How do I add cash-pay procedures to my medical practice?

Written by Oscar Tellez, founder of Regen Med Academy. Oscar is not a clinician. This post is education for licensed providers and is not medical advice. Last updated October 15, 2026.

You add cash-pay procedures to a medical practice one step at a time, starting with one service that fits the patients you already see and the license you already hold. First you confirm the service is legal in your state for your license. Then you train before you buy, put your consent, prices and payment rules in writing, get your staff ready, check your marketing words, and start small. This post walks through those steps in order.

Why do providers stall when adding cash-pay services?

I say this a lot: “A five minute consultation is not enough to really find out what a patient needs.” A service that patients pay for directly is one way a practice tries to get that time back.

Wanting it and doing it are two different things, though. Here is how I describe the providers who call me: “They want to get rid of insurance, but they’re scared not to, because that’s all they know.”

That fear is fair, because their staff, their software and their schedule were all built around insurance. I started Regen Portal because doctors kept asking me for consulting and marketing help after their marketing companies let them down. A lot of that help comes down to doing things in the right order, and that is what this post lays out.

The order matters because each step depends on the one before it. If you buy a machine before you check your scope, you may own a machine you are not allowed to use. Hard now, easy later is the short way to say it.

How do I start offering cash-pay services?

You start with two things you already have, which are your patients and your license.

Begin with your patients, and listen to what they ask about in a normal week. What do they ask for that you do not offer today, and what do you send to another office? Have your front desk write those requests down for a few weeks, because a list from your own practice tells you more than any trend report.

Then hold that list up against your license. What you may perform is set by your own state license and board. A Certificate of Completion does not extend it. So a service that your patients ask for, but your license does not cover, cannot be your first service.

Pick one service to begin with, and only one. Every new service brings its own rules, supplies, consent form and training, and one is enough to learn on.

Let’s say you run a family practice with two providers, and your front desk keeps a simple tally of every request for something you do not offer. After a few weeks, two or three requests fill most of the page. That short list is where you start. Which service to choose from it needs a post of its own.

Is the service legal in my state for my license?

This step comes before you spend any money. It is your responsibility to confirm the modality is legal in your state for your license. The authority on your own scope is your licensing board, not us.

There are two layers to check, and the federal layer comes first. What is the product or the device, and what has FDA approved it or cleared it for?

PRP is a useful example. FDA lists the systems that prepare it as a platelet and plasma separator for bone graft handling. In plain words, the devices that prepare PRP are FDA cleared for use with bone graft material, and injecting PRP is an off-label use.

Is off-label use of a device allowed? Federal law speaks to it in the section on the practice of medicine. It says the law is not to be read to limit a practitioner’s authority “to prescribe or administer any legally marketed device to a patient for any condition or disease within a legitimate health care practitioner-patient relationship.”

In plain words, a licensed provider may use a legally marketed device off-label inside a real provider-patient relationship. What the clinic may say about that use in its marketing is a separate question, and we get to it below.

The second layer is your state. Your board decides what your license may perform, what you may hand to your staff, and who must supervise. Nurse practitioners have one more thing to look up, because the AANP sorts the states into full practice, reduced practice and restricted practice.

State law in this field changes, sometimes more than once a year. Our reading of each state, with its sources and the date we checked, is on the rules by state page. It is a starting point, not legal advice.

Which questions belong to my attorney, my board, my carrier and my biller?

Some questions in this roadmap are not ours to answer, and they are not yours to guess at. Each one has a person whose job it is to answer it.

• Ask your attorney, in your own state, how the practice should be set up to offer this service, who may own it, and whether you need a medical director. These rules change from state to state.
• Ask your licensing board whether you may perform the procedure under your license, which tasks you may hand to your staff, and under what supervision.
• Ask your malpractice carrier whether the new procedure is covered under your policy, and get the answer in writing.
• Ask your biller whether the plans you work with cover the service. If you plan to stay in network, ask how to keep a service the patient pays for apart from your insurance work.
• Ask your accountant or tax adviser how to record and report the new service.

This post does not answer any of those five, and no course or sales rep should answer them for you. On coverage, here is all we say. You are responsible for your own coverage. Talk to us and we will help you work out what to ask your carrier.

Why should I train before I buy anything?

The rule is to train first and buy second. Here’s why. Before you train, you do not yet know what you need, and that is the moment when it is easiest to sell you something.

