Structured for the federal rules and the state ones.
Corporate practice of medicine and AKS both apply to telehealth billing. We structure the rental MSO for the federal safe harbor and your PC for each state's CPOM rules.
CPOM, AKS, and the MSO-PC structure
The rental phase is an MSO arrangement with Anvil's PC. The ownership phase is your MSO and your own PC, papered for state corporate practice of medicine. That is how telehealth billing stays inside the rules as volume moves.
Rental phase
- Your entity leases clinicians to Anvil's PC at a fixed, fair-market-value rate
- Your MSO provides administrative services to Anvil's PC for a fixed fee
- Fees set in advance, not tied to volume or value of referrals
- Written agreements with terms of at least one year
- Anvil's PC bills, collects, and pays under those agreements
Structured to align with the personal services and management contracts safe harbor, 42 CFR 1001.952(d). Counsel reviews every engagement. This is a description, not legal advice.
Ownership phase
- Your own PC formed in each state, with the entity type that state requires
- Licensed physician owner placed through Foundry PC
- Management services agreement between your MSO and your PC
- Control and economics allocated as each state's CPOM rules allow
- Payer contracts, credentialing files, and rates held by your PC
State CPOM structuring is separate from, and in addition to, the federal analysis. See the 50-state CPOM guide.
What is in place, and what is dated
| Control | Status |
|---|---|
| HIPAA privacy and security program, BAA available | In place |
| Encryption in transit (TLS 1.2+) and at rest | In place |
| Role-based access, MFA, audit logging | In place |
| Annual risk assessment and workforce training | In place |
| SOC 2 Type II | In progress. Target: TODO(launch): date |
| Public trust center and sub-processor list | On SOC 2 completion |
Compliance page language reviewed by counsel before publication. TODO(launch): counsel sign-off.
Owning the PC is the CPOM answer in practice
See own your contracts for how volume moves to an entity you control. The founder-level version is rent a PC vs own a PC. If you are leaving a network rental vendor, start with switching or the Anvil vs Bridge table.
Questions, answered
Is the rental structure legal?
It is structured to align with the personal services and management contracts safe harbor under the federal Anti-Kickback Statute: written agreements, terms of at least a year, compensation set in advance at fair market value, and not tied to the volume or value of referrals. Independent counsel reviews every structure. Anvil does not claim an OIG advisory opinion.
What about state corporate practice of medicine rules?
Federal fraud-and-abuse analysis does not address state CPOM. Each state has its own rules on who may own a professional entity and what a management company may control. We structure your own PC state by state through Foundry PC, which has done this across the country.
Who owns our PC?
A licensed physician placed through Foundry PC, under agreements that give your MSO the management rights and economics that state permits. That is the friendly-PC structure that most multi-state care companies use.
Is Anvil SOC 2 certified?
Not yet. SOC 2 Type II is in progress. The trust center will publish the report and sub-processor list on completion. HIPAA program, encryption, access controls, and audit logging are in place today.
Will you sign a BAA?
Yes, as part of onboarding. Request one on the BAA page.
Does this website collect PHI?
No. The marketing site collects business contact information only. Never enter patient information in a form here.
Bring your counsel. We will bring ours.
We share the structure memo summary and the agreement templates during diligence.