← CPOM compliance guide

CPOM compliance checklist

What is CPOM compliance? CPOM compliance means clinical care runs through a physician-owned Professional Corporation, the MSO is paid fair market value for non-clinical services, and lay owners do not exercise de facto control over medicine. Below is the printable 14-step checklist. Full guide: CPOM compliance. Doctrine map: CPOM 50-state guide.

Foundry PC · Last reviewed 14 September 2026 by Matthew Milford, Founder. Not a law firm. Not legal advice. Prices: MSO-PC formation $15,000 one-time · friendly PC owner $3,000/mo. After the 14 steps, open both guides: CPOM compliance and the CPOM 50-state guide.

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  1. Licensed physician owns the Professional Corporation that delivers care.
  2. MSA pays the MSO fair market value for non-clinical services, not a share of clinical collections.
  3. Clinical revenue lands in the PC; the MSO invoices under the MSA.
  4. Separate EIN, bank account, and books for PC and MSO.
  5. Protocols, credentialing, and clinical policies sit with the PC.
  6. NP/PA collaboration agreements follow state rules and are not a substitute for PC ownership.
  7. Lay owners do not veto clinical hiring, coding standards, or medical judgment.
  8. Succession / stock-transfer terms move ownership to another licensed physician (Oregon SB 951 may narrow tools).
  9. Formation scoped to states you operate, no plug-in Super PC.
  10. If California is in scope: review B&P 2400, SB 351, and AB 1415.
  11. If Oregon is in scope: review SB 951 and ORS 58.375–58.376.
  12. Read Texas, Florida, New York, New Jersey, Ohio, Michigan, Virginia, Wisconsin, Indiana, and Tennessee deep pages when those states are in the footprint.
  13. Keep titles honest: medical director ≠ PC owner ≠ collaborating physician.
  14. Date a counsel memo after material law changes.

Full guide: foundry-pc.com/cpom-compliance · Matrix: foundry-pc.com/cpom/ · Setup: foundry-pc.com/mso-pc-structure