Ownership: Oregon has a strict corporate practice of medicine bar: medical practices must be majority-owned by Oregon-licensed physicians, and SB 951 (signed June 9, 2025) bars management services organizations and their insiders from owning or controlling the practice, bans the "friendly physician" model, and bars MSOs from controlling hiring, physician pay, schedules, coding, pricing and payer contracts.
Certificate of need: Oregon's CON program, run by the Oregon Health Authority, reviews hospitals, skilled nursing and intermediate care and long-term care facilities, new hospital services and certain bed increases.
Nurse practitioners: AANP classifies Oregon as full practice: NPs may evaluate, diagnose and prescribe under Board of Nursing licensure (O.R.S. 678.375) with no physician collaboration or transition-to-practice requirement listed.
Who can own a medical clinic in Oregon
Oregon has a strict corporate practice of medicine bar: medical practices must be majority-owned by Oregon-licensed physicians, and SB 951 (signed June 9, 2025) bars management services organizations and their insiders from owning or controlling the practice, bans the "friendly physician" model, and bars MSOs from controlling hiring, physician pay, schedules, coding, pricing and payer contracts. The MSO rules apply to new arrangements from January 1, 2026 and to existing ones from January 1, 2029, with exemptions for hospitals and hospital-owned clinics, PACE, some behavioral health programs and telemedicine entities with no Oregon physical presence.
Sources: sidley.com, reedsmith.com
Business entity and registration
Physicians usually form a professional corporation or other professional medical entity that is majority-owned and majority-governed by Oregon-licensed physicians, registered with the Oregon Secretary of State Corporation Division. Lay investors generally participate only through an MSO that now must comply with SB 951.
Sources: reedsmith.com, sos.oregon.gov
Certificate of need in Oregon
Oregon's CON program, run by the Oregon Health Authority, reviews hospitals, skilled nursing and intermediate care and long-term care facilities, new hospital services and certain bed increases. NCSL does not list ASCs or imaging as covered, so typical physician offices, ASCs and imaging centers do not need a CON.
Sources: ncsl.org, oregon.gov
Licenses, registrations and state agencies
The Oregon Health Authority licenses hospitals, ambulatory surgical centers, freestanding birthing centers, outpatient renal dialysis facilities and extended stay centers. Physician offices are excluded from the ASC definition unless they have a distinct area used for outpatient surgery on a regular and organized basis beyond office procedures under local anesthesia or conscious sedation, and an ASC may not treat patients without a state license. We found no state license for ordinary physician offices or urgent care clinics.
Sources: oregon.public.law, oregon.gov
Oregon-specific requirements to know
SB 951 also voids most noncompete agreements for physicians, NPs and PAs (with exceptions for owners) and limits nondisclosure and non-disparagement clauses, effective June 9, 2025. Mergers, acquisitions and similar deals involving health care entities that meet OHA criteria must be noticed to the Health Care Market Oversight program (ORS 415.500 et seq.). Practitioners must register with the Oregon Prescription Drug Monitoring Program (ORS 431A.877).
Sources: reedsmith.com, oregon.gov, oregon.public.law
Agencies you will deal with
- Medical board: Oregon Medical Board
- Board of nursing: Board of nursing
- Board of pharmacy: Board of pharmacy
- Business registration: Oregon Secretary of State Corporation Division
- Facility licensing: Oregon Health Authority, Health Care Regulation and Quality Improvement
- Medicaid enrollment: Oregon Health Plan (OHA)
Nurse practitioners and physician assistants
Nurse practitioners: AANP classifies Oregon as full practice: NPs may evaluate, diagnose and prescribe under Board of Nursing licensure (O.R.S. 678.375) with no physician collaboration or transition-to-practice requirement listed.
Sources: storage.aanp.org
Physician assistants: Oregon PAs (titled physician associates) practice under a written collaboration agreement signed with a physician or their employer, with a specified collaboration plan required until the PA has 2,000 post-graduate clinical hours; agreements are kept at the practice and not filed with the Oregon Medical Board.
Sources: oregon.gov
Med spas, injectables and IV therapy in Oregon
A med spa that provides medical treatment is subject to Oregon's CPOM rules, so it generally needs to be owned by Oregon-licensed physicians, with any lay investment through an MSO that complies with SB 951. The Board of Nursing's October 2024 IV hydration interpretive statement says only physicians, PAs, APRNs with prescriptive privilege and naturopathic physicians with a prescribing endorsement may prescribe IV products, patients cannot self-select an IV "cocktail" from a menu, and RNs and LPNs act only on a prescriber's order within their individual scope.
