[cjy]

I checked and it appears there isn't really a loophole. Direct primary care providers are able to combine their offering with insurance and offer it on the ACA exchange, but they are subject to the same requirements of any other insurer. And none seem to be doing this yet:

From http://www.dpcare.org/specialties:

"H.R. 3590 recognizes DPC and allows DPC Medical Homes to offer coverage in health insurance exchanges in combination with a wraparound insurance policy provided by a qualified health plan (QHP). Working together, the two must satisfy all other essential health benefits requirements under H.R.3590. DPC practices provide all primary care in a monthly fee arrangement. The QHP is used for hospitalization, specialty care and other more costly services. The first DPC offering paired with a QHP in the healthcare marketplace went live in the Washington state exchange in January 2015. There are no DPC practices operating in the federally facilitated exchanges yet."