Providers tell us about this. They signed up for a course, and what was sold as training turned out to be a product pitch. They went home and still did not feel ready to see a patient.

A sales sheet can also blur words that mean different things, and “cleared,” “approved” and “registered” are three different words at FDA. Here is FDA’s own sentence on that: “Mere registration of an establishment or listing of a drug or device does not denote approval of the establishment, the drug or device.” So read the clearance for the exact system a seller shows you, and see what it was cleared for.

What should the training itself look like? It should be hands-on with a consenting patient, under supervision, and it should be plain about its limits. A day or a weekend does not make a specialist. What a course gives you is enough supervised contact to begin, and people to call afterward.

If you already own a system, bring it and learn on that one. If PRP is the service you picked, see our posts on choosing a PRP training program and on adding PRP to a medical practice.

What should be in writing before the first patient?

Three things should be on paper before anyone books: your consent form, your pricing policy and your payment policy.

Start with consent, and bring your attorney a short list of what you want the form to say in plain words. It should say what the service is, what its FDA status is, and what is known and not known about it. It should also say what else the patient could choose and what the service costs. If the use is off-label, it should say “off-label” and explain the word.

Any sample form you get from a course, ours included, is a teaching template, so your own attorney should review it before a patient signs it.

Next is the pricing policy. Decide the price once, write it down, and decide who in the office may change it. The Federation of State Medical Boards has a line about fees in its 2018 policy on regenerative and stem cell practices: “Physicians should refrain from charging excessive fees for treatments provided.”

There is also a federal rule to ask about. CMS tells patients that a good faith estimate is “a list of expected charges before you get health care items or services,” and that it applies when a patient has no insurance or chooses not to use it. CMS adds: “In most cases, providers and facilities must give you an estimate when you schedule care at least 3 business days in advance, or if you ask for one.” How that rule applies to your service is a question for your attorney or your biller.

Last is the payment policy. When is payment due, and what happens if a patient cancels or changes their mind after paying? Put the answers on one short page, hand it to every patient before the visit, and have your attorney read it too.

How do I get my staff and front desk ready?

Your front desk will hear the first question about the new service, and it will usually come by phone. So the people who answer the phone need training as much as the person who holds the syringe.

Every person on your team should be able to do four things. They should be able to say what the service is in one or two plain sentences. They should know the price and the payment policy. They should know what they may never say, which is anything that sounds like a promise, and they should know when to hand a question to a licensed provider.

Then settle who does what. Which tasks may a medical assistant do, and which ones belong to a nurse or to you? That is a scope question, so it goes to your board, not to a sales rep or a course.

Give the visit enough time on the schedule as well. A patient who pays out of pocket will have questions, and a short slot does not leave room for them. Before the first real patient, walk your team through one full visit, from the first phone call to the follow-up call.

What can I say in my marketing?

Our rule is short. You may say what the service is, who performs it, what it costs and what its status is. You may not promise what it will do for a patient.

Where does our rule come from? The FTC’s Health Products Compliance Guidance starts from one line: “Advertising must be truthful and not misleading.” It says you need “adequate substantiation for all objective product claims” before an ad runs. It also holds you responsible for claims that are “suggested or reasonably implied,” so a photo or a headline can carry a claim too.

Patient stories fall under the same guidance. It says, “Testimonials that report results more dramatic than users can generally expect are likely to be deceptive,” and it says that adding a line such as “Results not typical” does not fix them.

State boards can read your marketing too. In the same 2018 policy, the Federation of State Medical Boards said boards should review “professional marketing materials and claims, including any office/clinic and/or doctor websites” when they look into a complaint.

So read every page, post, brochure and phone script before the service goes live. Strike any line that says what the service will do for a patient, and ask your attorney to review what is left.

How small should I start?

Start smaller than you think you need to. This is what I tell the providers who train with us: “When you leave out of here, you are going to be confident enough to where you can essentially start practicing on your family and friends and staff to start off.”

Why those people first? They know you, so they are more likely to tell you what the visit was like, from the phone call to the follow-up.

A friend in your chair is still a patient. Use the same consent form, the same chart notes and the same policies you wrote in the step above. Ask your board whether it has its own rules about family members and employees as patients, and follow them.

