--- title: "Connecticut CPOM Rules 2026: Who Can Own a Practice" description: "Connecticut corporate practice of medicine rules: attorney general opinions, licensed-only PCs, medical foundations, and what telehealth founders must do." slug: connecticut-corporate-practice-of-medicine date: 2026-10-18 updated: 2026-10-18 author: MyOrbitHealth Compliance Team category: Compliance cpom: Moderate --- # Corporate Practice of Medicine in Connecticut: What Telehealth and Clinic Founders Need to Know Yes, Connecticut enforces a corporate practice of medicine (CPOM) rule, and we classify it as moderate. There is no single statute that says "corporations may not practice medicine." Instead, the rule traces back to Connecticut attorney general opinions reading the medical licensing statutes to mean that only licensed individuals can practice. The legislature then built around that rule: professional corporations owned by licensees, and since 2009, nonprofit medical foundations formed by hospitals and medical schools. Bottom line for a non-physician founder: you cannot own the entity that employs Connecticut physicians or bills for their services. The workable path is a physician-owned professional corporation (PC) or PLLC paired with your management services organization (MSO). For an NP founder, Connecticut is friendlier than most states. Experienced APRNs can practice without a collaborating physician, and the PC statute recognizes nursing-related corporations. PAs still work under a physician relationship. This is general information, not legal advice. Confirm the current rules with a healthcare attorney licensed in Connecticut. *Last reviewed October 2026. State rules change often; statute and case references are summaries, not quotations.* ## Key takeaways - Connecticut's CPOM rule comes from attorney general opinions interpreting the medical licensing statutes, Conn. Gen. Stat. §§ 20-9 and 20-10, rather than from an explicit statutory ban. - Under Conn. Gen. Stat. Chapter 594a, shareholders of a professional corporation must be licensed to render the service the corporation was formed to provide. - Connecticut authorizes nonprofit medical foundations (Chapter 594b), but only hospitals, health systems, and medical schools can form them, so they are not a route for a venture-backed founder. - APRNs in Connecticut may practice without a collaborating physician after at least three years and 2,000 hours of collaborative practice. - A 2026 Connecticut law (SB 196) adds private equity attestations and limits on hospital sale-leasebacks, a sign of rising scrutiny of investor influence over clinical care. ## Does Connecticut have a corporate practice of medicine doctrine? Yes. A 2010 Connecticut Law Tribune article by a [Shipman & Goodwin](https://www.shipmangoodwin.com/a/web/3pTHyNFhqNYMtC6M11JikY/Xbww5/Reprint_LAWRENCE_052410.pdf) partner explains that the prohibition was originally expressed in state attorney general opinions. The reasoning is simple. Sections 20-9 and 20-10 bar anyone from practicing medicine without a license, and only individuals can hold a license. A business corporation that employs physicians to treat patients is therefore practicing medicine without one. The same article notes two important limits on how far the doctrine has been pushed. It has not been applied to physicians employed by nonprofit hospitals. And the legislature created medical foundations in 2009 (Public Act 09-212) so that hospital systems could employ physicians through a dedicated nonprofit vehicle. What Connecticut does not appear to have is a dense body of recent enforcement cases. That is why we rate it moderate rather than strong. The doctrine is real and well-understood by Connecticut counsel, but it lives in opinions and statutory structure, not a detailed rulebook. ## Who can own a medical practice in Connecticut? Your options are narrow and intentional. **Professional corporations.** [Chapter 594a](https://www.cga.ct.gov/current/pub/chap_594a.htm) defines a professional corporation as one organized solely to render a professional service, with shareholders who are licensed to render it. The statute separately authorizes physician-only corporations and several mixed corporations: physicians with physician assistants or APRNs, physicians with chiropractors, physicians with psychologists, and physicians with podiatrists. In each, every shareholder must be licensed for one of the corporation's services. Section 33-182c also bars an out-of-state licensee from being a shareholder, director, or officer if they would practice in Connecticut unlawfully or direct Connecticut practitioners' professional judgment. **Professional LLCs.