A small physician group may be successful enough to employ dozens of people yet still handle legal problems only when a deadline or demand letter arrives. The practice needs contracts, payer relationships, clinical operations, staff policies, real estate and data security to function together. It does not necessarily need a full-time lawyer to make that happen. An outside or fractional general counsel model can create an affordable decision-making structure and a predictable process for escalating complex matters.
The first 90 days should produce more than an introductory call and a stack of generic templates. It should clarify who owns each business risk, identify the few material contracts and deadlines, and leave practice leadership able to act without guessing about legal consequences. For an ongoing relationship, see our guide to scope and escalation terms for fractional general counsel.
Days 1–15: map the organization and what can interrupt operations
Begin with a concise ownership and operational chart. Identify the licensed professional entity, individual owners, any management services organization, facilities, billing and IT vendors, employed or affiliated clinicians, and practice locations. Collect major payer participation agreements, the lease, financing agreements, employment or contractor documents, management services agreement and key vendor arrangements.
For each, note renewal and termination dates, required notices, change-of-control provisions, indemnification, dispute resolution and the person responsible for compliance. A seemingly small failure to give notice can interrupt payer access or prevent a sale. Obtain information about open litigation, audits, licensing complaints and actual or threatened payment holds before setting priorities.
Days 16–30: prioritize exposure and establish a monthly cadence
Rank issues by possible operational harm, not document count. A short letter threatening immediate termination of an essential contract may deserve attention ahead of a 60-page software renewal. An unresolved clinician enrollment issue may expose more revenue than a minor website policy revision. Separately identify obligations that cannot be delayed: regulatory response deadlines, preservation notices, payroll and wage matters, professional licensing or patient safety issues.
Put a regular legal-risk meeting on the management calendar. It might review pending contracts, payer denials and recoupments, owner disputes, employee incidents, privacy matters and upcoming deadlines. Maintain a confidential issues register with one owner and a next action for each open item. Not every operational problem requires a lawyer to attend; many require management to follow an established process.
Days 31–45: strengthen the contract intake system
Create a policy for which agreements require legal review and who is authorized to sign. A simple intake checklist can capture the parties, services, value, term, termination rights, data access, insurance, reimbursement dependencies, referral relationships and subcontractors. Major vendor agreements should specify reporting and exit obligations rather than merely say the vendor will perform services professionally.
Keep signed agreements and amendments in a central index, preserving superseded versions and relevant correspondence. Train management to avoid agreeing to broad indemnity, auto-renewal or personal guaranty provisions without understanding them. Where regulated referrals or licensed clinical practice are involved, an ordinary commercial template is inadequate.
Days 46–60: align compliance with real operational data
HHS-OIG’s General Compliance Program Guidance describes voluntary principles such as standards and policies, oversight, training, reporting, enforcement and appropriate responses to detected issues. OIG expressly says this guidance is not binding on every entity. Use it to evaluate how a particular practice actually operates rather than to make unsupported claims that every small medical office must hire a specific officer or committee.
Test a manageable set of claims or workflows based on actual risk. Can the practice retrieve the clinical record supporting a billed service? Does the RCM vendor provide claims history and audit support? Are exclusions being screened in the applicable population? Is there a way for staff to report a suspected problem without facing retaliation? Do corrective actions have a person responsible and a validation date?
Days 61–75: create practical incident playbooks
Prepare short instructions for receiving an ADR, commercial SIU letter, payment suspension, professional board notice, subpoena, suspected HIPAA incident, key employee complaint or threatened ownership dispute. Each playbook should specify the first contact, evidence to preserve, required notice assessment, external communications policy and escalation criteria. Playbooks should never give staff permission to respond substantively to every agency using the same template.
Review a sample scenario at a management meeting. For example, an insurance plan demands five years of patient records while a billing vendor claims exclusive access. Can the practice locate the contract, retrieve necessary information, apply appropriate privacy safeguards and meet the deadline? If not, prioritize those controls.
Days 76–90: deliver the ownership briefing
A useful 90-day closeout is a short executive risk map, not a giant volume of lawyer notes. It should show high-priority risks, improvements already implemented, decisions requiring owner approval, unresolved dependencies and a quarterly legal/compliance calendar. Distinguish actual legal requirements from voluntary good practices. Where issues need specialized counsel or experts, identify the reason and anticipated scope before incurring avoidable costs.
Outside counsel pricing can be structured as a defined monthly package, a retainer that reserves availability, an hourly arrangement or a matter-specific flat fee. The economics must reflect scope and the firm’s capacity. A practice should understand which activities are included, what generates additional fees and whether urgent litigation or investigation response requires separate engagement.
What does success look like?
Leadership knows who can sign contracts and speak for the practice; the important agreements are accessible; material deadlines are tracked; employee concerns are escalated; vendor data is retrievable; and high-exposure matters reach legal review early. The goal is not to find a violation in every process. It is to make ordinary operations more defensible, predictable and commercially valuable.
BOLO Health Law provides outside and fractional general counsel, healthcare contract counseling, and practice-risk planning.
Primary compliance resources
HHS-OIG General Compliance Program Guidance; HHS-OIG Compliance Programs for Physicians; HHS HIPAA Guidance for Professionals.
Attorney advertising. General educational information reviewed October 18, 2026, not legal advice. Rules and deadlines depend on the specific facts and jurisdiction. Reading this article does not establish an attorney-client relationship; any engagement is subject to conflicts, attorney admission and written terms.