Utah Healthcare Compliance: Entity Management Requirements

Introduction

If you're establishing a healthcare practice in Utah, you're navigating a relatively flexible regulatory environment—at least compared to states with strict Corporate Practice of Medicine restrictions. But "flexible" doesn't mean simple. You'll need to coordinate corporate filings with the Division of Corporations, secure professional licensing board approvals through DOPL, and maintain ongoing compliance across multiple state agencies.

Utah allows you to structure your medical practice as a Professional Corporation (PC), Professional Limited Liability Company (PLLC), or Limited Liability Partnership (LLP). The catch? All three require single-discipline ownership. Every shareholder, member, or partner must hold the same professional license, and you can only provide one specific type of professional service.

Formation costs start at $59-$81 depending on your entity type and processing speed, with annual renewals at $18. You'll also face biennial continuing medical education requirements of 40 hours for physicians and specialized medical record reporting if you contract with outside companies for record services.

Professional Entity Types for Utah Healthcare Organizations

Universal Ownership Rule: Regardless of which entity type you choose, all owners must be licensed professionals in the same discipline. A PC organized for medical practice cannot include dentists, chiropractors, or other healthcare professionals as owners unless they hold the same medical license.

Professional Corporations (PCs)

Professional Corporations represent the traditional structure for medical practice entities in Utah. When you file your Articles of Incorporation under Utah Code § 16-11-4, you'll need to specify the profession you'll practice, provide names and addresses of all shareholders, directors, and officers, and designate your registered agent.

The single-service limitation under Utah Code § 16-11-6 means your PC can only provide one specific type of professional service and related ancillary services. Utah Code § 16-11-9 reinforces this by requiring that your corporation only render professional services through licensed individuals.

Your entity name must include either "professional corporation" or "P.C." according to Utah Code § 16-11-16, and you're explicitly prohibited from using "incorporated" or "inc."

Professional Limited Liability Companies (PLLCs)

PLLCs offer similar liability protection with more flexible management arrangements than traditional corporate board structures. Your Certificate of Organization under Utah Code § 48-3a-1104 must include your company name (containing "professional limited liability company" or "PLLC"), principal office address, the specific professional service you'll provide, registered agent information, and names and addresses of members or managers.

Like PCs, you'll face the single-service limitation under Utah Code § 48-3a-1106. Utah Code § 48-3a-1101(2) explicitly includes medical and healthcare professions in the definition of "professional services," confirming this structure works for medical practices.

Limited Liability Partnerships (LLPs)

LLPs work particularly well for physician group practices. You'll file a Statement of Qualification under Utah Code § 48-1d-1101 with the Utah Division of Corporations, including your partnership name, principal office, and LLP designation. Your name must include "Registered Limited Liability Partnership," "Limited Liability Partnership," or approved abbreviations under Utah Code § 48-1d-1105.

Professional Services LLPs face the same restrictions as PCs and PLLCs. Utah Code § 48-1d-1305 imposes the single-service restriction, while Utah Code § 48-1d-1308 requires all partners to hold appropriate licenses.

Corporate Practice of Medicine Doctrine in Utah

Utah doesn't enforce a strict Corporate Practice of Medicine doctrine with explicit statutory prohibitions against corporate involvement in medical practice. Utah Code § 58-67-802 permits you to practice medicine through individual proprietorships, partnerships with other licensed physicians, professional corporations, or limited liability companies formed by licensed physicians.

According to healthcare compliance practitioners, Management Service Organizations (MSOs) are commonly used in Utah to allow non-physician investment in medical practice business operations. Under this structure, a non-physician entity provides administrative and business management services to your physician-owned professional corporation through a management services agreement, while you retain all clinical control and decision-making authority.

Fee-splitting arrangements for professional services not actually and personally rendered or supervised remain prohibited, and you must maintain control over all clinical decisions regardless of your employment structure.

