> ## Documentation Index
> Fetch the complete documentation index at: https://mso.getlemma.com/llms.txt
> Use this file to discover all available pages before exploring further.

# Multi-specialty and multi-profession structures

> When one professional entity can house multiple specialties, when professions must be siloed into separate entities, and the billing and shared-services consequences.

A single professional entity can generally house multiple **specialties within one profession** — a medical PC with dermatologists, internists, and psychiatrists is ordinary. It generally cannot house multiple **professions**: medicine, dentistry, physical therapy, and optometry are separate licensures, and in most states each needs its own entity with its own appropriately licensed owner.

## Specialty vs profession

The distinction that determines your entity count:

|                 | Same profession, different specialties       | Different professions                   |
| --------------- | -------------------------------------------- | --------------------------------------- |
| **Example**     | Dermatology + internal medicine + psychiatry | Medicine + dentistry + physical therapy |
| **Licensure**   | One license type (MD/DO)                     | Separate license types and boards       |
| **One entity?** | ✅ Usually yes                                | ❌ Usually no                            |
| **Owner**       | Any physician                                | Needs a licensee of each profession     |

A multi-specialty medical group is one PC owned by a physician, employing physicians of every specialty. A medical-plus-dental group is two entities.

## Where the lines fall

| Profession       | Typically its own entity? | Notes                                                          |
| ---------------- | ------------------------- | -------------------------------------------------------------- |
| Medicine (MD/DO) | —                         | The base case                                                  |
| Dentistry        | ✅ Separate                | Own corporate practice doctrine in many states, often stricter |
| Optometry        | ✅ Separate                | Own doctrine; retail carve-outs in some states                 |
| Podiatry         | ⚠️ Sometimes combinable   | Several states permit physician + podiatrist entities          |
| Chiropractic     | ✅ Separate                |                                                                |
| Physical therapy | ✅ Usually separate        | POPTS restrictions in some states                              |
| Psychology       | ⚠️ Sometimes combinable   | Several states permit physician + psychologist entities        |
| Nursing (NP)     | ⚠️ Varies                 | Scope-of-practice and ownership rules differ sharply by state  |
| Veterinary       | ✅ Separate                | Entirely separate regime                                       |
| Pharmacy         | ✅ Separate                | Plus its own licensure regime                                  |

**These groupings are statutory allowances, not general principles.** A state permits a combination only if its professional entity statute says so. If the statute doesn't name your combination, assume separate entities are required.

## Behavioral health is the hard case

The vertical where this bites hardest, because a single behavioral health group routinely employs:

* Psychiatrists (MD/DO)
* Psychiatric nurse practitioners (APRN)
* Psychologists (PhD/PsyD)
* Clinical social workers (LCSW)
* Professional counselors (LPC/LMHC)
* Marriage and family therapists (LMFT)

That is up to six distinct licensures under different boards. Whether one entity can employ all of them, and who may own it, varies dramatically by state.

Common patterns:

* **A broad "healthcare professional" entity statute** that permits several licensed professions in one entity
* **A physician-owned PC** employing the others as permitted by scope-of-practice rules
* **Separate entities** for the prescriber group and the therapy group
* **A psychologist-owned or LCSW-owned entity** in states that permit it

There is no general answer. Get a state-specific opinion before hiring across license types. See [Behavioral health and therapy groups](/concepts/industries/behavioral-health).

## Structuring a multi-profession group

When professions must be siloed, the shape extends the hub-and-spoke:

```mermaid theme={null}
graph TB
    MSO[MSO]
    MD[Medical PC<br/>physician-owned]
    DDS[Dental PC<br/>dentist-owned]
    PT[PT PC<br/>therapist-owned]

    MSO -->|MSA| MD
    MSO -->|MSA| DDS
    MSO -->|MSA| PT
```

Each entity gets its own MSA, its own transfer restriction agreement, its own BAA, its own EIN, its own Type 2 NPI, its own payer enrollments, its own bank accounts, and its own books. Per state.

