High-activity state. Oregon 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.
Checked August 2026. Oregon’s rules come from some combination of statute, licensing board regulation, attorney general opinions, and case law, and they change — check the legislation tracker for pending changes.
1. CPOM status — medicine
Tier: Strict — the strictest MSO statute in the country Doctrine now substantially governed by S.B. 951 and H.B. 3410 (2025), amending ORS 58.375 and 58.376 and adding ORS 676.555.2. Other professions
The medical answer does not determine the answer for other professions. Each has its own doctrine, board, and statute.
See Multi-specialty considerations.
3. Professional entity forms
Permitted forms: PC / professional medical entity Ownership: Physician majority required. MSO or MSO-agent majority ownership or control is barred. Overlapping ownership by shareholders of professional medical entities is restricted. 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
4. Fee-splitting and percentage management fees
Fee-splitting: Permitted, but read alongside the control prohibitions 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 and Set the management fee.5. Physician noncompetes
S.B. 951 voids most physician noncompetes 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.6. MSO-specific laws and registration
S.B. 951 is the most restrictive MSO law in the US. It reaches MSO control over scheduling, clinician compensation, coding, billing, and payer contract terms, and restricts share-transfer arrangements. Carve-outs include dental, physical therapy/occupational therapy, veterinary, and certain behavioral health.7. Transaction review and notice
Check whether Oregon 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 for the current list.8. Practical structuring notes
The compliance deadlines are the thing to internalize: January 1, 2026 for arrangements formed on or after June 9, 2025, and January 1, 2029 for pre-existing arrangements. That second date is a restructuring project, not a document review — and it will involve share transfers, MSA renegotiation, and payer notification. Note also that the share-transfer restriction is the provision that most directly attacks the standard friendly-PC toolkit.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
For the cases and statutes referenced above, see CPOM case law. For enacted and pending legislation across all states, see the CPOM & MSO legislation tracker.