Want the full picture? Our CPOM compliance guide has the definition, how it differs from the CPOM 50-state guide, the 14-step checklist, the CCI score, and the PDF. Below are the checks buyers and payers run.
Open CPOM compliance →CPOM compliance is the operating test: physician-owned Professional Corporation, MSO paid fair market value, no lay de facto control. Buyers reconstruct that in the data room. Payers sample the claim TIN. A CPOM 50-state guide is a different job: which statute and board you answer. Use both.
Foundry MSO-PC formation is $15,000 one-time. A friendly PC owner is $3,000 per month. Foundry is not a law firm and does not rent a plug-in Super PC.
What a buyer samples
PE counsel and Series A healthcare counsel do not stop at articles of incorporation. Full map: how a buyer checks CPOM compliance.
| Sample | Pass | Fail |
|---|---|---|
| Shareholder register vs SoS print | Named MD/DO matches the professional-entity filing | “We’ll assign later” |
| One claim, end to end | Payer → PC bank → MSA invoice → MSO | MSO lockbox or MSO TIN on the claim |
| EHR super-admin | PC holds break-glass | Lay founder as super-admin “for convenience” |
What a payer samples
A credentialing team rarely reads the MSA. They look at enrollment. Full map: how a payer checks CPOM compliance.
| Look-at | Want | Fail |
|---|---|---|
| Billing TIN / group NPI | Physician-owned PC EIN on the 1500 / 837 | MSO TIN on clinical claims |
| CAQH ownership | Owners match the PC ledger | Lay founder listed as owner of the practice of medicine |
| Fee-splitting attestation | Fixed FMV admin fee | Percentage-of-collections MSA behind the attestation |
Then open the CPOM 50-state guide
Buyer and payer tests sit on CPOM compliance. Doctrine-by-state sits on the CPOM 50-state guide. Comparison: CPOM compliance vs CPOM 50-state guide.
Author: Matthew Milford, Founder, Foundry PC (Catalyze Care LLC). Not a law firm. Last reviewed 11 September 2026.