Lexology July 2, 2025
The Corporate Practice of Medicine doctrine (“CPOM”) generally prohibits non-licensed individuals from practicing medicine or employing physicians to provide medical services. Although CPOM laws vary by state, a general strategy that allows non-physician entities to be involved in health care operations without violating CPOM is to form an MSO structure (sometimes also referred to as a Friendly PC structure), where a non-physician entity provides management services to a physician-owned professional corporation (“PC”). The entities generally institute safeguards to ensure all clinical functions are performed by the PC and only non-clinical services are performed by the management services organization (or “MSO”). In this article, we will refer to a PC/MSO arrangement as an “MSO Entity”.
Where two MSO Entities wish to...
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