Utah Healthcare Entity Formation Requirements

You'll need to complete both corporate formation with the Division of Corporations and professional licensing approvals through the Division of Occupational and Professional Licensing (DOPL). Here's what you'll pay: 

Formation Step Cost Processing Time Required/Optional
Name Reservation $22.00 120 days validity Optional
Articles of Incorporation (PC) $59.00 7-10 business days (Mail) / Instant (Online) Required
Certificate of Organization (PLLC) $59.00 7-10 business days (Mail) / Instant (Online) Required
Expedited Processing $75.00 1-2 business days (for Mail/Fax) Optional
Registered Agent $0 - $200+ Immediate Required
Annual Report (Renewal) $18.00 Due on anniversary date Required
Individual Professional Licenses $150-$210+ Varies by board (DOPL) Required

Submit your formation documents to: STATE OF UTAH, DIVISION OF CORPORATIONS & COMMERCIAL CODE, 160 East 300 South, Main Floor, Salt Lake City, UT 84114-6705. The Utah Division of Corporations strongly recommends consulting legal counsel for entity type selection and transaction guidance.

Ongoing Compliance Requirements

Annual Report Requirements

You must file annual reports during your entity's anniversary month. According to the Utah Division of Corporations, file online through the Utah business registration portal using a UtahID account. The filing fee is $18.00, with a $10.00 late fee if you miss your deadline. Contact the Division of Corporations at (801) 530-4849 to confirm your specific due date within your anniversary month.

Tax Obligations

Your tax obligations depend on your entity structure. Most healthcare professional entities structured as PLLCs are pass-through entities, with income passing through to your individual returns. If you've structured your entity as a C corporation, you'll face corporate-level tax obligations at the 4.5% rate for tax year 2025, filing Form TC-20 with the Utah State Tax Commission.

Healthcare-Specific Compliance Requirements

If you contract with outside companies for medical record requests, you'll need to file an additional annual report with the Utah Division of Professional Licensing, separate from your Division of Corporations filing.

Recent Legislative Changes

Three bills require your compliance review with differing effective dates: HB0251 (2023) amending court-related provisions and SB0180 (2023) modifying Utah Postsecondary Proprietary School requirements both have May 7, 2025 effective dates requiring near-term review. SB0041 (2024) Business Entity Technical Amendments became effective May 1, 2024.

The 2025 legislative session introduced targeted healthcare legislation: 1st Substitute S.B. 1010 creates tax credit certificates specifically for psychiatrists and psychiatric mental health nurse practitioners, affecting how eligible mental health professional entities claim and report annual tax credits. 2nd Substitute S.B. 256 modifies funding flows to rural healthcare entities, potentially affecting financial reporting requirements for practices operating in rural areas. Verify current passage status and effective dates before implementing compliance measures related to these legislative changes.

Professional Licensing Coordination

Division of Professional Licensing

The Division of Professional Licensing (DOPL) under the Utah Department of Commerce serves as your regulatory body for physician licensing. Reach DOPL at the Heber M. Wells Building, 160 East 300 South, P.O. Box 146741, Salt Lake City, UT 84114-6741, by phone at (801) 530-6628 or toll-free at (866) 275-3675, or online at dopl.utah.gov.

Continuing Medical Education Requirements

You must complete 40 hours of continuing medical education every two years for license renewal. At least 34 hours must be ACCME Category 1 CME credits, with up to 6 hours from other DOPL-approved continuing education. You can earn up to 15% of required hours (6 hours) through volunteer healthcare services at qualified locations, with 1 hour of credit per 4 hours of volunteer work.

If you prescribe controlled substances, you'll need at least 3.5 hours of continuing education in controlled substance prescribing every licensing period, as mandated by Utah Code 58-37-6.5. You must also complete at least one approved online suicide prevention training (valued at 0.5 credit each).

The Utah Medical Association is recognized by the Accreditation Council for Continuing Medical Education (ACCME) as the accrediting body for CME providers in Utah. Utah operates on a two-year renewal cycle for physician licenses, with continuing education requirements adjusted proportionately based on your initial licensure date within the renewal cycle.

License Renewal and Entity Ownership Impact

Utah law creates a direct statutory link between your physician licensure status and healthcare entity ownership eligibility. Utah Code § 53-2d-515 requires licensed healthcare providers whose ownership or controlling interest changes to submit information to the bureau establishing whether new owners meet licensure requirements. This means maintaining active, compliant physician licensure is essential for your ownership eligibility in healthcare entities practicing medicine.

