What is Corporate practice of medicine (CPOM)?
The corporate practice of medicine doctrine is a set of state laws restricting who may own or control a medical practice: in CPOM states, only licensed physicians or approved professional entities may own the medical side, employ providers for medical services, or direct clinical decisions. It shapes how non-physician med spa founders must structure ownership.
How it works in an aesthetic clinic
In a CPOM state, a non-physician founder typically forms a management company that owns the brand, lease, equipment, and non-clinical staff, while a physician-owned professional entity delivers the medical services; a management services agreement connects the two at fair-market terms. The same clinic in a non-CPOM state might be a single company. The doctrine decides the org chart before the first client is booked.
Corporate practice of medicine (CPOM) vs the MSO model
| Corporate practice of medicine (CPOM) | The state-law restriction on who may own and control medical practice |
|---|---|
| The MSO model | The two-entity structure commonly used to operate lawfully within that restriction |
Why it matters for clinic operators
Getting CPOM wrong risks the enforceability of the entire business, not just a fine: fee-splitting findings, voided agreements, and board action against the physician. Structure with healthcare counsel licensed in your state before signing a lease.
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