Step 7: Open bank accounts

Your professional entity needs its own bank account that the PC controls, because payer money must land there. Your MSO needs its own. They must never be the same account, and the PC’s account must not be one the MSO can unilaterally sweep. This is a compliance requirement as much as a banking task.

​

What Meridian did

Alex opened two accounts: Meridian Dermatology (Priya Shah, M.D., P.C.), Operating, with Dr. Shah as the sole signer and Alex holding view-only access, and Meridian Health Partners, LLC, Operating, with Alex as signer. Each application took about ten days because both entities were newly formed.

​

Why the PC account is a compliance matter

Three separate rules converge on this account:

1. CPOM. The PC earns the professional fees. If payer revenue lands in an MSO account, a regulator can argue that the lay entity is collecting for the practice of medicine. Control of the receipts is one of the indicia regulators examine.
2. Payer contracts and Medicare rules. Payers pay the entity they contracted with, at the Tax ID they enrolled. Medicare’s reassignment and payment rules require payment to be made to the provider or supplier, which constrains how receivables can be assigned or directed, a constraint that also shapes how lenders structure facilities against healthcare AR. See Working capital and lending against healthcare AR.
3. Basic corporate separateness. Commingled funds invite veil-piercing arguments and produce diligence findings that reduce your valuation.

​

The minimum account map

For a single-PC launch, open these: As you grow, this expands considerably: per-PC accounts, refund clearing accounts, per-location structures. See Structure accounts across your entities and Account structures for MSO-PC groups.

​

What the bank will ask for

How much you assemble depends entirely on where you apply.

​

At Lemma

The entity is verified from tax and state registration data, so the application is three groups of fields, the same for the PC and the MSO:

• Business profile: legal name, EIN, state of incorporation
• Control person: name, title, date of birth, address, email, phone — for the PC, the clinician-officer
• Beneficial owners: everyone at or above 25%

That is about 5 minutes per entity, and most are approved within hours. Government ID is requested only when the tax ID alone doesn’t verify, which is more likely for an entity formed two weeks ago. Nobody requires the MSA to open an account, but it is worth sending: Lemma configures the accounts against the funds flow the agreement describes, so the money moves the way the paperwork says it does. A generalist bank that asks for the MSA generally just files it.

​

At a brick-and-mortar bank

Everything above, plus a document packet per entity. For the PC: filed articles of incorporation (state-stamped), the EIN confirmation letter (CP 575), bylaws and the organizational consent authorizing accounts and naming signers, a stock certificate or ownership schedule showing the licensed shareholder, the clinician’s professional license, government ID for every signer and beneficial owner, and a DBA certificate if you operate under a brand. For the MSO: certificate of formation and operating agreement, EIN confirmation letter, beneficial ownership information, and a foreign qualification certificate in the operating state. See KYB/KYC document checklist for both lists in full.

​

Who signs

The PC’s signer must be the PC’s officer, in practice, the clinician-owner. This is the part founders find uncomfortable: the person controlling the account holding all the revenue is not the person running the business. Handle it with structure rather than workarounds:

• The clinician-owner is the signer on the PC account.
• Operations staff get view-only access for reconciliation.
• The MSA authorizes the MSO to provide billing and financial administration services, including preparing payments for approval.
• The monthly management fee moves on an invoice, not a standing sweep the MSO controls unilaterally.

An MSO with unilateral withdrawal authority over the PC’s operating account is a CPOM self-audit finding. See Move money between PC and MSO.

​

In-person vs online

Professional entities often trip a generalist bank’s online account opening flow: the automated KYB can’t verify a two-week-old PC with a licensed owner and a d/b/a. Expect either a manual review or a branch visit, and budget one to three weeks per entity. On a platform that verifies the entity from registration data, the same application takes about 5 minutes and clears the same day. Either way, start this in parallel with Step 6 rather than after it. There is also a structural problem at scale: a generalist bank gives you one login per legal entity. With one PC that is a minor annoyance; with ten it becomes a real operational burden, with dozens of logins, per-entity statements, and no cross-entity view. Open bank accounts for your MSO and PCs covers that problem and the options, including healthcare-focused platforms built around it.

​

Your artifact from this step

• PC operating account, open, with the clinician as signer
• MSO operating account, open
• Account and routing numbers recorded for Step 8’s EFT enrollments
• View-only access provisioned for bookkeeping
• A written note of which account each payer’s EFT will target

​

Checklist

• PC operating account open, signer is the PC’s licensed officer
• MSO operating account open
• No shared account between the entities
• Bookkeeper has read-only access to both
• Beneficial ownership questionnaires answered accurately
• Account numbers documented for payer EFT enrollment
• Confirmed no standing MSO sweep authority over the PC account

​

Next