New Hampshire CPOM Rules 2026: Who Can Own a Practice

New Hampshire does not appear to have a general corporate practice of medicine prohibition. As of October 2026, we found no New Hampshire statute that bars a business corporation from employing physicians, and health-law commentary on the state consistently lists it among the states without a CPOM doctrine. Physicians can work as employees or contractors of lay-owned organizations.

That is not a blank check. If you form a medical practice as a professional corporation, RSA 294-A limits shareholders to licensed professionals. Physicians still answer to the Board of Medicine for their clinical conduct. And clinicians treating New Hampshire patients by telehealth should plan on New Hampshire licensure.

For a non-physician founder, the bottom line is that a lay-owned company can generally employ or contract with New Hampshire physicians directly. For an NP founder, New Hampshire is a full practice authority state, which makes it one of the more open markets in the country for NP-led care.

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

Key takeaways

New Hampshire has no codified corporate practice of medicine doctrine, and law-firm surveys list it among states with no statutory CPOM prohibition.
A New Hampshire professional corporation under RSA 294-A:8 may issue shares only to licensed professionals and certain qualifying entities, so a lay investor cannot hold shares in a medical PC.
A former provision of New Hampshire's physician licensing chapter has reportedly been repealed, and the chapter does not appear to contain a stand-alone fee-splitting ban; confirm whether any Board of Medicine rule addresses fee splitting.
RSA 329:1-d is reported to treat an out-of-state physician who treats a New Hampshire patient by telemedicine as practicing medicine in the state, so plan on a New Hampshire license.
Under RSA 326-B:11, New Hampshire APRNs have plenary prescribing authority with no required collaborative agreement.

Does New Hampshire have a corporate practice of medicine doctrine?

No, not as a general rule. Unlike in neighboring Massachusetts, we found no New Hampshire statute, attorney general opinion, or appellate decision prohibiting lay corporations from practicing medicine through employed physicians. Have counsel confirm that no case law or Board of Medicine rule adds a restriction.

Two strands of commentary support that reading. A McLane Middleton column comparing New Hampshire and Massachusetts explained that New Hampshire physicians may practice by forming a professional entity or by working as an employee, member, consultant, or independent contractor for a health care organization. The Chapman and Cutler MSO primer likewise lists New Hampshire among states with no statutory CPOM prohibition.

The physician licensing chapter, RSA 329, regulates individual conduct, not who owns a practice. The Board of Medicine can discipline a physician for dishonest or unprofessional conduct or for violating the chapter or board rules under RSA 329:17. That is the lever a regulator would use if a corporate employer pushed a physician into substandard care.

Who can own a medical practice in New Hampshire?

It depends on the entity you choose.

Business corporation or LLC. Nothing in RSA 329 prevents a lay-owned general business entity from employing licensed physicians. This is the main practical difference from strong-CPOM states.
Professional corporation. If you form under RSA 294-A, ownership is restricted. RSA 294-A:8 limits shares to natural persons authorized to render the corporation's professional service (in New Hampshire or another U.S. jurisdiction), plus certain qualifying partnerships and professional corporations.
Multi-profession PCs. RSA 294-A:2 defaults to a single profession. A PC may serve two or more professions only where the licensing laws for those professions permit the combination.

Many New Hampshire founders still use a physician-owned PC for payer credentialing reasons or because investors want a structure that ports cleanly to stricter states. That is a choice, not a mandate.

Can nurse practitioners and physician assistants own a practice in New Hampshire?

New Hampshire is a full practice authority state. Under RSA 326-B:11, an APRN has plenary authority to possess, compound, prescribe, administer, and dispense drugs within scope, including Schedule II, and the nursing statute contains no collaborative or supervisory agreement requirement. An NP can run a clinical practice without a physician partner.

Because New Hampshire lacks a CPOM ban, an NP can generally hold an ownership interest in a general business entity that delivers care. Whether an NP may be a shareholder of a medical professional corporation alongside physicians turns on RSA 294-A:2 and the nursing and medical licensing laws, so confirm before forming that type of entity.

