Prerequisites
Per entity:- Filed formation documents, state-stamped
- EIN confirmation letter (CP 575)
- Bylaws or operating agreement, plus the consent authorizing accounts and naming signers
- Ownership documentation
- The clinician’s professional license (PC)
- Government ID for every signer and beneficial owner
- DBA certificate if operating under a brand
What accounts you need
Start with two. Add the rest as they solve a specific problem. See Account structures.
The rules that aren’t negotiable
1. Payer money lands in the PC’s account. Three separate rules converge here: CPOM (the PC earns the professional fee, and control of receipts is an indicium regulators examine), payer contracts and Medicare payment rules (payment goes to the enrolled entity), and basic corporate separateness. 2. Never a shared account between the entities. Ever. 3. The PC’s signer is the PC’s licensed officer, in practice, the clinician-owner. 4. No standing MSO sweep authority over the PC’s account. The money movement may be entirely legitimate; the control is the finding. The management fee moves on an invoice, not an automated pull. See Move money between PC and MSO.Steps
1
Assemble the document packet per entity
Newly formed professional entities are a harder KYB case than a normal LLC, because the bank must verify both the entity and the license behind it. Expect manual review or a branch visit, and budget 1–3 weeks per entity.
2
Answer beneficial ownership questions accurately
Standard forms do not understand this structure. “Who owns 25% or more?” — for the PC, the honest answer is the clinician, 100%, even though the economics are governed by the MSA.Answer accurately and be prepared to explain. Guessing at what the bank wants to hear produces an inaccurate filing.
3
Set signers and access deliberately
- Signer on the PC’s accounts: the PC’s licensed officer
- Read-only: bookkeeper, controller, and whoever reconciles
- Initiator, where supported: operations may prepare payments for the officer’s approval
- Never: an MSO executive as signer on a PC account
4
Apply the naming convention
Decide once:
[Brand] [State] PC, Operating. Consistent naming is what makes a thirty-account list readable and reconciliation scriptable.5
Record the account details for payer EFT enrollment
Routing and account number per PC, ready for EDI/ERA/EFT enrollment.
6
Confirm the bank surfaces ACH addenda data
The health care EFT standard carries the TRN reassociation trace number in the ACH addenda record — that is how you match a deposit to its 835. Many banks don’t display addenda in standard reporting, which forces manual matching. Ask before you choose.
The problem that arrives at scale
Being direct about it, because it is the honest state of the market. Generalist banks give you one login per legal entity. That is the product working as designed — to a bank, your eleven entities have no relationship to each other. At one PC it is an annoyance. At ten it means:- Eleven logins with separate credentials, and eleven statement downloads a month
- No cross-entity view, answering “how much cash do we have?” means logging into everything and building a spreadsheet
- Manual intercompany movement, ten fee transfers a month, each invoiced and reconciled separately
- Repeated KYB onboarding, every new PC is a fresh packet at the same friction as the first
- Per-entity check stock and signers for patient refunds
Lemma is a healthcare-focused banking experience built for exactly this shape of problem, one interface across every PC and the MSO, designed around MSO-PC compliance patterns rather than adapted to them. Named here as the designated disclosure page under our mention policy.Everything else on this page applies regardless of where you bank, and the account structure, signer, and reconciliation discipline described here works at any institution.
Verify it worked
- One operating account per PC, one for the MSO, no shared accounts
- PC signer is the PC’s licensed officer
- No MSO withdrawal authority over PC accounts
- Read-only access provisioned for bookkeeping
- Beneficial ownership answered accurately
- Naming convention applied
- Account details recorded for EFT enrollment
- ACH addenda availability confirmed
- Per-entity setup runbook written for the next entity