District of Columbia CPOM Rules 2026: Who Can Own a Practice

The District of Columbia's corporate practice of medicine (CPOM) position is unsettled, and we classify it that way. D.C. has no statute that clearly bars a business corporation from employing physicians. Its professional corporation law is reported to limit who can own a medical PC. And the one court decision most often cited, an older federal case involving a cooperative that employed doctors, is generally read as cutting against a strict ban rather than for one. Commentators place D.C. anywhere from "moderate" to "nuanced."

Bottom line for a non-physician founder: do not assume D.C. is CPOM-free just because the doctrine is thin. Most operators use a physician-owned professional entity plus a management services organization (MSO) for D.C. patients, because it holds up under either reading. For NP founders, D.C. is a full practice authority jurisdiction, which makes NP-led care models realistic.

This is general information, not legal advice. Confirm the current rules with a healthcare attorney licensed in the District of Columbia. Last reviewed October 2026. State rules change often; statute and case references are summaries, not quotations.

Key takeaways

As of October 2026, the District of Columbia has no clear statutory ban on the corporate practice of medicine, and its status is best described as unsettled.
D.C.'s professional corporation law is reported to require that shareholders of a medical professional corporation be licensed, so a non-physician should not expect to own a medical PC.
The frequently cited federal case Group Health Ass'n v. Moor is generally read as weighing against a strict CPOM bar in D.C.; confirm its current weight with counsel.
D.C. nurse practitioners have full practice authority under the AANP classification.
Clinicians treating patients located in D.C. should plan on holding a D.C. license unless counsel confirms an exception applies.

Does the District of Columbia have a corporate practice of medicine doctrine?

Not clearly. The CPOM doctrine, as a DePaul Law Review article describes it, is mostly a creature of state common law: courts reasoning that a corporation cannot hold a medical license, so it cannot practice medicine or employ physicians to do so. D.C. never developed a strong line of cases doing that.

The decision most often cited for D.C. is Group Health Ass'n v. Moor, an older federal district court case. As commonly described, it involved a nonprofit cooperative that employed physicians to provide prepaid care to its members, and it is generally read as rejecting the argument that this arrangement was the unlawful practice of medicine. That reading is part of why some guides list D.C. as permissive. Have counsel confirm the holding, any appellate history, and how much weight it carries today.

Pointing the other way:

D.C.'s professional corporation statute is reported to limit ownership of medical PCs to licensees, which implies that non-licensees should not control medical practice.
An older congressional survey on corporate dentistry grouped the District with jurisdictions that prohibit corporate practice in the dental context, which shows how D.C. has been characterized for licensed professions generally.
The D.C. Board of Medicine can discipline physicians whose clinical judgment is compromised, whoever employs them.

Our read: the risk of a D.C. regulator treating an MSO-supported physician practice as unlawful is low. The risk of a non-physician directly controlling clinical decisions is not.

Who can own a medical practice in the District of Columbia?

Professional corporations. D.C.'s professional corporation law is described in secondary sources as requiring shareholders, and key officers and directors, of a medical professional corporation to hold the relevant license. Confirm the exact current text before filing.

Other entities. Because D.C. lacks a clear CPOM ban, a nonprofit or business entity employing D.C.-licensed physicians is not clearly prohibited. Group Health is the historical example. Hospitals and health systems also employ physicians directly.

Non-physician investors belong in the MSO, which owns the brand, technology, and non-clinical operations.

Can nurse practitioners and physician assistants own a practice in the District of Columbia?

Nurse practitioners. D.C. is a full practice authority jurisdiction under the AANP classification, which generally means NPs can evaluate, diagnose, treat, and prescribe without a required physician collaboration agreement. Confirm the current details with D.C. counsel. That makes NP-staffed primary care, women's health, and behavioral health programs workable in D.C. Whether an NP can own a professional corporation depends on the PC statute's licensed-shareholder rule, which generally points to an NP-owned entity rendering nursing services, not medicine. Have D.C. counsel confirm.

