Building a healthcare clinic — a space where care meets community — is a dream for many forward-thinking entrepreneurs. You don’t have to wear a white coat to want to make a difference. But if you’re asking yourself, “Can I open a clinic without being a doctor in Texas?” you’re asking the right question.

Texas law protects the relationship between physicians and patients, setting clear rules about who can own and operate medical practices. Yet within those rules, there are ways that business leaders can contribute to healthcare in powerful, compliant ways.

Let’s explore what the Texas Medical Practice Act (Texas Occupations Code) and The Corporate Practice of Medicine doctrine mean for you — and how you might still achieve your vision of building a successful healthcare business.

Unpacking the Texas Corporate Practice of Medicine (CPOM)

At its core, CPOM Texas exists to protect patients by ensuring that medical decisions remain in the hands of qualified, licensed physicians. This separation guards against business interests overriding patient care — a principle deeply woven into the fabric of Texas healthcare law.

While this might initially suggest a hard “no” to a non-physician owning a medical practice, Texas law offers strategic pathways for non-physicians to contribute meaningfully, provided they adhere strictly to regulatory boundaries.

Why the Corporate Practice of Medicine Rules Exist in Texas

The strict structure of the Texas corporate practice of medicine doctrine isn’t just about maintaining legal formality. It’s also about safeguarding the heart of healthcare: the relationship between physicians and their patients.

The CPOM framework exists to ensure:

• Physician autonomy: Medical professionals must be free to make healthcare decisions based solely on what’s best for their patients, not influenced by business pressures or corporate targets.

• Ethical patient care: Treatment recommendations, diagnoses, and medical advice must be driven by clinical expertise, not financial incentives.

• Professional integrity: Protecting the independence of physicians helps preserve trust in the entire healthcare system.

Without CPOM protections, there would be a real risk that business interests could overshadow patient needs. Over time, that erosion of trust would undermine both patient outcomes and the credibility of the medical profession itself.

Texas enforces CPOM principles through the Texas Medical Practice Act and related laws to keep the focus exactly where it belongs: on delivering safe, ethical, patient-centered care.

Can a Non-Doctor Own a Medical Practice in Texas?

Direct ownership of a medical practice by a non-physician is generally prohibited. However, Texas law recognizes that healthcare is both a clinical service and a business. Non-physicians can still participate, but they must respect clear legal boundaries.

Two common legal structures under the Texas Medical Practices Act include:

1. Professional Associations (PAs)

A professional association allows licensed physicians to come together and form a corporate entity for their practice. Only those with medical licenses can own shares and control operations, keeping clinical decision-making firmly with healthcare providers.

2. Professional Limited Liability Companies (PLLCs)

A professional limited liability company offers physicians the benefits of liability protection while ensuring that ownership and clinical control stay within licensed hands.

Both structures align with the physician-owned practice model and ensure compliance with the Texas corporate practice of medicine principles. For a non-physician, directly forming or controlling a PA or PLLC that delivers medical care would violate Texas law.

Navigating the Narrow Exceptions to CPOM in Texas

While direct ownership by non-physicians is generally prohibited, Texas law provides few exceptions. Certain organizations — often government, nonprofit, or rural-based — may employ physicians directly while maintaining strict protections for clinical autonomy.

Eligible entities typically include:

• Nonprofit clinics and nonprofit medical practices

• Federally qualified health centers (FQHCs)

• Migrant health centers

• Accredited nonprofit medical schools

• Public school districts operating student health centers

• State-mandated institutions and public hospitals

• U.S. government and military healthcare facilities

• Hospital districts created by Texas statutes

• Rural health clinics (RHCs) certified under federal standards

• County-operated healthcare facilities in Texas counties with populations under 50,000

The employment relationship must not compromise the physician’s independent judgment, even in these exceptions. Operations may be managed administratively, but all medical care decisions must remain solely with licensed physicians.

How MSOs Open Opportunities for Non-Physician Entrepreneurs

For entrepreneurs and non-physicians who don’t qualify under these narrow exceptions, opportunity lies in partnering with physicians through the management services organization (MSO) model.

