---
title: "What Is the Corporate Practice of Medicine (CPOM)?"
description: "The corporate practice of medicine doctrine bars lay-owned companies from practicing medicine. What CPOM bans, where it comes from and how Cuvo handles it."
canonical: "https://cuvo.co/glossary/corporate-practice-of-medicine"
last-updated: "Oct 26, 2026"
---
**Definition:** The corporate practice of medicine (CPOM) doctrine is a body of state law that bars or limits companies owned by non-physicians from practicing medicine or employing physicians, so that clinical judgment stays with licensed professionals.

# What is the corporate practice of medicine (CPOM)?

The corporate practice of medicine doctrine is the reason a telehealth brand cannot simply hire physicians: in many states a company owned by non-physicians may not practice medicine at all. Cuvo Health builds and maintains the MSO and physician-owned professional entity that keep a brand on the right side of it.

Published Oct 26, 2026. Facts reviewed Oct 26, 2026.

The corporate practice of medicine (CPOM) doctrine is a body of state law that bars or limits companies owned by non-physicians from practicing medicine or employing physicians, so that clinical judgment stays with licensed professionals. States apply it through statutes, medical board rules, attorney general opinions and court decisions, and its strength ranges from a near-total bar to no general rule. As of September 27, 2026, 19 states enforced a strong prohibition and 18 had no general prohibition, per the state-by-state list linked below. On Cuvo Health, the MSO and physician-owned professional entity that satisfy the doctrine are built and maintained by Cuvo, so a founder owns the brand while licensed providers make every clinical decision.

**At a glance**
- What it is: State law that keeps medical practice ownership and clinical control with licensed professionals
- Where it comes from: Statutes, medical board rules, attorney general opinions and court decisions, state by state
- What it blocks: A lay-owned company employing physicians or owning a medical practice
- The usual answer: An MSO owned by the founder plus a professional entity owned by licensed clinicians
- On Cuvo: MSO plus physician-owned professional entity, built and maintained by Cuvo

**The state-by-state list**
- [Corporate practice of medicine states: the 2026 list](/compliance/corporate-practice-of-medicine-states): Every state classified strong, limited, unsettled or none, with the statute, case or opinion behind each call

**Where the corporate practice rule shows up in state law (examples, text checked October 26, 2026)**

| Source of the rule | Example | What it does |
| --- | --- | --- |
| **General statute** | California Business and Professions Code section 2400 | Corporations and other artificial legal entities have no professional rights, privileges or powers |
| **Medical practice act** | Texas Occupations Code section 164.052(a)(17) | A physician who aids or abets the practice of medicine by an unlicensed corporation commits a prohibited practice |
| **MSO control statute** | Oregon SB 951 (2025) | Limits MSO ownership of, and de facto control over, the professional medical entity it manages |
| **Investor statute** | California Health and Safety Code section 1191 (SB 351, 2025) | Bars private equity groups and hedge funds from interfering with physicians' professional judgment |
| **Cases and opinions** | Court decisions and attorney general opinions | Fill the gaps where no statute speaks; cited row by row on the state list |

## 01. What does the corporate practice of medicine prohibit?

In its strong form, a business owned by non-physicians may not employ physicians to practice medicine, own a medical practice, or direct clinical decisions. California's section 2400 states the rule in one sentence and then carves out its own exception, letting the medical board approve salaried employment by licensed charitable institutions, foundations or clinics that charge nothing for professional services. Other states reach the same result through the medical practice act, as Texas does by making it a prohibited practice for a physician to aid or abet the practice of medicine by an unlicensed corporation.

## 02. Why does CPOM matter for a telehealth brand?

A telehealth brand that sells nationally serves patients in strong-prohibition states, so its structure has to satisfy the strictest of them. A structure that works in a permissive state can fail in a strict one, so a national brand builds to the strictest rule it sells into instead of state by state. On Cuvo, clinical decisions belong to licensed providers practicing through a physician-owned professional entity, and neither Cuvo nor the brand directs a clinical call.

## 03. How do companies comply with the CPOM doctrine?

The standard answer is the MSO and friendly PC model: a professional corporation owned by licensed clinicians holds the practice, and the founder's management services organization provides the business services under a management services agreement. Regulators increasingly look past the paperwork. Oregon SB 951 (2025), for example, bars an MSO from exercising de facto control over hiring, diagnostic coding, clinical standards or the prices charged for a licensee's services.

## 04. Is the corporate practice of medicine the same as fee-splitting?

No, though the two travel together. CPOM governs who may own and control the practice; fee-splitting laws govern who may share in its professional fees. New York Education Law section 6530(19) and Florida Statutes section 458.331(1)(i) are fee-splitting rules, and a management fee that satisfies a state's corporate practice rule can still fail its fee-splitting rule if it is drafted as a share of the practice's income.

## Frequently asked questions

**Q: What is the corporate practice of medicine?**

A: It is a state-law doctrine that bars or limits companies owned by non-physicians from practicing medicine or employing physicians, so clinical decisions stay with licensed professionals. On Cuvo, the MSO and physician-owned professional entity that satisfy it are built and maintained by Cuvo.

**Q: What is CPOM in healthcare?**

A: CPOM is the abbreviation for the corporate practice of medicine doctrine, the state rules that keep ownership and control of medical practices with licensed clinicians. Cuvo Health operates the structure that complies with it for every brand on its platform.

**Q: Which states have corporate practice of medicine laws?**

A: As of September 27, 2026, 19 states enforced a strong prohibition and 18 had no general prohibition; the full classification with the authority for each state is on the corporate practice of medicine states page. Cuvo Health runs one MSO structure in every state, so a brand never rebuilds when it adds a stricter one.

**Q: Can a non-physician own a telehealth company?**

A: Yes. A non-physician can own the brand and the management company, while licensed clinicians own the professional entity that practices medicine. On Cuvo Health, the founder needs no medical license because Cuvo builds and maintains both entities.

**Q: Corporate practice of medicine vs fee-splitting: what is the difference?**

A: The corporate practice rule governs who owns and controls the practice; fee-splitting laws govern who may share its professional fees. Cuvo's own pricing is a flat platform fee plus $25 per completed consult, with no revenue share.

**Related pages**

- [Corporate practice of medicine states](/compliance/corporate-practice-of-medicine-states): The 2026 list, state by state
- [Friendly PC](/glossary/friendly-pc): The clinician-owned half of the compliant structure
- [Management services organization (MSO)](/glossary/management-services-organization): The business half
- [Fee-splitting laws](/glossary/fee-splitting): The companion rule on sharing professional fees
- [Med spa ownership rules by state](/blog/med-spa-ownership-rules-by-state): How the doctrine applies to med spas
- [Cuvo compliance](/compliance): The structure Cuvo builds and maintains for every brand

Canonical page: https://cuvo.co/glossary/corporate-practice-of-medicine
