What No One Is Saying About California CPOM in 2026

Healthcare attorney Shalyn Watkins wrote an article for the American Health Law Association examining California's increasingly aggressive enforcement of the state's corporate practice of medicine (CPOM) doctrine and what recent enforcement actions mean for management services organization-professional corporation (MSO-PC) structures. Using the California attorney general's settlement with Carbon Health as a case study, she explains that regulators have effectively provided a compliance roadmap for healthcare organizations by identifying specific arrangements that raise CPOM concerns, including option agreements, financing structures, operational control provisions and governance practices that undermine physician independence. She also highlights California's heightened scrutiny of existing MSO-PC models, increased willingness to impose personal liability and require unwinding of noncompliant arrangements, and the need for organizations to reassess current structures to ensure genuine physician autonomy in operational and clinical decision-making. The article provides practical guidance for healthcare organizations and advisers as they respond to the new enforcement environment and manage higher compliance expectations.

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