Neurology EHR Year-End Checklist: What to Wrap Up Before 2027

It's October, and the questions start coming in. Did we start our Promoting Interoperability period in time? When was the last security risk analysis? Is our EHR still certified? And what exactly changes for neurology practices in 2027?

If nobody on your team has clear answers, you're not behind. You're normal. But December 31 is a hard stop for 2026, and some of these items take weeks, not days. Here's the year-end checklist for neurology practices, built around your EHR.

The 2026 Deadlines You Can't Move

The 2026 MIPS performance period ends December 31, 2026. A few dates matter more than the rest:

• Promoting Interoperability needs 180 days. The last day to start a 180-day reporting period was July 5, 2026. If you didn't, look at the hardship exception before you write the category off.
• Hardship exceptions close December 31. Applications for the Promoting Interoperability hardship and extreme and uncontrollable circumstances exceptions are accepted through December 31, 2026, at 8 p.m. ET.
• Submission runs January 4 through March 31, 2027. Your 2026 data drives your Medicare payment adjustment in 2028, so it's worth getting right.

Those dates come from MDinteractive's 2026 MIPS key dates guide, and CMS notes they can change. Neurology practices reporting through the Quality Care for Patients with Neurological Conditions MVP should also confirm they have a full year of data for their four quality measures.

Your Neurology EHR Year-End Checklist

Work through these with whoever owns your EHR and your MIPS reporting. Most take less than an hour to check.

• Confirm your Promoting Interoperability period and measures. Pull the report from your EHR now, not in March. Gaps found in October can still be fixed. Gaps found during submission usually can't.
• Complete your 2026 security risk analysis. It's still required for 2026 Promoting Interoperability. CMS has proposed removing it from MIPS in 2027, but the HIPAA Security Rule requires a risk analysis either way, so keep doing it.
• Check that your EHR certification is current. Your MIPS submission depends on certified EHR technology. Ask your vendor for your current certification ID and confirm it on the ONC Certified Health IT Product List.
• Review how you handle patient access requests. Under the 21st Century Cures Act, delaying or blocking patient access to their records can count as information blocking. For clinicians, the penalty is a zero score in the MIPS Promoting Interoperability category.
• Test your patient portal like a patient would. Can a patient see an EEG report or a visit note promptly? If the answer depends on staff manually releasing it, write down the policy and the reason.
• Tighten up AI scribe documentation. If your providers use an AI scribe, make sure every note is reviewed and signed by the provider, and that templates still capture what payers ask for on EEG, EMG, and infusion visits.
• Update templates for the new MS codes. The FY2026 ICD-10-CM update replaced G35 with specific codes for each type of MS. Your templates should prompt for MS type and activity so coders aren't guessing.
• Ask your vendor about electronic prior authorization. Payer prior authorization APIs are due January 1, 2027. Find out now whether your EHR will connect to them and when.

Why Information Blocking Isn't Theoretical Anymore

For years, information blocking felt like a rule nobody enforced. That changed. HHS named it an enforcement priority in September 2025, and on February 11, 2026, the federal health IT office began sending letters of nonconformity to certain certified EHR developers, according to an Alston & Bird analysis.

For a neurology practice, the practical risk is your MIPS score. A zero in Promoting Interoperability is a big hole to climb out of. The fix is mostly paperwork: written policies for record requests, documented reasons for any delayed release, and an EHR that makes access easy by default. Our Cures Act compliance page explains how the MedicsCloud EHR handles patient access.

What 2027 Has in Store

CMS released the CY 2027 physician fee schedule proposed rule on July 14, 2026. It's not final yet, and the final rule usually lands in early November. But the direction is clear.

• Traditional MIPS has an end date. CMS proposed sunsetting traditional MIPS after the 2028 performance period. Starting in 2029, MVPs would be the only MIPS option for clinicians outside an APM, as HIMSS summarized.
• Electronic prior authorization comes to MIPS. CMS proposed a new electronic prior authorization measure for medical services, optional as a bonus in 2027 and required in 2028, plus a measure for prescription drugs starting in 2028.
• The performance threshold holds at 75 points. CMS previously finalized that level through the 2028 performance period.
• AI gets a seat at the table. The proposal adds an improvement activity for clinician use of AI to improve patient care, and asks for public input on how Medicare should pay for AI tools like scribes.

Electronic prior authorization is the one to watch in neurology. The American Academy of Neurology has pushed CMS on it directly. In a 2026 comment letter, the AAN called prior authorization burden one of its members' top concerns and urged CMS to make electronic workflows for drugs actually reduce work. For a specialty that lives on MRIs, EEGs, Botox, and infusions, an EHR that can talk to payer APIs will matter a lot by 2028.

Five Questions to Ask Your EHR Vendor Before January

• What's our current certification ID, and will it stay current through 2027?
• Can we run a Promoting Interoperability report today? If not, why not?
• How do you support electronic prior authorization with payer APIs? Ask for a date, not a roadmap slide.
• How does your AI scribe handle neurology exams? Generic templates miss reflexes, gait, and cranial nerve detail.
• Who answers when something breaks in March? Submission season is not the time to wait on a ticket queue.

If those answers make you nervous, it may be time to look around. Our neurology medical billing guide covers the revenue side of the same changes.

Why Some Neurology Practices Don't Dread December

Since 1977, ADS has helped specialty practices stay ahead of federal requirements. The ONC-certified MedicsCloud EHR includes neurology templates, a built-in MIPS dashboard, Cures Act connectivity, and MedicsScribeAI for ambient documentation. Our MIPS experts are available when you need help, and support answers in under 2 minutes. You can see how it all fits together on our neurology EMR and practice management page.

Want to see where your practice stands before December 31? Book a neurology EHR walkthrough. We'll show you the MIPS dashboard, neurology templates, and patient access tools in a live demo. Schedule your walkthrough, or call 1-800-899-4237 ext 2264.

This article is for general information and isn't legal or compliance advice. Proposed rules may change when CMS issues final rules.

Sources

• MDinteractive: 2026 MIPS reporting key dates and deadlines
• MDinteractive: 2027 QPP proposed rule, what's changing
• HIMSS: CMS proposes CY 2027 physician fee schedule
• Alston & Bird: Information blocking enforcement in 2026
• CMS fact sheet: Interoperability and Prior Authorization Final Rule (CMS-0057-F)
• American Academy of Neurology: 2026 comment letter to CMS on prior authorization
• ASTP/ONC: HTI-4 final rule