- Home /
- Resources /
- CPOM Laws by State
Corporate Practice of Medicine: A 50-State Overview
See where the corporate practice of medicine by state is strict, limited, or absent, plus the 2025 and 2026 law changes to confirm.
- 50-state coverage
- 2025-2026 law changes tracked
- Attorney-reviewed agreements
By the numbers
States Covered
Physician Placement
Key Takeaways
What You Need to Know
- California, New York, Texas, and five other strict states require a physician-owned clinical entity, so non-physician owners need a PC/MSO structure.
- About 18 states, including Florida, Missouri, and Utah, have no formal CPOM doctrine, though licensing, fee-splitting, and supervision rules still apply.
- Oregon, California, Indiana, and Massachusetts changed their CPOM rules in 2025 or 2026, and a federal bill introduced on September 16, 2026, would set a national ban.
- Opening in a second state usually means a new physician-owned entity, a physician licensed in that state, and a fresh review of your management agreement.
Does Every State Enforce the Corporate Practice of Medicine Doctrine?
About 32 states plus Washington, D.C. recognize some form of the doctrine, and roughly 18 states don’t, as per the June 2026 review. Enforcement strength varies widely even among states that recognize it, and sources classify states like Georgia, Ohio, and Kentucky differently, so confirm your state’s CPOM status before you structure.
How to Read This State-by-State Overview
This overview sorts the corporate practice of medicine by state into three groups based on CPOM enforcement level. More than a dozen states advanced CPOM or MSO bills in their 2025 and 2026 sessions, so statute-level detail quickly goes out of date.
- Strict CPOM states: A licensed physician must own the clinical entity, and regulators review management agreements closely.
- Limited or no restriction states: These states have no formal CPOM doctrine or rarely enforce one, which can allow direct ownership as long as licensing, supervision, and fee-splitting laws are met.
- Notable exception or recent change states: New legislation, attorney general opinions, court cases, or hospital and nonprofit carve-outs have changed who can own a practice or employ physicians in these states.
Nineteen states sit between the strict and no-doctrine groups, recognizing CPOM but enforcing it case by case. Your state’s CPOM status on the day you sign an agreement is the only one that counts.
The Three CPOM Categories
Corporate Practice of Medicine by State, at a Glance
California, Illinois, Massachusetts, Nevada, New Jersey, New York, Oregon, and Texas require a physician-owned clinical entity, so non-physician owners need a PC/MSO structure.
About 19 states recognize CPOM but enforce it inconsistently, including Arizona, Colorado, Pennsylvania, Washington, and Wisconsin, plus nuanced or disputed states like Georgia, Ohio, and Kentucky.
About 18 states, including Florida, Missouri, Nebraska, Utah, and Wyoming, have no formal CPOM doctrine, though licensing, fee-splitting, and supervision rules still apply.
Why Medical Director Co.
What Changes When You Expand Into Another CPOM State
Clinical Entity
Texas and New York CPOM rules require a professional corporation or PLLC formed under their own law, so a Florida professional association or a Missouri LLC won’t qualify there.
Physician Licensure
The medical director or collaborating physician must hold a license in the new state, which means a physician licensed only in Florida can’t oversee a Texas clinic.
Management Services Agreement
Fee terms need a fresh review, because New York prohibits percentage-based management fees that California allows in some arrangements.
Transaction Filings
Opening through an acquisition or outside investment can trigger pre-close notice rules in California, Massachusetts, Indiana, Colorado, and other states with transaction-review laws.
Check Your State's Rules
Get matched with a state-licensed physician fast.
Recent Changes
States With Notable Exceptions or Recent Changes
California: SB 351, effective January 1, 2026, codified California’s CPOM limits on private equity groups and hedge funds. The Attorney General also filed a 2026 amicus brief challenging friendly-PC stock-transfer provisions.
New York: Often cited as the strictest CPOM doctrine in the country. Pending bills, including S8442 and A9012, would add MSO ownership limits on top of existing percentage-based management fee prohibitions.
Texas: Generally prohibits non-physician entities from employing physicians, with narrow exceptions for nonprofit health organizations certified by the Texas Medical Board.
Oregon: SB 951, signed June 9, 2025 and amended by HB 3410, is widely described as the strictest CPOM law in the country. It applies to new arrangements from January 1, 2026, and existing arrangements from January 1, 2029.
Indiana: HB 1666, signed May 6, 2025, added ownership reporting and gave the Attorney General more authority over healthcare markets. SB 282 (2026) added a medical spa registration requirement.
Massachusetts & transaction review: H.5159, signed January 8, 2025, requires notice for certain private equity, REIT, and MSO transactions. New Mexico, Connecticut, Colorado, and Illinois added similar laws.
The federal bill: On September 16, 2026, congressional Democrats introduced the Stop Corporate Takeovers of Physicians Act of 2026, modeled on Oregon’s SB 951. Passage in 2026 would require significant additional congressional action.
Cost & Contract Options
How Medical Director Co. Helps Confirm Your State's Current Rules
Bolton Harris, J.D.
In-house healthcare attorney. We place state-licensed medical directors and collaborating physicians, usually within 24 hours, starting at $799 per month with no setup fees, and prepare collaborative agreements while tracking CPOM rule changes that affect your oversight. Entity formation and legal review of your structure stay with your healthcare attorney.
State-licensed physicians starting at $799 per month.
FAQ
Frequently Asked Questions
About 32 states plus Washington, D.C. recognize some form of the doctrine, and roughly 18 states don’t, as per the June 2026 review. Enforcement strength varies widely even among states that recognize it. Sources classify states like Georgia, Ohio, and Kentucky differently, so confirm your state’s CPOM status before you structure.
Florida, Missouri, Nebraska, Oklahoma, Utah, Virginia, and Wyoming are among the states with no CPOM doctrine. Florida regulates many non-physician-owned practices through Health Care Clinic Act licensing instead. Licensing, fee-splitting, and supervision rules still apply in every one of these states.
Oregon, Indiana, Massachusetts, and California all passed ownership or transaction laws in 2025, with several taking effect in 2026. Attorney general opinions and court cases can also shift how a state reads its existing doctrine. A federal bill introduced on September 16, 2026, would create a national ban if Congress passes it.
Start with your state medical board’s website and any published attorney general opinions on physician employment. Then check your legislature’s bill tracker for pending CPOM or MSO bills from the current session. Have a healthcare attorney licensed in that state review your structure before you sign a management services agreement.
Medical Director Co. places state-licensed medical directors and collaborating physicians for the clinical side of a PC/MSO structure. Our team prepares collaborative agreements and flags changes to your state’s CPOM rules that affect your oversight. Your healthcare attorney still handles entity formation and legal review of the structure.
Confirming Your State's CPOM Status Before You Structure
Your state’s CPOM category on this page tells you what kind of structure to expect, and your state’s current law tells you what to sign. Pull the medical board guidance and pending bills for your state, then have a local healthcare attorney confirm the ownership model. Once the structure is set, we’ll place the licensed physician who makes it work.
