Retainer Medicine

I was surprised to see this press release from DCBS, I don't recall any public discussion of how retainer services would be regulated during the last legislative session.  The registration asks for a business plan with specifics on how and when prepaid fees would be subject to refund, and a filter-type question on bankruptcy.  Some thoughts:

• What is to stop doctors from offering contracts that bar refunds under any condition?  Conceivably people could be paying up to a year's worth of fees up front.
• Who is buying these contracts?  Are they well-to-do people who are buying luxury, or is it low income people with cat coverage?  The lack of regulatory specifics suggest this is aimed at the former group, but some material suggests the latter.  If so the regulations are way too weak, see "predatory lending" for how that story ends.
• What protection is there against a doctor blowing all the money up front, or conversely taking on an arbitrarily large number of patients and never being available for appointments?

One could argue that consumers need no more protection from retainer medicine then they do from plumbers or electricians, but there is a big difference.  Society teaches us to be skeptical of contractors, from the adage about getting multiple quotes to fear stories about scams and rip-offs.  We don't have the same skepticism of doctors, quite the opposite.  People are taught they should listen to their doctors and do what they say.  That can lead to all kinds of conflict of interest situations even when the financing is at arms length via insurance, how does this work when the money is front and center?