CPOM Compliance for Connecticut Healthcare Startups
Connecticut is more flexible than California on classic CPOM, but CGS § 20-9(a) still requires a license before anyone practices medicine, and Chapter 594a still restricts who may own the professional corporation.
Get a Free CPOM AssessmentThe law in Connecticut
Key authorities (official text)
Connecticut DPH · Medical Examining Board · CGS Chapter 370 · Chapter 594a · Chapter 594bConnecticut Department of Public Health · Connecticut Medical Examining Board · CGS § 20-9 · § 20-8a · § 20-13c · § 33-182a · § 33-182c · § 33-182d · § 33-182g · Chapter 594b (medical foundations) · OLR 2013-R-0262 · OHS Physician Practice Workgroup (Feb 2023).
Connecticut CPOM is Moderate. The state does not copy California Business & Professions Code § 2400. Official text of CGS § 20-9(a): no person shall, for compensation, gain or reward, diagnose, treat, operate for or prescribe for any injury, deformity, ailment or disease of another person, nor practice surgery, until licensed as provided in § 20-10, and then only in the kind or branch of practice stated in such license. That is a license-to-practice rule. The Connecticut Office of Health Strategy’s February 2023 Physician Practice Workgroup report names § 20-9(a) as the statutory CPOM starting point and asks for more comprehensive CPOM guidance. Hartford and Stamford digital-health diligence still wants a physician-owned PC plus a fair-market-value MSA.
Do not cite Public Act 09-212 / Chapter 594b as Connecticut’s CPOM prohibition. The Connecticut General Assembly’s own Office of Legislative Research report 2013-R-0262 is the clean read: medical foundations were first authorized in 2009 through PA 09-212 so a hospital, health system, or medical school may organize a nonprofit medical foundation and practice through employed physicians. That is a hospital-system exception to the ordinary corporate-practice limit, not a digital-health exemption, and not a license for a lay LLC to hold itself out as practicing medicine.
Connecticut is not permission for a lay operating company to practice medicine. Chapter 370 licenses people. A medical-director title on a Delaware company does not satisfy § 20-9(a). The Medical Examining Board sits under § 20-8a and disciplines licensees under § 20-13c. Professional service corporations sit in Chapter 594a. § 33-182a defines a professional corporation as one whose shareholders are licensed to render the same professional service. § 33-182c is who may organize. § 33-182d requires professional services to be rendered only through licensed officers, employees, and agents. § 33-182g limits issuance and transfer of capital stock. Collaboration for NPs/PAs is a different job from owning the Professional Corporation. See collaborating physician vs physician PC owner. Longer narrative: Connecticut CPOM blog guide.
Typical PC / MSO structure in Connecticut
Form a Connecticut professional corporation under Chapter 594a owned by a Connecticut-licensed MD or DO. The MSO, often the Delaware operating company, provides non-clinical services under a written MSA at fair market value. Clinical revenue lands in the PC. Foundry forms that structure ($15,000) and matches a friendly PC owner ($3,000/mo). Not a rented Super PC. Not a Chapter 594b medical foundation unless you actually are a hospital, health system, or qualifying medical school.
If you also treat New York, Massachusetts, or New Jersey patients, Connecticut’s Moderate label does not control those states. Start with the CPOM 50-state guide and form for the footprint you actually have. Neighboring New York and Massachusetts have their own statutes and notice overlays.
When you still need a PC vs only an MSO
Use this as an operator rule, not a filing opinion. Confirm with counsel.
