Friendly PC Model: 3 Key Ancillary Agreements for CPOM Compliance
By Dustin PlumadoreHealth Care Attorney
Dickinson Wright
With the rebound of private equity ("PE") activity in healthcare across the United States, the Corporate Practice of Medicine and Dentistry ("CPOM" or "CPOD") has likewise experienced renewed focus by state legislatures and enforcement agencies in 2025. However, despite this rekindled attention, the often-referenced "Friendly PC" model remains the best structural strategy to ensure post-closing compliance with CPOM and CPOD regulations in most jurisdictions. Constructing a compliant “Friendly PC” structure will probably require the support of expert legal counsel to draft and negotiate the series of agreements necessary for its proper implementation. However, the following paragraphs identify some key considerations for three ancillary agreements, outside of the base transaction documents, commonly used to ensure compliance with CPOM and CPOD.
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How Hospitals Can Safeguard 340B Program Eligibility
By Karl Rebay,
Principal, Health Care Consulting Practice, Moss Adams (now Baker Tilly)
By Jesse Vo,
Senior Manager, Provider Reimbursement Services, Moss Adams (now Baker Tilly)
Hospitals and health systems across the country are grappling with changes in Medicaid eligibility brought on by recent industry shifts, including regulatory changes, the end of the public health emergency (PHE), Medicaid redetermination, and the halt of continuous enrollment. These seismic shifts have created a significant financial crisis for many health organizations: the loss of 340B Drug Pricing Program (340B) eligibility and access to beneficial drug pricing under the 340B program.
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Federal Health Law Enforcement in 2025
By David J. Davidson, Esq.Board Certified Health Care Attorney, Dickinson Wright
Much has been written about the healthcare policy changes implemented by the 2025 Trump administration. President Trump has issued numerous Executive Orders which establish new policies and rescind actions taken by previous administrations. Robert F. Kennedy, Jr. is overhauling and refocusing Health & Human Services. Dr. Mehmet Oz is implementing new policies at the Center for Medicare and Medicaid Services and auditing Medicare Advantage plans (of which he has been a historical proponent). The Food & Drug Administration is revising its Generally Regarded as Safe standards, fast-tracking approvals of new drugs, minimizing animal testing, and increasing its use of Artificial Intelligence. The National Institute of Health is amending its peer review process.
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Health Plan Financial Reports for California and Washington State
By David PeelPublisher and Editor, Healthcare News
We recently updated our financial reporting for health plans in California and Washington State. Click on the links below to see the numbers.