Structure accounts across your entities

This is the operational recipe for laying out accounts across a multi-entity group: which accounts, whose name, who signs, who sees. The compliance constraints come from Why MSO-PC banking is different; this page implements them.

Prerequisites

Every entity formed with its own EIN
A decision on your naming convention
Clarity on who the PC’s authorized officer is

The account map

Per PC

Account	Purpose	When to add
Operating	Payer EFTs and patient payments in; clinical payroll and the management fee out	Launch
Payroll	Funded from operating before each run	When clinical payroll exceeds a few people
Refund / disbursement	Patient refund checks drawn from a controlled account	When refund volume justifies it

For the MSO

Account	Purpose	When to add
Operating	Fee income; all non-clinical expenses	Launch
Payroll	Non-clinical payroll	Early
Tax reserve	Estimated taxes set aside	Early
Reserve / treasury	Runway and outage cushion	When there’s surplus

Every account is another reconciliation, another set of signers, and another statement. Add accounts because they solve a specific problem, not because a diagram looks tidy.

Naming convention

Decide once and never deviate:

Meridian Dermatology CO PC, Operating
Meridian Dermatology CO PC, Payroll
Meridian Dermatology AZ PC, Operating
Meridian Health Partners MSO, Operating
Meridian Health Partners MSO, Payroll
Meridian Health Partners MSO, Tax Reserve

This matters more than it sounds. It is what makes a thirty-account list readable, makes reconciliation scriptable, and prevents someone paying a Colorado expense from the Arizona account because the names were ambiguous.

Signing authority

Role	PC accounts	MSO accounts
Signer / authorized user	The PC’s licensed officer, the clinician-owner	MSO officers
Read-only	Bookkeeper, controller, reconciler	Same
Payment initiator (where supported)	Operations may prepare for the officer’s approval	MSO staff
Approver	The PC’s officer	MSO officer

The pattern that works: operations prepares, the PC’s officer approves. The MSA authorizes the MSO to provide financial administration services including preparing payments; the authority to release funds stays with the PC.

Never give the MSO unilateral withdrawal authority over a PC account. Not a standing ACH debit authorization, not an MSO executive as signer, not shared credentials. This is a CPOM self-audit finding regardless of whether the underlying transfers are legitimate.

Visibility vs control

These are different axes, and only one is a compliance question. Read-only visibility across all entities creates no CPOM exposure — nobody’s receipts or clinical judgment are controlled by someone seeing a balance. Withdrawal authority is the constrained thing. So: maximize visibility, constrain control. Give the MSO’s finance team read access to everything and withdrawal authority over nothing on the PC side.

How commingling actually happens

Not through fraud. Through convenience.

Scenario	Why it happens	Fix
MSO pays a PC expense because the PC is short	Friday afternoon, a vendor needs paying	Record an intercompany entry the same day, or lend on a note
PC pays an MSO expense because the card was handy	The wrong card was in someone’s wallet	Separate cards per entity, clearly labeled
One entity’s refund check drawn on another’s account	The check stock was in the drawer	Per-entity check stock, physically separated
Payer EFT enrolled to the wrong account	The form said “company account”	Verify every EFT enrollment against the entity
A shared credit card across entities	Simplicity	Never do this
Payroll for both entities from one account	One payroll provider, one funding account	Two funding accounts, one per employer

Every one of these is fixable the day it happens and painful a year later. The rule: if money moves between entities, there is either an invoice or a note, recorded on both sides, the same day.

Steps

Write the account map before opening anything

Which accounts, which entity, which purpose.

Apply the naming convention from account one

Set signers per the table above

Provision read-only access broadly, withdrawal authority narrowly

Issue per-entity payment cards, labeled

Store per-entity check stock separately, physically

Document the map and add it to the per-entity setup runbook

So entity twelve is set up identically to entity two. See Per-entity account checklist.

Review access quarterly

Departed employees, changed roles, and new entities. Access drift is a real finding.

Cash concentration, carefully

Groups with meaningful balances want to concentrate idle cash for yield. The constraints:

PC cash moves to the MSO only as an invoiced management fee or a documented loan repayment, never as an automated sweep
Each PC retains enough to cover clinical payroll and direct obligations
No structure may give the MSO withdrawal authority over PC accounts
Automated sweeps between differently owned entities are the pattern to avoid — the automation is what reads as control

Verify it worked

Account map documented before opening
Naming convention applied consistently
PC signers are PC officers; no MSO signers on PC accounts
Read-only access provisioned across all entities
No standing sweep or ACH debit authority for the MSO
Per-entity cards and check stock, physically separated
Setup runbook written
Quarterly access review scheduled

Formation & Corporate

Agreements

Credentialing & Payer Enrollment

Billing Operations

Patient Payments & Refunds

Banking & Finance

Compliance Tasks

Structure accounts across your entities

Prerequisites

The account map

Per PC

For the MSO

Naming convention

Signing authority

Visibility vs control

How commingling actually happens

Steps

Cash concentration, carefully

Verify it worked

​Prerequisites

​The account map

​Per PC

​For the MSO

​Naming convention

​Signing authority

​Visibility vs control

​How commingling actually happens

​Steps

​Cash concentration, carefully

​Verify it worked

Prerequisites

The account map

Per PC

For the MSO

Naming convention

Signing authority

Visibility vs control

How commingling actually happens

Steps

Cash concentration, carefully

Verify it worked