A three-profession group in four states is **twelve professional entities plus an MSO**. This is why integrated care models are operationally heavy, and why many groups deliberately narrow to one profession.

## Shared services and shared space

The MSO can provide space, equipment, staff, and systems to all of the entities — that is the point of having one MSO. Three things need care:

**Cost allocation.** Each PC's management fee should reflect the services *that* PC actually receives. Allocating shared costs arbitrarily undermines the fair market value analysis for every entity in the group. Use a defensible driver — headcount, square footage, visit volume, or direct attribution — and document the methodology.

**Referrals between entities.** When the medical PC refers to the physical therapy PC and both are managed by the same MSO, you are in Stark and Anti-Kickback Statute territory. Federal Stark restricts physician referrals for designated health services to entities with which the physician has a financial relationship, and physical therapy is a designated health service.<sup>1</sup> This needs specific analysis, not a general comfort that "we're all one group."

**Shared records.** If the entities share an EHR, records must remain segregated by entity, since each PC owns its own patients' records. Access controls should reflect that, and BAAs need to cover the arrangement.

## Billing consequences

Separate entities mean genuinely separate billing operations:

|                 | Medical PC                     | Dental PC                               | PT PC                                      |
| --------------- | ------------------------------ | --------------------------------------- | ------------------------------------------ |
| Claim format    | 837P                           | 837D                                    | 837P                                       |
| Procedure codes | CPT / HCPCS                    | CDT                                     | CPT                                        |
| Group NPI       | Its own                        | Its own                                 | Its own                                    |
| Tax ID          | Its own                        | Its own                                 | Its own                                    |
| Taxonomy        | Medical specialty              | Dental                                  | `225100000X`                               |
| Payers          | Medical plans                  | Dental plans, often different companies | Medical plans, with therapy-specific rules |
| Clearinghouse   | Must support all three formats |                                         |                                            |

<Note>
  🦷 **Dental**, dental benefits are frequently administered by entirely different companies from a patient's medical plan, with their own networks, their own credentialing, and their own annual maximums. A combined medical-dental group runs two nearly disjoint payer operations.
</Note>

<Note>
  👁 **Optometry**, the same split, sharper. Vision plans (VSP, EyeMed) and medical plans cover different services for the same patient, and determining which to bill is a per-encounter judgment. See [Optometry and vision](/concepts/industries/optometry).
</Note>

Make sure your clearinghouse supports every format you need before you commit. See [Choose a clearinghouse](/guides/billing/choose-a-clearinghouse).

## Questions to answer before building one

* [ ] Which professions will we deliver?
* [ ] Does our state permit any of them in a combined entity?
* [ ] Who will own each entity, and are they licensed in that state?
* [ ] How will shared costs be allocated, and is the method documented?
* [ ] Do referrals between our entities implicate Stark or AKS?
* [ ] Can our EHR and clearinghouse handle every claim format?
* [ ] How many total entities does this produce at our target footprint, and can we operate that many?

## Sources

1. 42 U.S.C. § 1395nn (Stark Law); designated health services defined at 42 C.F.R. § 411.351. [CMS Physician Self-Referral](https://www.cms.gov/medicare/regulations-guidance/physician-self-referral).


## Related topics

- [Who can own a professional entity](/concepts/entities/who-can-own-what.md)
- [Why multi-state groups have one PC per state](/concepts/entities/one-pc-per-state.md)
- [Stark, AKS, and why comp design is constrained](/concepts/compliance/stark-and-anti-kickback.md)
- [Form a professional corporation](/guides/formation/form-a-pc.md)
- [Set the management fee](/guides/agreements/set-the-management-fee.md)
- [California — CPOM & MSO reference](/reference/legal/states/california.md)
- [Provider taxonomy codes](/reference/edi/taxonomy-codes.md)