The Federal CPOM Bill Is Coming for Friendly-PC Models. Here's What Actually Survives It.

A bill introduced in Congress rarely changes how a med spa gets structured. This one is worth an exception, because of what it targets rather than whether it passes. On September 16, 2026, Senators Elizabeth Warren, Ron Wyden and Jeff Merkley introduced the Stop Corporate Takeovers of Physicians Act of 2026, with a companion bill in the House led by Representatives Val Hoyle, Alexandria Ocasio-Cortez and Suhas Subramanyam. If enacted, it would be the first federal law governing who can own and control a medical practice — modeled directly on Oregon's SB 951, the state law it explicitly draws from.

For med spas, wellness clinics and telehealth practices, the part worth reading closely isn't the politics. It's the five specific things the bill would prohibit, because several of them are exactly the mechanics that make a "friendly PC" model work in the first place.

What the Bill Actually Does

The bill doesn't invent corporate-practice-of-medicine doctrine. It federalizes it — including the PC/MSO split already familiar in strict-CPOM states — and extends it to every state, including ones like Florida that have no meaningful CPOM doctrine today. As introduced, it has five core pieces.

• CPOM rules go national: a company not majority-owned and majority-controlled by licensed clinicians (physicians, NPs and PAs) could not own or control a medical practice, employ or contract for a clinician's professional services, or practice medicine. Nonprofit, hospital, hospital-affiliated, critical-access and rural-emergency providers are exempt.
• Hard limits on MSOs: an MSO — and its owners, officers, employees and contractors — could not control or restrict the transfer of practice ownership, form or cause the formation of a practice it intends to contract with, finance the purchase of practice ownership, advertise medical services under any name other than the practice's own, or hold final authority over hiring, pay, schedules, staffing, revenue disbursement, revenue targets, coding, clinical policy, billing, pricing or payer contracts.
• Arm's-length, fair-market-value deals: management agreements must be negotiated by counsel and advisors the practice selects independently, and MSO fees must reflect fair market value as determined under FTC rules that have not yet been written.
• Real physician owners: practice owners must be licensed and present in a state where the practice serves patients, and substantially engaged in delivering care there — not a name on a filing spread across dozens of practices.
• Limits on restrictive covenants: noncompetes are void unless the clinician owns at least 25% of the practice; non-disclosure and non-disparagement agreements covering clinicians are void.

The Enforcement Is the Part Worth Taking Seriously

The FTC and state attorneys general could enforce the bill directly, and anyone injured by a violation could sue for treble damages and attorneys' fees, with a right to a jury trial. Courts finding a violation could order divestiture and disgorgement of revenue, and the bill would amend the Social Security Act to allow violators to be excluded from federal healthcare programs entirely. As introduced, the rules would take effect one year after enactment, with no grandfathering for existing agreements — and the bill expressly lets states keep or pass stricter rules on top of the federal floor.

Who It Actually Hits

The bill isn't written against physicians, and it isn't written against MSO structure as a concept. It's written against a specific pattern: a non-physician-owned company holds the brand, the bank account and the pricing, and sweeps nearly all of the profit through a percentage-based management fee. A physician owns the PC on paper — sometimes across dozens of PCs in many states — and a stock-transfer-restriction agreement lets the company replace that physician at will if they become inconvenient.

Almost every lever in that model is a specific thing this bill prohibits by name. The management agreement becomes void. The physician who nominally owns the PC could sue the company for treble damages and disgorgement of the revenue it swept. For non-physician founders, the bill doesn't ban owning an MSO — it changes what that ownership is worth. The MSO becomes a service business earning a fair-market-value fee, while the profit from medical services stays with the practice, and non-medical revenue like retail and esthetics remains the MSO's. Consulting firms that set up controlled-PC structures for clients are exposed too, since the MSO restrictions reach an MSO's contractors, not just its own conduct.

Why This Reads Like a Description of How We Already Built This

We didn't build MedGrid's MSO program in response to this bill — it was introduced last week. We built it around the same idea the bill is trying to force into law: that a management company's job is to run the business around a real, independent, actually-practicing physician, not to hold the levers that make the physician swappable. That's the whole reason this bill maps cleanly onto how we already operate.

