c)(1) of the Internal Revenue Code of 1986 is amended by adding at the end the following new subparagraph: (E) Treatment of direct primary care service arrangements (i) In general A direct primary care service arrangement shall not be treated as a health plan for purposes of subparagraph (A)(ii).
A qualifying arrangement would provide only primary care, with a fixed recurring fee as the sole payment for that care. The bill uses definitions of medical care and primary care practitioners from other statutes, with a stated exception to the practitioner definition.
The term direct primary care service arrangement means, with respect to any individual, an arrangement under which such individual is provided medical care (as defined in section 213(d)) consisting solely of primary care services provided by primary care practitioners (as defined in section 1833(x)(2)(A) of the Social Security Act, determined without regard to clause (ii) thereof), if the sole compensation for such care is a fixed periodic fee.
For any month, an arrangement would not qualify if a person's combined fees for all such arrangements exceeded $150. The limit would double to $300 if any of that person's arrangements covered more than one individual.
With respect to any individual for any month, such term shall not include any arrangement if the aggregate fees for all direct primary care service arrangements (determined without regard to this subclause) with respect to such individual for such month exceed $150 (twice such dollar amount in the case of an individual with any direct primary care service arrangement (as so determined) that covers more than one individual).
For this definition, primary care would exclude procedures requiring general anesthesia, prescription drugs other than vaccines, and laboratory services not typically provided in an outpatient primary care setting.
For purposes of this paragraph, the term primary care services shall not include— (I) procedures that require the use of general anesthesia, (II) prescription drugs (other than vaccines), and (III) laboratory services not typically administered in an ambulatory primary care setting.
The Secretary administering the tax provision would have to issue regulations or other guidance on the excluded services after consulting the Secretary of Health and Human Services.
The Secretary, after consultation with the Secretary of Health and Human Services, shall issue regulations or other guidance regarding the application of this clause.
The bill would add direct primary care arrangements to section 223(d)(2)(C), under a provision titled as treating arrangement fees as medical expenses. The surrounding existing statutory rules are not reproduced.
(b) Direct primary care service arrangement fees treated as medical expenses Section 223(d)(2)(C) of such Code is amended by striking or at the end of clause (iii), by striking the period at the end of clause (iv) and inserting , or, and by adding at the end the following new clause: (v) any direct primary care service arrangement.
The bill proposes an inflation adjustment using 2025 as the reference calendar year for tax years beginning after 2026. However, the adjustment refers to a dollar amount in subparagraph (D), while the bill places its new arrangement rules in subparagraph (E), making the adjustment's application uncertain.
(c) Inflation adjustment Section 223(g)(1) of such Code is amended— (1) by inserting , (c)(1)(D)(ii)(II), after (b)(2) each place it appears
(iii) in the case of the dollar amount in subsection (c)(1)(D)(ii)(II) for taxable years beginning in calendar years after 2026, calendar year 2025.
Section 223(c)(1) of the Internal Revenue Code of 1986 is amended by adding at the end the following new subparagraph: (E) Treatment of direct primary care service arrangements
The bill proposes reporting total fees on employees' W–2 forms for direct primary care arrangements provided in connection with employment. Its reference to the arrangement definition points to subparagraph (D), although the new definition is placed in subparagraph (E).
(d) Reporting of direct primary care service arrangement fees on W–2 Section 6051(a) of such Code is amended
(18) in the case of a direct primary care service arrangement (as defined in section 223(c)(1)(D)(ii)) which is provided in connection with employment, the aggregate fees for such arrangement for such employee.
Section 223(c)(1) of the Internal Revenue Code of 1986 is amended by adding at the end the following new subparagraph: (E) Treatment of direct primary care service arrangements
The proposed amendments would apply to months beginning after December 31, 2025, within tax years ending after that date.
The amendments made by this section shall apply to months beginning after December 31, 2025, in taxable years ending after such date.
The supplied action snapshot, updated October 7, 2026, records introduction in the House and referral to the House Committee on Ways and Means on February 5, 2025.
Source snapshot updated 2026-10-07T19:48:53Z. 2025-02-05: Referred to the House Committee on Ways and Means. 2025-02-05: Introduced in House
A closer look
Reviewed version: Introduced in House · 2025-02-05. These findings describe provisions and who may benefit; they are not judgments of waste, corruption, or motive.
This review covers the supplied bill text. “None identified” does not rule out provisions in later versions or accompanying reports and disclosures.
Provisions outside the bill’s main subject, or policy changes attached to appropriations.
None identified in the reviewed text
No unrelated riders were identified in the complete supplied introduced text. This conclusion is limited to that version and does not establish attachment history or the contents of other versions or accompanying materials.
Spending directed to particular recipients or places outside ordinary competitive or formula-based allocation.
None identified in the reviewed text
No earmarks were identified in the complete supplied introduced text. This conclusion is limited to that version; accompanying materials that could establish formal earmark status are not supplied.
Narrow exceptions, exemptions, or preferential treatment that warrant a closer look.
None identified in the reviewed text
No materially narrow special benefits beyond the main policy's ordinary coverage and eligibility rules were identified in the complete supplied introduced text. This conclusion does not extend to other versions or accompanying materials.
Full text preserved for this analysis. Legislative record snapshot: Oct 7, 2026. How PlainBill uses AI