| Connecticut fact pattern | Typical entity | Why |
|---|---|---|
| Connecticut-only, cash-pay, physician already owns the practice | May stay on the existing professional corporation | Still document clinical control and FMV admin if an MSO is in the picture |
| Venture-backed or multi-state telehealth that includes Hartford / Stamford | Connecticut professional corporation + FMV MSA | Buyers and payers test CPOM compliance the same way they do in strict states |
| Hospital / health-system employed physicians | May sit in a Chapter 594b medical foundation | PA 09-212 is that exception. A startup MSO is not a hospital |
| Connecticut plus New York, Massachusetts, or New Jersey | Form for the strict / moderate states, then qualify Connecticut | Connecticut’s Moderate label does not soften BCL § 1507, CHIA reporting, or N.J.A.C. 13:35-6.16 |
Fee-splitting and funds-flow risk
CGS § 20-13c is the Medical Examining Board disciplinary overlay. A percentage-of-collections management fee is the pattern that looks most like a split of professional fees and like de facto control. Prefer a fixed or FMV-supported admin fee. Pair this page with the fee-risk table on CPOM compliance.
| Connecticut pattern | Risk | Safer pattern |
|---|---|---|
| Lay LLC holds itself out as practicing medicine | High: § 20-9(a) license overlay | Licensed-professional corporation under Chapter 594a |
| MSO paid % of professional collections | High: § 20-13c + diligence overlay | Fixed FMV admin fee with a memo |
| Cite PA 09-212 as a startup CPOM waiver | Wrong chapter: OLR 2013-R-0262 is medical foundations | Hospital/health-system facts only; otherwise physician PC + FMV MSA |
| Lay equity in the professional corporation | High: § 33-182a / § 33-182g | Licensed-physician ownership of the PC |
| Physician PC + FMV MSA + separate books | Base case | Revisit FMV when volume changes |
Medical Examining Board vs buyer / payer checks
The Medical Examining Board disciplines licensees. Buyers and payers run a different file. Use both columns: license risk and diligence risk are not the same test. Full operating map: CPOM compliance.
| Who checks | What they sample | Connecticut fail signal |
|---|---|---|
| DPH / Medical Examining Board | Unlicensed practice (§ 20-9); unprofessional conduct (§ 20-13c) | Figurehead PC owner; MSO writing protocols |
| Buyer diligence | Shareholder ledger vs Secretary of the State; one claim from payer to PC bank to MSA invoice | MSO lockbox; percentage MSA; no Connecticut-licensed owner |
| Payer / credentialing | Claim TIN and group NPI on the physician-owned PC | Marketing MSO TIN on the claim |
What Connecticut founders need to know
- Connecticut is Moderate, not “no CPOM.” § 20-9(a) is a license rule; Chapter 594a is the ownership rule.
- PA 09-212 created medical foundations for hospitals and health systems. It is not a digital-health waiver.
- OHS’s 2023 Physician Practice Workgroup named CPOM as an open Connecticut policy issue. Diligence teams notice that.
- Hartford / Stamford health-tech diligence still asks who owns the PC, who bills, and how the MSA is priced.
- Foundry does not drop clients into a plug-in 50-state PC. Multi-state needs a 50-state licensed physician.
Operational checklist: CPOM compliance. Setup path: MSO-PC formation ($15,000). Full map: CPOM 50-state guide. Book a call from the homepage.
Connecticut CPOM FAQ
Does Connecticut have strict CPOM?
Connecticut is Moderate / more flexible than California or New York. There is no B&P § 2400 analogue. CGS § 20-9(a), Chapter 594a, and § 20-13c still expect licensed control of medicine and clean fees. Foundry keeps Connecticut as Moderate on the CPOM 50-state guide.
Do I still need an MSO-PC in Connecticut?
Yes for most venture-backed and multi-state models. The professional entity holds clinical care; the MSO is paid fair market value for non-clinical services.
Did Public Act 09-212 create Connecticut’s CPOM ban?
No. PA 09-212 / Chapter 594b authorized nonprofit medical foundations. Cite OLR 2013-R-0262. A startup MSO is not a hospital.
How does Connecticut treat fee-splitting?
§ 20-13c is the disciplinary overlay. A percentage-of-collections MSA is the high-risk pattern. Prefer a fixed FMV admin fee.
How does Foundry help with Connecticut CPOM?
MSO-PC formation is $15,000 one-time. A Connecticut-licensed physician PC owner is $3,000/mo. Foundry is not a law firm.