State CPOM Coverage
We provide physician PC owner services in all 50 states and DC. Below are detailed guides for the highest-enforcement states.
Priority CPOM Enforcement States
These states have the most active CPOM enforcement and require the most attention for operators. Click any state for a detailed guide.
California
Heavy CPOM enforcement. SB 351 effective January 1, 2026.
Texas
Strong CPOM under the Medical Practice Act. Active Texas Medical Board enforcement.
New York
Strict CPOM under Education Law Article 131. Courts have voided non-compliant agreements.
Florida
CPOM enforced with specialty-specific rules. Telehealth has additional requirements.
New Jersey
CPOM applicable. Specific attention to behavioral health and substance abuse treatment.
Coverage in All 50 States + DC
While the guides above focus on the highest-enforcement states, we provide physician PC owner services and documentation support in all 50 states and DC. Every state has some form of physician licensure requirement that affects MSO-PC structures.
Even states without dedicated CPOM statutes may have licensing requirements, payer rules, or Medicare/Medicaid conditions of participation that require physician ownership of the practice entity. We evaluate each state individually.
Inquire About Your StateHow CPOM Enforcement Varies by State
Active Medical Board enforcement and audit programs. Courts have voided non-compliant management agreements. Non-compliance is an existential business risk.
Examples: California, New York, Texas
Enforcement present with specialty-specific variations. Growing regulatory attention in key sectors (medspa, telehealth). Compliance strongly recommended.
Examples: Florida, Illinois, Pennsylvania
CPOM prohibition exists in statute but enforcement activity is lower. Payer rules and Medicare/Medicaid conditions may still require physician ownership.
Examples: New Jersey, Colorado, Georgia
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