Zocdoc's Per-Booking Model Gains Regulatory Approval

Zocdoc, a platform connecting patients and doctors, secured approval for its payment structure. Founded in 2007, the company allows users to book appointments online. Initially using a subscription model, Zocdoc shifted to a per-booking system where healthcare providers pay only for confirmed appointments. This change aimed to better align incentives and reduce provider churn. However, the per-booking model raised concerns about violating the Anti-Kickback Statute (AKS), which restricts compensation for referrals involving federally funded healthcare services. Instead of directly challenging regulators, Zocdoc proactively engaged with the Office of Inspector General (OIG) to seek legal validation. In 2019, the OIG approved Zocdoc's model, confirming that transactional payment structures can operate legally within healthcare if safeguards protect patient choice and ensure market fairness. This regulatory clearance allows other digital health platforms to explore outcome-based payment models. Zocdoc's success demonstrates how healthcare companies can navigate complex regulations to improve access and efficiency. The company's approach offers a blueprint for other platforms seeking to implement similar payment structures while adhering to legal requirements.