Then add outside patients slowly. Keep the schedule light, leave long slots, and call the clinician who trained you when something looks different from the day you trained.

What should I watch in the first months?

Watch the things you can count in your own practice. This list has no income figure in it, because nobody outside your practice can know that number.

• Watch the questions patients ask, and fix your phone script and your consent form where the same question keeps coming up.
• Watch your paperwork. Is the consent signed, and is the chart complete, on every single case?
• Watch your time and your costs. How long does a visit really take, and what do the supplies and the staff time for one case add up to in your own numbers?
• Watch your marketing words. New staff and new posts can drift toward promises, so read what is public again every month.
• Watch for anything that did not go as planned, and write down what happened and who you called.

On that last point, know where problems with a product or a device get reported. FDA describes MedWatch as “the FDA’s medical product safety reporting program for health professionals, patients and consumers.” Whether you have a duty to report an event, and to whom, is a question for your attorney and your board.

When do you add a second service? Add it when the first one runs without you thinking about each step, and when your team can explain it without a script.

Where does Regen Med Academy fit in this roadmap?

We fit in two of the steps, and we stay out of the others. Regen Med Academy is an education company, so we sell education and nothing else. We are not tied to any vendor, and we take no commission.

The first place we fit is the training step. All of our training is private, and it comes in two shapes. You can come to an instructor’s location, which starts at $5,000. Or the instructor can come to your practice and train you with your own staff, which starts at $10,000 with travel and lodging inside the quote.

Those are starting figures, and every engagement is quoted. You leave with a Certificate of Completion, your course materials, sample consent forms and ongoing access to our clinicians.

The second place we fit is the plan. We review your practice, including its branding, marketing, operations and strategy, and we give you a written practice roadmap. The review is included, and you keep what we find whether you train with us or not.

Where do we stay out? We do not give legal, tax or billing advice, we do not decide your scope, and we do not provide your malpractice coverage. We also do not offer CME or credit hours of any kind, and the certificate is not a license.

Frequently asked questions

Do I have to stop taking insurance to add a cash-pay service?

Adding one service that patients pay for does not, by itself, turn yours into a cash based medical practice. Whether you can keep your insurance work and add a service beside it, and how, depends on your payer contracts and your state. Take that question to your biller and your attorney before you set a price.

How long does it take to add a first cash-pay service?

There is no standard answer, and we will not give you a number of weeks. The time depends on how fast your board, your attorney and your carrier answer you, when you can train, and how ready your staff is. Do not let a date on the calendar push you past a step.

Can a nurse practitioner or a PA add a cash-pay procedure?

That depends on the state, the license and the procedure, so nobody can answer it for every reader at once. What you may perform is set by your own state license and board. A Certificate of Completion does not extend it. Start with your board.

Do I need new malpractice coverage for a new procedure?

Do not assume your current policy covers a new service. You are responsible for your own coverage. Call your carrier before you train, describe the procedure in plain words, and ask for the answer in writing. Talk to us and we will help you work out what to ask your carrier.

Can my market afford a cash-pay service?

Providers ask us this before they book, and we cannot answer it from the outside. Nobody can promise that patients will come or that they will pay. What you control is the consultation. A good one gives the patient time, explains what the service is and what its status is, states the full price, and lets the patient decide without pressure.

Key takeaways

• Start with the patients you already see and the license you already hold, and pick one service.
• Confirm the service is legal in your state for your license before you spend money. Your board is the authority on your scope.
• Train before you buy, and read the clearance for any system a seller shows you.
• Put your consent form, pricing policy and payment policy in writing, and have your attorney review them.
• Train the front desk too, and take the question of who does what to your board.
• In marketing, say what the service is and what its status is. Do not promise what it will do.
• Start with staff, family and friends, and keep the same paperwork for them as for anyone.

RMA disclosure

Regenerative Medicine Academy (RMA) is an education company. We train licensed providers in some of the techniques this post covers. This post is education only. It is not medical, legal, business, tax or financial advice.

It is your responsibility to confirm the modality is legal in your state for your license. Do that before you book. How your practice is set up to offer a new service is a question for your own attorney in your own state.

Your next step

Start a list of what your patients ask for, and take the scope question to your board. If you want to begin with the rules, get the free FDA course, which is self-paced and takes about 45 minutes. When you have picked a service, see all courses or request a date now. A person reads it and calls you back within one business day.