| name | cpom-compliance |
| title | Corporate Practice of Medicine Compliance |
| description | Drafts Corporate Practice of Medicine (CPOM) compliance structure documents for healthcare entities. Covers compliant organizational models (PC/PA, MSO, friendly PC), MSA architecture, operational compliance checklists, and state-specific regulatory analysis. Use when structuring healthcare operations, reviewing CPOM compliance, drafting MSO/MSA arrangements, or advising on physician practice ownership in CPOM-restricted jurisdictions. |
| author | CaseMark |
| author_url | https://github.com/CaseMark/skills/tree/main/skills/legal/cpom-compliance |
| license | Apache-2.0 |
| version | 0.1.0 |
| execution_mode | open |
| jurisdiction | us |
| practice | healthcare |
| language | en |
Corporate Practice of Medicine Compliance
Drafts a regulatory compliance framework ensuring lawful separation of corporate ownership from medical practice under CPOM doctrine.
Prerequisites
Gather before drafting:
- Entity details — structure, state(s) of operation, healthcare sectors (medical, dental, optometry, telemedicine, PT)
- Existing agreements — MSA/MSO arrangements, physician employment contracts, governance documents
- Jurisdictional scope — all states where entity operates or plans to expand
- Business model — revenue structure, physician compensation methodology, admin service arrangements
Document Structure
1. Introduction & Scope
- Define CPOM doctrine and application to the entity
- State jurisdictions covered
- Identify violation consequences: license revocation, contract voidability, criminal prosecution, civil fines
2. State-Specific CPOM Analysis
Produce a jurisdictional matrix covering: state, prohibition level (strict/moderate/permissive), key statute, exemptions, enforcement pattern.
- Limit to entity's actual operational footprint — no generic 50-state surveys unless requested
- Note sector-specific variations (telemedicine, dental, optometry, PT face different scrutiny)
- Flag recent legislative changes
- Mark uncertain citations with [VERIFY]
3. Compliant Organizational Structures
Compare models:
| Structure | Physician Control | Risk | Best For |
|---|
| PC/PA | Full ownership + governance | Low | Single-state practices |
| MSO + PC | PC controls all clinical decisions | Low-Med | Multi-state platforms |
| Friendly PC | Nominal — high regulatory scrutiny | High | Avoid unless carefully structured |
| PPM | Shared governance | Medium | Large physician groups |
For each: governance requirements, operational boundaries, de facto control scrutiny factors, selection criteria.
Friendly PC warning: Never present as low-risk. Always flag for heightened scrutiny.
4. Management Services Agreement (MSA) Architecture
