Concierge medicine SEP + gold IRA stacking

Updated: June 23, 2026

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If you practice family medicine, internal medicine, or a specialty and you add concierge revenue alongside a continuing hospital W-2 role, you open a second retirement plan that the employed-side 403(b) cannot give you. The concierge entity, not the hospital, sponsors it, and that single fact is what unlocks the extra capacity.

What changes in practice: the concierge self-employment earnings fund a SEP IRA whose annual ceiling is set by IRC §408(k), not by the elective-deferral cap that limits your 403(b). This guide walks the full sequence, from the entity-structure choice to the SEP computation, the controlled-group check against your employer, and finally a sized, IRS-approved metals slice under IRC §408(m).

The first decision in the sequence is the entity structure of the concierge practice itself. A solo concierge clinic billed as a sole proprietorship reports net earnings on Schedule C; the same revenue inside a single-member LLC taxed as an S corporation produces W-2 wages plus a residual K-1 distribution. The SEP compensation base differs materially between the two, so you settle the structure before you size a single contribution.

The destination decision, where any post-rollover gold IRA slice ends up, sits at the end of the sequence and is the most reversible part of the planning. Even there, the dealer you pick matters more than the metal you pick. Before the destination custodian receives any funds, screen the dealer against the 2026 OPRS dealer list of operators we caution against.

Three adjacent layers each have their own guide. The Stark Law layer that interacts with any continued financial relationship to the W-2 hospital system is in our Stark Law and 403(b) practice acquisition guide. The asset-protection layer underneath any IRA wrapper is in the malpractice asset-protection framework for physicians.

The in-service mechanic at the W-2 plan is in the physician 403(b) in-service distribution guide. The phasing-down arc that often runs alongside concierge expansion is in the late-career physician 403(b) phasing-down sequencing guide.

What concierge medicine actually changes about contribution capacity

The retirement-side change a concierge practice introduces is a second compensation source, separate from your W-2 practice, that can sponsor its own retirement plan. Net earnings from self-employment under IRC §401(c)(2) form the compensation base for a SEP IRA, a Solo 401(k), or a defined-benefit plan, depending on the entity structure and the contribution target.

The W-2 elective-deferral cap at the hospital 403(b) does not bind the concierge-side contribution. The controlled-group rules under IRC §414(b) and §414(c) do not aggregate the two plans when the W-2 employer and the concierge entity are unrelated. That is the common case when you join an existing hospital system and run the concierge practice as an independent venture.

The four concierge-revenue structures we see in physician practices, each with a different SEP compensation base and a different Stark-adjacent posture toward the W-2 hospital system, are summarized below. The compensation base column shows the input to the SEP contribution formula; the actual contribution ceiling is the lesser of 25 percent of that base or the annual statutory limit at IRC §415(c)(1)(A).

The first three rows describe situations where the concierge entity is an independent sponsor for SEP purposes and the contribution ceiling is computed on the concierge compensation base alone.

The fourth row describes the situation where the concierge arrangement runs through a subsidiary of the same hospital system that issues the W-2 for the employed-side practice. In that case, the controlled-group rules apply and the §415 ceiling is shared.

The plan-administrator and entity-attorney determination of which row applies is the controlling documentation, not the credentialing department’s description of the arrangement.

SEP IRA mechanics under IRC §408(k), in plain language

A SEP IRA is an employer-sponsored retirement plan that uses an IRA as the funding vehicle. The contribution is funded by the employer (the concierge entity), is deductible on the entity’s tax return, and accumulates inside an IRA wrapper at a custodian of the physician’s choice.

The plan is established with a one-page IRS Form 5305-SEP and has no annual Form 5500 filing requirement for plans that cover only the owner or a small number of employees. The plan-document simplicity is the design feature that makes the SEP the default first-step retirement plan for a single-owner concierge practice.

Specific one: the contribution ceiling is uniform percentage, not selective. The SEP requires the same contribution percentage for every eligible employee, capped at the lesser of 25 percent of the eligible employee’s compensation or the §415(c) annual ceiling. The 2025 §415(c) ceiling is 70,000 dollars; the 2024 figure was 69,000 dollars.

The uniform-percentage rule means a concierge practice with eligible non-owner employees must contribute the same percentage for those employees as for the physician-owner. The eligible-employee definition at IRC §408(k)(2) includes employees aged 21 or older who have performed services for the employer in three of the immediately preceding five years.

Specific two: the self-employed compensation base is net of one-half SE tax and net of the SEP itself. For sole-proprietor and single-member-LLC concierge structures, the compensation base is net self-employment earnings minus the deduction for one-half of self-employment tax minus the SEP contribution itself.

