The Corporate Practice of Medicine (CPOM) doctrine governs how medical services can be provided and ensures that licensed physicians maintain control over clinical decision-making. While Minnesota does not have a strict CPOM law compared to some states, healthcare providers and businesses operating within the state must still adhere to guidelines that protect the integrity of medical practice and comply with professional licensure laws.

Minnesota’s CPOM regulations present challenges for healthcare providers, but Access Plus Health is here to help. Our 2025 compliance guide offers clear advice on meeting legal requirements, ensuring your practice remains efficient and compliant. Trust us to support your practice’s success in Minnesota’s healthcare system.

This guide outlines the essentials for navigating CPOM compliance in Minnesota for 2025, helping healthcare providers understand the regulations and avoid potential pitfalls.

1. Understanding CPOM in Minnesota

Minnesota does not formally prohibit the corporate practice of medicine, allowing entities to employ physicians directly. However, regulations ensure that the employment arrangements do not interfere with physicians’ independent medical judgment.

  • Key Principle: The focus is on protecting patient care from undue influence by non-physicians or business interests.
  • Scope: Applies to entities like hospitals, telehealth providers, and medical spas.

2. Ownership and Control of Medical Practices

While Minnesota permits corporations to employ physicians, certain restrictions apply to ensure compliance with professional conduct standards:

  • Medical Directors: Physicians must retain responsibility for clinical decisions and oversee healthcare services.
  • Professional Corporations: Physicians or other licensed healthcare professionals must own and control these entities to comply with licensure rules.

3. Supervision and Collaboration Agreements

Healthcare providers such as nurse practitioners (NPs) and physician assistants (PAs) may collaborate with physicians to deliver care. Minnesota requires written agreements outlining their scope of practice and supervision.

  • Essentials of Agreements:
    • Clearly define roles and responsibilities.
    • Specify the level of physician oversight required.
    • Update agreements annually or as needed.

4. Telemedicine Compliance

Telehealth is a growing field in Minnesota, and providers must comply with state-specific regulations to avoid legal complications.

  • Key Considerations:
    • Physicians providing telemedicine must be licensed in Minnesota.
    • Telehealth services must maintain the same standard of care as in-person visits.
    • Data privacy and HIPAA compliance are critical for telemedicine platforms.

5. Avoiding Fee Splitting and Kickbacks

Fee-splitting and kickbacks are prohibited in Minnesota, aligning with federal anti-kickback statutes and Stark Law.

  • What to Watch For:
    • Ensure that compensation arrangements between physicians and entities are fair market value.
    • Avoid agreements that incentivize referrals.
    • Consult legal experts for complex financial arrangements.

6. Hiring Physicians as Employees

Corporations hiring physicians must ensure that the employment relationship complies with state and federal regulations. Physicians must retain autonomy over clinical decisions without undue influence from non-medical stakeholders.

  • Compliance Tips:
    • Draft contracts that separate clinical and business decision-making.
    • Allow physicians to control patient care decisions.
    • Avoid performance metrics tied to patient volume or revenue generation.

7. Medical Spas and Non-Traditional Practices

Medical spas and similar businesses are increasingly popular in Minnesota, but they must operate within CPOM compliance rules.

  • Guidelines for Compliance:
    • Medical directors must oversee all medical procedures.
    • Ensure that only licensed professionals perform clinical tasks.
    • Clearly define the supervisory role of physicians in contracts.

8. Professional Liability Insurance

Entities employing physicians should provide adequate professional liability coverage to protect against potential malpractice claims.

  • Best Practices:
    • Ensure that physicians and mid-level providers are covered under the entity’s policy.
    • Regularly review and update coverage limits.

9. Regulatory Updates for 2025

Minnesota periodically updates healthcare regulations to address evolving practices and technologies. For 2025:

  • Anticipated Changes:
    • Enhanced telemedicine guidelines, especially for cross-state care.
    • Stricter enforcement of data security measures in healthcare IT.
    • Greater scrutiny of non-physician-owned entities providing medical services.

Stay informed by regularly reviewing updates from the Minnesota Board of Medical Practice and consulting with legal professionals.

10. Steps to Ensure Compliance

To ensure CPOM compliance, healthcare providers and businesses should adopt proactive measures:

  1. Conduct Legal Reviews:
    • Work with healthcare attorneys to review contracts and employment agreements.
  2. Establish Clear Policies:
    • Define roles and responsibilities for physicians and non-medical staff.
  3. Train Staff:
    • Provide regular training on CPOM principles and compliance requirements.
  4. Monitor Changes:
    • Stay updated on state and federal regulations affecting healthcare practices.

Minnesota’s approach to the Corporate Practice of Medicine doctrine offers flexibility for healthcare providers, but compliance is key to avoiding legal risks and ensuring high-quality patient care. By adhering to the principles of physician autonomy, regulatory guidelines, and ethical business practices, healthcare entities can thrive while maintaining the trust of patients and regulators.

Whether you are a physician, business owner, or healthcare provider, understanding and addressing CPOM compliance essentials in Minnesota will position you for success in 2025 and beyond.

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