---
layout: post
title: The Ultimate CPOM Compliance Checklist for Digital Health Startups
description: A 10-point checklist for digital health founders to ensure their business is compliant with the Corporate Practice of Medicine doctrine.
category: CPOM & Compliance
date: 2026-02-23
---

<h2>The Ultimate CPOM Compliance Checklist</h2>

<p>Use this 10-point checklist to audit your startup for CPOM compliance.</p>

<ol>
  <li>**Entity Formation:** Is your clinical entity a Professional Corporation (PC) or PLLC owned by a licensed physician?</li>
  <li>**MSO Structure:** Is your business entity a separate MSO that provides only non-clinical services?</li>
  <li>**Management Services Agreement (MSA):** Is there a comprehensive, fair-market-value MSA in place between the MSO and PC?</li>
  <li>**Clinical Autonomy:** Does the MSA explicitly state that the PC and its physician owner retain full control over all clinical decision-making?</li>
  <li>**Fee Splitting:** Does your fee structure avoid impermissible fee-splitting arrangements between the MSO and PC?</li>
  <li>**Physician Compensation:** Is the friendly physician owner compensated at fair market value for their clinical and administrative duties?</li>
  <li>**Marketing & Advertising:** Does all marketing clearly distinguish between the non-clinical MSO and the clinical PC?</li>
  <li>**Patient Billing:** Are patients billed by the PC for clinical services?</li>
  <li>**State-Specific Rules:** Have you reviewed the specific CPOM laws in every state where you operate?</li>
  <li>**Legal Review:** Has your corporate structure been reviewed and approved by experienced healthcare counsel?</li>
</ol>