The effective contribution ceiling expressed against gross Schedule C net is therefore approximately 20 percent, not the headline 25 percent. The IRS publication that walks through the computation step by step is IRS Publication 560; the worksheet on the SEP IRA contribution computation appears in chapter 5 of that publication.

For S corporation concierge structures, the compensation base is the W-2 wages paid to the physician-owner; K-1 distributions are not compensation for SEP purposes.

Specific three: the deadline runs to the tax-filing deadline including extensions. The SEP contribution for tax year T is funded by the due date of the entity’s tax return including extensions. A physician who files an extended Form 1040 with the SEP funded by October 15 of year T+1 retains the year-T deduction.

The deadline flexibility is the operational reason the SEP is preferred over the Solo 401(k) when concierge revenue is variable. The actual contribution amount can be sized once the year’s net earnings are known.

Four-step sequence from concierge revenue to destination allocation

The sequence below is what we see executed cleanly when the concierge revenue is structured before the first SEP contribution. The controlled-group posture against the W-2 employer is documented, and the destination allocation is modeled before the trustee-to-trustee transfer to the self-directed IRA. Steps one and two are reversible (no contributions have moved). Steps three and four are more consequential, though the SEP itself is annually re-fundable, so the irreversibility is softer than a 403(b) full-balance rollover.

Step 1. Concierge entity structure determination. The concierge practice is filed with the state as a sole proprietorship, a single-member LLC (default tax treatment), or a single-member LLC with an S corporation election. The entity-side attorney and the tax accountant produce a written memo that confirms the structure and identifies whether any concierge revenue routes through a hospital-system subsidiary that would trigger controlled-group aggregation with the W-2 plan. Output: the entity formation documents plus the controlled-group determination memo.

Step 2. SEP contribution capacity computation. The compensation base is computed from the prior-year financial statements or the trailing-twelve-month projection. For sole proprietorships and disregarded single-member LLCs, that means Schedule C net earnings minus one-half SE tax minus the SEP contribution itself. For S corporation electors, it means W-2 wages. The 25 percent / 70,000 dollar ceiling (2025) is then applied.

The continuing 403(b) elective deferrals at the W-2 employer are tracked separately and do not reduce the SEP capacity because the two plans are sponsored by different employers in the independent-row scenarios.

Step 3. SEP IRA establishment and first contribution. The SEP IRA is opened at the chosen custodian. Use a self-directed IRA custodian if the eventual destination includes IRS-approved precious metals. Use a conventional custodian if the SEP will stay in traditional securities and a separate gold-IRA bucket will be funded later via a trustee-to-trustee transfer.

IRS Form 5305-SEP is signed and retained in the entity’s plan documentation file. The first contribution is funded by the entity’s tax-filing deadline including extensions. The contribution is reported on Form 5498 at the receiving custodian.

Step 4. Destination allocation including the sized gold IRA slice. The diversified-equity, fixed-income, and target-date sleeves take the majority of the SEP accumulation. The alternative-asset slice (commonly three to ten percent of investable net worth in household-finance literature) flows to the gold IRA at an OPRS-screened custodian and dealer. Run the destination dealer against the operators OPRS warns against before any metals invoice is signed; dealer markup, depository fee, and buy-back posture each affect the long-run net of the slice.

The SEP and the gold IRA can be the same IRA account at a self-directed custodian. Alternatively, they can be two separate IRAs: the SEP as a conventional brokerage IRA, the gold IRA as a self-directed IRA, with periodic trustee-to-trustee transfers between them.

Stacking the SEP against a continuing 403(b) and the IRC §415 limit

A physician who continues employed-side W-2 hours alongside the concierge practice is participating in two separate retirement plans: the W-2 employer’s 403(b) and the concierge entity’s SEP IRA. The IRC §402(g) elective-deferral cap (23,500 dollars in 2025, with a 7,500 dollar catch-up for participants aged 50 or older) applies to the 403(b) elective deferrals only.

The SEP contribution is an employer non-elective contribution, not an elective deferral, and does not count against the §402(g) cap. The two plans each have their own §415(c) ceiling (70,000 dollars in 2025) when the sponsoring employers are unrelated under §414(b) and §414(c).

Here is the stacking math in 2025 figures, assuming you are age 50 or older and your concierge compensation base supports the maximum SEP contribution. You have 23,500 dollars of W-2-side elective deferral, plus 7,500 dollars of catch-up, plus any employer match the hospital plan provides.

On top of that, you have a separate SEP contribution up to 70,000 dollars on the concierge side against its own §415(c) ceiling. A physician who fully funds both sides carries materially more tax-deferred capacity than under the W-2 alone.