** Connecticut's Uniform Limited Liability Company Act (Chapter 613a) lists physicians and surgeons and physician assistants among the professions that can use a PLLC. Members must be licensed to render the service, and the name must include "PLLC" or similar. **Medical foundations.** Under [Conn. Gen. Stat. § 33-182bb](https://www.cga.ct.gov/2013/rpt/2013-R-0262.htm), a hospital, health system, or medical school can organize a nonprofit medical foundation to practice medicine through employed providers. Foundations cannot operate for profit and must file annual reports with the Office of Health Strategy. **Nonprofit hospitals** employ physicians directly without CPOM challenge, per the Shipman & Goodwin analysis. A non-physician investor fits none of these categories. Equity goes into the MSO, not the PC. ## Can nurse practitioners and physician assistants own a practice in Connecticut? **Nurse practitioners.** Connecticut is a full practice authority state, with a ramp. The [Department of Public Health](https://portal.ct.gov/dph/practitioner-licensing--investigations/aprn/aprn-practice) explains that for the first three years after Connecticut licensure, an APRN must practice in collaboration with a Connecticut physician. After at least three years and 2,000 hours, and written notice to DPH, the APRN may practice independently. A 2023 change lets qualifying out-of-state experience count toward the three years. Because Chapter 594a covers nursing services and physician-APRN combinations, an experienced APRN can generally own a professional entity for nursing services. Have counsel confirm the right entity and name before filing. **Physician assistants.** Connecticut PAs practice in a collaborative relationship with a physician, a change made by Public Act 19-144. The [2025 publication of Chapter 370](https://cga.ct.gov/2025/pub/chap_370.htm#sec_20-12d) provides for a written delegation agreement with a supervising physician under § 20-12d; confirm whether later legislation has changed that requirement. A PA can be a shareholder in a physician-PA professional corporation, but a PA-only medical practice is not a practical model in Connecticut. ## How does the friendly PC-MSO model work in Connecticut? The [friendly PC-MSO model](/blog/friendly-pc-mso-model) is the standard answer. A Connecticut-licensed physician owns the PC. The PC holds payer contracts, employs or contracts the clinicians, and controls every clinical decision. Your MSO provides the brand, technology, marketing, billing support, and staff under a [management services agreement](/blog/management-services-agreement-guide). Connecticut-specific points to get right: - **Fees.** We did not find a Connecticut statute that expressly caps or bans percentage-based management fees, and an older Manatt survey listed Connecticut among states with no fee-splitting statute. That is not a green light. A fair market value flat or cost-plus fee remains the defensible choice, and federal anti-kickback and Stark rules apply to any federal payer business. - **No voting trusts.** Chapter 594a restricts PC shareholders from handing voting power to non-licensees through voting trust arrangements. Stock transfer restrictions and succession agreements must be drafted with that in mind. - **Clinical independence.** The physician owner needs real authority over protocols, prescribing, and staffing of clinical roles. - **Watch the transaction rules.** Connecticut's 2026 law [SB 196](https://www.healthlawdiagnosis.com/2026/06/connecticut-heightens-scrutiny-of-private-equity-in-healthcare-with-law-banning-hospital-sale-leaseback-agreements-and-requiring-private-equity-attestations/) targets hospitals, but bills defining "captive professional entities" have been introduced in recent sessions. Expect more review of MSO-controlled physician groups. ## What does this mean for a telehealth brand serving Connecticut patients? CPOM follows the patient. If your Connecticut patient is in Connecticut during the visit, Connecticut's rules govern, wherever your company or clinician sits. Licensing is the first hurdle. Connecticut has no general out-of-state telehealth registration for physicians, so treating clinicians need a full Connecticut license. The temporary pathway for out-of-state behavioral health providers expired June 30, 2025, according