The Corporate Practice of Medicine (CPOM) doctrine ensures that clinical decision-making remains under the control of licensed physicians, safeguarding the integrity of patient care. While Minnesota’s CPOM regulations offer more flexibility than stricter states, compliance is essential to avoid legal challenges and maintain high ethical standards in medical practice.

Compliance with Minnesota’s CPOM regulations is critical for medical practices to avoid legal risks in 2025. Access Plus Health provides a detailed roadmap to guide you through key requirements, from structuring collaborations to managing oversight responsibilities. Let us help you ensure your practice remains compliant and successful in Minnesota.

This roadmap outlines practical steps for medical practices in Minnesota to navigate CPOM compliance in 2025, ensuring operational success and patient safety.

1. Understand CPOM in Minnesota

Unlike states with rigid CPOM laws, Minnesota permits corporate entities to employ physicians directly. However, this flexibility comes with requirements designed to protect physician autonomy.

• Key Principle: Physicians must retain authority over all medical decisions, free from undue influence by corporate interests.
• Scope: Applies to hospitals, telehealth providers, urgent care centers, and non-traditional practices such as medical spas.

2. Physician Autonomy: The Cornerstone of Compliance

Maintaining physician autonomy is critical to CPOM compliance. Medical decisions must prioritize patient welfare over business objectives.

• Best Practices:
  
  • Clearly separate clinical responsibilities from business or administrative tasks in contracts.
  • Avoid performance incentives tied solely to financial outcomes or patient volume.
  • Ensure that non-clinical staff do not have authority over clinical operations.

3. Structuring Employment Contracts

Employment agreements for physicians should align with Minnesota’s CPOM regulations while safeguarding the interests of both the physician and the employing entity.

• Contract Essentials:
  
  • Explicitly state that physicians retain full control over patient care decisions.
  • Outline roles and responsibilities for non-physician administrators, ensuring no interference in clinical matters.
  • Include clauses addressing compliance with Minnesota law and professional licensure requirements.

4. Licensing and Ownership Requirements

Medical practices in Minnesota must comply with licensing rules and, in some cases, ownership requirements.

• Professional Corporations:
  
  • Practices owned by physicians or other licensed professionals are preferable for reducing CPOM-related risks.
  • Ownership structures should clearly define roles to prevent conflicts of interest.
• Telehealth Providers:
  
  • Physicians providing telemedicine services must hold valid Minnesota licenses and adhere to the same standards as in-person care.

5. Collaboration Agreements for Mid-Level Providers

Nurse practitioners (NPs) and physician assistants (PAs) working in Minnesota often require collaboration or supervision agreements with physicians.

• Key Elements:
  
  • Specify the scope of practice for mid-level providers.
  • Include protocols for remote supervision in telehealth or rural care settings.
  • Regularly review and update agreements to reflect current laws and practice needs.

6. Avoiding Fee Splitting and Kickbacks

Minnesota prohibits fee-splitting arrangements that could compromise patient care or create ethical conflicts.

• Compliance Tips:
  
  • Ensure that compensation models reflect fair market value.
  • Avoid revenue-sharing arrangements tied directly to patient referrals or service volume.
  • Seek legal counsel for complex financial relationships.

7. Telehealth-Specific Compliance

With the rapid expansion of telehealth, ensuring CPOM compliance in virtual care settings has become increasingly important.

• Action Steps:
  
  • Use secure, HIPAA-compliant telehealth platforms to protect patient data.
  • Clearly document telehealth visits and maintain robust records.
  • Provide patients with informed consent outlining the nature and limitations of telemedicine services.

8. Data Security and Privacy

Minnesota medical practices must adhere to data security regulations to protect patient information, especially in telehealth and digital recordkeeping.

• Best Practices:
  
  • Encrypt patient data and implement secure access controls.
  • Regularly train staff on recognizing cybersecurity threats.
  • Conduct periodic audits to ensure compliance with HIPAA and state-specific privacy laws.

9. Adapting to 2025 Regulatory Changes

Healthcare regulations in Minnesota continue to evolve, particularly in response to advancements in telehealth and integrated care models.

• Anticipated Updates:
  
  • Expanded licensing requirements for multi-state telehealth providers.
  • Enhanced scrutiny of compensation models to prevent fee-splitting violations.
  • New guidelines for AI-driven diagnostic tools and their role in clinical decision-making.

10. Regular Compliance Audits

Conducting regular audits is essential to identify and address potential CPOM compliance issues before they become legal liabilities.

• Audit Checklist:
  
  • Review contracts for alignment with CPOM principles.
  • Evaluate supervision agreements and telehealth protocols.
  • Assess data privacy and security measures.

11. Training and Education

Investing in staff training ensures that everyone in the practice understands CPOM regulations and their role in maintaining compliance.

• Training Topics:
  
  • Physician autonomy and ethical decision-making.
  • Compliance requirements for telehealth and mid-level providers.
  • Best practices for preventing fee-splitting and kickbacks.

12. Partnering with Legal Experts

Engage healthcare attorneys with CPOM expertise to review contracts, policies, and business structures. This proactive approach minimizes risks and ensures that your practice operates within the bounds of Minnesota law.

Ensuring CPOM compliance in Minnesota is not just about meeting regulatory requirements—it’s about protecting the integrity of medical practice and delivering the highest standard of patient care. By prioritizing physician autonomy, structuring contracts effectively, and staying informed about evolving regulations, medical practices can navigate the complexities of CPOM compliance with confidence in 2025 and beyond.