CPOM Compliance for Texas Healthcare Startups
Texas enforces CPOM strictly through the Texas Medical Board. Startups operating in Texas need a compliant PC structure before seeing patients. Pair this deep page with CPOM compliance and the CPOM 50-state guide.
Get a Free CPOM AssessmentThe Law in Texas
Key statute (official text)
Texas Occupations Code ch. 155 (§ 155.001 et seq.)Texas CPOM is a license-to-practice rule plus a control rule. Occupations Code § 155.001 says a person may not practice medicine in Texas without a license issued under that subtitle. The Texas Medical Board disciplines licensees who aid unlicensed practice or cede clinical control to a lay company. A physician-owned PC plus an FMV MSA is the diligence default. Foundry formation is $15,000; a Texas-aware PC owner is $3,000/mo.
Texas prohibits the corporate practice of medicine and requires that medical practices be owned and controlled by licensed physicians. Official starting points: Occupations Code ch. 151 (Medical Practice Act general provisions), ch. 155 (license to practice), ch. 162 (regulation of the practice of medicine), and ch. 164 (disciplinary actions). Telehealth into Texas does not create a carve-out.
Professional entities that hold the clinical practice are organized under Texas Business Organizations Code ch. 301. Filing a PA or PLLC is not the same as CPOM compliance. Buyers still sample funds flow. Use Texas’s rules here alongside the full CPOM 50-state guide.
Founders should separate (1) physician PC ownership, (2) NP/PA delegation or supervision under Occupations Code ch. 157, and (3) MSO admin services. Confusing those roles is a common Texas risk. See collaborating physician vs friendly PC owner.
What Texas Founders Need to Know
- Only licensed physicians may own or control a medical practice in Texas
- Non-physician entities must use an MSO/PC structure
- Texas has specific rules around physician supervision of NPs and PAs
- Telehealth companies must comply with Texas CPOM rules for TX patients
- Violations can result in TMB disciplinary action and civil liability
How Foundry PC Helps Texas Startups
Foundry PC specializes in matching healthcare founders with a Friendly PC Owner: a licensed physician who can own the Professional Corporation in Texas, enabling your company to operate in full compliance with state CPOM laws. We handle the matching, the MSO-PC structure, and ongoing compliance so you can focus on building.
Book a Free Texas CPOM AssessmentHow an MSO-PC works in Texas
Texas still expects a licensed physician to own the clinical entity. Telehealth into Texas from another HQ does not skip that. A Texas-aware PC owner plus an MSO is the usual pattern. We form the documents for Texas with the states you are adding next, not a fake 50-state plug-in PC. See MSO-PC formation.
Corporate practice and “control”
The risk in Texas is often de facto control: the MSO dictating clinical protocols, hiring, or coding in a way that looks like it is practicing medicine. Keep clinical control in the PC. Fair-market-value management fees, not a split of professional revenue dressed up as rent.
- Texas-licensed physician owns the clinical entity
- TMB can discipline licensees tied to unlawful corporate practice
- Supervision/collaboration for NPs and PAs is separate from PC ownership
- Document FMV MSA terms; avoid percentage-of-collections “rent”
Formation for Texas (and other states you need) is $15,000 via MSO-PC formation. PC owner matching is $3,000/mo. Compare California and New York on the CPOM 50-state guide.
Fee-splitting and illegal remuneration (Texas .gov)
Texas Occupations Code ch. 102 restricts solicitation of patients and illegal remuneration. A percentage-of-collections MSA is the high-risk management-fee pattern on diligence, same theme as the CPOM compliance fee table. Prefer a fixed FMV admin fee with a memo. TMB board rules sit on top of the statute text; confirm current chapters with counsel.
This is not a plug-in national PC. Foundry does not rent a shared Texas shell. Scope formation to Texas plus any other states you treat. See the honesty block on the CPOM 50-state guide.
TMB enforcement vs buyer / payer checks
Occupations Code ch. 164 is how the Texas Medical 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 | Texas fail signal |
|---|---|---|
| Texas Medical Board | Licensee aiding unlicensed practice; de facto clinical control by a lay company (ch. 164 / 155) | Figurehead PA owner; MSO writing protocols |
| Buyer diligence | Shareholder ledger vs Secretary of State; one claim from payer to PC bank to MSA invoice | MSO lockbox; percentage MSA; no Texas-licensed owner |
| Payer / credentialing | Claim TIN and group NPI on the physician-owned PA | Marketing MSO TIN on the claim |
Texas CPOM FAQ
Does Texas have strict CPOM?
Yes. Texas is Strict on the CPOM 50-state guide. Occupations Code ch. 155 requires a license to practice. A physician-owned PA/PLLC plus an FMV MSA is the diligence default.
What enforcement bodies act on Texas CPOM?
The Texas Medical Board is the primary license enforcer. Buyers reconstruct control in the data room; payers sample the claim TIN. Pair this page with CPOM compliance.
How does Texas treat fee-splitting?
Occupations Code ch. 102 restricts solicitation and illegal remuneration. A percentage-of-collections MSA is the high-risk pattern. Prefer a fixed FMV admin fee.
How does Foundry help with Texas CPOM?
MSO-PC formation is $15,000 one-time. A Texas-licensed physician PC owner is $3,000/mo. Foundry is not a law firm.
Sources and citations
Primary .gov authorities cited on this Texas deep page. Confirm current text with counsel. Statutes change.
- Occupations Code ch. 151: Medical Practice Act general provisions
- Occupations Code ch. 155: license to practice medicine (§ 155.001 et seq.)
- Occupations Code ch. 157: physician delegation (NP/PA is not PC ownership)
- Occupations Code ch. 162: regulation of the practice of medicine
- Occupations Code ch. 164: disciplinary actions
- Occupations Code ch. 102: solicitation of patients / illegal remuneration
- Business Organizations Code ch. 301: professional entities
- Texas Medical Board and board rules