An MSO provides vital business and administrative support to medical practices without infringing on medical decisions. Services often include:

• Financial management (billing, collections)

• Human resources and staffing

• IT systems and cybersecurity

• Marketing strategy and patient engagement

• Facility management and maintenance

• Regulatory compliance support

In this model, non-physicians can own and operate the MSO, focusing on the business engine that keeps clinics running. Physicians maintain full control over medical judgment and patient care decisions.

Keys to a Successful MSO and Medical Practice Partnership

Careful planning and clean legal separation are crucial to building a compliant MSO-practice relationship. Key factors include:

• No meddling in medicine: Business services must be clearly separated from clinical care.

• Separate legal entities: The MSO and the medical practice must remain independent entities with robust service contracts.

• Fair market value: Payments must reflect actual service value to avoid any appearance of improper profit-sharing.

• Federal compliance: Practices serving Medicare or Medicaid patients must also comply with the federal Stark Law and Anti-Kickback Statute requirements.

Clear agreements, strong governance, and distinct operational roles help ensure your venture complies with healthcare laws.

Other Healthcare Ventures Non-Physicians Can Pursue in Texas

If launching a full medical clinic feels out of reach, consider adjacent healthcare opportunities. Non-physicians in Texas can own and operate businesses such as:

• Wellness centers

• Physical therapy facilities (with proper licenses)

• Non-invasive aesthetic centers (e.g., spas offering facials, massages, or nutrition services)

• Telehealth administrative platforms (partnered with licensed physicians)

When structured carefully, these models allow non-physicians to participate meaningfully in healthcare without crossing legal boundaries. While these businesses don’t provide direct medical services, they complement healthcare delivery and offer rewarding entrepreneurial opportunities.

However, a licensed physician must be involved anytime services blur into diagnosing, prescribing, or treating.

So, Can I Open a Medical Practice in Texas? A Roadmap

Starting a medical practice in Texas — whether you’re a physician or partnering as a non-physician entrepreneur — requires careful planning and strict compliance with healthcare laws. Here’s your roadmap to success:

• Choose the right legal structures: Physicians form a PA or PLLC; non-physicians create the MSO.

• Build the right team: Collaborate with trusted, qualified physicians aligned with your vision.

• Draft comprehensive contracts: Clearly define service agreements, responsibilities, and compensation terms while preserving physician autonomy.

• Navigate the regulatory landscape: Understand and comply with the Texas Medical Practice Act, CPOM, Stark Law, and Anti-Kickback Statutes.

• Secure all necessary licenses: Proper certifications protect your business and reputation.

• Plan for sustainable growth: Develop a business strategy that balances operational efficiency with patient-centered care.

The Risks of Missteps: Why Expert Legal Guidance Matters

Healthcare law is complex. Well-intentioned mistakes can have serious consequences. Even unintentional Texas Medical Practices Act violations can result in devastating consequences, including fines, license suspensions, or criminal charges.

Common pitfalls include:

• Perceived control over clinical decisions: Even small influences can lead to allegations of illegal CPOM violations.

• Improper financial arrangements: Profit-sharing structures that resemble illegal kickbacks.

• Sham entities: Setting up an MSO that looks compliant but controls clinical operations.

Partnering with experienced healthcare legal counsel is essential. The right advisors can help you create a structure that is compliant, ethical, and primed for long-term success.

Healthcare Entrepreneurship in Texas: Your Path Forward

Texas healthcare law is designed to protect patients and preserve the integrity of medical care, and rightfully so. But within those boundaries, there’s real room for innovation.

If you’ve been asking, “Can I open a clinic without being a doctor?” the answer is yes — with the right structure, partnerships, and a deep respect for the rules shaping this industry.

Whether you envision a telehealth startup, an urgent care clinic, or a new wellness center, your success starts with building on a foundation of compliance, ethics, and collaboration.

Ready to Build Your Future in Healthcare?

At 99MGMT, we specialize in helping entrepreneurs and physicians launch successful, compliant healthcare practices in Texas. Contact 99MGMT today to schedule a consultation and discover how we can help you launch a compliant, thriving healthcare business in Texas.