> ## 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.

# Structure accounts across your entities

> The recommended account map per PC and for the MSO, naming conventions, signing authority, read-only access, and how commingling happens accidentally.

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](/concepts/banking/why-healthcare-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:

```text theme={null}
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.

<Warning>
  **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.
</Warning>

## 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

<Steps>
  <Step title="Write the account map before opening anything">
    Which accounts, which entity, which purpose.
  </Step>

  <Step title="Apply the naming convention from account one" />

  <Step title="Set signers per the table above" />

  <Step title="Provision read-only access broadly, withdrawal authority narrowly" />

  <Step title="Issue per-entity payment cards, labeled" />

  <Step title="Store per-entity check stock separately, physically" />

  <Step title="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](/reference/banking/per-entity-account-checklist).
  </Step>

  <Step title="Review access quarterly">
    Departed employees, changed roles, and new entities. Access drift is a real finding.
  </Step>
</Steps>

## 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


## Related topics

- [Banking and books for entity #3 (and #4, and #12…)](/start/second-state/banking-and-books.md)
- [Open bank accounts for your MSO and PCs](/guides/banking/open-bank-accounts.md)
- [Move money between PC and MSO (the right way)](/guides/banking/move-money-mso-pc.md)
- [Set up bookkeeping and consolidation](/guides/banking/set-up-bookkeeping.md)
- [Account structures for MSO-PC groups](/concepts/banking/account-structures.md)
- [Intercompany money movement](/concepts/banking/intercompany-money-movement.md)
- [Per-entity account & access checklist](/reference/banking/per-entity-account-checklist.md)