December is when the deadlines bunch up. Most of this list takes a few minutes per item if you start in November, and every date and threshold below comes from the IRS, the federal regulations or HHS, linked where it appears.
None of it is tax or legal advice for your situation. If you have an accountant, send them this list.
Clients
Issue new Good Faith Estimates for 2027. A Good Faith Estimate for recurring sessions can't cover more than 12 months. If you expect to keep seeing a self-pay client past that, the rule requires a new one (45 CFR 149.610). If a client's current estimate dates from early 2026, issue the new one before it runs out. If your fee changes in January, the new estimate should show the new fee.
The rest of the rule, briefly:
- It covers uninsured and self-pay clients, when you schedule a session or when they ask.
- Timing depends on lead time. Book 3 or more business days ahead and the estimate is due within 1 business day. Book 10 or more business days ahead and you have 3. If a client asks for one, you have 3 business days.
- A client can dispute a bill that comes in at least $400 above the estimate, within 120 days of receiving the bill (45 CFR 149.620).
- Estimates are part of the client's record. Keep them as you keep the record, and give a copy of any estimate from the last 6 years if asked.
Our free Good Faith Estimate generator makes a compliant one in a couple of minutes, and our Good Faith Estimate guide covers what has to be on it.
Send fee changes in writing, early. If you are raising your fee for 2027, give clients notice now rather than in the first session of January. Our guide to raising fees with existing clients has a script.
Send year-end superbills. Clients who use out-of-network benefits, an HSA or an FSA need statements to claim. Each FSA plan sets its own deadlines for spending and claiming, so send December's superbills before the holidays.
Remind clients about open enrollment. This is when clients can pick a 2027 plan that pays them back for your sessions. Our open enrollment guide has an email you can send.
Taxes
Pay the fourth-quarter estimated tax by January 15, 2027. That is the last 2026 payment on Form 1040-ES. You can skip it if you file your 2026 return by February 1, 2027 and pay everything you owe with it (IRS Form 1040-ES).
File 1099-NEC forms by February 1, 2027. For payments made in 2026, you file one for anyone who isn't your employee and was paid at least $2,000 for services, such as a contract biller or a contract clinician. Payments to most corporations are excluded. That threshold was $600 before 2026, and the IRS says it may be adjusted for inflation from 2027. The usual January 31 deadline falls on a Sunday in 2027, so the due date is the next business day (IRS 1099-NEC instructions).
Know when to expect a 1099-K. For 2026, payment processors only have to send one if you received more than $20,000 across more than 200 transactions (IRS). Some send them below that, and some states set lower thresholds. A missing 1099-K doesn't change what you report.
Use the right mileage rate. If you drive for work, the 2026 business rate changed mid-year: 72.5 cents a mile from January through June and 76 cents from July through December (IRS). Split your log at July 1.
HIPAA and records
Review your risk analysis. The Security Rule requires an accurate and thorough risk analysis, a review of your safeguards as needed, and periodic evaluation (45 CFR 164.308, 164.306). It doesn't say annual, but year end is a good time for it. A new laptop, a new app or a new staff member are the kinds of change a review should catch. HHS proposed a stricter Security Rule in January 2025. As of October 30, 2026 it has not been finalized, so the current rule still applies.
Check every business associate agreement. List each vendor that stores or sees client information: your EHR, email, phone and text service, billing help, cloud storage. You need a signed BAA with each one (45 CFR 164.502(e)). Our HIPAA guide for private practice walks through the rest.
Keep HIPAA documentation for 6 years. Policies, risk analyses and other required HIPAA documents must be kept for 6 years from when they were created or last in effect (45 CFR 164.316). How long you keep clinical records is set by your state, and it is often longer for minors.
Confirm your license renewal and CE. Renewal dates and continuing education rules are set by your state board. If your renewal falls in early 2027, check your CE hours now, while there's time to finish them.
If you see Medicare clients
Medicare's telehealth flexibilities now run through December 31, 2027, and the in-person visit requirement for mental health telehealth is delayed until January 1, 2028, under the Consolidated Appropriations Act, 2026 (CY 2027 physician fee schedule proposed rule). The final 2027 fee schedule hadn't been published as of October 30, 2026.
The AMA's CPT 2027 announcement lists its main updates, and psychotherapy isn't among them (AMA). Check the 2027 code book before you change anything in your templates.
Doing less of this next year
Most of this list is paperwork that could happen as you go. In CoralEHR, Good Faith Estimates for self-pay clients are issued at booking, superbills take one click with diagnoses carried over by date of service, and every practice signs our BAA at onboarding. That leaves taxes and your license for December.
Read on October 30, 2026. Rules and thresholds change. Confirm anything that affects your filings with the IRS, your state board or your accountant.
Frequently Asked Questions
Do therapists need new Good Faith Estimates every year?
For self-pay clients in ongoing therapy, yes in practice. Federal rules say a Good Faith Estimate for recurring services can't cover more than 12 months, and a new one is required if sessions are expected to continue past that (45 CFR 149.610).
When are 1099-NEC forms due for 2026?
February 1, 2027. The deadline is January 31, but that falls on a Sunday in 2027, and IRS rules move it to the next business day. For payments made in 2026, you file one for each contractor you paid at least $2,000.
Does HIPAA require an annual risk assessment?
No. The Security Rule requires an accurate and thorough risk analysis, a review of your safeguards as needed, and periodic evaluation. It doesn't say annual. A yearly review is a sensible habit, and it is not a legal deadline.
Will I get a 1099-K for 2026 card payments?
Federal rules only require payment processors to send one if you received more than $20,000 across more than 200 transactions. Some processors send them below that, and some states set lower thresholds. Either way, you report all of your income.
Arhaan Gupta
Co-founder and CEO, CoralEHR
I co-founded CoralEHR, an EHR for private-pay therapy practices, and I set up every new practice with them myself.
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