CPOM Compliance for Colorado Healthcare Startups
Colorado retains the CPOM doctrine with meaningful exceptions — but for digital health and non-hospital founders, physician ownership rules still apply.
Get a Free CPOM AssessmentThe Law in Colorado
Key Statute
C.R.S. § 12-240-138 (Medical Practice Act — Professional Entities)Colorado's Medical Practice Act permits medicine to be practiced through professional service corporations, LLCs, and LLPs — but shareholders must be Colorado-licensed physicians, with a narrow allowance for physician assistants to hold minority shares. Statutory exceptions permit hospital employment (C.R.S. § 25-3-103.7) and provider-network employment, which is why Colorado is often mislabeled a "non-CPOM" state.
What Colorado Founders Need to Know
- Medical professional entities must be owned by Colorado-licensed physicians — PAs may hold shares only while physicians retain majority ownership
- Hospitals and provider networks have statutory employment exceptions — but those don't extend to typical digital health startups
- Employers may not restrict a physician's independent medical judgment, and cannot require collaborative agreements as a condition of employment
- Lay-owned companies serving Colorado patients still need a physician-owned professional entity for clinical services
- The MSO/PC structure is the standard compliant approach for non-physician founders in Colorado
How Foundry PC Helps Colorado Startups
Foundry PC matches healthcare founders with a Friendly PC Owner — a Colorado-licensed physician who owns the professional entity — and builds the MSO-PC structure so your company can operate compliantly under the Medical Practice Act. We handle the matching, the entity formation, and ongoing compliance so you can focus on building.
Book a Free Colorado CPOM AssessmentFurther Reading
Ready to get compliant in Colorado?
Book a free 20-minute call with our team. We'll review your structure and tell you exactly what you need to operate in Colorado.
Book a Free Call