Opening a Second DPC Location in 2027 (Signals, Staffing, Licenses and Leases)

When Should a DPC Practice Open a Second Location?

Open a second direct primary care location when your first site is full and the patients you are turning away live or work somewhere else. If the waitlist is near your current office, a second clinician or longer hours at the same address is cheaper and simpler. If your panel is not full yet, a second site adds another rent and more staff without fixing growth. Before you sign anything, plan for the registrations that follow each address (a CLIA certificate, possibly a DEA registration, NPI and state updates) and decide in writing how members use each site.

This guide is for DPC owners already running one practice who are weighing a new address. It covers the signals worth trusting, staffing, the registrations that attach to a location, the lease, and how members move between sites. It is not legal, tax or financial advice, and the parts that depend on your state need your own attorney, CPA and insurance broker.

How Do You Know It Is Time for a Second DPC Location?

The strongest signal is a full panel paired with demand from a different area. The DPC Alliance's State of DPC report (data collected from October to November 2024, published July 2026, 465 responses) found that 31.6% of physician respondents said their panel was full, and that full panels clustered in the 400 to 700 patient range. The same survey found that 89.3% of respondents run a single location, so a second site is a step few DPC owners in that sample had taken.

The AAFP's 2026 DPC data brief, which surveyed physicians in 2026 about their 2025 practices, reports an average panel of 504 patients in 2025 across all 313 respondents, 53% of them practicing in DPC. It also found that patient panel growth was the top challenge DPC respondents named (40%). That matters here, because a second location solves a capacity or geography problem. It does not solve a growth problem, and it adds a second set of fixed costs while you wait for the new site to fill.

Signals worth tracking in your own data before you decide:

• Your panel is at the size you defined as full, and you have closed enrollment or started a waitlist. Our break-even panel size guide helps you set that number for your hours and fees.
• The waitlist has an address. Sort waitlist and inquiry zip codes. If a real share of them sit in one other town or neighborhood, that is where a second site would fill.
• Current members are driving a long way. Look at where existing members live. A cluster far from the office is both a retention risk and a ready-made founding group for a new site.
• An employer wants you somewhere else. A contract with an employer whose people work across town can anchor a new location. Our guide to selling DPC to employers covers how those deals are built.
• You can test demand first. A founding member presale for the new site tells you whether people will pay before you sign a lease.

Second Location, Second Clinician or More Hours?

A second site is one of several ways to add capacity, and it is the one with the most moving parts. Compare it honestly with the options that keep everyone under one roof. Our guides on when to hire a second DPC physician and adding an NP or PA to a DPC go deeper on the same-site paths.

The AAFP brief shows more non-physician clinicians with their own panels per DPC office, on average. It found that 69% of DPC practices ran a single physician panel, while the average number of non-physician clinicians with independent panels per office more than doubled, from 0.61 in 2024 to 1.29 in 2025.

How Do You Staff a Second DPC Location?

Start with who is clinically in the room at each site and on which days. If you are the only physician, a second site means splitting your week, and every day you spend at the new site is a day the first site runs without you. If an NP or PA will staff the new site, check your state's supervision or collaboration rules for a clinician working at a different address from their supervising physician. Those rules differ by state, so start with our guide on whether nurse practitioners can open a DPC, then confirm with your state boards.

Support staff is the second question. In the AAFP brief, respondents practicing in DPC reported averages of 3.38 full-time equivalent nonclinical and administrative staff and 2.26 medical assistant FTEs, the largest staff categories in the survey. Among single-location practices in the DPC Alliance report, about a third had no support staff and another third had one staff member. A second site needs someone to answer the door, room patients and run point-of-care tests on the days it is open, even if the phones and messages are handled from one place.

For budgeting a medical assistant, the Bureau of Labor Statistics lists a median annual wage of $45,690 for medical assistants in May 2025.

Source: BLS Occupational Outlook Handbook, medical assistants.

If staff split their day between your two clinics, the drive counts. The Department of Labor's rule at 29 CFR 785.38 says travel from job site to job site during the workday must be counted as hours worked for nonexempt employees. Build that time into schedules, and ask your CPA how to handle mileage reimbursement. Our guide to hiring your first DPC medical assistant covers job descriptions and onboarding.

Which Licenses and Registrations Does Each DPC Location Need?

Some registrations belong to you as a clinician and travel with you. Others belong to a physical address and have to be repeated or updated for the new site. The table below sorts them, and our DPC credentialing and licenses checklist explains how to apply for each one.

CLIA for a second site

Under 42 CFR 493.35(a), a lab that performs only waived tests must file a separate application for each laboratory location. The exceptions in 493.35(b) are narrow. Labs that move from site to site, such as mobile units, health fairs and temporary testing locations, can work under the home base's certificate, and the other exceptions cover limited public health testing and hospital campuses. A second DPC office that runs a rapid strep or a urine dipstick is a fixed location, so plan on its own certificate.

CMS's fee schedule, effective January 27, 2024, lists a Certificate of Waiver at $248 for two years, per location. New York and Washington follow separate state processes.

Source: CMS CLIA certificate fee schedule.

DEA for a second site

Under 21 CFR 1301.12(a), you need a separate registration for each principal place of practice where controlled substances are dispensed. Paragraph (b)(3) carves out an office used by a practitioner who is registered at another location in the same state, where controlled substances are prescribed but neither administered nor dispensed as a regular part of practice, and where no supply is kept. If the new site will only send prescriptions, it may fall under that exception. If you will administer or dispense a controlled substance there, or keep any controlled substances on hand, register the address.

A practitioner registration costs $888 and lasts three years.

Source: 21 CFR 1301.13.