• Practices owned and controlled by licensees: every PC we build is 100% physician-owned, formed as an MD PC, PA or SC depending on the state — not a company with a name on a filing.
• Owners present and substantially engaged: one physician per PC, one PC per location or state. We don't stack a single doctor's signature across dozens of clinics.
• Physician as the decision-maker: the physician is the owner and principal of their own PC from day one, not a name substituted in after the structure is already built.
• No MSO control of practice revenue: PC banking is genuinely separate — patient revenue lands in the PC's own account, set up through our banking partner, not swept into the MSO's.
• Fair-market-value compensation: a flat, fair-market-value management fee, not a percentage sweep of collections — the exact structure the bill is written to eliminate.
• Arm's-length negotiation: the practice reviews its own agreements with its own independently selected counsel, not counsel the MSO picked for them.
• Clearly defined roles: a real medical director agreement, MSA and consulting agreement that spell out who actually does what — not a single document trying to do all three jobs at once.

The honest version of this: no one can claim final compliance with a bill that hasn't passed, whose FTC fair-market-value standard hasn't been written yet, and whose one-year effective-date clock hasn't started. But there's a real, practical difference between a structure that would need minor refinements once that standard exists and one that depends entirely on the exact controls this bill bans by name. That difference is knowable right now, and it's worth knowing which side of it your clinic is on before a regulator, a plaintiff's attorney, or your own physician asks.

What to Check Now, Regardless of Whether This Bill Moves

These are good practice under today's state-by-state CPOM rules regardless of what happens in Congress — and they're the same questions a regulator or a plaintiff's attorney would ask first.

• Who owns your PC? Is the physician actually licensed in your state, genuinely involved in your clinic, and not spread across dozens of other practices?
• Is there a stock-transfer-restriction or succession agreement? If your structure depends on the ability to swap out the physician at will, it depends on something this bill specifically bans.
• How is your management fee set? A percentage of collections that sweeps most of the profit is the pattern the bill targets by name. A flat fee backed by an actual fair-market-value analysis is not.
• Who controls the bank account? Revenue should land in the PC's own account, with the physician as a signer who holds real authority over it.
• Whose name is on your ads? If medical services are marketed under the management company's name rather than the practice's own, that's a specific thing the bill prohibits — and in some states, like California, it already requires the brand to run through the PC as a registered fictitious name.
• Did the practice have its own lawyer? The physician should have reviewed the management agreement with counsel they chose themselves, not counsel the MSO provided.

Where MedGrid Fits

This is the structural review we already run for every clinic we build — physician ownership, real engagement, arm's-length agreements, fair-market-value fees, revenue that actually lands in the PC's account. If you're not sure which side of this your current structure sits on, that's exactly the conversation to have with us before it becomes a question someone else asks first. See our breakdowns of what corporate practice of medicine actually restricts and why a PC — not a PLLC — is the entity CPOM doctrine calls for, and our note on why we say "connect," not "assign," when we talk about your medical director.

Frequently Asked Questions

• Is this bill actually going to become law?: Almost certainly not this session — Congress has a short calendar before the November midterms, and bills this significant rarely move that fast. It's a real marker for where CPOM regulation is heading, in Washington and in the states already copying Oregon's SB 951, rather than an imminent deadline.
• Does this bill ban MSOs?: No. It bans a specific set of controls an MSO can't hold over a practice — final authority over hiring, pay, revenue disbursement, billing and similar decisions, plus financing or controlling the transfer of practice ownership. A management company providing genuinely non-clinical services for a flat, fair-market-value fee is not the target.
• What is the "friendly PC" or "friendly physician" loophole this bill targets?: A structure where a physician nominally owns the professional entity that state CPOM law requires, while a non-physician-owned company actually controls the practice through the management agreement — often backed by a stock-transfer-restriction agreement that lets the company replace that physician if they become inconvenient.
• Would MedGrid clinics need to restructure if this passes?: Based on the bill as introduced, our expectation is minor refinements once the FTC's fair-market-value standard exists, not a rebuild — because the structure is already built around physician ownership, real engagement, arm's-length agreements and flat fees. That's an expectation based on the bill's current text, not a compliance guarantee for a law that hasn't passed.
• Does this affect clinics in states without CPOM rules today, like Florida?: If enacted, yes — the bill would apply nationally regardless of a state's current CPOM posture, which is the specific feature that makes it different from every existing state law on this subject.

This article is general information about a bill that has been introduced in Congress but has not passed, not legal advice for your specific clinic. Its provisions, including the FTC's eventual fair-market-value standard, could change materially before any enactment, and state CPOM law continues to govern your structure in the meantime. Consult qualified healthcare counsel about your specific structure.