The corporate practice of medicine (CPOM) doctrine restricts the ability of non-physician entities to employ or engage physicians or direct the practice of medicine in certain states. The CPOM doctrine’s rules, which are anything but uniform, make it a threshold issue for any digital health company with a care delivery component. Join Wilson Sonsini for its semi-annual training for digital health executives, designed to keep them current on both the fundamentals and the latest developments shaping CPOM compliance. Each session addresses the core framework and spotlights what has changed since the last installment, so your team can stay ahead of the fast-moving regulatory landscape.

This series is built for founders, C-suite leaders, physician owners, general counsel, and compliance officers who need a clear, recurring touchpoint on CPOM risk. It’s equally valuable for investors in the digital health space who want to understand how these structures work and where the compliance lines fall. We recommend it as standing executive training for any organization operating MSO-PC (management services organization-professional corporation) structures.

Each session covers:

• CPOM foundations — The core prohibitions, the policy rationale, and how the doctrine operates across key jurisdictions
• Structuring essentials — How MSOs, PCs, and affiliated entity structures are used to maintain compliance
• State spotlight and emerging trends — An in-depth look at recent legislative, regulatory, case law, and enforcement developments in active jurisdictions
• Practical takeaways — What concrete steps organizations should be taking now to strengthen compliance and reduce enforcement risk

Spotlight This Session: California and Oregon

This session will take a close look at the California and Oregon developments reshaping the field, including the California Attorney General's amicus brief in Art Center Holdings v. WCE CA Art (taking the position that MSO succession and stock transfer restriction rights to replace a physician owner can violate CPOM even if never exercised), the California Attorney General's recent settlement with Aspen Dental, and the Oregon SB 951 challenge in Eugene Emergency Physicians v. PeaceHealth (the first private enforcement action under what is widely considered to be the strictest CPOM law in the country).

Why It Matters

CPOM compliance is not just a one-time paperwork exercise—it requires ongoing effort. A non-compliant structure can trigger regulatory penalties and unlicensed-practice exposure, and put licensure, payor relationships, and company valuation at risk. It can also drive investment outcomes, where sophisticated investors treat CPOM compliance as a fundamental diligence and risk factor, which makes a clean, defensible structure increasingly important to raising capital and reaching a successful exit.