Physician assistants in New Hampshire practice under RSA 328-D, which generally ties PA practice to a relationship with a physician. Confirm current collaboration terms with the Office of Professional Licensure and Certification.

How does the friendly PC-MSO model work in New Hampshire?

You do not need it to comply with CPOM here. A lay-owned company can contract directly with New Hampshire physicians and NPs.

Multi-state telehealth brands often use one anyway. If your brand also serves Massachusetts, North Carolina, or other strong-CPOM states, running all states through a consistent friendly PC-MSO model keeps contracts, credentialing, and audits uniform.

If you do use an MSO in New Hampshire, the fee terms face less state-specific pressure than in states with active fee-splitting statutes. A former provision of the physician licensing chapter has reportedly been repealed, and the current chapter does not appear to carry a separate fee-splitting ban. Confirm whether any Board of Medicine rule restricts fee splitting. Federal rules still apply. The Anti-Kickback Statute and Stark law can reach percentage fees tied to referrals for federally reimbursed services, so fair-market-value pricing remains the safer default.

What does this mean for a telehealth brand serving New Hampshire patients?

Licensure is the binding constraint, not ownership.

RSA 329:1-d is reported to provide that an out-of-state physician who provides services by telemedicine to a New Hampshire patient is practicing medicine in New Hampshire and must be licensed there; confirm the current wording. We did not find a telehealth-only registration for physicians. The CCHP New Hampshire summary describes the licensure requirement and notes a consultation exception for out-of-state physicians advising a New Hampshire-licensed physician. The New Hampshire Bar warns that regular or frequent consultation becomes unlicensed practice.

New Hampshire has been reported to participate in the Interstate Medical Licensure Compact, which can speed up licensure for eligible physicians; confirm current participation. Telemedicine prescribing of controlled substances may also carry additional conditions under New Hampshire law, so confirm the current rules. See telehealth licensing by state for comparisons.

New Hampshire CPOM at a glance

Topic	New Hampshire (as of October 2026)
CPOM enforcement	None (no general prohibition found)
Primary legal basis	No CPOM statute; RSA 294-A limits PC ownership; RSA 329 governs physician conduct
Professional entity options	Business corporation or LLC; professional corporation (RSA 294-A) owned by licensees
Fee-splitting rule	No clear stand-alone state ban found; confirm Board of Medicine rules
NP practice authority	Full
Out-of-state telehealth licensing	No telehealth registration found; plan on a full New Hampshire license (RSA 329:1-d)
Typical structure for non-physician founders	Lay-owned entity employing or contracting clinicians; PC-MSO optional for multi-state consistency

Frequently asked questions

Does New Hampshire prohibit the corporate practice of medicine?

We found no general prohibition as of October 2026. Commentary on New Hampshire law consistently describes physicians as free to work as employees or contractors of lay-owned organizations. Ownership limits apply only if you choose a professional corporation.

Can a non-physician own a medical practice in New Hampshire?

Generally yes, through a business corporation or LLC that employs or contracts with licensed clinicians. A non-physician cannot hold shares in a medical professional corporation under RSA 294-A:8.

Can a nurse practitioner open a practice in New Hampshire without a physician?

Yes. New Hampshire grants APRNs full practice authority, and RSA 326-B does not require a collaborative or supervisory agreement. NPs still need to be licensed by the New Hampshire Board of Nursing.

Do out-of-state doctors need a New Hampshire license for telehealth?

Plan on it. RSA 329:1-d is reported to treat telemedicine with a New Hampshire patient as practicing medicine in the state. A limited physician-to-physician consultation exception is reported, but it does not cover routine patient care.

Do I still need an MSO structure in New Hampshire?

Not for CPOM compliance. Multi-state brands often keep one so that New Hampshire operations match the structure required in stricter states.

Sources

Launch in New Hampshire on a structure that is already built

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