COPM is an antiquated doctrine that has no sound basis in public policy, no firm basis in Idaho law, and has been widely . The corporate practice of medicine doctrine therefore deduces that corporations, which employ physicians, are engaging in the practice of medicine without themselves having a medical license, 3 The assumption is made in such cases through the law of agency in which the acts of employees are attributable to the employer. ), is rooted in the Pennsylvania Supreme Courts decision in Neill v. Gimbel Brothers, Inc., 199 A. One of the benefits of getting advice from an astute healthcare lawyer is finding the right Goldilocks strategyneither too hot on the enforcement side, nor too cool on the profit side. georgia corporate practice of medicine. The first section of this article explains the constraints on ownership of medical businesses imposed by the corporate practice of medicine doctrine.The second section of the article details the role of the professional medical corporation, which is the only business entity permitted to provide medical services or employ physicians in California. 4 Although meeting the integral part test suffices for the operating test, traditionally applicants have also provided or been asked to provide information to establish that they also meet the flexible community benefit standard" derived from Rev. 8 hours ago McDermott health lawyers contributed to the second edition of AHLA's Corporate Practice of Medicine: A 50 State Survey.Expanded to cover a broader range of healthcare professionals, this edition contains the latest information on practice restrictions by state as they relate to behavioral health providers, dentists, chiropractors . Section 43-34-42 provides the penalty for unlicensed practice of medicine or any related violation. The physician owner had no control over any decisions made by the medical practice, nor did the physician owner appear in charge of any of the practice profits or design. KHN (Kaiser Health News) is a national newsroom that produces in-depth journalism about health issues. 2 These "CPOM" states. has been advising physicians, dentists, and other health care professionals and their businesses as to contractual, regulatory and transactional matters for over 45 years. Rachel E. (Lusk) Klebanoff, Esq. The Medical Board of California continues to receive complaints and inquiries about the law, and some repeating issues are presented here. For example, a MSO may, find jobs for licensed professionals; find licensed professionals for potential employers; and manage the services of licensed professionals, including providing services to the professional for a fee, e.g., scheduling or billing. Digital Health Legal Roadblocks: Is the MSO Structure the Answer to Kickback and Corporate Practice of Medicine Concerns? To get this down on paper, the California Medical Associations Board of Trustees authorized the formation of a Technical Advisory Committee (TAC) to examine the issues surrounding the corporate practice of medicine bar and the various financial and contractual arrangements currently in place between hospitals, physicians, and other interests and to develop a response to those arrangements. Forming and structuring Practice Management entities, including Physician Practice Management companies, as well as Optometrist Management, Dental Management, Therapist Management, and Veterinarian Management. Does Healthcare Law Favor or Smash Integrated Healthcare Practices Between Medical Doctors and Chiro Smart Healthcare Venture, Smart Legal Choices. Phone: (404) 685-1662 - Medical Practice Formation :: Atlanta Medical Practice Formation Attorney What Is the Corporate Practice of Medicine? The court examined whether the PLLC "engages in any business other than the practice of medicine," and found that it did not.11 Physical therapists are licensed, and the practice of physical therapy falls within the "practice of medicine." The arrangement did not violate the doctrine. Expanded to cover a broader range of healthcare professionals, this edition contains the latest information on practice restrictions by state as they relate to behavioral health providers, dentists, chiropractors, optometrists, and more. Compliance Issues for Consulting Fees, Honoraria, Medical Directorships, and Other Types of Remuneration. 43-11-17 (2010) . Crafting the right plan takes legal experience as well as knowledge of the corporate practice of medicine, anti-kickback and fee-splitting, and other legal pitfalls that can ensnare the healthcare venture. In the strong form of Corporate Practice of Medicine, there is a typically a violation, whether the physicians are hired as employees or independent contractors, to provide medical services. Is the MSO going too far into medical practice, in the eyes of the regulators who enforce the corporate practice of medicine prohibition? She represents physicians, dentists, medical group practices, and other health-related entities in transactional, regulatory, and compliance matters. First and foremost, one must understand that, in most states, the piercing of the outermost layer of the skin or the epidermis and the rendering . Since California is a state that follows the corporate practice of medicine doctrine, those thinking of practicing medicine or even opening their own practice must be mindful of the roles non-licensed individuals play in the corporation. The MSO is paid a fee for providing these services to the medical practice, which should