Set up your compliance calendar

A compliance calendar is a single tracked list of every recurring obligation across both entities, every clinician, and every payer. Groups that don’t build one in the first 90 days discover it in year two, usually because a license lapsed, a CAQH attestation expired mid-credentialing, or a Medicare revalidation deadline passed and billing privileges were deactivated.

​

Why this is worse in an MSO-PC group

A single practice has one entity’s filings and a handful of clinician credentials. An MSO-PC group multiplies almost everything:

• Per entity: annual reports, franchise taxes, registered agent renewals, foreign qualifications, times (number of PCs + 1)
• Per clinician: license, DEA, board certification, malpractice, CAQH, times every clinician
• Per clinician per payer: recredentialing, times every payer
• Per entity per payer: revalidations and contract renewals

A five-state group with fifteen clinicians and eight payers is tracking several hundred dated obligations. A spreadsheet works until it doesn’t; credentialing software exists for exactly this reason.

​

The obligations

​

Corporate, per entity

Administrative dissolution of a PC is a revenue event, not a paperwork event. A dissolved entity’s payer contracts and billing privileges are at risk, and reinstatement plus payer notification can take months. Set the annual report reminder 60 days early.

​

Clinician credentials, per clinician

​

Payer, per clinician per payer, and per entity per payer

Medicare revalidation notices go to the address in PECOS. If nobody monitors that address, the first you’ll hear about it is when billing privileges are deactivated. Confirm the correspondence address in PECOS is one a human reads, and check your revalidation due date directly in the Medicare Revalidation Lookup Tool.

​

Ongoing monitoring, monthly

Monthly is the widely recommended cadence for exclusion screening. Document each check with a date and a screenshot or report — an undocumented check is one you cannot prove you did.

​

HIPAA and compliance program

See Build a minimum viable HIPAA program.

​

Structural review, the one nobody calendars

The 2025–2026 legislative wave — Oregon SB 951, California SB 351, Vermont Act 133, and transaction-review laws in a growing list of states — made this the highest-value recurring review on the list. Structures that were compliant when drafted are not automatically compliant now, and Oregon’s compliance deadline for pre-existing arrangements is January 1, 2029.¹

​

Build it in an hour

​

Template

Copy this structure:

​

You’ve finished the first 90 days

You have a billing rhythm, a denial process with a prevention loop, a refund process, a monthly close that reconciles three ways, and a calendar that will keep you out of the two most common self-inflicted crises in this industry: a lapsed credential and an out-of-date MSA.

​

Next

​

Sources

1. Or. S.B. 951 (2025 Reg. Sess.), with compliance for arrangements pre-dating June 9, 2025 required by January 1, 2029. Enrolled bill; Holland & Knight, An Update on the Implementation and Implications of Oregon’s New CPOM Laws (May 2026).