Last week, I served as a panelist/speaker for a nationally-broadcast webinar regarding the formation of physician multispecialty groups. One of the topics addressed by this webinar—the one that prompted the greatest number of questions from the audience—was the CPOM doctrine.
Essentially, the CPOM doctrine, which is found in the laws of many states, including New Jersey, prohibits unlicensed and lesser-licensed individuals, business corporations and other entities from employing physicians to practice medicine—all in an effort to ensure that only those entities owned and controlled by licensed professionals shall render healthcare services, subject to certain exceptions. The CPOM doctrine also prohibits the division or splitting of professional fees between physicians and lay persons/lay entities and/or the payment for referrals.
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