Year End October 1, 2026 8 min read

The 1099-NEC Year-End Checklist for Therapy Agency Owners (2026 Filing)

January is the worst possible month to discover that a therapist’s W-9 was never collected, or that the only record of what you paid someone lives scattered across eleven months of bank transfers. The work that makes 1099 season painless is work you do in October, November, and December.

Here is the checklist, with the 2026 rules — which include a significant change that most year-end articles still get wrong.

What changed for 2026

The federal reporting threshold for Forms 1099-NEC and 1099-MISC rose from $600 to $2,000 for payments made on or after January 1, 2026, and will be adjusted for inflation beginning in 2027. If an article tells you the threshold is $600, it’s describing the old rule. Two cautions: state thresholds may not match the new federal one, and filing a form you weren’t strictly required to file is cheap protection — see the Section 530 note below.

The Dates That Matter

Who Actually Needs a Form

This is where therapy agencies have a wrinkle that general small-business advice misses.

Who you paid
Form
Notes
Unincorporated therapist (sole proprietor, single-member LLC)
1099-NEC, box 1
Standard nonemployee compensation
Incorporated therapist (PC, PLLC, S-corp)
Often 1099-MISC, box 6
The corporation exemption does not apply to medical and health care payments
An attorney
Reportable
Also an exception to the corporation rule
A W-2 employee
None
W-2, not 1099

That second row is the one to slow down on. The familiar rule — “you don’t send a 1099 to a corporation” — has a carve-out for medical and health care payments, which are reported in box 6 of Form 1099-MISC and are not covered by the corporate exemption. An agency paying an incorporated PT for patient visits can easily fall inside that carve-out. Whether your particular payments belong in 1099-NEC box 1 or 1099-MISC box 6 is a question for your CPA; the expensive mistake is assuming that an incorporated therapist means no form at all.

The October–December Checklist

✓
A signed W-9 on file for every contractor you paid this year
Not an email with a tax ID in it — the actual form, signed, with the entity name, federal tax classification, and TIN. You need it to file accurately, and you needed it before the first payment went out.
✓
Names and TINs that match IRS records
A TIN is treated as missing if it isn't provided or isn't nine digits, and incorrect if the name and TIN combination doesn't match IRS or SSA files. Mismatches generate notices and can require 24% backup withholding on future payments, which is a conversation nobody wants to have with a therapist in February.
✓
A per-contractor payment total for the full calendar year
One number per therapist, covering January 1 through December 31, matching what actually left your account. If you are reconstructing this from bank exports in January, that is the process problem to fix this year.
✓
Entity type confirmed for each contractor
The W-9's federal tax classification box determines whether you are in 1099-NEC or 1099-MISC box 6 territory. Therapists who incorporated mid-year are the common trap.
✓
Current mailing address for every contractor
Including the ones who stopped taking visits in March. Returned mail in February is a real and avoidable headache.
✓
Your state's filing requirements checked
States vary in whether they adopted the new $2,000 federal threshold or kept a lower one, and in whether they want a copy filed with the state at all. Don't assume the federal rule settles it.
✓
An e-file plan if you'll cross ten returns
Count every information return you file, not just 1099-NECs. If you're at or over ten, electronic filing is mandatory and you need the account or the provider arranged before January.

Should You File Below the Threshold Anyway?

Often, yes — and this is the part worth raising with your CPA. Under Section 530, a business that treats therapists as contractors keeps its safe-harbor protection against back employment taxes only if it has reporting consistency: all required Forms 1099 actually filed for those workers. Separately, if the IRS ever reclassifies a worker, the reduced assessment rates under IRC section 3509 are meaningfully lower when the required forms were filed — roughly 10.68% of wages versus about 13.71%.

Against that, the marginal cost of filing one extra form for a per-diem therapist who earned $1,400 is close to zero. The threshold tells you the minimum; your risk posture may argue for more. We walk through that tradeoff in detail in what to do when a 1099 therapist might have been an employee.

