MSO-PC structure and corporate practice of medicine for telehealth
What is an MSO-PC structure and does my telehealth startup need one?
An MSO-PC structure splits a care company into a physician-owned professional corporation that delivers and bills care and a management services organization that founders and investors own. Many states' corporate practice of medicine rules require it when non-physicians own the business. Anvil structures your PC for each state's rules, with counsel reviewing every structure.
Updated October 30, 2026
Corporate practice of medicine for telehealth is set state by state, and AKS is federal; both apply to telehealth billing. We structure the rental MSO for the federal safe harbor and your PC for each state's CPOM rules.
MSO-PC structure for telehealth
An MSO-PC structure for telehealth is a physician-owned professional corporation that bills, plus a management company. In the rental phase, your MSO provides administrative services to Anvil's PC for a fixed fee set in advance. In the ownership phase, your MSO manages your own PC, and that PC holds the payer contracts. That is how you own your payer contracts.
Paper the entity under corporate practice of medicine for telehealth.
Corporate practice of medicine for telehealth
Corporate practice of medicine for telehealth means state rules on who may own a professional entity and what a management company may control when you bill medical services. The ownership path is your own PC. What changes when the contracts sit in your own entity is covered in what in-network nationally means.
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.
Volume later sits on contracts your PC holds, which is how you own your payer contracts. The rent-first choice is renting a PC versus building your own professional corporation. If you are leaving a rental vendor, start with switching from a network rental vendor. To compare vendors, see the Bridge alternative fact table. Planning ranges start at 90837 reimbursement rates by state.
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 date publishes with the trust center. |
| Public trust center and sub-processor list | On SOC 2 completion |
Compliance copy is reviewed by counsel before publication.
Own the contracts, not the rental
Questions, answered
What is corporate practice of medicine telehealth?
State rules on who may own a professional entity and what a management company may control when you bill medical services. Telehealth billing still has to fit those rules. We structure an AKS safe harbor MSO for the rental phase and your own PC for CPOM compliance by state, with HIPAA in place and SOC 2 in progress.
What is an MSO-PC structure and does my telehealth startup need one?
An MSO-PC structure splits a care company into a physician-owned professional corporation that delivers and bills care and a management services organization that founders and investors own. Many states' corporate practice of medicine rules require it when non-physicians own the business. Anvil structures your PC for each state's rules, with counsel reviewing every structure.
What is the Anti-Kickback Statute safe harbor for an MSO in telehealth?
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 is CPOM compliance by state for telehealth?
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.