Record checked 16 September 2026 · sources retrieved 16 September 2026

The public-record framework: law, the bankruptcy perimeter, naming evidence and decision rights

Eight public-record modules of the investigation, checked to 16 September 2026: the statutory architecture California uses to keep medical judgment with licensed physicians, the two 2026 statutes that extend it to management companies and private equity, the perimeter of the Wellpath Holdings bankruptcy and what it left untouched, what the companies themselves have said about CFMG's separateness, how federal labour filings name the entity, and the decision-rights map this investigation exists to complete.

The controlling question, and the rule this page obeys

When an administrative issue became a physician-reserved decision, who had the last word? The method runs the chain: administration → recommendation → professional review → final approval or veto → implementation.

Every proposition below rests on an independent public source named in the evidence table. Where a public source establishes a point, the point is stated and labelled. Where no public source was located, the question is published as Open at the level of the statewide structure — never at the level of a site, a person, a date or a sequence of events. Nothing here is drawn from private records, correspondence or any individual's account, and no such material will be published in any form, including in abstract or de-identified form.

Module A The legal architecture of California's corporate-practice prohibition

Public record Business and Professions Code § 2400 provides that corporations and other artificial legal entities have no professional rights, privileges or powers. § 2052 makes practising, attempting to practise, or holding oneself out as practising medicine without a certificate a public offense. § 2264 reaches a physician who aids or abets unlicensed practice. § 650 governs fee-splitting.

Analytical inference A California professional medical corporation formed under the Moscone-Knox Professional Corporation Act is the recognised exception to § 2400. The Corporations Code sections are to be cited directly, after reading, before this inference is restated as a public-record proposition.

The Board's list of physician-reserved decisions

Administrative statement The Medical Board of California's published guidance identifies decisions that are to be made by a California-licensed physician, among them which diagnostic tests are appropriate, the need for referral or specialist consultation, responsibility for the patient's overall care and treatment options, and how many patients a physician must see or how many hours a physician must work.

Open Commentators reproducing that guidance extend the list to payer-contracting parameters, coding and billing decisions, and approval of medical equipment selection. Those three items remain Open here until the Board's own page is read and cited in place of the secondary reproduction.

Analytical inference Practitioner commentary reports that California courts have declined to split the practice of medicine into a business side that may be run without a licence and a professional side that requires one, and that entity control over matters requiring clinical training — equipment selection among them — has been found actionable. No case is named on this page until the reported decisions are read.

SB 351 (Cabaldón) — reported as signed 6 October 2025, effective 1 January 2026

Media report Law-firm summaries report that the statute prohibits private equity groups and hedge funds, including those involved through management contracts, from interfering with the professional judgment of physicians and dentists; voids contract terms permitting such interference; limits noncompete and nondisparagement clauses; and gives the Attorney General enforcement authority, including injunctive relief.

Open The chaptered text has not been read — the official legislative site refuses automated retrieval — so no provision is quoted or stated as established here.

AB 1415 — reported as signed October 2025, effective 1 January 2026

Media report The same summaries report that the statute extends the Office of Health Care Affordability's pre-transaction notice framework to "noticing entities" — private equity groups, hedge funds, management services organizations, and entities that own or control them — with notice due at least 90 days before a covered transaction and OHCA able to open a cost and market impact review. Secondary sources give 11 and 13 October as the signing date; this page says October 2025.

Open The chaptered text and the signing history have not been read. Both remain the owner's primary read.

Analytical inference Both statutes are prospective. Nothing in this investigation describes a pre-2026 arrangement as violating either. They are cited only as the state's current statement of the control it treats as impermissible.

Module B The bankruptcy perimeter: who filed, who did not, what changed

Public record In re Wellpath Holdings, Inc., et al., No. 24-90533 (ARP) (Bankr. S.D. Tex.). The official notice gives the petition date as 11 November 2024. Press accounts giving 12 November are not followed; the court's date governs.

Public record The jointly administered debtors include Wellpath Holdings, Inc. (24-90533), Wellpath LLC (24-90563), Wellpath Management, Inc. (24-90564), Wellpath Recovery Solutions, LLC, Zenova Management, LLC and Zenova Telehealth, LLC.

Open Whether California Forensic Medical Group, Inc. was itself a debtor. The excerpt of the debtor list read for this supplement does not show it. The point is stated neither way until the claims agent's complete debtor list is read.

Public record The plan became effective and was substantially consummated on 9 May 2025 (Dkt. 2680). The confirmation order is Dkt. 2596.

Media report The amended plan filed 10 February 2025 was described as providing for debt-to-equity conversion, a takeback facility and a liquidating trust; and the court was reported to have confirmed the plan over release objections following a global settlement. Both points are to be confirmed on the docket before they are restated as public record.

