Essential Year-End Deadlines

Compliance datelines

Essential Year-End Deadlines matter more than ever for healthcare organizations facing tighter rules, rising cyberattacks, and shrinking margins. These Essential Year-End Deadlines help you plan the last weeks of this year and the first quarter of next year, so your team stays ahead of penalties and keeps revenue stable.

Below is a quick reference table you can share with your compliance officer, practice manager, and IT or billing partners.

Essential Year-End Deadlines at a Glance

Date / Period

Who Is Affected

Deadline or Milestone

Key Action to Take

Dec 23, 2024

Covered entities and BAs

HIPAA Privacy Rule for reproductive health compliance date (most parts)

Update reproductive health privacy policies, workflows, and attestation forms.

Dec 31, 2024

All providers and BAs

Year-end snapshot for 2024 compliance

Confirm 2024 SRA, OSHA training, and MIPS 2024 submissions are complete and documented.

Jan 1, 2025

Institutional providers

CMS Medicare / Medicaid / CHIP application fee rises to $730

Budget for enrollment, revalidation, or new locations using the new fee

Early Mar 2025

All covered entities and BAs

Comment period closes for proposed HIPAA Security Rule changes

Review proposed rule, submit comments, and brief leadership on likely impact.

All of 2025

MIPS eligible clinicians

2025 MIPS performance year runs Jan 1–Dec 31

Collect data for Quality, Cost, Promoting Interoperability, and Improvement Activities.

Jul 2025 (or earlier)

MIPS clinicians choosing PI

Start minimum 180-day Promoting Interoperability period

Confirm CEHRT use and begin your PI reporting window.

Oct 2025 (or earlier)

MIPS clinicians

Start minimum 90-day Improvement Activities period

Lock in your 90-day window and document activities.

Apr 1–Dec 1, 2025

MIPS groups using MVPs

MVP registration window

Decide if you stay in Traditional MIPS or register for an MVP.

Dec 31, 2025

MIPS eligible clinicians

2025 MIPS performance period ends

Finish data capture and close any pending exception requests.

Jan 2–Mar 31, 2026

MIPS participants

2025 MIPS submission window

Submit all 2025 MIPS data by Mar 31, 2026 to avoid up to a 9% penalty.

Feb 16, 2026

Covered entities and BAs

New HIPAA Notice of Privacy Practices requirements

Publish updated NPP reflecting reproductive health protections.

At least once each year

All orgs with ePHI

HIPAA Security Risk Analysis and Security Management Plan

Perform and document an SRA, then track corrective actions.

At least annually

Staff with blood or OPIM exposure

OSHA Bloodborne Pathogens training

Deliver and log training at hire and at least every 12 months.

Throughout the year

Covered entities and BAs

SAFER Guides self-assessment (High Priority Practices)

Complete annual self-assessment and keep proof for MIPS PI attestation.

How Essential Year-End Deadlines Shape Your Bottom Line

Essential Year-End Deadlines do more than clutter your calendar. They control how much Medicare pays you in 2027, how regulators view your risk posture, and how well your team responds when something goes wrong.

Because MIPS and HIPAA now intersect more tightly, a gap in one area can ripple into others. A missing Security Risk Analysis, a late MIPS submission, or an outdated HIPAA Notice of Privacy Practices can trigger penalties, audits, or reputational damage.

Therefore, treating these dates as a single connected plan makes life easier. You protect revenue, reduce legal exposure, and move your program from “reaction” to “control.”

MIPS 2025: Performance Year Today, Payment Adjustments Tomorrow

The 2025 MIPS performance year runs from January 1 through December 31, 2025. Your 2025 MIPS score drives Medicare Part B payment adjustments in 2027.

MIPS still scores you on a 0–100 point scale. The performance threshold remains 75 points. Scores at or below that threshold risk up to a 9% negative payment adjustment, while high performers may see a positive adjustment.

You earn this final score across four categories: Quality, Cost, Promoting Interoperability, and Improvement Activities. The weights remain stable, so you can reuse parts of your 2024 strategy, as long as you adjust for new details in measures and reporting.

