The year-end CME checklist for physicians: meet your CME deadline without the December scramble

Racing a CME deadline? This year-end CME checklist helps physicians confirm cycles, count credits, close required-topic gaps and prep for an audit.

By Shift CME · October 6, 2026 · 9 min read
Updated October 2026

State rules change often; your board has the final word.

It's December 30. The house is finally quiet, and you're searching your inbox for the certificate from a course you definitely took in April. Or was it March? Plenty of physicians have spent some version of this evening, none of them fondly.

The short answer: your CME deadline is set by your state medical board, and it isn't always December 31. Your specialty board and your employer may keep separate clocks. A year-end CME checklist that works:

Confirm every deadline.
Count credits by category.
Close gaps in required topics first.
Log any self-claimed Category 2 time.
File your documentation where an auditor could find it.

Start in October and December gets much quieter.

When is my CME deadline, really?

Expect several clocks:

Your state medical board. The Federation of State Medical Boards' board-by-board overview (updated August 2026) finds that 63 of 67 boards require substantial CME (at least 15 hours a year), and 55 require specific topics. Cycles can be annual, biennial or triennial, ending on different dates.
Your specialty board. Your MOC deadline runs separately. ABIM diplomates using the Longitudinal Knowledge Assessment have until December 31, 2026 to answer fourth-quarter questions. LKA enrollment for anyone with an assessment due in 2026 closes November 15, 2026.
The DEA, if you're registering for the first time. DEA MATE Act training is a one-time, eight-hour requirement on treating and managing patients with opioid or other substance use disorders. The DEA made it due at your first registration or renewal submitted on or after June 27, 2023 (a checkbox on the form). Registrations run on a three-year cycle, so most physicians registered before mid-2023 have already made the affirmation.
Your employer. Privileges, credentialing and fiscal-year CME allowances follow your medical staff office or contract.

How do year-end CME deadlines differ by state?

Four examples, as of September 2026:

Year-end CME deadlines in four states
State	What's required	When the clock runs out
Alabama	25 AMA PRA Category 1, AOA Category 1-A, or equivalent credits per year	Credits must be earned Jan. 1 to Dec. 31 of each calendar year (ALBME)
Pennsylvania (MD)	100 hours per two-year cycle, including 20 AMA PRA Category 1, 12 in patient safety or risk management, 2 in child abuse recognition and reporting, and (for prescribers and dispensers) 2 in pain management, addiction or opioid prescribing. New since May 1, 2026: a one-time, 2-hour organ and tissue donation course, due within 5 years of initial licensure or renewal, whichever comes first.	Licenses expire Dec. 31 of even years, so Dec. 31, 2026 is a renewal deadline (PA State Board of Medicine)
Texas	48 credits every 24 months. At least half must be formal Category 1 or 1-A, including at least 2 hours of medical ethics or professional responsibility. The rest may be informal, such as self-study or grand rounds. Opioid and human trafficking CME follow renewal-based schedules.	Your biennial registration period, not the calendar year. Mandatory CE tracking for all licensees, through CE Broker, began Sept. 1, 2026 (Texas Medical Board)
California	50 hours per biennial cycle, plus one-time or conditional topics. Most physicians need a one-time 12-hour course on pain management and terminally ill patients (pathologists and radiologists are exempt), and some internists and family physicians owe 20% of their CME in geriatrics.	The last day of the month in which the license was issued. "There is no grace period" (Medical Board of California)

Practicing elsewhere? See CME Requirements by State, then your own board's website.

Your year-end CME checklist: 10 steps before December 31

Work through it in order; the early steps size the rest.

Confirm every deadline in writing. License expiration, CME cycle dates (they don't always match), MOC due dates and DEA registration, all on one page.
Pull your transcripts. ACCME calls CME Passport "a free, centralized web application" for viewing, tracking and generating transcripts of your reported CME credit. It shows only what providers report, so add society and hospital transcripts and stray certificates. In Texas, check CE Broker too.
Count by category, not just in total. Category 1 minimums are the classic trap. A Pennsylvania MD can log 110 hours and still fall short if fewer than 20 are Category 1.
Close gaps in required topics first. This is where many renewals stall. Allow for reporting lag. Pennsylvania's child abuse training is reported by the provider, and the board says that may take up to 7 days. December 30 is the wrong day to take it. And check when new rules are due: South Carolina's Act 106 (approved March 9, 2026) adds a one-hour human trafficking course for physicians in certain fields and settings, such as emergency medicine, primary care and OB/GYN, due by Jan. 1, 2028 for anyone licensed before 2026, then every six years.
Claim credit you already earned. Skipped a meeting evaluation this spring? Claiming windows close, so check now.
Log your self-directed learning. For AMA PRA Category 2, record title or description, subject, dates and credits (more below).
Check your MOC status in your specialty board's portal rather than assuming points were reported.
Use or document your CME allowance under your employer's policy, and keep the receipts.
Book 20 minutes with your tax professional if you pay for any CME yourself.
Build a CME audit folder. Boards really do audit. Alabama runs a random audit every year and asks you to keep records for three years after the year you earned the CME. California asks for at least four years.

And in January? Make room for learning you choose. Here's how Shift CME works: choose a destination, your dates and your specialty to plan a conference around your practice. Then check in from your phone at your destination and follow your program. Shift CME takes care of the conference planning, documentation, and record keeping. Travel, accommodation, and external learning costs are separate, and in certain circumstances may be reimbursable by your employer. See what a plan looks like. No account needed.

How do I find last-minute CME credits that actually count?

