> ## 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.

# Per-entity account & access checklist

> The repeatable setup runbook for every new PC: accounts, EFT enrollments, signers, bookkeeper access, invoicing, statements, and check stock.

The runbook to execute for every new professional entity. Follow it identically each time so entity twelve takes as long as entity two.

## 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

Plus:

* [ ] 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

## The four that break everything

<Warning>
  If you check nothing else:

  1. **Legal name identical everywhere**, one mismatch means enrollment rejections across every payer
  2. **EFT to the PC's account, never the MSO's**, a CPOM problem plus weeks of re-enrollment per payer
  3. **ERA pointing at your current clearinghouse**, otherwise you get money you cannot post
  4. **No MSO withdrawal authority over the PC's account**, a control finding regardless of whether the transfers are legitimate
</Warning>


## Related topics

- [Banking and books for entity #3 (and #4, and #12…)](/start/second-state/banking-and-books.md)
- [Form the second-state PC](/start/second-state/new-pc-formation.md)
- [Open bank accounts for your MSO and PCs](/guides/banking/open-bank-accounts.md)
- [Structure accounts across your entities](/guides/banking/structure-accounts-across-entities.md)
- [Set up EDI, ERA, and EFT with each payer](/guides/enrollment/set-up-edi-era-eft.md)
- [KYB/KYC document checklist for account opening](/reference/banking/kyb-document-checklist.md)
- [The complete agreement stack (checklist)](/reference/legal/agreement-stack-checklist.md)
