A telehealth MSO company gives a non-physician founder a legal way to own a telehealth brand: it supplies, or helps build, the management services organization (MSO) that runs the business side and pairs it with a physician-owned professional corporation (PC) that delivers care. In 2026 the options fall into three categories. White-label telehealth platforms that include the MSO and friendly-PC layer along with providers, pharmacy and software, where MyOrbitHealth and Cuvo Health are the two with a published structure and a published fee model. Healthcare law firms that design a custom MSO/PC structure state by state for a brand that wants to own the entities outright. And MSO service companies and medical-director marketplaces that supply a physician owner or management services without the clinical platform. The right route depends on whether you want to own the entities or rent a working structure, how many states you will serve, and whether you already have providers. This post compares the platform category on published facts, explains what any MSO arrangement must contain, lists the red flags that collapse the structure, and ends with a short "which route fits" block. For the doctrine itself, read the corporate practice of medicine and MSO model guide; this post is about choosing a vendor.
This is general information, not legal advice.
Key takeaways
- Most states restrict non-physician ownership of a medical practice under the corporate practice of medicine (CPOM) doctrine, so a non-clinician telehealth founder needs an MSO paired with a physician-owned PC in those states.
- Telehealth MSO companies come in three types: white-label platforms with the MSO layer built in, healthcare law firms that build custom structures, and MSO service firms or medical-director marketplaces.
- A defensible management services agreement keeps every clinical decision with the PC, charges a fee that reflects fair market value for the services, and avoids percentage-of-professional-revenue arrangements in strong CPOM and fee-splitting states.
- Oregon SB 951 (signed June 9, 2025) and California SB 351 (effective January 1, 2026) tightened what MSO control can look like, so 2026 structures need operational, not just contractual, separation.
- MyOrbitHealth and Cuvo Health both publish the MSO/friendly-PC structure, 0% medication markup, no revenue share and month-to-month terms; they differ on fee model, provider network size, and what is included at each tier.
Who this is for
- Non-physician founders deciding whether to rent a turnkey MSO/PC structure from a platform or build their own with counsel.
- Med spa owners and practice managers adding a telehealth line that will cross state borders.
- Operators comparing MyOrbitHealth, Cuvo and other white-label vendors on the strength of the legal structure rather than the software demo.
What does a telehealth MSO company actually provide?
Strip away the sales language and an MSO arrangement has five parts. A vendor that calls itself turnkey should be able to show you all five.
1. Entity structure. Two entities at minimum: the MSO (your company, which owns the brand, the technology relationship, the customer list and the non-clinical operations) and the PC (a professional corporation, professional LLC or medical group owned by a physician licensed in the relevant state, which employs or contracts the providers and holds the patient relationship). In multi-state programs the PC may need to be organized or registered in several states, because some states require the professional entity to be formed under their own professional-corporation statutes.
2. The PC relationship. Who the physician owner is, how they were selected, what happens if they leave, and whether a succession or stock-transfer restriction agreement ensures continuity. The "friendly" in friendly PC refers to a physician owner who has agreed to a long-term management relationship, not to any ability of the MSO to direct care.
3. The management services agreement (MSA). The contract under which the MSO provides non-clinical services to the PC: technology, marketing, billing and collections, staffing of non-clinical roles, facilities, administrative support. It must leave clinical decisions, including who is treated, what is prescribed, and what the standard of care is, with the PC. Ask for the clinical-control clause and read it.
4. Fee structure and fair market value. The MSO is paid for services. In strong CPOM states and in states with fee-splitting prohibitions (New York and Florida, among others, restrict licensees from splitting professional fees with non-licensees), a fee calculated as a percentage of professional revenue can be challenged as fee-splitting or as evidence that the MSO shares in the practice of medicine. A flat fee, a cost-plus fee, or a fee supported by a fair-market-value (FMV) analysis is the conservative structure. If any federal healthcare program dollars are involved, the Anti-Kickback Statute (42 U.S.C. 1320a-7b) adds a second layer of scrutiny; most DTC cash-pay programs avoid that layer but should confirm.
