Oregon CPOM Rules 2026: SB 951 and the MSO Crackdown

Oregon has the strictest corporate practice of medicine regime in the country as of October 2026. The state always required physician-controlled medical entities. Senate Bill 951, signed June 9, 2025, went further: it targets the management services organization (MSO) itself. An MSO and its owners, officers, employees and contractors can no longer hold a majority of the medical practice they manage. The law also takes a list of business decisions out of the MSO's hands. The classic "friendly PC," where an MSO insider owns the practice on paper, is the arrangement the law was written to end. New structures have had to comply since January 1, 2026. Structures that existed before June 9, 2025 have until January 1, 2029.

For a non-physician founder, an MSO model is still legal in Oregon, but the PC owner must be independent of your MSO. For an NP founder, Oregon's full practice authority helps, but check whether SB 951 reaches your entity before you rely on it.

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

Key takeaways

• Oregon medical professional corporations must be majority-owned and majority-directed by licensed professionals under ORS 58.375; summaries differ on whether the enrolled text says "licensees" or Oregon-licensed physicians, so confirm the wording. SB 951 amended that section and added ORS 58.376.
• SB 951 bars an MSO's shareholders, directors, members, managers, officers and employees from owning or controlling, individually or together, a majority of a professional medical entity the MSO contracts with. HB 3410 extended this to MSO contractors.
• MSOs may not hold final authority over listed decisions, including hiring, firing, scheduling and pay for clinicians, diagnostic coding, and patient billing and collection policies.
• The ownership and control rules apply from January 1, 2026 to entities formed on or after June 9, 2025, and from January 1, 2029 to entities that existed before that date.
• Law-firm summaries report a carve-out for telemedicine providers with no physical location in Oregon where patients receive clinical services. Read its exact scope in the statute before you rely on it.

Does Oregon have a corporate practice of medicine doctrine?

Yes, and since 2025 it has been mostly written into statute. Before SB 951, Oregon's doctrine rested on its professional corporation law, which required physician control of entities practicing medicine. SB 951 kept that foundation and added direct regulation of the companies that manage practices. Check whether later legislation has amended SB 951 or HB 3410 before relying on any detail below.

Per the enrolled text of SB 951 and analyses by Ropes & Gray and Nixon Peabody, the law does three things:

1. Ownership separation. MSO insiders cannot own or control a majority of the professional medical entity (PME) the MSO serves. Narrow exceptions are reported, including one for small ownership stakes and one for incidental MSO shares; summaries describe their conditions differently, so confirm them in the statute.
2. Dual-role limits. One person generally cannot be both a PME owner or leader and a paid MSO director, officer, employee or contractor. HB 3410, enacted later in 2025, extended these limits to contractors and is reported to have narrowed a physician director and officer exception; confirm its current terms.
3. Decision control. MSOs may not exercise "de facto control" over a PME's operations in ways that affect clinical decision-making or quality of care.

Holland & Knight's May 2026 update describes Attorney General enforcement plus a private right of action for actual and punitive damages and attorney fees. A reported lawsuit, Eugene Emergency Physicians v. PeaceHealth, may be an early test of "de facto control"; check its current status.

Who can own a medical practice in Oregon?

A medical PC in Oregon must have licensed professionals holding a majority of each class of voting shares and making up a majority of the board; confirm whether the enrolled text requires "licensees" or Oregon-licensed physicians. Officers other than the secretary and treasurer must be Oregon-licensed physicians. A lay investor cannot be the majority owner.

Reported SB 951 exemptions include hospitals and hospital-affiliated clinics, long-term and residential care facilities, PACE organizations, crisis line providers, opioid treatment programs, certain tribal and coordinated care entities, and the telemedicine carve-out above. Summaries group these differently, so map your entity against the statutory list.

Can nurse practitioners and physician assistants own a practice in Oregon?

Oregon gives nurse practitioners full practice authority. NPs can evaluate, diagnose and prescribe without physician supervision. That makes NP-led primary care, mental health and weight-management practices common in Oregon.

Two open questions matter for founders. First, whether SB 951's definition of a professional medical entity reaches NP-owned entities. Second, whether ORS 58.375 allows NPs or physician associates to hold minority shares in a medical PC. Do not assume either answer. Oregon renamed physician assistants "physician associates." They generally practice under collaboration agreements rather than traditional supervision. If a physician associate will run part of your service, get the current collaboration rules confirmed.