be fair market value and commercially reasonable for the services provided. The policy expressed in Business and Professions Code section 2400 against the corporate practice of medicine is intended to prevent unlicensed persons from interfering with or influencing the physicians professional judgment. You may access the full text of the Georgia OCGA at site here. The challenge is that the healthcare venture managed by able healthcare entrepreneurs wants to call the shots. States with a weak Corporate Practice of Medicine prohibition potentially might allow such companies to hire physicians to provide medical services, so long as the contract clarifies that the company cannot interfere with clinical decision-making. McDermott health lawyers contributed to the second edition of AHLAs Corporate Practice of Medicine: A 50 State Survey. Title 31, Chapter 33 addresses health records. 1.5021(b). Similarly, in Allstate Insurance Company vs. Northfield Medical Center, P.C., 228 N.J. 596, 159 A.3d 412 (2017), the New Jersey Supreme Court affirmed a trial courts conclusion that a New York lawyer and a California chiropractor violated the states Insurance Fraud Prevention Act (IFPA) because they promoted and assisted in the creation of a practice structure that was designed to circumvent regulatory requirements with respect to control, ownership and direction of a medical practice.. Corporate Practice of Medicine: A 50 State Survey. Gen. 4 (Jan. 28, 1994) (business corporations may not employ On the other hand, the practice of medicine prioritizes patient care. Healthcare Facilities According to the MBC, certain things require complete Professional Medical Corporations control and decision, while others require that Professional Medical Corporations have at least shared control with the MSO and other aspects do not necessarily require the Professional Medical Corporations involvement at all. The official Administrative Rules are published separately from the law and further clarify the regulations form the OCGA and are specific to the professions licensed by . While there often is a Corporate Practice of Medicine exception for hospitals that hire physicians, the AGs rationale in the 1995 opinion, cited above, provides a good statement of the logic behind the weak version of the prohibition against Corporate Practice of Medicine. We will be focusing on the exclusive decisions of the Professional Medical Corporation/Practicing Physician and the MSO respectively and decisions where neither party may solely make ultimate decision. The "corporate practice of medicine" doctrine restricts the types of healthcare businesses non-physicians can own, but with MSO agreements and appropriate legal guidance, entrepreneurs have an . Carefully review the state law when performing a field examination of an entity that is engaged in CPOM. Consider whether the applicant described, in detail, the methods and procedures through which the exempt parent controls the shareholder; If there are indicators of a lack of control by the exempt parent you should consider further development or consultation with counsel, if appropriate. How would you know? Concierge Medical Practices In all states where the IRS has issued determinations, the IRS has received this information. However, two more recent cases applying Pennsylvania law (albeit by non-Pennsylvania courts), further caution about the structure of these private equity (or other non-licensed entities or people) and medical and dental arrangements. Georgia law provides a fairly typical definition of the "practice of medicine" (O.C.G.A., Section 43-34-21) as well as a prohibition against unlicensed practice of medicine (Section 43-34-22 (a)). WE PROVIDE LEGAL STRATEGY & REGULATORY ADVICE TO BUSINESSES THAT ACCELERATE HEALTH AND WELLNESS, Addiction Treatment Centers the corporate practice of medicine regulations are action-able against your license to practice podiatry. The management fee must be at fair market value. Colorado Revised Statutes Title 12. Each state has its own laws, of course. Negotiating, or assisting other counsel in negotiating, with lenders and insurance providers concerned about state law and/or corporate practice of medicine compliance. , it has no legitimate business interest in enforcing the covenant not to compete with Dr. Parikh." 1 Overview of Virginia Corporate Practice of Medicine Doctrine 12 The theoretical basis for the corporate practice of medicine doctrine is that only individuals who have received the requi- The applicant must ensure that the PSC operates in a charitable manner and remains an integral part of the exempt parent holding beneficial title. While California law does allow a percentage of gross revenues under certain conditions, generally, percentages raise enforcement issues. Strong v. Weak Corporate Practice of Medicine States. The court held that the . Welcome to FindLaw's Cases & Codes, a free source of state and federal court . A Professional service is the personal service rendered by a physician, surgeon or doctor of medicine pursuant to a license under 481 through 524 of Title 59 of the Oklahoma Statutes, and any subsequent laws regulating the practice of medicine. Medical Practice Act: Business and Professions Code Section 2052, requiring a medical license to practice medicine, and Section 2400, declaring that corporations have no professional rights, privileges, or powers. Also, because it is allowed only to provide professional services, it can only manage the services that it provides. This is not something that should be undertaken casually. 