A site across a state line needs a license in that state, and if you will handle, dispense or prescribe controlled substances there, a DEA registration in that state and that state's controlled substance license where one is required. Our guide to telehealth prescribing rules for 2027 covers seeing members by video when they are located in another state.

NPI and Medicare opt-out

Your individual NPI does not change when you add a site, but your NPPES record should list the new practice location. If HIPAA covers your practice, 45 CFR 162.410 requires you to report changes to the required data elements in your NPPES record within 30 days. If you have opted out of Medicare, 42 CFR 405.410(b) says the affidavit goes to each Medicare Administrative Contractor you would otherwise bill, so a site in a different contractor's region may need its own filing. Our guide on how to opt out of Medicare for DPC covers the affidavit itself.

Dispensing deserves its own check. The AAFP brief found that 54% of DPC practices dispensed noncontrolled medications in-house, and states differ on whether a dispensing permit attaches to the physician or the address. Our guide to DPC dispensing, medications and labs and the state pages at /start-a-dpc are the place to start.

What Should You Check in the Lease for a Second Location?

The lease is a large commitment for a second site. Decide first whether the new site sits inside your existing entity or a new one, with your attorney and CPA, using our PLLC vs. LLC guide as background. Then read the lease with these questions in mind:

• Permitted use. Does the lease and the local zoning allow a medical office, including lab tests and medication storage, at this exact address?
• Term and exit. Does the term fit a site that might take a while to fill, and is there an early exit, a renewal option or a right to assign the lease if you sell or restructure?
• Build-out. Who pays for exam rooms, a sink, a lab corner and accessibility work, and is there a tenant improvement allowance?
• Schedule, if it is part-time. For a satellite open a few days a week, does the lease spell out exactly which days and hours you have the space?
• Who the landlord is. If the landlord is a hospital, a specialist or anyone you refer patients to, ask your attorney about the federal Anti-Kickback rules.

That last point has a specific rule behind it. The space rental safe harbor at 42 CFR 1001.952(b) requires, among its six standards, a signed written lease of at least one year, rent set in advance at fair market value that does not reflect referrals, and, for part-time space, a lease that specifies the exact schedule, length and rent for each interval. Whether it applies depends on whether any part of your business touches federal health care programs, so read our DPC Anti-Kickback and Stark basics and ask your attorney. Our guide to DPC office space in 2027 covers the rest of the space search.

How Do Members Move Between DPC Locations?

Decide this before the new site opens, and put it in the membership agreement. There are two basic shapes, and both can work.

• One membership, every site. Members book wherever is convenient. This is simplest to explain, but it means both sites need the member's chart, both front desks need the same schedule view, and your capacity planning has to account for members who move around.
• A home site, with visits elsewhere. Each member belongs to one site and one clinician, and can book at the other site when needed. This keeps continuity with one doctor and makes panel math cleaner per site.

Whichever you pick, keep one chart per patient that both sites can open, one phone number and message inbox that reaches the care team wherever they are, and one billing record per member. Some states' DPC laws spell out what a direct primary care agreement must contain, so check direct primary care laws by state before you change your agreement, and give existing members written notice of what changes for them.

If you are tempted to charge more for access to both sites, check the HSA math. Starting in 2026, Public Law 119-21 lets a direct primary care service arrangement sit alongside an HSA, as long as it meets the law's other conditions, including a fixed periodic fee as the sole compensation for care, and the combined monthly fees for all of a person's arrangements do not exceed a cap. For 2027, that cap is $150 for one person and $300 for a membership covering more than one person.

Source: IRS Rev. Proc. 2026-24.

A both-sites fee on top of a regular membership counts toward that combined total, and a per-visit charge for using the other site is not a fixed periodic fee. Our guide to DPC HSA rules for 2027 covers the details, and how to raise DPC membership prices covers telling members about any change.

What Changes Day to Day With Two DPC Locations?

The clinical work at a second site looks a lot like the first. What changes is the work between people who are no longer in the same hallway. A lab result arrives at one site for a patient seen at the other. A refill request lands in an inbox that the person at the new site cannot see. A medical assistant at the first site promises a callback, and the clinician who needs to make it is across town. In a single office, someone leans through a doorway and the loop closes. With two addresses, it closes only if the tools are connected and the task lands with the right person.

That is the part a dedicated tech team like Tabflows helps with. Tabflows connects the EHR, billing and messaging tools a clinic already uses, so follow-ups, tasks and patient context sit in one place for both sites. It is not an EHR, a billing system or a messaging app, and it works alongside the ones you have.

Track the new site on its own numbers from day one (sign-ups, cancellations and how long it takes to cover its own costs), using our guide to DPC metrics to track in 2027. Our DPC startup financing guide and DPC business plan template work for a second site as well as a first.

A Short Checklist Before You Sign

• Confirm the first site's panel is full by your own definition, and that the demand you are turning away lives near the new address.
• Test demand with a presale or an employer conversation before you commit to a lease.
• Decide who staffs the new site clinically on each day it is open, and check your state's rules for NP or PA supervision at a separate address.
• Choose the entity that will sign the lease, with your attorney and CPA.
• Read the lease for permitted use, term, exit, build-out and, for part-time space, the exact schedule.
• If the new site will run any test, get its CLIA certificate before testing starts. If it will handle, dispense or prescribe controlled substances, register it with DEA unless it qualifies as a prescribe-only office in the same state.
• Update NPPES within 30 days, and check whether your Medicare opt-out needs a new affidavit.
• Write into the membership agreement how members use each site, and keep any both-sites fee a fixed periodic fee inside the HSA cap.

A second location is a real milestone, and the owners who reach it have already built something patients want. Taking the time to get the registrations, the lease and the member experience right means the new site starts with the same trust the first one earned. For the bigger picture, our 2027 guide to starting a DPC practice covers the foundations, and the DPC Finder lists practices across the country.