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, buyer and payer checks, and the PDF. Below are the funds-flow mistakes that fail diligence.
Open CPOM compliance →A CPOM compliance checklist is useless if it only asks “do you have a PC?” Buyers and payers now ask where the money goes. Below are the funds-flow checks that go with Foundry’s CPOM compliance guide and the downloadable CPOM compliance checklist PDF.
Print the PDF for the data room. Use the table below to explain why lockboxes, percentage MSAs, and MSO payroll for clinicians fail CPOM compliance even when the articles of incorporation look clean. For how buyers and payers actually check the file, see buyer diligence and payer credentialing. State doctrine still lives on the CPOM 50-state guide.
The 10-point CPOM compliance checklist (still the start)
- Entity: clinical care sits in a physician-owned PC or PLLC, not a lay LLC practicing medicine.
- MSO: the operating company provides only non-clinical services.
- MSA: a written, fair-market-value management services agreement exists and is signed.
- Clinical autonomy: protocols, credentialing, and medical judgment stay in the PC.
- Fee-splitting: the MSO is not paid a share of professional fees dressed up as rent.
- Physician stipend: the PC owner is paid FMV for ownership, not volume or referrals.
- Marketing: the brand can live in the MSO; claims and licenses stay with the PC.
- Billing: patients and payers are billed by the PC.
- States: you reviewed the CPOM 50-state guide for every state you treat, not a rented Super PC.
- Counsel: independent healthcare counsel customized and signed off. Foundry is not a law firm.
The full CPOM compliance guide expands this to 14 steps (succession, SB 351, SB 951, role clarity, dated review). Do not stop at ten if California or Oregon is in the footprint.
Funds-flow mistakes that fail CPOM compliance
| Mistake | What diligence sees | Fix |
|---|---|---|
| MSO sweeps the lockbox | Lay company owns the practice of medicine | PC bank; MSA invoice. See funds flow on CPOM compliance |
| MSA = % of collections | Fee-splitting in many states | Fixed or FMV-supported admin fee |
| Clinicians on MSO payroll | De facto employment by the lay company | Contracts with the PC |
| Unsigned / expired MSA | No paper for FMV or scope | Execute before first claim |
| Medical director, no PC owner | Quality title is not ownership | Friendly PC owner at $3,000/mo |
| Plug-in Super PC | Shared national shell | Your PC; scoped states. See why not a Super PC |
These rows match the “common CPOM compliance mistakes” table in our CPOM compliance guide. If your bank statements contradict the org chart, the checklist score is zero no matter how pretty the MSA recitals are.
How this checklist maps to Foundry pricing
MSO-PC formation is $15,000 one-time for the states you operate. A physician PC owner match is $3,000 per month. That is the cheapest way to have a real owner, a real MSA, and a real funds-flow story before a raise. Download the PDF, keep it with the MSA, and date a counsel memo after the last statute change.
Author: Matthew Milford, Founder, Foundry PC. Last reviewed 15 September 2026. General information, not legal advice.