178 (1938), which has not been overruled or modified in the 82 years since the original holding. Decisions regarding coding and billing procedures for patient care services. A version of this article was published in The Daily Record on September 8, 2015.. 1 This analysis assumes the organization is formed as a corporation, however the organization may be formed as some other type of legal entity allowable under the laws of the state, such as an LLC. Manager approves the expenditures of the PSC. So, what it means is that only doctors can practice medicine. Call 1-800-GEORGIA to verify that a website is an official website of the State of Georgia. Atty. Seek assurance that there is no such requirement. There are many benefits to operating a business in a corporate form. This ban on the corporate practice of medicine (CPM) . State law prohibitions against corporate practice of medicine come in to flavors: The distinction between the strong and weak versions can be particularly important when designing an MSO (management services organization) structure. Thus, a medical practice is not supposed to be a business that employs medical professionals but rather owned by mostly practitioners themselves. These documents should have established adequate control by the exempt parent. Expanded to cover a broader range of healthcare professionals, this edition contains the latest information on practice restrictions by state as they relate to behavioral health providers, dentists, chiropractors, optometrists, and more. M&A (Acquisitions & Sales of Healthcare Businesses), Fraud & Abuse (Anti-Kickback, Fee-Splitting, Stark), Management Services Organizations (MSO) Issues, Medical Device & Mobile Medical App Issues, ANTI-AGING & FUNCTIONAL MEDICINE PRACTICES, BEHAVIORAL & MENTAL HEALTHCARE PROVIDERS AND LIFE COACHES, COMPLEMENTARY & INTEGRATIVE MEDICINE PROVIDERS, CONCIERGE & DIRECT PRIMARY CARE MEDICAL PRACTICES, DIETARY SUPPLEMENT & NUTRACEUTICAL COMPANIES, HEALTHCARE FACILITIES (HOSPITALS, LABS, DME, IMAGING), Corporate practice of medicine, anti-kickback and fee-splitting: deep down the rabbit hole, Corporate practice of medicine and fee-splitting lead medical spa enforcement. Responding to state professional board inquiries, information requests, complaints, investigations, and other related matters. (Bill) Kalogredis, Esq. Telemedicine Ventures. How Can a Multi-Disciplinary Health & Wellness Platform Handle Legal Risks? The corporate practice of medicine, or CPOM, is a doctrine that's enshrined in many states' laws, either by statute, which is the laws on the books, or by judge-made law case law. Seeking the advice of knowledgeable and experienced professionals is imperative before taking any such steps. Dietary Supplement Companies The Board's new position removes obstacles to non-physician investments in medical practices and other transactions that previously were prohibited by the Board's enforcement of an antiquated rule known as the corporate practice of medicine doctrine . The SCA prohibits the shareholder from disposing of the stock without the parents permission. However, given the structural complexity of many such medical entities, including MSOs, it is vital to ensure that any corporate/business arrangements comply with the requirements of the CPOM doctrine. Cannabis Ventures About The Georgia Composite Medical Board, Frequently Asked Questions About The Board, Frequently Asked Questions about Complaints, Nurse Protocol Agreements Reviewed by the Board, Prescription Drug Monitoring Program (PDMP), Continuing Education and Other Required Training for Physicians. Professions and Occupations. Again, these situations are very fact-specific. 43-34 and 34A) is the statutory authority (law) that establishes the Georgia Composite Medical Board, the Medical Practice Act, and the Patient Right to Know Act (Physician Profile). Fenton Law Group has a practice focused on the transactional legal issues that arise in the medical industry including, the CPOM doctrine. 2023 Fenton Law Group, LLP.All rights reserved. The TAC developed a list of those decisions which would affect, directly or indirectly, the practice of medicine and assigned the decision making authority of those decisions to the appropriate party, i.e. Reg. 2010 Georgia Code TITLE 43 - PROFESSIONS AND BUSINESSES CHAPTER 11 - DENTISTS, DENTAL HYGIENISTS, AND DENTAL ASSISTANTS . The Corporate Practice of Medicine: Is It Applicable for Your Client? What is the corporate practice of medicine? The legislation, which went into effect July 1, 2012, amends Tennessee Code Annotated Sections 68-11-205 and 63-6-204 by providing an exception to Tennessee's prohibition on the corporate practice . Because the Professional Service Corporation (or PSC) is owned by natural persons (shareholders), it is normally a taxable corporation, however, the IRS will recognize a PSC as exempt if it meets certain stringent requirements. The intent of the doctrine was to ensure that only licensed medical professionals delivered medical care and that lay persons and entities not influence treatment decisions. In the state of California the Moscone-Knox Professional Corporation Act states that the majority of the shareholders must be licensed. Corporate Practice of Medicine (CPOM) application is far from simple, and adoption and enforcement vary by state. Performing pre-investment evaluation and due diligence, and, where