to the [Office of Legislative Research](https://www.cga.ct.gov/2024/rpt/pdf/2024-R-0122.pdf). See our [telehealth licensing by state](/blog/telehealth-licensing-by-state) guide for planning. The practical structure: a Connecticut PC (or a multistate PC registered in Connecticut and owned by a Connecticut-licensed physician), Connecticut-licensed clinicians, and an MSO agreement. APRNs past their three-year collaborative period are a strong staffing option for primary care, weight management, and behavioral health programs. ## Connecticut CPOM at a glance | Topic | Connecticut (as of October 2026) | |---|---| | CPOM enforcement | Moderate | | Primary legal basis | AG opinions interpreting Conn. Gen. Stat. §§ 20-9, 20-10; PC structure in Ch. 594a | | Professional entity options | Professional corporation (Ch. 594a), PLLC (Ch. 613a); nonprofit medical foundation for hospitals/medical schools (Ch. 594b) | | Fee-splitting rule | No express statute confirmed; use fair market value flat fees | | NP practice authority | Full, after 3 years and 2,000 hours of collaboration | | Out-of-state telehealth licensing | No; full Connecticut license required | | Typical structure for non-physician founders | Physician-owned PC or PLLC plus MSO | ## Frequently asked questions ### Can a non-physician own a medical practice in Connecticut? No. Shareholders of a Connecticut medical professional corporation must be licensed to render the services it provides. A non-physician can own the management company that supports the practice, but not the entity that practices medicine. ### Is the corporate practice of medicine illegal in Connecticut? Connecticut treats a business corporation employing physicians to treat patients as unlicensed practice, based on attorney general opinions reading the licensing statutes. Nonprofit hospitals and statutory medical foundations are the main exceptions. ### Can a nurse practitioner open an independent practice in Connecticut? Yes, after completing at least three years and 2,000 hours of practice in collaboration with a physician and notifying the Department of Public Health. Newer APRNs need a collaborating physician until they meet those thresholds. ### Does Connecticut allow out-of-state doctors to provide telehealth without a Connecticut license? Generally no. Physicians treating patients located in Connecticut need a Connecticut license, and the temporary out-of-state behavioral health registration pathway ended June 30, 2025. ### Can an MSO charge a percentage of revenue in Connecticut? We did not find a Connecticut statute that expressly prohibits it, but percentage fees raise fee-splitting and federal fraud and abuse questions. A fair market value flat or cost-plus fee is the more defensible design. ## Sources - [Conn. Gen. Stat. Chapter 594a, Professional Service Corporations](https://www.cga.ct.gov/current/pub/chap_594a.htm) - [Conn. Gen. Stat. Chapter 370, Medicine and Surgery (2025)](https://cga.ct.gov/2025/pub/chap_370.htm#sec_20-12d) - [Connecticut OLR, Medical Foundations (2013-R-0262)](https://www.cga.ct.gov/2013/rpt/2013-R-0262.htm) - [Shipman & Goodwin, "Another Way To Operate," Connecticut Law Tribune (2010)](https://www.shipmangoodwin.com/a/web/3pTHyNFhqNYMtC6M11JikY/Xbww5/Reprint_LAWRENCE_052410.pdf) - [Connecticut DPH, APRN Practice](https://portal.ct.gov/dph/practitioner-licensing--investigations/aprn/aprn-practice) - [Connecticut OLR, Recent Changes to Connecticut's Telehealth Law (2024-R-0122)](https://www.cga.ct.gov/2024/rpt/pdf/2024-R-0122.pdf) - [Health Law Diagnosis, Connecticut private equity law (June 2026)](https://www.healthlawdiagnosis.com/2026/06/connecticut-heightens-scrutiny-of-private-equity-in-healthcare-with-law-banning-hospital-sale-leaseback-agreements-and-requiring-private-equity-attestations/) For how Connecticut compares nationally, see our [corporate practice of medicine 50-state guide](/blog/corporate-practice-of-medicine-50-state-guide). ## Launch in Connecticut on a structure that is already built MyOrbitHealth can form a PC-MSO structure for your brand through our [PC-MSO formation](/pc-mso-formation) service, or supply a Connecticut-licensed physician owner or collaborating physician through our [physician PC owner services](/physician-pc-owner). You can also launch on our existing MSO / friendly-PC structure, where 2,400+ licensed providers make every clinical decision and MyOrbitHealth does not practice medicine. [Book a call](https://myorbithealth.com/book) to scope it. ```html ```