If You Get It Wrong

Corrected returns exist and are routine — a wrong amount or a wrong TIN is fixed by filing a corrected form, not by hoping nobody notices. Penalties for late or incorrect information returns generally scale with how long you take to fix them, so a correction filed promptly costs far less than one filed under inquiry. If a form is simply missing, file it late rather than not at all; the Section 530 and section 3509 consequences of an unfiled return outlast the penalty.

The Real Fix Is Not a January Fix

Every item on that checklist is easy if the information was captured as the year happened, and miserable if it wasn’t. The agencies that find January uneventful share a few habits:

That is precisely the gap 1099 therapist payment software is meant to close: visits logged once by the therapist, per-visit rates applied automatically, and year-to-date totals that are current every day of the year — so 1099 season becomes a report you pull and hand to your CPA, rather than a week of reconstruction. For the mechanics of paying contractors correctly during the year, see our step-by-step guide to paying 1099 therapist contractors.

Frequently Asked Questions

What is the 1099-NEC threshold for 2026?

For payments made on or after January 1, 2026, the federal reporting threshold for Forms 1099-NEC and 1099-MISC is $2,000, raised from the long-standing $600 threshold. Beginning in 2027 the amount is adjusted annually for inflation and rounded to the nearest $100. State thresholds do not necessarily match the federal one, so agencies should confirm their state's requirement separately.

When are 1099-NEC forms due for the 2026 tax year?

January 31. Form 1099-NEC must be furnished to the recipient and filed with the IRS by that same date, whether filed on paper or electronically. Filing ten or more information returns in total, aggregated across all types, makes electronic filing mandatory.

Do I send a 1099 to a therapist who is incorporated?

Often yes. Payments to a corporation are generally exempt from 1099 reporting, but that exemption does not apply to payments for medical and health care services, which are reported in box 6 of Form 1099-MISC. A therapy agency paying an incorporated PT, OT, or ST for patient visits can fall within that exception. Whether a specific payment belongs on 1099-NEC box 1 or 1099-MISC box 6 is worth confirming with a CPA, but assuming that incorporation means no form at all is a common and costly error.

What happens if a contractor's name and TIN don't match IRS records?

A TIN is considered missing if it is not provided or is not nine digits, and incorrect if the name and TIN combination cannot be matched to IRS or SSA files. Nonemployee compensation is subject to backup withholding at 24% if the payee has not furnished a TIN or the IRS notifies the payer of a mismatch. Collecting and verifying W-9 information before the first payment avoids this entirely.

Should a therapy agency file 1099s for contractors paid less than the threshold?

It is worth discussing with a CPA. Section 530 safe harbor protection against back employment taxes requires reporting consistency, meaning all required Forms 1099 were filed for those workers, and if a worker is later reclassified the reduced rates under IRC section 3509 are lower when the forms were filed, roughly 10.68% of wages versus about 13.71%. Because the cost of filing an additional form is minimal, many agencies file above the strict minimum as protection.

Not legal or tax advice. This article is general information for agency owners, not legal, tax, or employment advice. Worker classification and information-reporting rules are fact-specific and change. Figures here reflect federal rules for the 2026 tax year; state rules differ. Confirm your own situation with a CPA or employment attorney before acting.

AC
Andrew C., PT, DPT
Physical Therapist & Founder, HomeHealthSync

Andrew built HomeHealthSync after running a home health therapy staffing agency and spending too many hours on manual billing and contractor management. HomeHealthSync automates the entire workflow — from visit submission to contractor payment — for PT, OT, and ST therapy staffing agencies. His article “From Clinician to Contract Therapy Owner: The Back-Office Reality Nobody Prepares You For” appears in The Quarterly Report, the publication of APTA Home Health, an Academy of the American Physical Therapy Association (Summer 2026, Vol. 61 No. 3; member access).