Phase 1, before the entity exists
- Entity name decided, satisfying professional entity naming rules
- Naming convention confirmed for accounts:
[Brand] [State] PC, [Purpose] - Chart of accounts template ready (identical to every other PC)
- Registered agent arranged
- Friendly owner vetted: license verified, OIG LEIE and SAM.gov clear, documented
Phase 2, formation
- Formation documents filed and state-stamped
- Board pre-approval obtained, if the state requires it
- Bylaws or operating agreement adopted
- Organizational consents adopted, naming account signers
- Shares or membership interests issued, with restrictive legend
- Transfer restriction agreement executed
- EIN obtained; CP 575 legal name recorded exactly as printed
- State tax and employer registrations complete
- MSO foreign-qualified in this state, if new
Phase 3, identifiers
- Type 2 NPI obtained, with the NPPES legal name matching the CP 575 exactly
- Group taxonomy selected and recorded
- Each clinician’s Type 1 NPI confirmed (no duplicates created)
- CAQH profiles updated with this location and re-attested
- W-9 prepared with the exact CP 575 legal name
Phase 4, banking
- Operating account opened, in the PC’s name
- Signer is the PC’s licensed officer, not an MSO executive
- No MSO withdrawal authority: no standing sweep, no ACH debit authorization, no MSO signer
- Read-only access provisioned: bookkeeper, controller, reconciler
- Naming convention applied
- Beneficial ownership answered accurately (clinician, 100%)
- Routing and account numbers recorded for EFT enrollment
- ACH addenda visibility confirmed, you need the TRN to reconcile
- Payroll account opened, if segregating
- Refund/disbursement account opened, if applicable
- Check stock ordered, drawn on this PC’s account, with this PC’s signer
- Payment card issued for this entity, labeled
Phase 5, payer enrollment
Per payer:- Group contract executed by the PC’s officer; effective date recorded
- Fee schedule obtained and reviewed before signing
- Timely filing limit and appeal deadline recorded
- Each clinician credentialed and linked; provider effective dates recorded
- Retro-effective dates requested in writing
- EDI enrollment approved (not merely submitted)
- ERA enrollment pointing at your current clearinghouse
- EFT enrollment pointing at this PC’s operating account
- Any VCC-paying payer converted to EFT
- Test claim submitted and accepted at 277CA
- First 835 received and posted
- First EFT confirmed in the correct account, reassociating by TRN
- Medicare: CMS-855B, 855I per clinician, 855R reassignment, CMS-588 EFT; PTANs recorded
- Medicaid: state agency enrollment and every MCO in the service area
Phase 6, billing stack
- Entity configured in the EHR/PM with its own Tax ID and group NPI
- Separate submitter configuration at the clearinghouse, so claims cannot go out under another entity’s Tax ID
- Fee schedules loaded for underpayment detection
- Scrubber edits configured, including the auth-required edit
- ERA auto-posting configured, with group code mapping tested against a real 835
Phase 7, accounting
- General ledger created from the identical chart of accounts template
- Intercompany account pairs created on both sides:
- Management fee expense (PC) ↔ revenue (MSO)
- Loan payable (PC) ↔ receivable (MSO)
- Interest expense (PC) ↔ income (MSO)
- Added to the consolidation model with eliminations
- Added to the monthly close checklist
- Management fee invoice template configured for this entity
- Uncashed-check ledger started
Phase 8, agreements
- MSA executed, drafted for this state’s current law
- Transfer restriction agreement executed
- BAA executed (this PC ↔ MSO, a separate one per PC)
- IP/brand license extended to this entity
- Clinician employment agreements executed, with state-appropriate restrictive covenants
- Board and member consents adopted by both entities
Phase 9, compliance calendar
- State annual report due date, with 60-day lead
- Franchise tax due date, with 30-day lead
- Registered agent renewal
- Owner’s license renewal and DEA, with 60-day lead
- CAQH re-attestation, with 14-day lead
- Malpractice renewal, with 60-day lead
- Medicare revalidation, with 90-day lead
- Medicaid revalidation
- Payer recredentialing dates
- Monthly OIG LEIE and SAM.gov screening
- Annual MSA review
- Annual CPOM self-audit
Phase 10, verify before go-live
- Entity active and in good standing
- Legal name identical across CP 575, W-9, NPPES, bank, and every payer
- PC signer is the PC’s officer; no MSO withdrawal authority anywhere
- Every EFT enrollment points at this PC’s account
- Every ERA enrollment points at your current clearinghouse
- Test claim accepted; test remittance posted; test deposit reconciled by TRN
- Entity added to the close checklist, consolidation model, and compliance calendar
- Per-entity setup runbook updated with anything learned