> ## 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.

# Arizona — CPOM & MSO reference

> Corporate practice of medicine status, professional entity forms, fee-splitting, noncompete law, and MSO-specific requirements in Arizona.

Arizona recognizes the corporate practice of medicine doctrine at a **moderate** level: lay ownership of the professional entity is restricted, and workable MSO-PC structures are well established.

<Note>
  **High-activity state.** Arizona sees substantial MSO-PC activity, which means both more precedent to work from and more scrutiny. Budget for state-specific counsel rather than adapting a template from elsewhere.
</Note>

<Note>
  **Checked August 2026.** Arizona's rules come from some combination of statute, licensing board regulation, attorney general opinions, and case law, and they change — check the [legislation tracker](/reference/legal/cpom-legislation-tracker) for pending changes.
</Note>

## 1. CPOM status — medicine

**Tier:** Moderate

Doctrine recognized through case law rather than a comprehensive statute. *Funk Jewelry Co. v. State ex rel. La Prade* and *State ex rel. Bd. of Optometry v. Sears* are the commonly cited authorities.

## 2. Other professions

The medical answer does **not** determine the answer for other professions. Each has its own doctrine, board, and statute.

| Profession                          | Where to check                                                                                                                                                   |
| ----------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------- |
| **Dentistry**                       | The state dental board and the dental practice act. Dentistry is frequently regulated more explicitly than medicine, and several states impose DSO registration. |
| **Optometry**                       | The optometry board. Retail-optical carve-outs are common and narrow.                                                                                            |
| **Physical therapy / chiropractic** | The respective boards. POPTS restrictions may apply.                                                                                                             |
| **Veterinary**                      | The veterinary board. CPVM exists in some states and not others, on a different map from medicine.                                                               |
| **Behavioral health**               | Multiple boards, one per license type. Whether one entity may employ several license types is the key question.                                                  |

See [Multi-specialty considerations](/concepts/entities/multi-specialty-considerations).

## 3. Professional entity forms

**Permitted forms:** PC

**Ownership:** Minority non-licensed ownership has been permitted under the professional corporation framework

Also confirm before filing:

* **Naming rules**, designator requirements, and whether the name is constrained to licensed owners' surnames
* **Board pre-approval**, whether a licensing board certificate is required *before* the secretary of state will file
* **Officer and director licensure**: several states restrict these roles to licensees, not just shareholders, which forecloses MSO executives serving on the PC's board

See [PC vs PLLC vs PA](/concepts/entities/pc-vs-pllc-vs-pa) and [Form a professional corporation](/guides/formation/form-a-pc).

## 4. Fee-splitting and percentage management fees

**Fee-splitting:** Permitted

The practical question for your MSA is whether a **percentage-of-collections** management fee is viable. Flat and cost-plus structures carry materially lower fee-splitting exposure everywhere. See [Fee-splitting rules](/concepts/model/fee-splitting) and [Set the management fee](/guides/agreements/set-the-management-fee).

## 5. Physician noncompetes

Enforceable subject to reasonableness limits — verify current law

Noncompete law moved substantially in 2025–2026. The FTC's Non-Compete Rule was vacated, the FTC dropped its appeals in September 2025, and the rule was removed from 16 C.F.R. pt. 910 effective February 12, 2026, leaving regulation primarily to the states, several of which have since restricted or voided physician noncompetes. **Verify current law in this state before including one.** See the [legislation tracker](/reference/legal/cpom-legislation-tracker).

## 6. MSO-specific laws and registration

None specific

## 7. Transaction review and notice

Check whether Arizona requires notice or approval for healthcare transactions, and whether MSO or private-equity ownership must be disclosed. A growing set of states added these regimes in 2025–2026 — see the [legislation tracker](/reference/legal/cpom-legislation-tracker) for the current list.

## 8. Practical structuring notes

Minority lay ownership does not usually solve the investor problem — a capped minority stake delivers neither control nor a clear path to economics, and CPOM's control prong operates independently of ownership percentage. Most groups still use the standard MSO-PC structure.

### The standing checklist for any state

* [ ] Confirmed the permitted entity form **for your profession**
* [ ] Confirmed whether board pre-approval is required before filing
* [ ] Confirmed whether officers and directors must be licensees
* [ ] Confirmed the fee structure is lawful here
* [ ] Clinical carve-out drafted against **this state's** current statutory language
* [ ] Transfer restriction agreement checked against current state law
* [ ] Noncompete provisions checked against current state law
* [ ] MSO foreign-qualified before it has employees here
* [ ] Any MSO registration or transaction notice obligation identified

## 9. Sources and where to verify

| What                                    | Where                                                                                     |
| --------------------------------------- | ----------------------------------------------------------------------------------------- |
| Professional entity statute             | Arizona code — professional corporation / professional LLC provisions                     |
| Medical practice act and board rules    | The Arizona medical board                                                                 |
| Dental, optometry, PT, veterinary rules | The respective Arizona boards                                                             |
| Attorney general opinions               | The Arizona Attorney General                                                              |
| Entity formation and good standing      | The Arizona Secretary of State                                                            |
| Pending legislation                     | The Arizona legislature's bill tracker                                                    |
| Unclaimed property                      | The Arizona unclaimed property administrator, via [unclaimed.org](https://unclaimed.org/) |

For the cases and statutes referenced above, see [CPOM case law](/reference/legal/cpom-case-law). For enacted and pending legislation across all states, see the [CPOM & MSO legislation tracker](/reference/legal/cpom-legislation-tracker).


## Related topics

- [The corporate practice of medicine doctrine](/concepts/model/cpom.md)
- [Fee-splitting rules, explained](/concepts/model/fee-splitting.md)
- [Who can own a professional entity](/concepts/entities/who-can-own-what.md)
- [Form a professional corporation](/guides/formation/form-a-pc.md)
- [Draft the management services agreement (MSA)](/guides/agreements/draft-a-management-services-agreement.md)
- [Run a CPOM self-audit](/guides/compliance/run-a-cpom-self-audit.md)
- [CPOM case law](/reference/legal/cpom-case-law.md)
- [CPOM & MSO legislation tracker](/reference/legal/cpom-legislation-tracker.md)
- [MSA clause anatomy](/reference/legal/msa-clause-anatomy.md)