Physician assistants. D.C. PAs generally practice in a relationship with a physician rather than independently. A PA-led telehealth model in D.C. still needs a physician in the structure. Confirm the current supervision rules with the D.C. Board of Medicine.

How does the friendly PC-MSO model work in the District of Columbia?

For a brand serving D.C. patients, the friendly PC-MSO model is the conservative default. A D.C.-licensed physician owns the professional entity. That entity employs or contracts the clinicians, owns the medical records, holds payer contracts, and makes every clinical decision. Your MSO supplies the platform, marketing, scheduling, billing support, and staff.

D.C.-specific drafting points:

Fees. We did not confirm a D.C. statute that specifically addresses fee-splitting with management companies. A fair market value flat or cost-plus fee is the safer design, and federal anti-kickback and Stark rules apply to Medicare and Medicaid business.
Control. Avoid MSA terms that let the MSO hire or fire clinicians, set prescribing protocols, or override clinical decisions. Those terms create risk in any jurisdiction, settled or not.
Regional consistency. Many D.C. patients cross into Maryland and Virginia. Building one structure that also satisfies Maryland's rules simplifies the region. See our Maryland CPOM guide.

What does this mean for a telehealth brand serving District of Columbia patients?

CPOM and licensure turn on where the patient is during the visit. A patient logging in from a D.C. address triggers D.C. rules, even if your company is in Austin and your doctor is in Ohio.

On licensing, we could not verify a D.C. out-of-state telehealth registration pathway. Plan on clinicians holding a D.C. license unless counsel confirms an exception or compact route applies to your providers. Our telehealth licensing by state guide covers how to map licenses across your footprint.

Practical structure: D.C.-licensed clinicians, a physician-owned professional entity (often your multistate PC with a D.C.-licensed owner), and an MSA with clean control provisions.

District of Columbia CPOM at a glance

Topic	District of Columbia (as of October 2026)
CPOM enforcement	Limited or unsettled
Primary legal basis	No clear CPOM statute; reported PC ownership limits; Group Health Ass'n v. Moor generally read against a strict bar
Professional entity options	Professional corporation (reportedly licensed shareholders); other entities not clearly barred
Fee-splitting rule	No D.C.-specific rule confirmed; use fair market value fees
NP practice authority	Full
Out-of-state telehealth licensing	Unverified; plan on a D.C. license
Typical structure for non-physician founders	Physician-owned professional entity plus MSO

Frequently asked questions

Does Washington, D.C. have a corporate practice of medicine ban?

D.C. has no clear statutory ban, and its leading case, Group Health Ass'n v. Moor, is generally read against a strict prohibition. Professional corporation ownership is still reported to be limited to licensees, so the doctrine's status is unsettled.

Can a non-physician own a medical practice in D.C.?

Secondary sources report that a non-physician cannot own a D.C. medical professional corporation; confirm with D.C. counsel. Other structures may be possible given the unsettled doctrine, but most founders use a physician-owned entity plus an MSO to stay safe.

Can nurse practitioners practice independently in D.C.?

Generally yes. D.C. is classified as a full practice authority jurisdiction, which generally means NPs can practice without a required physician collaboration agreement. Confirm the current details with D.C. counsel.

Do telehealth providers need a D.C. license to treat D.C. patients?

Plan on it. We could not verify a D.C. telehealth registration pathway for out-of-state clinicians, so confirm any exception with D.C. counsel before relying on it.

Is the friendly PC model required in D.C.?

It is not clearly required, but it is the conservative choice. It protects against a stricter reading of the doctrine and matches how most multistate telehealth brands already operate.

Sources

For the national picture, see our corporate practice of medicine 50-state guide.

Launch in the District of Columbia on a structure that is already built

MyOrbitHealth can form a PC-MSO structure for your brand through our PC-MSO formation service, or supply a physician PC owner or collaborating physician through our physician PC owner services. 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 to scope it.