Last-minute CME only helps if it's the right kind. Work out what you're short on:

Category 1: choose accredited activities and check the credit designation first.
General hours, in a state that accepts Category 2: self-directed learning may fill the gap (see the next section).
A required topic: nothing else substitutes. Find a course your board accepts.

Does reading journal articles count toward CME?

It can, as AMA PRA Category 2 Credit. The AMA says Category 2 is self-designated and self-claimed by individual physicians for activities not certified for Category 1. They must comply with the AMA definition of CME and relevant AMA ethical opinions, be non-promotional, and be a worthwhile learning experience related to your practice, as you judge it. Examples include reading authoritative medical literature, consulting with peers and self-assessment. The AMA PRA booklet adds teaching. Fine print:

Claim your actual participation time. Sixty minutes equals one credit, claimed in 15-minute (0.25-credit) increments and rounded to the nearest quarter hour.
You keep the log yourself. No certificate arrives.
You can't claim Category 2 for an activity you already claimed as Category 1.

Boards differ. Pennsylvania accepts Category 2 for hours beyond its Category 1 minimum. Texas allows informal self-study for up to half. Alabama requires Category 1 or its equivalent. So you may be able to self-claim AMA PRA Category 2 credit for qualifying self-directed learning under AMA rules, but check how much your board counts. More in AMA PRA Category 2 Credit, Explained.

What happens if I miss my CME deadline?

It depends on your board. The useful moves happen before the deadline.

Waivers have deadlines of their own. Pennsylvania says waiver requests "should be submitted to the Board 90 days prior to the end of the biennial renewal period." For the Dec. 31, 2026 renewal that falls around October 2, so the window may be closing or already closed. California suggests requesting a waiver approximately three months before your license expires, and "waivers are not available if you have been audited."
Lapses are visible. An unrenewed California license shows as "Delinquent" online. After 30 days, penalty and delinquency fees apply, and practicing on an expired license is illegal.
Never attest to CME you haven't finished. California makes you certify CME compliance "under penalty of perjury." Being a few credits short is fixable. A false attestation is a much bigger problem.

What if I'm picked for a CME audit?

Respond on time. Alabama says missing documentation can bring formal charges, reprimands and fines, and that the discipline is public and reportable to the National Practitioner Data Bank. Keep one folder: certificates (with your name, course, date, hours, provider and category) plus your Category 2 log.

Are CME expenses tax-deductible?

This section is general information, not tax advice. Talk to a qualified tax professional about your own situation.

Self-employed physicians: IRS Topic 513 says self-employed individuals report qualifying work-related education expenses on Schedule C (or F). Generally, the education must maintain or improve skills needed in your present work, or be required by your employer or the law to keep your present salary, status or job.
Employed (W-2) physicians: you generally can't deduct unreimbursed work-related education. The miscellaneous itemized deduction that covered it was suspended for 2018 through 2025, and the Congressional Research Service reports that P.L. 119-21 made that suspension permanent for tax years beginning after December 31, 2025. The usual route is an employer CME allowance.
Mixed or entity situations: S corporations, partnerships, accountable plans, or 1099 locums or moonlighting income alongside a W-2 can change the picture. Ask your tax professional.
Travel: That line in IRS Publication 970 ("You can't deduct the cost of travel as a form of education…") is widely misread. It targets travel that is the education, like a history teacher touring Europe for general enrichment. It doesn't rule out travel costs you incur to attend qualifying work-related education. Publication 970 treats those as a separate category that self-employed physicians may be able to deduct when the education is the main purpose of the trip. The deciding factor is usually documentation: a clear agenda, a record of your actual study time, and proof that learning, not sightseeing, was the reason you went. That's the record Shift CME is built to keep. Your confirmed itinerary, day-by-day participation and course evaluation stay together in Records, ready to hand to your accountant. Publication 463 explains the travel records the IRS expects. (Not tax advice. W-2 employees generally can't deduct unreimbursed expenses under current federal law, and eligibility depends on your situation, so check with a tax professional.)
Timing: Topic 513 refers to education expenses "paid during the year," so ask your tax professional which tax year a December payment belongs to.

Year-end CME FAQ

Is the CME deadline December 31 for every physician?

No. Alabama's and Pennsylvania's MD cycles end December 31; Texas and California don't follow the calendar year. Per the FSMB, four boards (Indiana, Montana, New York, South Dakota) set no hours, though New York requires child abuse identification and infection control training.

Does CME carryover apply to extra credits?

Sometimes. Texas lets up to 48 excess hours carry forward for up to two years, except ethics and opioid hours. The FSMB notes that Alabama and Arizona (MD) allow no rollover.

Do I need to redo the DEA MATE training at every DEA renewal?

No. It's a one-time requirement, and the DEA says the affirmation "will not be a part of future registration renewals." Registrations renew every three years.

Can I earn CME credit?

It depends on the session. A presentation or journal module offers AMA PRA Category 1 Credit™ only where its accredited provider offers a CME activity and supplies instructions for claiming it; then you claim it as that provider directs. That credit comes from the provider, not from Shift CME, and not every session offers it. Physicians may also self-claim AMA PRA Category 2 Credit™ for learning they judge meets the AMA's requirements, and your Shift CME records can support that claim. Nurse practitioners and physician assistants follow their own certifying bodies' rules: NCCPA lets PAs self-claim Category 2 CME, while AANPCB and ANCC require accredited contact hours, which Shift CME does not award.

Your records reflect your recorded study-day participation and any course evaluation you submit, and can support your self-claim of AMA PRA Category 2 Credit™. AMA PRA Category 1 Credit™ comes only from a session's accredited provider, where that provider offers a CME activity and supplies instructions for claiming it, not from Shift CME, and not every session offers it.

Sources

Make room for your next question

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