The arrangement is familiar everywhere: a physician is paid a monthly fee, told they need not attend, and the business runs on the strength of their name.
Most states leave you to infer that this is a problem, from a doctrine, a position statement, or a case. Kansas wrote it down. Under KSA 65-2837(b)(15), a licensee may not allow another person or entity to use the licensee’s licence to practise — a named ground for discipline.
Read it as the physician
That subsection is not aimed at the business. It is aimed at the licence holder, and it sits in the list of things that cost people their licence.
It also reframes the sales conversation. When a vendor says the role is “light touch” and “you will not need to be involved”, they are describing the elements of (b)(15) as though they were benefits.
What use by the physician actually looks like
- The physician sets or approves the protocols, rather than receiving them.
- The physician can describe the service menu from memory.
- Delegation decisions are theirs, and they can say who is qualified for what and why.
- Chart review happens on a schedule they control and can evidence.
- They can decline something — a service, a product, a patient — and that decision holds.
If none of those are true, whose licence is being used?
The entity rule points the same way
Kansas prohibits general business entities from engaging in learned professions such as medicine, whether by employing or contracting with physicians. The exception is a professional corporation or limited liability company wholly owned by licensed professionals — and in Kansas those entities carry the “PA” designation rather than “PC”.
Employing or contracting with is worth noting. Restructuring an employment relationship as a services contract does not move it outside the prohibition.
Delegation has its own provision
KSA 65-28,127 governs licensees who direct, supervise, order, refer, accept responsibility for, enter into practice protocols with, or delegate acts constituting the practice of the healing arts. That list is the vocabulary of a real clinical relationship, and it is the standard the arrangement will be measured against.
Where to start
The Kansas Board of Healing Arts publishes its own guidance on corporations. Read it before forming anything, and before a physician signs. It is short, it is authoritative, and it costs nothing.
Related reading
Frequently asked questions
What does KSA 65-2837(b)(15) prohibit?
A licensee allowing another person or entity to use the licensee’s licence to practise. It is a ground for discipline against the physician.
Can a business entity contract with a physician in Kansas?
Kansas prohibits general business entities from engaging in medicine by employing or contracting with physicians, unless the entity is a professional corporation or LLC wholly owned by licensed professionals.
What governs delegation?
KSA 65-28,127, covering licensees who direct, supervise, order, refer, accept responsibility for, enter protocols with, or delegate healing arts acts.
Where is the board’s guidance?
The Kansas Board of Healing Arts publishes guidance on corporations through its general counsel resources.
General information about Kansas practice structure, not legal advice. Confirm your obligations with healthcare counsel licensed in Kansas.