Public record In Overfield v. Wellpath Community Care, LLC (E.D. Cal., No. 2:24-cv-00199), the court recorded that claims against the debtor entities, including Wellpath LLC, were discharged and a plan injunction issued; that the automatic stay ended 8 May 2025; and that the case continued, including a motion to compel financial documents from defendant California Forensic Medical Group, Inc.

Analytical inference The public record shows CFMG continuing as a litigating defendant after the debtor entities' discharge. That is consistent with CFMG's separate legal existence. It is not a finding about control.

Module C What the companies have said

Company position In November 2024 a Wellpath board co-chair told a Santa Barbara publication that facilities operating under the Wellpath name in California are owned by a separate entity, CFMG; that CFMG is owned primarily by its physicians; that CFMG contracts for management services from Wellpath; that the two have no ownership overlap; and that the bankruptcy concerned Wellpath, not CFMG.

Media report In February 2025 a Monterey County publication described Wellpath as having "used to operate under the name" CFMG.

Analytical inference The two characterisations conflict, and this page resolves nothing beyond what primary records show. The instability in naming is itself evidence of branding integration. It is not evidence of ownership, and the physician-ownership statement remains a company position until a stock instrument is read.

Open Where the investigation makes a specific point about control and no company response to that point was located in the public record, the article says so rather than leaving the absence unmarked.

Module D How the entity is named in federal labour proceedings

Public record National Labor Relations Board case captions name the entity in three different forms. Each row below is branding and naming evidence — not an alter-ego or control finding. The employer as named in the underlying petition or charge is to be read from each case page before the table is treated as complete.

Module E What public records can and cannot establish about who employs physicians

This is a method module. It contains no facts about any individual.

Records that are public, and are read

• County contracts and board-of-supervisors agenda items — the contracting party and its signatory.
• Secretary of State filings — entity status, and the officers and agent listed in Statements of Information.
• Court and NLRB captions.
• Claims-agent debtor lists and filed schedules.
• Publicly posted job advertisements — the employer named in the posting.
• OHCA transaction notices, where filed after 1 January 2026.

Only those records are read. Records that are confidential by law are not used, and no proposition in this investigation rests on one.

Open Across California counties served under CFMG contracts, which entity is identified as the physicians' employer in public records, and is that identification consistent across contracts, postings and captions? The table is to be built one row per public document, and no conclusion is drawn beyond the table.

Module F What regulators can and cannot reach

Analytical inference Licensing boards regulate licensees: the Medical Board of California and the Osteopathic Medical Board of California discipline individual physicians. The corporate-practice statutes reach lay entities principally through the unlicensed-practice provisions and, from 2026, through Attorney General enforcement under SB 351.

Public record Complaints are not findings. Board complaint files are generally confidential; a board acts publicly through an accusation; and discipline requires proof by clear and convincing evidence. A closed complaint is neither a finding of wrongdoing nor an exoneration.

This investigation does not report the existence, subject, status or outcome of any complaint or investigation concerning any entity or person discussed, and it names no physician in any role.

Open Whether any OHCA transaction notice involving the entities named in this investigation is publicly posted. OHCA's notice listings are to be checked, and the answer recorded as "none located" if none is found.

Module G The decision-rights map, applied to correctional care

The map takes Module A's physician-reserved decisions and asks, for each, what public documents reveal about who recommends, who reviews, who approves and who implements in the correctional setting. Only three source classes are admitted: county contracts and their scopes of work, court-appointed monitor or expert reports in public consent-decree matters, and policies attached to public contracts. Every row below is Open until a public document is read for it.

Module H County accountability record, to 15 September 2026

Media report Monterey County. A request for proposals for jail health care issued in early 2025, with bids due 27 March and award scheduled for late April. The incumbent three-year contract was reported at $44.3 million and was to end in December 2025. A 2015 class-action settlement set care requirements. Open the current contractor, and the status of the settlement's monitoring as of September 2026.

Media report Santa Barbara County. Supervisors put the jail health contract out to bid in late 2024, and the contract was reported to expire at the end of March 2025. Open the award outcome and the current contractor.

Company position Scale. Company filings and releases describe roughly 400 or more facilities nationally and a workforce above 13,000. Wellpath was reported at the time of filing to serve jails in 34 of California's 58 counties; that county figure is not published here as fact until it is confirmed from county records.

For every county in the investigation, the contractor as of September 2026 is re-verified from the county's own agenda or contract record, or the row is marked Open.

Evidence table, retrieved 16 September 2026

Every proposition on this page maps to a row here or to an approved release file. Rows marked pointer rest on a secondary source that stands in for a primary record not yet read; the propositions they support are published as Open, and the row is replaced when the primary source is read. Links point at outside servers — they are citations, not files offered by this site.

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Related in this investigation

• California’s PC–MSO boundary (Modules A, F)
• Bankruptcy as a structural stress test (Module B)
• What California litigation says (Modules B, D)
• Employment infrastructure and professional authority (Module E)
• Decision-chain methodology (Module G)
• County contract atlas (Module H)
• Back to the investigation landing page · Open questions and evidence needed