The Corporate Practice of Medicine (CPOM) doctrine in Maryland ensures that clinical decisions remain in the hands of licensed physicians, safeguarding patient care from corporate influence. As the healthcare industry evolves with emerging technologies and innovative care models, understanding and adhering to Maryland’s CPOM laws in 2025 is critical for providers, telehealth businesses, and medical directors. This roadmap offers a comprehensive guide to navigating Maryland’s CPOM regulations.

Navigating Maryland’s Corporate Practice of Medicine (CPOM) laws is essential for healthcare providers in 2025. Access Plus Health offers a compliance roadmap to help you understand ownership restrictions, physician oversight requirements, and collaboration structures. With our expert guidance, your practice can stay compliant and focus on delivering high-quality patient care.

What is CPOM and Why Does It Matter?

The CPOM doctrine restricts non-physician entities from owning or controlling medical practices. The primary goals are to:

• Preserve Physician Autonomy: Clinical decisions must be made solely by licensed physicians, prioritizing patient welfare over corporate interests.
• Maintain Ethical Standards: By limiting corporate influence, CPOM laws promote integrity in patient care.
• Ensure Accountability: Physicians remain directly accountable for the quality of care delivered.

Key Elements of Maryland’s CPOM Regulations

1. Physician Ownership:
   Medical practices in Maryland must be owned or controlled by licensed physicians or physician-led entities. Corporate entities are prohibited from directly owning medical practices.
2. Clinical Decision-Making Authority:
   Physicians must have full authority over all aspects of patient care, including diagnosis, treatment, and follow-up. Non-physician entities are restricted to administrative functions.
3. Application to Telehealth:
   Maryland’s CPOM laws extend to telehealth providers, requiring licensed Maryland physicians to oversee all virtual patient interactions.
4. Management Services Agreements (MSAs):
   MSAs must clearly define the separation between administrative and clinical responsibilities, ensuring compliance with CPOM regulations.

Compliance Challenges in 2025

1. Emerging Care Models:
   Hybrid care models, such as telehealth and remote monitoring, require clear oversight structures to align with CPOM regulations.
2. Technology Integration:
   The use of AI, machine learning, and wearable devices complicates compliance, as these tools must support physician decision-making without replacing it.
3. Multi-State Operations:
   For providers operating in multiple states, aligning Maryland’s CPOM laws with other states’ regulations adds complexity.
4. Ambiguous Contracts:
   Poorly drafted agreements between physicians and corporate entities can inadvertently lead to violations of CPOM regulations.

Steps to Ensure Compliance

1. Review Ownership Structures

• Confirm that medical practices are owned or controlled by licensed physicians in Maryland.
• Avoid direct ownership by corporate entities unless they are physician-led.

2. Draft Comprehensive MSAs

• Clearly delineate roles and responsibilities for clinical and administrative functions.
• Include clauses that explicitly prohibit non-physician entities from influencing patient care.

3. Engage Legal Counsel

• Consult healthcare attorneys to review contracts, operational workflows, and licensing requirements for CPOM compliance.

4. Conduct Regular Audits

• Periodically assess compliance practices, including MSAs, workflows, and technology use, to identify and address potential risks.

5. Educate Stakeholders

• Train physicians, administrators, and corporate partners on Maryland’s CPOM regulations to ensure awareness and adherence at all levels.

Special Considerations for Telehealth Providers

Telehealth providers must navigate specific CPOM requirements in Maryland, including:

1. Licensing:
   Physicians overseeing telehealth services must hold a valid Maryland medical license.
2. Oversight of Technology:
   Telehealth platforms and AI tools must operate under the supervision of licensed physicians, supporting rather than replacing clinical decision-making.
3. Data Privacy Compliance:
   Ensure that telehealth services comply with HIPAA and Maryland-specific data security laws while adhering to CPOM principles.

The Role of Management Services Agreements (MSAs)

MSAs are a critical tool for ensuring CPOM compliance. Key considerations include:

1. Defining Roles Clearly:
   Specify that non-physician entities may handle administrative tasks but cannot interfere in clinical operations.
2. Updating Contracts Regularly:
   Periodically review and update MSAs to reflect changes in CPOM laws and healthcare operations.
3. Ensuring Transparency:
   MSAs should include language that promotes transparency and adherence to Maryland’s CPOM laws.

Consequences of Non-Compliance

Failing to comply with Maryland’s CPOM regulations can result in:

• Financial penalties and fines.
• Legal disputes and reputational damage.
• Revocation of physician licensure for those involved in non-compliant practices.

Future Trends in Maryland CPOM Regulations

1. Telehealth Expansion:
   As virtual care grows, Maryland’s CPOM laws may adapt to address new challenges in maintaining physician oversight in digital health.
2. AI and Automation:
   Future updates may clarify the use of AI and other emerging technologies in clinical care, ensuring compliance with CPOM principles.
3. Cross-State Compliance Frameworks:
   Multi-state providers may develop standardized compliance strategies to align with diverse CPOM laws across jurisdictions.

Maryland’s CPOM laws are foundational to maintaining ethical healthcare delivery and physician autonomy. By understanding these regulations and implementing proactive compliance strategies, providers can navigate the complexities of 2025 with confidence. Whether operating a traditional practice or embracing telehealth innovations, adherence to CPOM laws ensures high standards of care, legal protection, and trust in the healthcare community.