Multi-Profession Entity Considerations

Utah law explicitly prohibits multi-discipline ownership of healthcare professional entities through its single-discipline requirement. Both Professional Corporations under Utah Code § 16-11-6 and Professional Limited Liability Companies under Utah Code § 48-3a-1106 may provide only one specific type of professional service. All owners must be licensed professionals in the same field, meaning your PC organized for medical practice cannot include dentists, chiropractors, psychologists, or any other healthcare professionals as owners unless they hold the same medical license.

FAQs about Utah Healthcare Entity Compliance

Can non-physicians own medical practices in Utah?

Utah doesn't enforce a strict Corporate Practice of Medicine doctrine prohibiting corporations from employing physicians or participating in medical practice operations. Instead, Utah regulates physician practice through licensure requirements and professional corporation ownership rules. You can structure your practice as a Professional Corporation (PC), Professional Limited Liability Company (PLLC), or Limited Liability Partnership (LLP), all of which must be owned and controlled by licensed physicians to provide medical services. Under Management Service Organization (MSO) arrangements, a non-physician entity may provide administrative and business management services to your physician-owned professional corporation through a management services agreement, while you retain all clinical control and decision-making authority. Hospital employment is also permitted through appropriate corporate structures, provided you maintain clinical autonomy over all medical decisions.

What happens if a physician's license lapses while they own part of a healthcare entity?

Utah Code § 16-11-13 establishes mandatory purchase or redemption procedures for disqualified shareholders. When a shareholder loses licensure or otherwise becomes disqualified from ownership, your Professional Corporation must purchase or redeem that shareholder's interest. Additionally, Utah Code § 53-2d-515 requires healthcare providers whose ownership or controlling interest changes to submit information to the bureau establishing whether new owners meet licensure requirements. Your entity must ensure all owners maintain active, compliant licensure to preserve legal status.

Are annual reports required for Utah healthcare entities?

Yes. You must file annual reports during your entity's anniversary month of formation at a cost of $18.00, with a $10.00 late fee if you file after the deadline according to the Utah Division of Corporations Fee Schedule. File online through the Utah business registration portal using a UtahID account. If you contract with outside companies for medical record requests, you'll face an additional annual reporting requirement with the Utah Division of Professional Licensing, separate from your Division of Corporations filing.

What is the difference between a Professional Corporation and a Professional LLC in Utah?

Both entity types face the same single-discipline restriction and professional ownership requirements. The primary differences relate to governance structure and formation documents. You'll file Articles of Incorporation under Utah Code § 16-11-4 for Professional Corporations and must include "professional corporation" or "P.C." in your name, with explicit prohibition against using "incorporated" or "inc." For Professional LLCs, you'll file a Certificate of Organization under Utah Code § 48-3a-1104 and must include "professional limited liability company," "P.L.L.C.," or "PLLC" in your name. Both structures cost $59.00 to form and $18.00 annually to maintain. Your choice between structures typically depends on desired management flexibility, with PLLCs offering more flexible management arrangements than the traditional corporate board structure of PCs.

Can physicians from different medical specialties practice together in one entity?

Yes, with important limitations. Physicians from different specialties within the same licensed profession (cardiology and orthopedics, for example—both practiced by licensed physicians holding the same physician license type) can practice together in a single entity, as all holders must possess the same professional license type required by Utah Code §§ 16-11-7 and 16-11-8. However, different healthcare professions (physicians and dentists, or physicians and chiropractors, for instance) cannot practice together in a single entity due to the single-discipline requirement in Utah Code § 16-11-6 for PCs and Utah Code § 48-3a-1106 for PLLCs. Each enumerated licensed profession in Utah Code § 16-11-2(3) constitutes a separate specific type of professional service.

Streamline Your Utah Healthcare Compliance with Discern

Tracking anniversary month deadlines, coordinating filings across multiple state agencies, and ensuring ownership changes comply with licensing requirements creates constant administrative anxiety for healthcare practices. 

Ready to simplify your healthcare entity compliance? Book a demo with Discern today and see how we can reduce your administrative burden while ensuring your Utah entities stay in good standing.

Utah healthcare entity management and compliance requirements 2026
Author
The Discern Team
Published Date
January 30, 2026
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