necessary, amending or restating all documents related to Friendly PC or Captive PC arrangements, including entity formation documents, management agreements, continuity agreements, employment agreements, and lending or leasing agreements. Do not hold themselves out to the public generally as being authorized to engage in the practice of the profession for which the . Medical Groups, Medical Centers If state law requires the stockholder to have beneficial as well as legal title to the stock, the PSC will probably not qualify for exemption. The legal principle that undergirds both Tenn. Code Ann. These "corporate practice" restrictions are imposed by statute in some states, and in others by regulation or case law. Board Rule 480-28, Practitioner Dispensing of Drugs. The American Health Law Association (AHLA) Corporate Practice of Medicine survey more thoroughly examines the variation of practice restrictions by each state as they relate to behavioral health providers, chiropractors, and other types of health care professionals. Can a Subscription-Based Healthcare Startup Legally Deploy the RN Profitably? The corporate practice of medicine doctrine is a medical practice act aimed at protecting patients from deceptive behavior that might come with the private ownership of medical corporations by non-licensed individuals including: The commercialization of the practice of medicine The imbalance between patient obligations and stakeholder obligations Interference of a physicians medical judgment due to outside influences. We understand the state-by-state nuances of the state laws governing licensed professional services, and we work closely with our clients through each step of their venture to ensure state licensure compliance. If not done properly, this may not fly. In this way, the Medical Board of California pulls together the various pieces of legislation. The management company controlled the day-to-day operations of the medical practice, had responsibility for all financial matters, and had the right to seize control of the practice at any time through an undated resignation letter signed by the physician. 1. one or more persons licensed pursuant to the medical practice act of 1987, as heretofore or hereafter amended, may form a corporation pursuant to the "business corporation act of 1983", as amended, to own, operate and maintain an establishment for the study, diagnosis and treatment of human ailments and injuries, whether physical or mental, and It is not legal in this state for a non-licensee to own any portion, no matter how small, of a physician practice. Medical practices of all types are subjected to various regulations from business formation to HIPAA compliance, and everything in between. In order to avoid regulatory pitfalls, however, contractual MSO arrangements need to be structured carefully to ensure that . https://cohenhealthcarelaw.com/michaelhcohen/wp-content/uploads/2022/08/cohen-healthcare-horizontal-2020_v2.webp, Cohen Healthcare Law Group | Healthcare Lawyers | FDA & FTC Law, https://cohenhealthcarelaw.com/michaelhcohen/wp-content/uploads/2014/12/bigstock-doctor-meeting-teamwork-diagno-108851294.png. That is, it cannot provide management services to other occupational therapists. Although most prohibit it, some have no regulatory statute at all. How you know. WE PROVIDE LEGAL STRATEGY & REGULATORY ADVICE TO BUSINESSES THAT ACCELERATE HEALTH AND WELLNESS, Addiction Treatment Centers California corporate practice of medicine strict prohibition. University of Maryland Physicians v. Commissioner, T.C. the corporate practice of medicine doctrine. Can you get the Priestly Blessing from your Healthcare & FDA Lawyer? To get to the prohibition against the corporate practice of medicine (or Corporate Practice of Medicine), you have to put these three sources together. What is the Corporate Practice of Medicine Doctrine? MSO has no duty to consult with the Professional Medical Corporation/ Practicing Physician, even on an informal basis. However, the MSOs services must not interfere with the professionals medical (clinical) judgment or otherwise result in MSO control over the medical aspects of the medical practice. The SCA imposes the provisions of IRC 501(c)(3) on the operation of the PSC. For example, what if the telemedicine or digital health venture or mobile app guides the user (aka patient) to a specific pathway of diagnostic tests and/or treatments? do permit Professional Service Corporations -- a special type of corporation which must be owned by physicians -- to do so. These may include favorable income tax treatment and immunity from certain types of liability. Georgia Dental Law. Things are state-specific. . legally may provide medical services except under the supervision, control and responsibility of a licensed physician. Exclusive Decisions vested in the MSO has sole responsibility for the decision. Subsequent case law is sparse and other authorities provide limited guidance on the applicability of the CPOM doctrine. There are usually exceptions to the corporate practice of medicine prohibitionnotably, for example, the case of hospitals. This is good news if you are planning a multi-state or national model of health and wellness services, whether through physical healthcare clinic sites or digital health or mobile health (telemedicine, etc.). Then usually a third set of statutes that deal with who can organize and own a professional corporation. 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