The IRS pages on 403(b) contribution limits and on SEP contribution limits set out the controlling figures. The cost-of-living adjustment notice published each fall updates the numbers for the following year.

The discipline that makes the stacking work is the controlled-group determination at Step 1. If the concierge revenue runs through a subsidiary of the same hospital system as the W-2 plan sponsor, §414(b) aggregates the two plans into a single controlled group. That means the §415(c) ceiling is shared across both. Most concierge arrangements structured by physician-side counsel are organized to avoid this overlap, and the entity formation in Step 1 is where that posture is locked in.

Common mistakes at the concierge + SEP + gold IRA intersection

The mistakes below are drawn from patterns we see in the practice-management literature for physician concierge transitions and from the dealer-side marketing material the OPRS desk evaluates for the destination side. Each is correctable when the Step 1 entity-structure determination and the Step 2 SEP-capacity computation are done before any contribution is funded.

Mistake 1. Computing SEP capacity on gross Schedule C revenue instead of net earnings. The SEP compensation base for sole-proprietor and disregarded-LLC structures is net SE earnings minus one-half SE tax minus the SEP contribution itself.

Computing the 25 percent ceiling on gross revenue overstates the deductible contribution and risks a Form 5330 excise tax on the excess. Correction: use the IRS Publication 560 chapter 5 worksheet, or the equivalent calculation in the entity accountant’s planning software, before funding the contribution.

Mistake 2. Routing concierge revenue through a hospital-system subsidiary that triggers controlled-group aggregation. A concierge arrangement structured by the W-2 hospital system as a subsidiary often aggregates with the W-2 plan under §414(b) or §414(c). That shrinks the stacking capacity to a shared §415(c) ceiling. Correction: the entity-side attorney confirms in writing whether the concierge entity is independent of the hospital-system controlled group before the SEP plan document is signed.

Mistake 3. Funding the SEP on the W-2 elective-deferral timeline instead of the entity-return extended deadline. The SEP contribution deadline is the entity’s tax-return due date including extensions, not the calendar year-end. Funding the SEP in December based on a still-uncertain annual net-earnings estimate often produces either an under-contribution or an excess contribution. Correction: the SEP contribution is sized after the year’s net earnings are known, and funded by the extended return deadline.

Mistake 4. Routing the entire SEP accumulation to a gold IRA. A 100 percent gold IRA replaces one concentrated exposure (the practice itself, or the hospital system employer stock) with another. Correction: the destination allocation reproduces the diversified mix the household already uses for the rest of the portfolio, with an alternative-asset slice sized at three to ten percent of investable net worth.

Mistake 5. Naming the destination dealer before the custodian and depository are confirmed. Three operational counterparties must be in place for a self-directed gold IRA: custodian, depository, and dealer. Sequencing them correctly avoids costly restarts.

Dealer-side marketing that bundles the three often hides the markup at the dealer layer behind the bundle. Correction: the custodian is named first, the depository is selected from the custodian’s approved list, and the dealer is the last decision in the sequence. Check the destination dealer against the 2026 OPRS list before signing any metals invoice.

Our take: the SEP stacking capacity is one of the most under-used tax-deferred tools available to physicians who add concierge revenue alongside an employed practice. The discipline is in Step 1 (independent entity structure to avoid controlled-group aggregation) and Step 2 (correct compensation-base computation).

A SEP that funds the §415 ceiling for several years builds a meaningful self-directed balance. A measured gold IRA slice inside that balance keeps the account clean for the spouse or heirs across the inflation cycles late-career portfolios actually face. The dealer holding the metals inside the wrapper decides the long-run net.

Frequently asked questions

Can a physician contribute to both a W-2 employer 403(b) and a SEP IRA in the same year?

Yes, when the W-2 employer and the concierge entity sponsoring the SEP are unrelated employers under IRC §414(b) and §414(c). The 403(b) elective deferrals are constrained by the §402(g) annual limit (23,500 dollars for 2025, plus 7,500 dollar catch-up at age 50 or older).

The SEP contribution is a non-elective employer contribution and has its own §415(c) annual ceiling at the concierge entity, separate from the 403(b)’s §415(c) ceiling at the hospital employer. The two limits stack when the controlled-group test is negative.

Does the SEP IRA have to be opened at a self-directed custodian to hold gold?

Yes, for the slice that holds IRS-approved precious metals under §408(m). Conventional brokerage IRAs hold securities and cash; physical precious metals require a self-directed IRA at a custodian that supports the §408(m) asset class plus a separate depository that holds the bullion.