Because of these rules, Essential Year-End Deadlines for MIPS should anchor your calendar:

  • By mid-year, start your 180-day Promoting Interoperability period.
  • By early fall, lock your 90-day Improvement Activities period.
  • By December 1, decide if your group will register for a MIPS Value Pathway or stay in Traditional MIPS.

Once the performance year closes on December 31, 2025, the submission window opens on January 2, 2026 and closes on March 31, 2026. Submitting even a day late can forfeit your entire score and force the maximum penalty.

SAFER Guides: The “Yes or Zero” MIPS Requirement

The 2025 MIPS Promoting Interoperability rules now tie your score directly to the SAFER Guides. To earn more than zero points in the PI category, you must attest Yes to completing both:

  1. A Security Risk Analysis, and
  2. An annual self-assessment using the High Priority Practices SAFER Guide.

If you attest “No” for the SAFER Guide measure, CMS gives your Promoting Interoperability category a score of zero, regardless of your other PI data.

Because of this high impact, build Essential Year-End Deadlines around SAFER work. Many organizations schedule a “Digital Safety Week” near year-end. During that week, they walk through the High Priority Practices checklist, confirm EHR configurations, and document remaining gaps with clear owners and due dates.

Security Risk Analysis: HIPAA Requirement and MIPS Foundation

A Security Risk Analysis (SRA) has always been a core requirement under the HIPAA Security Rule. Today, it also anchors your MIPS Promoting Interoperability score and your defense against ransomware investigations.

The proposed 2025 HIPAA Security Rule update would sharpen these expectations. It would require a written assessment that identifies all systems with ePHI, maps reasonably anticipated threats, documents vulnerabilities, and ties those findings to your environment and operations. It would also strengthen expectations around business associate oversight, contingency planning, and technical safeguards such as multi-factor authentication and encryption.

These 2025 HIPAA Security modifications remain proposed and are still under review. However, regulators have made their direction very clear: they expect deeper SRAs, stronger technical controls, and documented follow-through.

Your Essential Year-End Deadlines should include three concrete SRA actions:

  1. Complete or update your formal SRA for all ePHI, including data handled by IT, billing, legal, and other business associates.
  2. Build or refresh a Security Management Plan that turns SRA findings into specific tasks, owners, and timelines.
  3. Align both the SRA and the plan with the proposed 2025 Security Rule so you will not scramble later.

Here, specialized support can save time. For example, Taino Consultants offers an SRA that already includes a Security Management Plan and an annual task roadmap. Their methodology incorporates guidance for the 2025 HIPAA Security modifications while clearly noting that these changes are still proposed.

This kind of blueprint helps you treat Essential Year-End Deadlines as checkpoints in a living security program, not just boxes to check.

HIPAA Privacy Deadlines: Reproductive Health and NPP Updates

The HIPAA Privacy Rule to Support Reproductive Health Care Privacy created two major compliance dates. The rule took effect in June 2024. It set a general compliance date of December 23, 2024 for most provisions, and an additional February 16, 2026 deadline for updating the Notice of Privacy Practices.

Therefore, Essential Year-End Deadlines should reserve time to:

  • Update policies covering reproductive health records and related requests.
  • Implement the required attestation process when you receive requests that may involve reproductive health information.
  • Train staff on when they must refuse or limit disclosures, and how the new presumption of lawful care works.

By early 2026, you also need an updated Notice of Privacy Practices that clearly explains these protections. That work takes time because you should coordinate legal review, patient-facing materials, website updates, and translation, where needed.

When you review Essential Year-End Deadlines with your privacy officer, include a simple NPP project plan. That plan should schedule drafting, review, training, and go-live so you avoid last-minute changes.

OSHA Bloodborne Pathogens Training: Annual and Documented

OSHA’s Bloodborne Pathogens Standard requires employers to provide training at the time of initial assignment and at least annually thereafter. This rule applies to anyone with reasonably anticipated exposure to blood or other potentially infectious materials, including many clinic, lab, dental, and long-term care staff.

