EffectiveHigh Impact
Oregon MSO and corporate-practice restrictions reshape clinic platform structures
Oregon SB 951 restricts how management services organizations and their owners, directors, officers, employees, or affiliates may own, control, manage, or participate in professional medical entities they support.
Operator impact: Oregon clinic platforms, med spa MSOs, private equity groups, and friendly-PC structures should review ownership, control rights, board roles, equity-transfer restrictions, management agreements, and de facto control over clinical or business operations.
Effective Jan 1, 2026
Deadline Jan 1, 2029
ProposedHigh Impact
New Hampshire SB 666 would create healthcare transaction and CPOM restrictions
New Hampshire SB 666 would create oversight for material healthcare transactions and restrict for-profit, private-equity, and MSO control over healthcare providers.
Operator impact: New Hampshire clinic platforms and MSOs should monitor the bill for potential transaction-notice requirements, control limitations, clinical-judgment protections, penalties, and divestiture or rescission risk.
ProposedHigh Impact
Washington corporate practice and MSO restrictions remain a live legislative watch item
Washington SB 5387 proposes restrictions around corporate practice of medicine, ownership of medical practices, employment of licensed providers, and MSO-style control arrangements.
Operator impact: Washington-facing telehealth clinics, med spas, DPC groups, concierge practices, and MSO-backed platforms should monitor the bill because it could materially affect ownership, employment, and management-service structures.
ProposedHigh Impact
Rhode Island CPOM bill targets MSO ownership and control structures
Rhode Island S2459 would establish the Rhode Island Ban on the Corporate Practice of Medicine Act and regulate ownership, control, and management relationships involving medical practices.
Operator impact: Rhode Island medical practices, telehealth groups, cash-pay clinic platforms, med spas, and MSOs should watch for limits on stock-transfer restrictions, ownership overlap, and management-service control over clinical entities.
EnactedHigh Impact
Vermont enacts clinical decision-making law targeting corporate interference
Vermont H.583 was signed by the Governor on June 15, 2026 and creates a state-level framework around clinical decision-making and corporate influence in medical practice.
Operator impact: Vermont clinic platforms, MSOs, investor-backed practices, telehealth groups, and med spa structures should review whether management agreements, ownership controls, staffing authority, pricing pressure, or clinical protocol control could be viewed as interference with licensed professional judgment.
ProposedHigh Impact
Texas corporate practice structure watch opened
Texas is queued for ongoing review around clinic ownership, MSO control, medical decision-making, and fee flow structure.
Operator impact: Operators using MSO, marketing, or management-fee models should review agreements, authority boundaries, and physician control points.
WatchHigh Impact
New Jersey CPOM structure remains a high-risk med spa ownership issue
New Jersey corporate-practice-of-medicine analysis continues to highlight that MSOs may provide management support but should not control clinical decision-making in medical spas.
Operator impact: New Jersey med spa founders and investors should review ownership, MSO fee structure, clinical authority, medical director agreements, and delegation boundaries before scaling.
EffectiveHigh Impact
California restricts PE and hedge fund interference with physician and dental judgment
California SB 351 prohibits private equity groups and hedge funds involved with physician or dental practices from interfering with professional judgment or exercising control over specified clinical and business functions.
Operator impact: California MSO, investor-backed, and rollup models should review control rights, employment decisions, clinical protocols, coding and billing authority, record ownership, equipment approvals, and restrictive covenants.