How does the friendly PC-MSO model work in Oregon?

It still works, but the "friendly" part has to be truly independent now. The friendly PC-MSO model usually puts an MSO employee or allied physician in the owner seat. SB 951 targets exactly that. Hooper, Lundy & Bookman calls the law aimed squarely at "friendly PC" arrangements.

An Oregon MSO can still provide accounting, budgeting, personnel administration, facilities and compliance support, advise on non-clinical decisions, and buy or lease practice assets at arm's length. It cannot have the final say on clinician hiring, firing, scheduling or pay, make diagnostic coding decisions, or set patient billing and collection policies. Summaries conflict on payor contracts, so treat payor contracting as the PME's decision. Restrictive covenants changed too: law-firm summaries report that many noncompete, nondisclosure and nondisparagement agreements with clinicians are now unenforceable, with exceptions. Confirm the current rules and whether they reach agreements signed before the law. Rewrite any template management services agreement with an Oregon reviewer. Do not just change the governing-law clause.

What does this mean for a telehealth brand serving Oregon patients?

Licensure comes first. Oregon has offered a license to practice medicine across state lines under ORS 677.139, described as available to out-of-state physicians and physician associates with a full, unrestricted license elsewhere and no sanctions. It is narrower than a full license and is reported not to allow dispensing or in-person practice in Oregon. Confirm that it is still issued and its current limits. See our telehealth licensing by state guide.

On CPOM, the reported telemedicine exemption is the key question. A brand with no Oregon clinic where patients receive care may fall outside some SB 951 restrictions, depending on the exact wording. Plan as if the full rules apply until counsel says otherwise: use a PC owner with no equity or paid role at your MSO beyond what the statute allows, keep clinical and clinician-employment decisions with the PC, and avoid succession provisions that let the MSO swap out the owner.

Oregon CPOM at a glance

Frequently asked questions

Is the friendly PC model illegal in Oregon now?

Not entirely. MSO-PC structures remain legal. But SB 951 bars an MSO's shareholders, directors, officers, employees and (after HB 3410) contractors from owning or controlling a majority of the PC the MSO serves. A PC owned by your MSO's medical director or employee is the setup the law targets.

When do I have to comply with SB 951?

Entities formed on or after June 9, 2025 have been subject to the ownership and control rules since January 1, 2026. Entities that existed before June 9, 2025 have until January 1, 2029. The restrictive covenant changes are reported to have taken effect earlier; confirm their effective date and whether they reach existing agreements.

Does SB 951 apply to telehealth companies?

Law-firm summaries report an exemption for telemedicine providers with no physical location in Oregon where patients receive clinical services. Its exact reach depends on the statutory text. Confirm with Oregon counsel before structuring around it.

Can a nurse practitioner own a practice in Oregon?

Oregon NPs have full practice authority, so NP-led practices are common. Whether SB 951's restrictions reach an NP-owned entity, and whether NPs may hold shares in a medical PC, should be confirmed with counsel.

What happens if an MSO violates SB 951?

The law allows Attorney General enforcement, including civil penalties and injunctions. It also lets affected practices and licensees sue the MSO for actual and punitive damages and attorney fees.

Sources

• Oregon Legislature, Enrolled Senate Bill 951 (2025)
• Ropes & Gray, Key Takeaways Related to Oregon's New CPOM Law
• Nixon Peabody, Oregon SB 951: Corporate practice of medicine law explained
• Taft, Oregon Alters Rules for Healthcare-Private Equity Relationships for Second Time in Two Months (HB 3410)
• Holland & Knight, An Update on the Implementation and Implications of Oregon's New CPOM Laws (May 2026)
• Hooper, Lundy & Bookman, New Oregon CPOM law takes aim at "Friendly PC" arrangements
• ORS 677.139, License to practice medicine across state lines

For how Oregon compares with other states, see the 50-state corporate practice of medicine guide.

Launch in Oregon on a structure that is already built

Oregon is the worst state in which to improvise an MSO structure. MyOrbitHealth can form a PC-MSO structure for your brand, supply an independent physician PC owner or collaborating physician, or let you launch on its existing MSO / friendly-PC structure, where 2,400+ licensed providers make every clinical decision. See PC-MSO formation, physician PC owner services, or book a call.