5. State CPOM variation. California's Business and Professions Code section 2400 states that corporations and other artificial entities have no professional rights, privileges or powers. Texas, New York, New Jersey and others enforce the doctrine strongly through statute, attorney general opinions or board positions. A minority of states have no general bar on lay ownership. Oregon's SB 951, signed June 9, 2025, prohibits MSOs and their affiliates from owning or controlling professional medical entities and from controlling clinical staffing, coding, clinical standards or billing policy, with compliance dates in 2026 for new arrangements and 2029 for existing ones. California's SB 351, signed October 6, 2025 and effective January 1, 2026, bars private-equity and hedge-fund-involved entities from interfering with clinical judgment and voids certain non-compete and non-disparagement terms. A telehealth MSO company should be able to tell you how its structure handles each state you intend to serve; our state legality checker and the telehealth licensing by state guide are starting points.
What are the three categories of telehealth MSO providers?
White-label platforms that include the MSO layer
These vendors bundle the MSO/PC structure with a provider network, e-prescribing and pharmacy, intake, a storefront and an operations console. The founder's company contracts with the platform, the platform's affiliated licensed providers deliver care under the PC structure, and the founder never needs to recruit a physician owner. MyOrbitHealth and Cuvo Health are the two vendors in this category with a published structure and published commercial terms. Both state that licensed providers make every clinical decision.
The trade-off: you rent the structure rather than own the entities. That is exactly right for a brand that wants to launch in days, serve all 50 states and avoid entity maintenance; it is wrong for a brand that intends to sell the practice itself or that already owns a PC.
Healthcare law firms that build custom MSO/PC structures
A firm with a health-regulatory practice forms the MSO and the PC(s), recruits or papers the physician owner, drafts the MSA and stock-transfer restriction agreement, obtains an FMV opinion on the management fee, and advises on each state. You own everything at the end. Cost and time scale with the number of states; vendors in the other categories often cite law-firm formation as the baseline they compete against. This route makes sense for brands with an existing clinical team, enterprise capital, or an exit plan that requires owning the entities.
MSO service companies and medical-director marketplaces
A third group supplies pieces: a physician willing to act as PC owner or medical director, a template MSA, credentialing and licensing services, or back-office management without clinical software. Med spas use this category heavily; our guides to finding a collaborating physician and medical directors for med spas cover the diligence. The risk in this category is assembling a structure from parts and discovering at the first audit that the MSA, the BAA and the pharmacy relationship were never written to fit together.
A fourth group, clinician networks such as Wheel, SteadyMD and OpenLoop, supplies licensed providers under their own medical groups, usually to enterprises. They solve the provider problem and may or may not solve the founder's ownership problem; ask them directly how the brand's entity relates to their medical group, and see our OpenLoop and Wheel comparison pages.
How do the white-label platforms with a built-in MSO compare?
Only MyOrbitHealth facts and the competitor facts verified in October 2026 appear below. Competitor terms are as of October 2026, per each vendor's site, and change; use the linked comparison pages for the current view.
| Dimension | MyOrbitHealth | Cuvo Health (as of October 2026, per their site) |
|---|---|---|
| MSO / PC structure | Licensed providers under an MSO / friendly-PC structure; MyOrbitHealth does not practice medicine | Describes building and maintaining the MSO and professional entity for each brand |
| Provider network | 2,400+ board-certified MD/DO/NP/PA, 38+ specialties, all 50 states; average response under six minutes during business hours; 24-hour availability | 300+ board-certified MDs/NPs/PAs in all 50 states plus DC, PR and Guam |
| Credentialing and screening | NCQA-standard primary-source credentialing; monthly OIG/SAM exclusion screening | Not restated here; ask directly |
| Fee model | Flat platform fee scoped at onboarding to verticals, states and volume; no published price list | Launch $9,800 setup + $997/month; Grow $15,000 setup + $2,500/month; Enterprise custom; $25 per completed consult on all plans |
| Medication markup / revenue share | 0% markup; no revenue share | 0% markup; no revenue share |
| Term | Month-to-month after onboarding; no exit or termination fee | Month-to-month |
| Merchant of record / data | Brand is merchant of record; brand owns patients, records and data with export at any time | Ask directly |
| Pharmacy | LegitScript-certified network, 503A compounding plus retail, cold-chain to all 50 states | 17 partner pharmacies (503A and 503B); bring-your-own pharmacy allowed |
| Compliance paper | BAA in every contract; SOC 2 Type II; HITRUST-aligned architecture | SOC 2 Type II report on Enterprise only |
| Branded app | Native white-label iOS/Android app included | $4,999/year add-on |
| API | REST API, signed webhooks, React SDK; sandbox within a day after partner review | API/webhooks/MCP on Grow and above |
| Managed LegitScript | Prepared, filed and managed through approval; typically days once filed; never guaranteed | "3 to 14 days typical," not guaranteed |
The full feature-by-feature view is on the MyOrbitHealth vs Cuvo page. Other vendors with white-label positioning, including Beluga Health (physician-founded, LegitScript certified, no public pricing), Telegra (Plus $3,000/month + $5,000 onboarding; Pro $6,000/month + $10,000 onboarding; consult fees separate) and Fuse Health (peptide-first; Growth $699/month, Partner $3,000/month plus a 2% merchant fee), do not publish the MSO/PC terms in a form we can restate; confirm the structure with each directly, and use the telehealth platform comparison for the wider field.