Sources: reedsmith.com, oregon.gov
Planning an aesthetic or IV business? See how to start a med spa and how to start an IV therapy business.
Step-by-step checklist in Oregon
- Choose your structure and check ownership rules. Decide who will own the practice and confirm it fits Oregon’s corporate practice of medicine rules. Oregon has a strict corporate practice of medicine bar: medical practices must be majority-owned by Oregon-licensed physicians, and SB 951 (signed June 9, 2025) bars management services organizations and their insiders from owning or controlling the practice, bans the "friendly physician" model, and bars MSOs from controlling hiring, physician pay, schedules, coding, pricing and payer contracts.
- Form the entity with the Oregon Secretary of State Corporation Division. Physicians usually form a professional corporation or other professional medical entity that is majority-owned and majority-governed by Oregon-licensed physicians, registered with the Oregon Secretary of State Corporation Division.
- Get federal numbers. Apply for an EIN from the IRS, then a Type 2 NPI for the practice and Type 1 NPIs for each clinician through NPPES.
- Confirm licenses with the Oregon Medical Board. Every physician needs a Oregon license. Check the board’s rules for any practice registrations, supervision agreements or office requirements before opening.
- Check certificate of need and facility licensing. Oregon's CON program, run by the Oregon Health Authority, reviews hospitals, skilled nursing and intermediate care and long-term care facilities, new hospital services and certain bed increases.
- Register to prescribe. Register with the DEA for controlled substances and complete any Oregon controlled substance registration and prescription monitoring program enrollment. SB 951 also voids most noncompete agreements for physicians, NPs and PAs (with exceptions for owners) and limits nondisclosure and non-disparagement clauses, effective June 9, 2025.
- Set up lab, safety and privacy basics. Get a CLIA certificate if you will run any lab tests, including waived tests, and put HIPAA privacy and security and OSHA policies in place.
- Enroll with Medicare, Medicaid and insurers. Enroll in Medicare through PECOS, enroll with Oregon Health Plan (OHA) and start commercial credentialing early, because payer enrollment often takes months.
- Plan staffing around NP and PA rules. AANP classifies Oregon as full practice: NPs may evaluate, diagnose and prescribe under Board of Nursing licensure (O.R.S. 678.375) with no physician collaboration or transition-to-practice requirement listed.
- Launch your marketing before opening day. Claim your Google Business Profile, publish a website with online booking and start ads and content four to eight weeks before you open, so the schedule is not empty on day one.
The national steps are explained in more detail in our guide to how to start a medical clinic, and costs are broken down in how much it costs to start a clinic.
Marketing a new clinic in Oregon
New clinics usually fail on cash flow before they fail on care. The fastest fix is patients booked before opening day: a complete Google Business Profile, a website with online booking, local search ads and a few weeks of social content showing the team and the space. We run that launch for new clinics and keep it going once the doors open.
Plan your Oregon launch with us →
Sources
- https://www.sidley.com/en/insights/newsupdates/2025/06/oregon-revises-corporate-practice-of-medicine-law
- https://www.reedsmith.com/articles/oregon-enacts-strict-new-corporate/
- https://sos.oregon.gov/business/Pages/default.aspx
- https://www.ncsl.org/health/certificate-of-need-state-laws
- https://www.oregon.gov/OHA/PH/ProviderPartnerResources/HealthcareProvidersFacilities/HealthcareHealthCareRegulationQualityImprovement/Pages/index.aspx
- https://storage.aanp.org/www/documents/no-index/state-fact-sheets/oregon.pdf
- https://www.oregon.gov/omb/Licensing/Pages/SP-PA-Collaborative-Practice.aspx
- https://oregon.public.law/statutes/ors_442.015
- https://www.oregon.gov/oha/PH/PROVIDERPARTNERRESOURCES/HEALTHCAREPROVIDERSFACILITIES/HEALTHCAREHEALTHCAREREGULATIONQUALITYIMPROVEMENT/Documents/ASCInitialLicensureAndCertificationGuidance.pdf
- https://www.oregon.gov/osbn/Documents/IS_IVHydrationTherapy.pdf
- https://www.oregon.gov/oha/HPA/HP/Pages/health-care-market-oversight.aspx
- https://oregon.public.law/statutes/ors_431A.877