The Consolidated Appropriations Act of 2026, signed into law Feb. 3, includes updates to the Medicare Clinical Laboratory Fee Schedule (CLFS) under the Protecting Access to Medicare Act (PAMA). These updates include a data reporting period from May 1-July 31, 2026, based on private payer data collected from Jan. 1-June 30, 2025, and a delay of planned payment reductions through 2026. PAMA reformed the CLFS into a single national fee schedule based on private market data from “applicable laboratories” serving Medicare beneficiaries, including hospital outreach, independent and physician office laboratories.
Additional updates under PAMA include:
- Delays CLFS rate reductions of up to 15% through Dec. 31, 2026.
- Updates private payer data that the Centers for Medicare & Medicaid Services (CMS) will use to set the 2027 CLFS rates by shifting the data collection period to Jan. 1 through June 30, 2025, rather than the same period in 2019.
- Establishes the May 1-July 31, 2026 data reporting period for applicable laboratories, to allow the CMS to calculate CLFS rates that will be effective Jan. 1, 2027.
A hospital-based outreach laboratory is considered an “applicable laboratory” if it meets the following criteria:
- Furnishes laboratory tests to nonpatients, rather than admitted inpatients or registered outpatients.
- Bills for Medicare Part B laboratory services furnished to nonpatients using the Form CMS-1450 under type of bill 14X.
- Meets or exceeds the low expenditure threshold, having received at least $12,500 in Medicare CLFS revenues during the six-month data collection period.
The MHA encourages hospitals to monitor the CMS CLFS reporting website for updated materials, including frequently asked questions, the required Excel reporting template and the list of test codes for which laboratories are intended to report private payor rates and volumes.
Members with enrollment questions should contact the MHA health finance team.