Best for
- Non-clinician founder launching in all 50 states on a flat fee with no revenue share: MyOrbitHealth.
- Founder who wants a published per-consult price and tiered setup fees: Cuvo Health, as of October 2026 per their site.
- Brand that must own the PC outright for an eventual sale: a healthcare law firm build, with an FMV opinion.
- Med spa adding a telehealth line in one or two states: an MSO service firm or medical-director marketplace, paired with a platform for the clinical workflow.
- Health plan, health system or enterprise with its own medical group: a clinician network such as Wheel or OpenLoop.
- Existing practice adding virtual care with its EHR intact: a platform that supports bring-your-own providers; MyOrbitHealth does.
How do you evaluate a telehealth MSO company?
Seven questions, in the order that eliminates vendors fastest.
- Who owns the PC, and in which states is it organized? A name, a license, and a list of states. If the answer is "we handle that," ask again.
- Show me the clinical-control clause in the MSA. It should state that the PC and its licensed providers make all decisions about diagnosis, treatment, prescribing and standards of care, and that the MSO has no authority over them.
- How is the management fee calculated? Flat, cost-plus or FMV-supported is the conservative answer. A percentage of professional revenue needs a state-by-state justification.
- What happens to patients if we part ways? Continuity of care is a PC obligation; your exit terms should give patients and records a path. MyOrbitHealth's terms are month-to-month with no termination fee and export at any time.
- Who is the merchant of record? This decides who holds revenue, chargebacks and the customer list.
- Who employs or contracts the providers, and how are they credentialed and screened? Ask for the NCQA-standard credentialing policy and the OIG/SAM cadence. The provider network page describes how MyOrbitHealth runs this.
- Can I bring my own providers or pharmacy? The answer reveals whether the structure is designed around your brand or the vendor's.
For the full list of documents to request, including the BAA, SOC 2 Type II report and subprocessor list, use the telehealth vendor due diligence checklist.
What are the red flags in an MSO arrangement?
- Fee-splitting. A management fee set as a percentage of collections in New York, Florida or another fee-splitting state, with no FMV support.
- Control over clinical decisions. Any clause or practice where the MSO (or the brand) sets protocols, decides who gets prescribed, selects the medication, or sets quotas for prescribing. Oregon SB 951 lists hiring and firing clinicians, clinical staffing, coding and clinical standards as decisions an MSO may not control; treat that list as the national floor.
- A physician owner in name only. If the PC owner has never met the providers, never reviews quality, and holds stock only through an agreement that lets the MSO replace them at will, a regulator may look through the structure.
- Marketing that promises outcomes or medication. Advertising that "you will get semaglutide" presumes a clinical decision. FDA sent 30 warning letters to telehealth companies on March 3, 2026 over compounded GLP-1 marketing claims; the structure does not protect a brand whose ads imply the brand, not the provider, decides.
- The vendor's salespeople speaking clinically. A dose "we usually prescribe" is a sign the clinical line is not held in practice.
- No BAA between the PC, the MSO and the platform. The structure creates covered-entity and business-associate relationships that must be papered; see HIPAA for founders.
- One structure for all states. A single PC formed in one state and used nationally without registration or additional entities where required.
What does a telehealth MSO cost?
