1. Pricing limitations undermine professional autonomy and market efficiency The policy mandates that fees for uninsured services “must reasonably reflect professional costs, administrative costs, and the patient’s ability to pay.” This limits the physician’s autonomy in setting prices and disregards the fundamental principle that the value of professional expertise and time varies based on market demand, patient context, and unique circumstances in each practice. By requiring prices to be “reasonable,” the standard introduces ambiguity, which could chill innovation or competitive differentiation in service delivery. Physicians should be free to price according to their value proposition without being second-guessed by regulatory bodies, provided services remain legal and patients have choice. 2. Compulsory fee disclosures before service are redundant and may disrupt care The obligation to disclose or itemize all fees in advance of care for uninsured services places an undue administrative burden and could delay care, particularly in fast-paced or emotionally charged patient encounters. Informed patients can always request a fee schedule; a regulatory mandate for up-front disclosure micromanages professional judgment in communicating with patients. 3. Restrictions on signage, notices, and delegation of communication are inflexible The stipulation that “a general notice to patients is not sufficient” and that only the physician can make final decisions about fee disputes is unduly rigid. In larger medical practices or clinics, trained staff or electronic systems can efficiently communicate policies and handle most fee-related interactions, freeing up physicians to focus on clinical matters. 4. Prohibition of advance payments for urgent services limits practice sustainability Forbidding collection of payment in advance for uninsured urgent services that are not available elsewhere is illogical: it exposes practices to non-payment risks and may encourage abuse of these services by patients with no intention of paying. Physicians should have flexibility in managing financial risks in situations where the public system is not responsive. 5. Ban on fees for professional “availability” ignores the realities of standby care Disallowing fees for simply “being available” undervalues the significant professional and opportunity costs clinicians assume by making themselves accessible. Standby arrangements, especially in remote or concierge settings, are valuable and deserving of compensation—even if a specific act of care is not ultimately required. 6. Block fee constraints undermine innovation in practice delivery The requirements around block fees—such as forced patient choice and written disclosures—create barriers to innovative service packages and may stifle creative solutions for practice sustainability. In comparable industries, bundling and subscription offerings are commonplace; restricting physicians in this area inhibits the evolution of medical business models, especially in the face of underfunding of public services. 7. Anti-preferential treatment and cross-compensation rules are problematic The instruction that block fee payers cannot receive preferential access, and that no block fee can include services otherwise compensated, is overly prescriptive. In competitive markets, incentive structures (like loyalty rewards or bundled perks) are standard practice—so long as core insured services are not denied, flexibility in practice management should be preserved. Conclusion: The document’s recommendations, though well-intended, impede physician autonomy, business model innovation, and economic sustainability. More flexible, market-driven approaches—tempered with laws against clear abuses—are preferable to heavy-handed regulatory micromanagement.