Oregon SB 951, signed June 9, 2025, bars a management services organization from owning or controlling a majority of a practice it manages, limits dual governance roles, bars MSO control of hiring, pay, clinical policy, pricing and coding, and curbs noncompetes. It applies to new arrangements from 2026 and existing ones from January 1, 2029.
Oregon's SB 951, signed by Governor Tina Kotek on June 9, 2025 and amended by HB 3410 the following month, bars a management services organization (MSO) and its affiliates from owning or controlling a majority of a professional medical entity it manages, limits MSO owners and staff from serving in governance roles at that practice, and bars MSOs from controlling a list of clinical and business decisions. Law-firm summaries describe the restrictions as applying to new arrangements from January 1, 2026, with existing arrangements given until January 1, 2029. A telehealth company with Oregon patients needs counsel to decide whether its structure is covered or exempt.
The descriptions below come from the published summaries of McGuireWoods, Epstein Becker Green, McDermott Will & Emery and Venable. They are a starting point for your lawyer, not a substitute for reading the enrolled bill.
What does SB 951 prohibit?
- Ownership. An MSO, alone or with affiliates, may not own or control a majority of the shares of a professional medical entity with which it has a management services contract.
- Dual roles. MSO-affiliated individuals are restricted from serving as directors or officers of the managed practice, and from similar governance roles, with limited exceptions.
- De facto control. MSOs may not exercise control over listed decisions, which the summaries describe as including clinician hiring and termination, compensation, scheduling, clinical policies, setting prices for medical services, and coding decisions.
- Restrictive covenants. Noncompetition agreements with medical professionals are largely unenforceable, with exceptions such as for clinicians who own more than 10 percent of the practice, and nondisclosure and nondisparagement agreements between medical professionals and MSOs, hospitals or hospital-affiliated clinics are restricted except in limited cases such as negotiated settlements.
Which services may an MSO still provide?
According to McGuireWoods' summary, MSOs may still provide services such as payroll, human resources, employment screening, purchasing, accounting, budgeting, personnel management, real estate management, and assistance with payer negotiations. The line is between supporting the practice and deciding for it.
When does it apply?
- Restrictive covenant provisions: to contracts entered after the law took effect.
- Ownership and control provisions: from January 1, 2026 for newly formed arrangements, according to the summaries, with some firms also describing ownership transfers after enactment as covered.
- Existing arrangements: by January 1, 2029.
Why does the timing matter so much?
Because an existing arrangement that is restructured, recapitalized or sold may be treated as new. Firms differ slightly in how they describe which arrangements count as new. That is one of the first questions for counsel if your Oregon structure was formed or changed in 2025 or 2026. A company that assumes it has until 2029 and then closes a financing round in 2027 may find the earlier date applies to it. Before any transaction, ask counsel whether the deal itself starts the clock.
Is there an exemption for telehealth?
There is a narrow one. Venable's summary describes an exemption for "telemedicine practices without a physical location where patients receive clinical services in Oregon," and McDermott describes a limited carve-out for practices providing solely telemedicine services that allows dual employment of physicians by the MSO and the practice. A company that offers any in-person care in Oregon, or plans to, should assume the exemption may not fit. The other exemptions listed in the summaries include hospitals, long-term care and residential care facilities, PACE organizations, certain behavioral health entities, and some tribal and urban Indian health programs.
Who can enforce it?
Epstein Becker Green's summary describes a private right of action in Oregon circuit court for damages, injunctions or other equitable relief. Summaries differ on the role of state agencies, so ask counsel how enforcement would reach your arrangement.
Steps for a telehealth company with Oregon patients
- Confirm whether you have, or plan, any physical location in Oregon where patients receive care.
- Map who decides each item on the SB 951 list today: hiring, pay, schedules, clinical policies, pricing, coding.
- Check whether any MSO owner, officer or employee also serves as an officer or director of the practice.
- Pull every noncompete, nondisclosure and nondisparagement agreement with Oregon clinicians.
- Note any planned change of control. Oregon also requires notice to the Oregon Health Authority at least 180 days before closing covered health care transactions (ORS 415.501).
- Put January 1, 2029 on the compliance calendar if you rely on the existing-arrangement date.
Background on the model itself is in the friendly PC and MSO model and corporate practice of medicine and telehealth. Oregon's telehealth rules are summarized on our Oregon page.
Our Counsel-Ready Structure Packet ($950) organizes these facts for your lawyer. See pricing.
Common questions
- When does Oregon SB 951 take effect?
- According to law-firm summaries, its ownership and control restrictions apply to new arrangements from January 1, 2026 and to arrangements that existed before then from January 1, 2029. Restrictive covenant provisions apply to contracts entered after the law took effect.
- Does Oregon SB 951 apply to telehealth companies?
- It can. Summaries describe a narrow exemption for telemedicine practices without a physical location in Oregon where patients receive clinical services. A company with any in-person care in Oregon should have counsel review whether the exemption fits.
- What can an MSO still do under SB 951?
- Administrative support such as payroll, human resources, employment screening, purchasing, accounting, budgeting, real estate management and help with payer negotiations, according to McGuireWoods' summary. It may not control clinical and key business decisions of the practice.
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