Centralized treasury across multiple PCs means one dashboard and one policy — not one account. Here's how to run it without breaking CPOM rules.
Centralized doesn't mean one bank account. It can't, legally, not in how the MSO-PC structure is put together (opens in a new tab). CPOM keeps PCs separate by design.
What it means: one dashboard, one set of policies, one point of control. The money sits in many accounts. The decisions sit in one place.
Patient and payer dollars hit the PC first. Always. The PC then pays the MSO a management fee on a documented schedule. Cash moves down the contractual chain, never sideways.
Break this rule and you've got fee-splitting, which most state medical boards treat as a felony.
You can centralize these without touching ownership:
Don't centralize these. Ever.
The PC is its own legal entity. It needs to look and act like one in every audit.
You're past DIY when:
If two of these hit, you're already paying for the wrong setup.
Decentralized treasury isn't free. It costs in three places:
A lean treasury team shouldn't be the team that loses its weekends.
A clean centralized treasury looks like this:
For Lemma, that looks like $10M FDIC per entity through the IntraFi sweep network, virtual accounts per location for payer EFT routing, and a single dashboard your CFO actually checks on a Tuesday.
Centralized treasury isn't one account. It's one source of truth. Pick a single dashboard across the whole entity structure (opens in a new tab), and the work shrinks from a Friday spreadsheet to a Monday glance.