MSO-PC compliance

Many healthcare groups are organized as a physician-owned professional entity (a PC or, where permitted, a PLLC) supported by a management services organization (MSO). Lemma is built for this structure: each legal entity gets its own accounts, cash sweeps automate the funds flow between an MSO and its practices, and role-based access lets MSO staff operate day to day while the practice keeps oversight. Beyond those defaults, send us your management services agreement and related documents, and we configure guardrails on your accounts that match how regulators expect a compliant MSO-PC relationship to operate. This page describes banking controls, not legal advice. Corporate practice of medicine (CPOM) requirements vary by state and depend on your specific agreements and conduct. We are the only ones to offer MSO-PC compliant banking, and we configure the best we can from the documents you give us — but we cannot guarantee compliance. Work with healthcare regulatory counsel to confirm what your structure requires.

​

Why bank account control matters

In states that enforce the corporate practice of medicine doctrine, the licensed professional owner of the practice must keep ultimate control of the practice, including its finances. Enforcement actions have specifically targeted banking arrangements: consolidated accounts the practice owners could not access, management companies with unrestricted access to practice funds, and sweep arrangements the physician could not stop. For practices that bill Medicare or Medicaid, federal rules additionally require that government-payer receivables land in an account the provider controls. The common thread: the physician should never have to ask the MSO for permission to access the practice’s money, and should always be able to see it and turn off the tap.

​

What Lemma configures

​

A physician on file

We record which owner of each entity is its physician on file. That member’s access is protected: no one — not the MSO, not other owners, not even the physician themselves — can lower their permissions or remove them from the entity inside the product. The team settings page explains why those controls are locked, and any attempt to change them through the API is rejected as well. If the physician on file needs to change — a sale, retirement, license event, death, or disability — contact us. We verify the successor and make the change deliberately, so the transition itself stays compliant instead of happening through a quiet settings edit.

​

Inviting licensed professional owners at application submit

For the same reason, when you submit a PC, PLLC, or PA application, the review step lists every licensed professional owner who isn’t already a collaborator and offers to invite them. Each owner has a Yes/No toggle, defaulted to Yes. Leave it on Yes to send the invite at submission, or switch to No to submit without inviting that owner. Either choice lets you submit the application. Invites sent this way carry over to the entity once the application is approved, so the licensed professional owner has access to the account from day one without any extra setup.

​

Physician authority no rule can override

Approval rules route a transfer above your threshold to an owner for approval, and when they are active, creating or editing a cash sweep needs an owner’s approval too. No such rule can stand between the physician and the practice’s money. Owners can approve requests they raised themselves, so the physician on file — whose Owner role is locked and cannot be lowered — can always move the practice’s funds and stop a sweep without asking the MSO. This is what CPOM expects: the physician’s authority over practice funds is ultimate, not delegated. Every approval is recorded with who gave it, self-approvals included, and that audit trail is standing evidence that the physician, not the MSO, controls the account.

​

Guardrails from your agreements

Send us your management services agreement and we align your account setup with it: the funds flow (patient revenue landing in the practice’s account before management fees move to the MSO) and sweep configurations the physician can always see and stop.

​

A paper trail on the money itself

Guardrails control what can happen. Attachments record why it happened: attach the management services agreement to a fee transfer, or a loan agreement to a capital contribution, and the justification sits on the transaction rather than in an inbox. A cross-entity attachment is visible to both entities, so the practice and the MSO read the same document — neither side holds a private version of the record. Paired with an invoice, where the practice’s owner reads the agreement before approving the payment, an intercompany fee becomes a documented, arm’s-length transaction on its face.

​

Go deeper on the MSO-PC model

This page covers what Lemma configures on your accounts. For everything around it, Lemma maintains the MSO-PC Wiki, a free, cited reference on the structure itself. It covers CPOM state by state, entity formation, the agreement stack, payer enrollment, and billing. Useful starting points: