MSO Management Services CPOM Disputes California
🏢 MSO & Corporate Practice of Medicine Disputes
California CPOM violations, management services agreements, fee-splitting, private equity deals, and unwinding non-compliant arrangements
Corporate Practice of Medicine & MSOs in California
California’s Corporate Practice of Medicine (CPOM) doctrine prohibits non-physicians from owning or controlling medical practices. This 100+ year-old principle aims to preserve physician independence, prevent financial conflicts of interest, and ensure medical decisions are made based on patient welfare rather than corporate profit motives.
The explosion of private equity investment in healthcare—dermatology, ophthalmology, gastroenterology, pain management, urgent care—has created a sophisticated work-around: the Management Services Organization (MSO). MSOs provide administrative, marketing, billing, and staffing services to physician-owned professional corporations under Management Services Agreements (MSAs). When structured properly, MSO arrangements comply with CPOM. When structured improperly—or when MSOs exercise de facto control over medical decision-making—they violate California law and create substantial legal exposure.
What Is the Corporate Practice of Medicine Doctrine?
Business & Professions Code § 2400: “No person, firm, partnership, association, or corporation, or any other entity shall practice medicine or surgery unless licensed by the Medical Board or the Osteopathic Medical Board.”
California courts interpret § 2400 broadly to prohibit:
- Non-physicians owning medical practices
- Non-physician entities employing physicians to provide medical services
- Lay corporations exercising control over medical judgment, patient selection, or clinical protocols
- Financial arrangements that give non-physicians indirect control over medical decision-making
Why California Is Strict: Many states have relaxed or abolished CPOM restrictions, but California maintains one of the nation’s strictest interpretations. The Medical Board actively enforces CPOM, viewing violations as threats to patient safety and physician professionalism.
The MSO Structure: Compliant vs. Problematic
Compliant MSO Model:
- Physician-owned professional corporation (PC) provides all medical services
- MSO (investor-owned entity) provides non-clinical administrative services under MSA
- MSO fees are reasonable fixed amounts or percentage of revenue, not tied to specific patient referrals
- Physician PC retains full control over hiring/firing clinical staff, treatment protocols, patient acceptance
- Physician PC can terminate MSA without losing clinic infrastructure or patient base
- MSA clearly delineates MSO’s administrative role vs. physician’s clinical autonomy
Problematic MSO Model:
- MSO makes clinical staffing decisions (hires/fires physicians, NPs, MAs)
- MSO dictates treatment protocols, patient volume targets, or procedure mix to maximize revenue
- MSO controls patient scheduling, determines which patients are seen
- MSO fee structure incentivizes unnecessary procedures or high-volume/low-quality care
- Physician cannot realistically terminate MSA—MSO controls facilities, equipment, patient records, billing systems
- MSO represents itself publicly as the healthcare provider, relegating physician PC to back-office role
| Control Factor | CPOM-Compliant MSO âś“ | CPOM Violation Risk âś— |
|---|---|---|
| Hiring/Firing Clinical Staff | Physician PC decides which physicians, NPs, PAs, RNs to hire; MSO may handle HR paperwork | MSO controls physician hiring, sets compensation, terminates physicians without PC input |
| Treatment Protocols | Physician PC develops clinical protocols based on medical standards; MSO has no input | MSO mandates specific treatment algorithms, product usage, or procedure quotas to increase revenue |
| Patient Selection | Physicians decide which patients to accept/decline based on clinical judgment | MSO screens patients for insurance status or ability to pay; directs physicians to prioritize high-margin cases |
| Fee Structure | Fixed monthly fee or reasonable percentage of net revenue (e.g., 20-30% for comprehensive admin services) | Percentage of gross revenue exceeding 50%; per-patient or per-procedure fees (illegal fee-splitting under B&P § 650) |
| Marketing & Branding | Physician PC is prominently identified as medical provider; MSO acknowledged as administrative partner | MSO brand dominates; patients believe MSO (not physician PC) is their healthcare provider |
| Termination Rights | Physician PC can terminate MSA with 90-180 days’ notice and continue operating independently | Physician PC cannot realistically terminate—MSO owns facilities, equipment, patient lists, proprietary systems |
Private Equity & CPOM: The New Frontier
Private equity firms have invested billions in California physician practices, particularly in specialties with high procedure volumes and ancillary revenue (dermatology, ophthalmology, GI, pain management, dental). PE firms cannot directly own medical practices, so they use MSO structures. Key concerns:
- Aggressive management fees: PE-backed MSOs often charge 40-60% of gross revenue, far exceeding the value of administrative services provided
- De facto control: PE firms exercise control through MSA provisions, board seats, or economic pressure
- Rollup consolidation: PE acquires multiple practices, creates regional “networks,” and negotiates payer contracts—activities that may constitute practicing medicine without a license
- Exit pressure: PE investment horizons (3-7 years) create pressure to maximize short-term revenue, potentially compromising care quality
- Physician license suspensions for aiding/abetting corporate practice
- Practice shutdowns and receiverships
- Criminal referrals for willful CPOM violations
- Multi-million dollar restitution orders
Common CPOM Violations in California MSO Arrangements
Violation 1: MSO Control Over Clinical Staffing
Fact Pattern: Private equity firm acquires dermatology practice by purchasing the real estate, equipment, and patient lists. Forms physician PC (owned by existing physicians) and MSO (owned by PE). MSA grants MSO “sole discretion” to hire and terminate all clinical staff, including physicians, NPs, and PAs. Physicians become employees of MSO, not PC.
CPOM Issue: By employing physicians directly, MSO is practicing medicine. Physicians must be employed by physician-owned PC, not lay-owned MSO. This structure violates B&P § 2400.
Additional Problems:
- MSO can fire physicians who refuse to meet revenue targets or comply with non-clinical directives
- Physician PC becomes a shell entity with no real operational control
- Patients may unknowingly be treated by MSO-employed (not PC-employed) physicians, vitiating informed consent
Violation 2: Revenue-Based Compensation That Incentivizes Overtreatment
Fact Pattern: MSO pays physician PC 50% of net collections. MSO separately pays individual physicians production bonuses tied to procedure volume (e.g., $X per Mohs surgery, $Y per cosmetic filler syringe sold). Physicians face pressure to maximize procedures to meet income expectations.
CPOM Issue: While percentage-based MSO fees are not per se illegal, compensation structures that incentivize unnecessary treatment create ethical and legal problems:
- Fee-splitting under B&P § 650 (discussed below)
- Fraud and abuse under federal Stark Law / Anti-Kickback Statute
- Medical Board discipline for unprofessional conduct if overtreatment harms patients
- Potential insurance fraud if procedures are not medically necessary
Violation 3: MSO-Mandated Treatment Protocols to Maximize Revenue
Fact Pattern: MSO conducts “utilization review” and determines that practice’s Botox usage is “below benchmarks.” MSO directs physicians to offer Botox to all patients over 35 during routine visits and sets monthly Botox revenue targets. Physicians who resist are threatened with termination or compensation reductions.
CPOM Issue: MSO is dictating clinical decision-making (when to offer Botox) based on financial rather than medical criteria. This is corporate practice of medicine—lay entity controlling medical judgment.
Ethical/Legal Consequences:
- Violates physician’s duty to exercise independent medical judgment
- May constitute unprofessional conduct under Medical Board standards
- Patients may have claims for unnecessary treatment, battery (lack of informed consent), or fraud
Violation 4: “Friendly PC” That Physician Cannot Terminate
Fact Pattern: Physician “sells” practice to PE-backed MSO. MSA establishes physician PC owned by selling physician, but MSO:
- Owns all facilities, equipment, and patient records
- Controls scheduling, billing, and EHR systems
- Holds exclusive rights to use practice name and brand
- Requires 5-year non-compete if physician terminates MSA
Physician realizes MSO model is unethical or unprofitable and wants to leave but cannot take patients or continue operating independently.
CPOM Issue: MSA creates de facto control by MSO even though physician “owns” PC. Physician’s inability to terminate MSA and continue practicing demonstrates that MSO, not physician, controls the practice.
Unwinding Options:
- Argue MSA is void under B&P § 2400 (CPOM violation) and seek rescission
- Challenge non-compete as unreasonable restraint on physician’s ability to practice
- File Medical Board complaint alleging CPOM, potentially forcing MSO to renegotiate
Fee-Splitting & Kickback Issues in California MSO Deals
Business & Professions Code § 650: Prohibition on Fee-Splitting
B&P § 650: Prohibits paying or receiving “any consideration, compensation, or remuneration” for patient referrals or for securing patronage. Violators face license discipline, civil penalties, and potential criminal prosecution.
While § 650 is often discussed in the context of specialist-to-specialist referrals, it also applies to MSO arrangements where payments are structured as kickbacks for patient referrals or based on specific patient services.
MSO Fee Structures: Legal vs. Illegal
| Fee Structure | Legal Analysis | CPOM / § 650 Risk |
|---|---|---|
| Fixed monthly fee (e.g., $25,000/month for admin services) | Legal if fee reasonably reflects value of services provided | Low risk—no linkage to specific patients or procedures |
| Percentage of net revenue (e.g., 25% of collections for billing, marketing, HR, facilities) | Generally legal if percentage is reasonable and MSO provides substantial services | Moderate risk if percentage exceeds value of services (40-60% fees may be suspect) |
| Percentage of gross revenue exceeding 50% | Questionable—suggests MSO is extracting profit rather than charging for services | High risk—may be disguised ownership or fee-splitting |
| Per-patient fees (e.g., $50 per new patient referred by MSO marketing) | Illegal under B&P § 650—direct payment for patient referrals | Very high risk—clear fee-splitting/kickback violation |
| Per-procedure fees (e.g., $200 per Mohs surgery, $100 per colonoscopy) | Illegal under B&P § 650—payment tied to specific services, incentivizing overtreatment | Very high risk—violates both § 650 and federal AKS |
| “Marketing fees” for patient leads | Illegal if fee is per-patient or contingent on patient converting to paying customer | High risk—disguised referral fee |
Federal vs. California Anti-Kickback Rules
California MSO arrangements must comply with both federal and state law:
Federal Anti-Kickback Statute (AKS): Prohibits offering or receiving remuneration to induce referrals for services covered by federal healthcare programs (Medicare, Medicaid). Violations are felonies. Safe harbors exist for certain MSO arrangements if properly structured.
Federa Stark Law (Physician Self-Referral Law): Prohibits physician referrals for designated health services (DHS) to entities with which the physician has a financial relationship, unless an exception applies. Covers lab, imaging, PT, and other ancillary services.
California B&P § 650: Broader than federal law—applies to all patient referrals (not just Medicare/Medicaid) and has fewer safe harbors. An arrangement compliant with federal AKS may still violate California § 650.
Physician Ownership of Ancillary Services & PORA
California’s Physician Ownership and Referral Act (PORA, B&P § 650.01): Limits physicians’ ability to self-refer to ancillary service entities they own (imaging, labs, PT). Physicians must comply with disclosure requirements and ownership percentage limits.
In MSO contexts, PORA issues arise when:
- Physician PC co-owns MSO or ancillary entities
- MSO owns imaging center, lab, or DME company and incentivizes physician referrals
- Physicians receive indirect financial benefits from referring patients to MSO-owned ancillaries
Unwinding Non-Compliant MSO Deals
When Physicians Want Out
Physicians trapped in problematic MSO arrangements—whether due to CPOM concerns, oppressive economics, or ethical conflicts—face significant barriers to exiting:
- MSA may have long terms (5-10 years) with limited termination rights
- Non-compete clauses prevent practicing in same geographic area
- MSO controls facilities, equipment, patient records—physician cannot take patients
- Early termination penalties equal to years of lost MSO fees
- MSO may sue for breach of contract, seeking millions in damages
Legal strategies for unwinding:
Strategy 1: Rescission Based on CPOM Violation
Legal Theory: MSA is void ab initio (void from inception) because it violates B&P § 2400. A contract that violates public policy is unenforceable.
Requirements:
- Demonstrate MSO exercises control over clinical decision-making
- Show fee structure constitutes illegal fee-splitting under B&P § 650
- Prove physician PC is sham entity with no real control
Remedy: Court declares MSA void; physician need not pay termination penalties or comply with non-compete; MSO must return any fees that exceed fair market value of services actually provided.
Risks: If MSA is void, MSO may demand return of any “acquisition payment” or signing bonus paid to physician; physician may face Medical Board investigation for participating in CPOM violation.
Strategy 2: Reformation Based on Unconscionability or Fraud
Legal Theory: MSA is unconscionable (one-sided, oppressive) or induced by fraud (MSO misrepresented level of support, revenue projections, or autonomy physician would retain).
Reformation vs. Rescission: Reformation modifies contract to make it enforceable; rescission voids it entirely. Reformation may be preferable when physician wants to continue relationship but on fairer terms.
Typical Reforms:
- Reduce MSO fee percentage from 50% to 25%
- Eliminate non-compete or reduce scope
- Grant physician PC ownership of patient records and scheduling systems
- Clarify that physician PC (not MSO) controls all clinical decisions
Strategy 3: Leverage Medical Board Complaint
Approach: Physician (or attorney on physician’s behalf) files Medical Board complaint documenting CPOM violations and requesting investigation. Medical Board subpoenas MSA and conducts investigation.
Outcomes:
- MSO, fearing shutdown or license actions against affiliated physicians, agrees to renegotiate MSA
- Medical Board issues cease-and-desist order, effectively voiding MSA
- MSO sues physician for breach; physician counterclaims for CPOM violation and uses Board investigation as evidence
Risks: Physician may face discipline for participating in CPOM arrangement; whistleblower physicians sometimes face retaliation (firing, defamation, frivolous lawsuits).
Strategy 4: Negotiate Buyout or Exit Package
Approach: Physician proposes financial settlement to terminate MSA early—e.g., pay MSO $X lump sum (less than termination penalty) in exchange for release from MSA and non-compete.
When Viable:
- Physician has capital or financing to fund buyout
- MSO recognizes CPOM or fraud exposure and prefers settlement to litigation
- Physician has strong alternative employment opportunity and MSO would rather take cash than risk losing physician’s productivity
- CPOM violations: Document MSO control over clinical decisions; threaten rescission claim
- Fee-splitting violations (B&P § 650): Highlight illegal fee structures
- Fraud in inducement: Demonstrate MSO misrepresented revenue projections or autonomy
- Patient loyalty: Emphasize that patients are loyal to physician, not MSO brand—physician’s departure will decimate MSO’s revenue
- Regulatory exposure: Note that Medical Board or DMHC could investigate and shut down non-compliant MSO
Sample Demand Letters for MSO/CPOM Disputes
Sample 1: Physician PC Demanding MSA Rescission (CPOM Violation)
Date: [Current Date]
To: [MSO Entity Name]
[MSO Address]
Attn: Chief Executive Officer and Legal Counsel
From: [Physician Name], M.D. / [Professional Corporation Name]
[Address]
RE: NOTICE OF RESCISSION – MANAGEMENT SERVICES AGREEMENT VIOLATES CALIFORNIA’S CORPORATE PRACTICE OF MEDICINE DOCTRINE
Dear [MSO Representative]:
On behalf of [Professional Corporation Name], I hereby rescind the Management Services Agreement dated [MSA Date] (the “MSA”) on grounds that it violates California’s prohibition on the corporate practice of medicine and constitutes illegal fee-splitting under Business & Professions Code § 650.
Background: On [MSA Date], [PC Name] entered into the MSA with [MSO Name]. Under the MSA, [MSO] provides administrative services including billing, marketing, HR, and facilities management in exchange for [X]% of gross revenue. At the time of signing, we believed this arrangement complied with California law. However, over the [time period], it has become clear that [MSO] exercises de facto control over clinical decision-making in violation of Business & Professions Code § 2400.
CPOM Violations Under the MSA:
1. MSO Control Over Clinical Staffing: Despite the MSA’s nominal designation of [PC Name] as employer of all clinical staff, [MSO] in practice:
- Makes all hiring and firing decisions for physicians, nurse practitioners, and physician assistants without input from [PC Name]
- Sets compensation for clinical staff based on productivity metrics designed to maximize MSO revenue
- Terminated Dr. [Name] in [Date] over clinical disagreements without [PC Name]’s consent
2. MSO Mandates Treatment Protocols to Maximize Revenue: [MSO] has repeatedly directed clinical staff to:
- Offer [specific procedures] to all patients regardless of medical necessity
- Meet monthly quotas for [specific services] (e.g., “Each physician must perform [X] procedures per month”)
- Use [specific products/devices] supplied by MSO-affiliated vendors, overriding physicians’ clinical judgment about superior alternatives
These directives are based on financial optimization, not medical standards, and constitute corporate practice of medicine—lay control of clinical judgment.
3. Economic Structure Prevents [PC Name] From Terminating MSA: The MSA grants [MSO]:
- Ownership of all medical equipment, facilities, and proprietary software systems
- Exclusive rights to use our practice name and brand
- Control over all patient records and billing systems
While the MSA nominally allows [PC Name] to terminate with 180 days’ notice, doing so would leave us with no facilities, no patient records, no billing infrastructure, and a 5-year non-compete preventing us from practicing within [geographic radius]. This is de facto MSO ownership of the practice, violating § 2400.
Fee-Splitting Violation (B&P § 650): The MSA’s [X]% gross revenue fee structure, combined with [MSO]’s control over patient volume and procedure mix, constitutes illegal fee-splitting. [MSO] effectively receives a percentage of every patient encounter and procedure, incentivizing it to maximize patient volume and high-margin procedures regardless of medical necessity.
Legal Basis for Rescission: Under California law, contracts that violate public policy (including B&P §§ 2400, 650) are void and unenforceable. We need not continue performing under a void contract. Moreover, Business & Professions Code § 2400’s purpose—protecting physician independence and patient welfare—supports rescission as the appropriate remedy.
DEMAND: Within 30 days of this letter, [MSO] must:
- Acknowledge rescission of the MSA effective [Date]
- Transfer ownership of all patient records to [PC Name] in HIPAA-compliant format
- Grant [PC Name] a perpetual, royalty-free license to continue using the practice name and brand
- Provide [PC Name] with access to facilities and equipment on a month-to-month basis for up to 12 months at fair market lease rates to allow orderly transition
- Release [PC Name] and all affiliated physicians from the non-compete provisions in the MSA and individual employment agreements
- Return all MSO fees paid in excess of fair market value for services actually provided (estimated at $[amount] based on independent valuation of administrative services)
Consequences of Non-Compliance: If [MSO] does not agree to rescission and the terms above, we will:
- File a civil action seeking declaratory relief (judicial determination that MSA is void), rescission, restitution, and damages
- File a complaint with the Medical Board of California detailing the CPOM violations and requesting investigation
- File a complaint with the Attorney General’s Office regarding violations of B&P §§ 2400, 650
- Notify all patients that [PC Name], not [MSO], is their healthcare provider and that [PC Name] is separating from [MSO] due to regulatory compliance concerns
We take no pleasure in this action. However, continuing under an unlawful MSA exposes us to Medical Board discipline and compromises our ability to exercise independent medical judgment. We must prioritize patient welfare and legal compliance.
Please confirm your response within 30 days.
Sincerely,
[Physician Name], M.D.
On behalf of [Professional Corporation Name]
cc: [PC’s Legal Counsel]
Sample 2: MSO Demand to Physician PC for Unpaid Management Fees
Date: [Current Date]
To: [Professional Corporation Name]
[PC Address]
Attn: [Physician Owner]
From: [MSO Name]
[MSO Address]
RE: DEMAND FOR PAYMENT – UNPAID MANAGEMENT SERVICES FEES UNDER MSA
Dear [Physician]:
This letter demands immediate payment of unpaid management services fees owed by [PC Name] to [MSO Name] under the Management Services Agreement dated [MSA Date].
Outstanding Balance:
- [Month 1]: [X]% of gross revenue = $[Amount] (due [Date], unpaid)
- [Month 2]: [X]% of gross revenue = $[Amount] (due [Date], unpaid)
- [Month 3]: [X]% of gross revenue = $[Amount] (due [Date], unpaid)
- Late fees per MSA Section [X]: $[Amount]
- Total outstanding: $[Total]
Despite multiple invoices and payment reminders, these fees remain unpaid. Your emails citing “concerns about the MSA’s legality” do not excuse performance. Under California contract law, parties must perform while disputes are resolved unless a court grants relief.
Services Provided by MSO: During the period of non-payment, [MSO Name] continued to provide the following services as required under the MSA:
- Medical billing and revenue cycle management (collected $[amount] on behalf of [PC])
- Facility provision and maintenance (rent, utilities, janitorial, repairs)
- Electronic health records and practice management software access
- Marketing and patient acquisition (generated [X] new patient appointments)
- Human resources and payroll administration for [X] employees
- Malpractice insurance procurement and premium payment
[PC Name] has benefited from these services while refusing to pay, constituting unjust enrichment.
Response to [PC]’s CPOM Allegations: Your recent communications allege that the MSA violates California’s corporate practice of medicine doctrine. These allegations are without merit:
1. [PC] Retains Full Clinical Control: The MSA explicitly vests all clinical decision-making authority in [PC Name]. [MSO] provides administrative and operational support only. We do not hire or fire physicians, dictate treatment protocols, or control patient selection. Those allegations are false.
2. Our Fee Structure Is Standard: The [X]% revenue share is consistent with market rates for comprehensive MSO services in California. Independent valuation (attached) confirms our fees are reasonable for the scope of services provided.
3. [PC] Can Terminate MSA: Section [X] of the MSA allows [PC] to terminate with 180 days’ notice. While certain assets (facilities, equipment) are owned by [MSO] and would not transfer upon termination, [PC] is free to lease alternative space and purchase equipment. This is standard for MSO arrangements and does not constitute CPOM.
DEMAND FOR PAYMENT: [PC Name] must pay $[Total] within 10 business days of this letter. Payment should be remitted via wire transfer to [account information].
Consequences of Non-Payment: If payment is not received by [Deadline Date], we will:
- Suspend MSO services (billing, EHR access, facility access) per MSA Section [X], which allows service suspension for non-payment
- File a civil action for breach of contract, seeking outstanding fees plus interest, attorney’s fees, and costs
- Record a lien against [PC Name]’s assets and accounts receivable
- Exercise our contractual right to offset amounts owed to [PC] from patient collections we manage
We do not wish to disrupt patient care, but [PC]’s refusal to honor its contractual obligations leaves us no choice. We are prepared to work with [PC] on a payment plan if cash flow is the issue, but we cannot continue providing services without compensation.
Please contact me immediately at [phone/email] to arrange payment or discuss resolution.
Sincerely,
[MSO Representative Name]
[Title]
Enclosures: Outstanding invoices; MSA; independent valuation of MSO services
Attorney Services for MSO & CPOM Disputes
MSO and corporate practice of medicine disputes involve complex healthcare regulatory issues, high-stakes economics, and sophisticated business structures. Physicians trapped in problematic MSO deals and investors seeking to enforce MSAs need counsel who understands California’s CPOM doctrine, Medical Board enforcement, and the business realities of private equity healthcare transactions.
How I Can Help
I represent California physicians, professional corporations, MSO investors, and landlords in CPOM disputes, MSA litigation, and regulatory defense. My practice combines healthcare regulatory law with complex commercial litigation to achieve practical outcomes for clients.
- MSA review & CPOM compliance audit: I analyze existing MSAs to identify CPOM violations, fee-splitting risks, and oppressive terms
- Rescission/reformation demands: I draft demands asserting CPOM violations and seeking to void or reform MSAs
- Unwinding strategies: I negotiate exits from problematic MSO deals, leveraging CPOM concerns to reduce termination penalties and eliminate non-competes
- Medical Board representation: I represent physicians in Board investigations arising from CPOM allegations
- Litigation representation: I defend physicians against MSO breach claims and prosecute affirmative claims for rescission, fraud, and restitution
- CPOM-compliant MSA drafting: I structure MSAs that comply with B&P §§ 2400, 650 while protecting MSO’s economic interests
- Due diligence for healthcare acquisitions: I review target practices for CPOM, fee-splitting, and regulatory compliance issues
- Collection demand letters: I draft demands for unpaid MSO fees that address CPOM defenses proactively
- Defense against rescission claims: I defend MSOs against physician claims that MSAs are void due to CPOM violations
- Regulatory strategy: I advise on Medical Board and Attorney General enforcement risks
Why Specialized Counsel Matters
- Medical Board knowledge: Understanding how CPOM enforcement works, what triggers investigations, and how to respond
- Healthcare transaction experience: Familiarity with MSO structures, PE healthcare deals, and practice valuations
- Litigation strategy: Knowing when rescission vs. reformation vs. negotiated exit is optimal
- Regulatory leverage: Using CPOM and fee-splitting risks to negotiate favorable settlements without triggering enforcement actions
- Business pragmatism: Balancing legal purity with commercial reality—not all CPOM violations warrant nuclear options
Submit Your Case for Review
MSO disputes involve millions of dollars, physician livelihoods, and substantial regulatory exposure. Whether you’re a physician seeking to exit a problematic MSA or an MSO enforcing contractual rights, I can help you navigate California’s CPOM framework and achieve a resolution that protects your interests.
Send me your MSA, correspondence regarding the dispute, and financial information (revenue, MSO fees paid). I’ll evaluate CPOM compliance, identify leverage points, and outline a strategy for demand letters, negotiation, or litigation.
Hourly or contingency representation available depending on case type. CPOM compliance audits $3,500-$7,500. MSA unwinding often contingency (percentage of termination penalty savings). Attorney’s fees sometimes recoverable under MSA provisions.