Because OSHA fines can exceed tens of thousands of dollars, you should treat OSHA training as a fixed Essential Year-End Deadline. Many organizations commit to completing their annual sessions by October and use November and December for make-up sessions.

Tie this OSHA work into your broader compliance plan. For instance, you can house OSHA training assignments, certificates, and sign-in logs in the same platform you use for HIPAA and MIPS documentation. Solutions like EPICompliance provide integrated OSHA, HIPAA Privacy, HIPAA Security, and ACA/OIG Medicare training, along with reminders and task tracking, which helps keep these annual obligations from slipping through the cracks.

Medicare Enrollment Application Fees: Planning for $730 in 2025

If you are an institutional provider, you must now budget for a $730 federal application fee for calendar year 2025. This fee applies when you initially enroll in Medicare, Medicaid, or CHIP, when you revalidate enrollment, or when you add a new Medicare practice location in 2025.

Physicians and non-physician practitioners who enroll using form CMS-855I do not pay this fee, but hospitals, ASCs, SNFs, DMEPOS suppliers, and other institutional providers do.

As you build Essential Year-End Deadlines, include a simple check: are you planning any expansions, ownership changes, or new locations during the coming year? If so, update your financial plan to account for these fees and collect the necessary documents early, so the fee does not delay your enrollment or revalidation.

Turning Essential Year-End Deadlines into a Single Timeline

To make Essential Year-End Deadlines manageable, pull them into a single timeline that everyone can see. Then assign owners and dates.

In the spring and early summer, confirm your MIPS strategy, select measures, and map your 180-day PI and 90-day Improvement Activities windows. At the same time, schedule your HIPAA SRA and SAFER self-assessment so they do not collide with the busiest months of flu and respiratory season.

During late summer and fall, complete your SRA, begin drafting any needed HIPAA policy updates, and confirm your OSHA training calendar. Many practices also finalize business associate reviews during this period, so they have time to address gaps before year-end.

In the final quarter, focus on closing open tasks. That work includes finishing Improvement Activities, verifying PI data capture, reconciling training completion, and ensuring that all new regulatory requirements have a clear go-live plan, especially the reproductive health privacy rule and any local payer changes.

Once the calendar flips, you use January through March to validate your MIPS data and submit everything by March 31, 2026. At the same time, you can start your next SRA planning cycle and schedule the first wave of staff training and spot checks.

Quiet Helpers in the Background: Taino Consultants and EPICompliance

Many organizations want to simplify Essential Year-End Deadlines by turning them into repeatable workflows. That is where tools and advisors matter.

A structured SRA with a built-in Security Management Plan can save hours of internal meetings. Taino Consultants focuses on SRAs that produce a clear risk register, a practical task plan spread across the year, and guidance that already reflects the proposed 2025 Security Rule changes, even while those changes remain under review.

In parallel, an online platform such as EPICompliance can centralize your policies, forms, business associate agreements, training records, and recurring task lists for HIPAA, OSHA, and ACA/OIG Medicare requirements. Their tools help you assign work, track completion, and keep proof ready if a surveyor, payer, or OCR investigator asks for documentation.

With this kind of support behind the scenes, Essential Year-End Deadlines feel less like emergencies and more like routine maintenance.

A Personal Note on Essential Year-End Deadlines

In many practices, year-end still feels chaotic. Leaders juggle staffing gaps, flu surges, and payer changes while also trying to close charts and lock in MIPS submissions.

However, when you treat Essential Year-End Deadlines as a shared roadmap, the mood shifts. Teams know what to expect, who owns each task, and when support partners step in. That sense of control reduces stress and frees time for what matters most: patient care and staff wellbeing.

If your organization has felt constantly behind, consider this year the moment you reset. Use these Essential Year-End Deadlines as your starting template, adjust them to your realities, and build a rhythm that works for your people and your patients.

Final Call to Action

Essential Year-End Deadlines are not just dates on a calendar. They are decision points that shape revenue, risk, and reputation for the next two years.

Take control now: review, refresh, and actively manage your program. For quick, practical guidance, see EPICompliance webcasts (Watch on YouTube) and keep your team tuned to the changes that are coming next.