A common operational pattern is to open the SEP at a conventional custodian for the equity, fixed income, and target-date sleeves. Then execute a trustee-to-trustee transfer of the alternative-asset slice to a separate self-directed IRA at a precious-metals-supporting custodian.

Does a Solo 401(k) offer more contribution capacity than a SEP for a concierge practice?

Sometimes, depending on the compensation base. The Solo 401(k) allows both an elective deferral (subject to §402(g)) and an employer non-elective contribution, with the combined limit at §415(c). At low to moderate net earnings, the Solo 401(k) can reach the §415(c) ceiling at a lower compensation base than a SEP because the employee deferral does not have the 25-percent-of-comp constraint.

At higher compensation bases, the two plans converge at the §415(c) ceiling. The Solo 401(k) carries a Form 5500-EZ filing requirement once assets exceed 250,000 dollars; the SEP does not.

Are SEP IRA assets protected from creditors during a malpractice judgment?

The federal bankruptcy exemption for retirement funds under 11 USC §522(d)(12) covers SEP IRA assets as a class of retirement funds. The contributory-IRA dollar cap at §522(n) does not apply to rollover amounts; SEP contributions are employer non-elective and the entire balance is generally treated as rollover-eligible for §522 purposes.

State-law IRA exemption outside of bankruptcy varies by state; the destination-state statute is the controlling number when a future judgment is at issue outside of a bankruptcy filing. The broader wrapper-by-wrapper view is in the malpractice asset-protection framework.

Does FINRA or the SEC guidance address SEP IRA gold IRA suitability?

FINRA publishes general investor education on precious metals IRAs and on retirement-plan rollover decision-making. The FINRA rollover-decision investor alert covers the trade-offs between leaving a balance in a former-employer plan, rolling to an IRA, and other options. FINRA does not endorse any specific dealer or product.

The SEC investor education at investor.gov reinforces the same diligence framing for self-directed IRA structures. For a physician adding a SEP-funded gold IRA slice, the suitability question is the standard one. It asks whether the destination allocation reproduces the household’s diversification model and whether dealer-side counterparty risk is evaluated before the metals invoice is signed.

The practical sequence at the concierge-expansion stage is the four-step framework above, executed in order, with the entity-structure determination and the SEP-capacity computation locked before the first contribution is funded.

The most consequential decision is not which dealer sells the metals. It is whether the concierge entity is structured to avoid controlled-group aggregation with the W-2 hospital employer. A second question is whether the destination allocation reproduces the diversification model the household already uses for the rest of the portfolio.

Sizing a gold IRA slice at the same alternative-asset percentage used across the broader household keeps the account manageable for a spouse or heirs navigating the inflation cycles that late-career portfolios actually encounter.

More on OPRS

For the in-service mechanic that unlocks the W-2 employed-side 403(b) during continued employment, see the physician 403(b) in-service distribution guide. For the phasing-down arc that often runs in parallel with concierge expansion, see the late-career physician 403(b) phasing-down sequencing guide.

For the Stark Law and acquisition-timing layer that interacts with any continued hospital-system referral relationship, see the Stark Law and 403(b) practice acquisition framework. For the wrapper-by-wrapper view of which dollars a malpractice or restitution judgment can reach, see the malpractice asset-protection framework for physicians.

The OPRS-reviewed dealer shortlist sits at our 2026 gold IRA dealer list, and the underlying step-by-step rollover mechanics are in the 401(k) to gold IRA rollover guide.

Sources cited

1. IRC §408 — SEP IRA framework §408(k) and IRA-permitted bullion §408(m)
2. IRC §401(c)(2) — self-employment income definition
3. IRC §415(c) — annual additions ceiling
4. IRC §414(b) and §414(c) — controlled-group rules
5. 11 USC §522(d)(12) and §522(n) — bankruptcy exemption for retirement funds
6. IRS Publication 560 — Retirement Plans for Small Business
7. IRS — 403(b) contribution limits
8. IRS — SEP contribution limits
9. FINRA — Should You Roll Over Your 401(k)?
10. SEC — Investor.gov diligence framing
11. IRC §402(g) — elective-deferral cap
12. IRS Form 5305-SEP — SEP plan document

Important note: OPRS is an editorial platform, not a law firm, registered investment advisor, or tax advisor. Entity-structure decisions, SEP plan-document drafting, controlled-group determinations, asset-protection planning, and rollover-and-allocation decisions depend on entity-side counsel review, plan-document language, and state-specific rules that only licensed counsel and tax professionals can evaluate. Past performance is not a guarantee of future results.

Published by OPRS Editorial.