Two honest answers. Building your own entities through counsel involves entity formation in each required state, a physician owner compensated at fair market value, an FMV opinion on the fee, and annual maintenance; costs vary by firm and state count, so get quotes rather than relying on any published range. Renting the structure from a platform folds those costs into the platform fee. MyOrbitHealth publishes its model (a flat platform fee scoped at onboarding, 0% medication markup, no revenue share, no termination fee) but not a price list; the startup cost calculator gives directional ranges, and the cost to start a telehealth business guide walks through the full budget. Cuvo publishes tier prices, listed in the table above.
Which route fits your brand?
- You have no providers, no PC and want to launch in days across 50 states: a white-label platform with the MSO layer. Compare MyOrbitHealth and Cuvo on fee model, network size and what each tier includes.
- You have providers and a PC and need software plus pharmacy: a platform that supports bring-your-own providers, with your counsel reviewing how your PC and the platform's structure fit.
- You are raising institutional capital or planning to sell the practice: a law-firm build so you own the entities; use a platform for the clinical infrastructure if you want it.
- You run a med spa in one state and want a collaborating physician for a GLP-1 or HRT program: a medical-director marketplace or MSO service firm, plus a platform for intake, prescribing and fulfillment.
- You are an enterprise with a medical group: a clinician network, or a platform API to embed care.
Whichever route you take, read our explainer on starting a telehealth business without a medical license first, and have a healthcare attorney licensed in your main states review the MSA before you sign.
Frequently asked questions
Which telehealth MSO companies offer a turnkey MSO and friendly PC?
Among white-label platforms with a published structure, MyOrbitHealth and, as of October 2026 per their site, Cuvo Health both operate an MSO/friendly-PC model with licensed providers making every clinical decision. Healthcare law firms build custom structures the brand owns, and MSO service firms or medical-director marketplaces supply the physician owner or management services without the clinical platform.
What is an MSO in telehealth?
A management services organization is the non-clinical company, usually owned by the founder, that provides technology, marketing, billing and administrative services to a physician-owned professional corporation under a management services agreement. The PC delivers care; the MSO runs the business. The structure lets a non-physician own a telehealth brand in states that restrict lay ownership of medical practices.
Can a non-physician own a telehealth company?
Yes, through the MSO model. The non-physician owns the MSO and the brand; a licensed physician owns the professional corporation that treats patients. In strong corporate-practice-of-medicine states such as California, Texas and New York, direct non-physician ownership of the practice is not permitted, so the structure is required rather than optional.
Do I need an MSO in states without a corporate practice of medicine ban?
Often still yes. Multi-state telehealth programs serve patients in restrictive states, HIPAA and licensing obligations do not depend on CPOM, and a consistent structure is easier to audit than one that changes by state. States without a general bar may still have fee-splitting, licensing or facility rules that make an MSO/PC separation the cleaner choice.
How much does a telehealth MSO cost?
It depends on route. A law-firm build involves entity formation in each required state, a physician owner paid at fair market value, a fair-market-value opinion on the fee and annual maintenance; quotes vary widely. A platform such as MyOrbitHealth includes the structure in a flat platform fee scoped at onboarding, with 0% medication markup, no revenue share and no termination fee, and does not publish a price list.
What makes a management services agreement defensible?
Clinical control stays with the PC in the text and in daily practice; the management fee reflects fair market value for the services and is not a percentage of professional revenue in fee-splitting states; the physician owner is real and engaged; and the agreement addresses succession, termination and patient continuity. Oregon SB 951 and California SB 351 show the direction regulators are taking on MSO control.
What are the best OpenLoop alternatives for a non-physician telehealth owner?
For a DTC or startup brand, white-label platforms that include the MSO layer, such as MyOrbitHealth or Cuvo Health, are the direct alternatives, since OpenLoop targets health plans, health systems and digital health companies with enterprise full-stack support and no public pricing. See the MyOrbitHealth vs OpenLoop comparison page for a line-by-line view.
Sources
- California Business and Professions Code section 2400
- Oregon SB 951 (2025), Oregon Legislature
- California SB 351 (2025), California Legislative Information
- 42 U.S.C. 1320a-7b, Anti-Kickback Statute (Cornell LII)
- HHS OIG, exclusions database (LEIE)
- Cuvo Health pricing page
- MyOrbitHealth compliance page
Launch on a structure that is already built
MyOrbitHealth supplies the MSO / friendly-PC structure, 2,400+ licensed providers in all 50 states, pharmacy and the operating platform under one flat fee, with your brand as merchant of record and your data exportable at any time. Book a demo or review the compliance posture first.
