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Many healthcare groups are organized as a physician-owned professional entity (a PC or, where permitted, a PLLC) supported by a management services organization (MSO). Lemma is built for this structure: each legal entity gets its own accounts, cash sweeps automate the funds flow between an MSO and its practices, and role-based access lets MSO staff operate day to day while the practice keeps oversight. Beyond those defaults, send us your management services agreement and related documents, and we configure guardrails on your accounts that match how regulators expect a compliant MSO-PC relationship to operate. This page describes banking controls, not legal advice. Corporate practice of medicine (CPOM) requirements vary by state and depend on your specific agreements and conduct. We are the only ones to offer MSO-PC compliant banking, and we configure the best we can from the documents you give us — but we cannot guarantee compliance. Work with healthcare regulatory counsel to confirm what your structure requires.

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Why bank account control matters

In states that enforce the corporate practice of medicine doctrine, the physician-owner of the practice must keep ultimate control of the practice, including its finances. Enforcement actions have specifically targeted banking arrangements: consolidated accounts the practice owners could not access, management companies with unrestricted access to practice funds, and sweep arrangements the physician could not stop. For practices that bill Medicare or Medicaid, federal rules additionally require that government-payer receivables land in an account the provider controls. The common thread: the physician should never have to ask the MSO for permission to access the practice’s money, and should always be able to see it and turn off the tap.

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What Lemma configures

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A physician on file

We record which owner of each entity is its physician on file. That member’s access is protected: no one — not the MSO, not other owners, not even the physician themselves — can lower their permissions or remove them from the entity inside the product. The team settings page explains why those controls are locked, and any attempt to change them through the API is rejected as well. If the physician on file needs to change — a sale, retirement, license event, death, or disability — contact us. We verify the successor and make the change deliberately, so the transition itself stays compliant instead of happening through a quiet settings edit.

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Physician authority above every role

Approval rules normally enforce two-person control: a transfer above your threshold must be approved by an owner, and no one can approve a transfer they requested themselves. When approval rules are active, creating or editing a cash sweep also requires an owner’s approval. For entities with a physician on file, the physician can approve these requests themselves — including ones they initiated. This is deliberate: CPOM expects the physician’s authority over practice funds to be ultimate, so the physician sits above every regular access level, including Owner (the highest role a normal member can hold, despite what the name suggests). Every self-approval is recorded, which is the point, the audit trail is standing evidence that the physician, not the MSO, controls the account.

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Guardrails from your agreements

Send us your management services agreement and we align your account setup with it: the funds flow (patient revenue landing in the practice’s account before management fees move to the MSO) and sweep configurations the physician can always see and stop.