Reviewed by Chris Saviano
Key Takeaways
- Congress blocked scheduled Clinical Laboratory Fee Schedule cuts for 2026 through the Consolidated Appropriations Act, 2026, signed February 3, 2026.
- The 2026 PAMA reporting window ran May 1 through July 31, 2026, and has already closed.
- Labs reported private payer data from January through June 2025, not the outdated 2019 data originally planned.
- Absent further action, CLFS rates can be cut by up to 15 percent per year for 2027, 2028, and 2029.
- The RESULTS Act, the leading permanent fix, has bipartisan support but has not passed Congress.
Congress delayed the next round of Medicare Clinical Laboratory Fee Schedule cuts for 2026 and reopened PAMA reporting under revised terms. It is not a permanent fix, and the law that provided it set up a new deadline that starts in 2027. Here’s what actually happened, what’s still unresolved, and what a laboratory should be watching next.
What Just Changed for 2026
Section 6226 of the Consolidated Appropriations Act, 2026, signed into law on February 3, 2026, did two things. First, it eliminated the scheduled CLFS payment reduction for 2026, so no phase-in cut applied this year. Second, it reopened the PAMA private payer data reporting cycle on a revised timeline. According to CMS’s own CLFS and PAMA reporting page, the reporting window ran from May 1 through July 31, 2026, and has already closed.
Applicable laboratories, generally those receiving more than half their Medicare revenue from the CLFS or Physician Fee Schedule, and at least $12,500 of it from the CLFS, were required to report private payer rates and test volumes during that window. CMS will use that data to set CLFS rates effective January 1, 2027.
Why the Data Collection Period Moved From 2019 to 2025
Before this year’s change, the next reporting cycle was still set to use private payer data from 2019, seven-year-old numbers that no longer reflected current market rates for most labs. The Consolidated Appropriations Act updated the data collection period to January 1 through June 30, 2025 instead. CLFS rates for 2027 will be based on payer rates that are actually current, rather than a pre-pandemic snapshot most labs would have struggled to reconstruct accurately.
What’s Coming in 2027 If Nothing Else Changes
The relief Congress passed covers 2026 only. Starting January 1, 2027, and continuing through 2029, CLFS payment reductions are capped at up to 15 percent per year compared to the prior year’s rate for each test, based on the newly reported private payer data. That’s a ceiling on how much a test’s rate can drop in a single year, so a test could see reductions in more than one of those years.
The American Clinical Laboratory Association estimates that roughly 800 to 820 commonly billed laboratory tests are exposed to these reductions absent further congressional action. That figure comes from ACLA’s advocacy materials, not from CMS directly, so it’s worth treating as an informed industry estimate rather than an official government projection.
The RESULTS Act: The Permanent Fix Still Waiting on Congress
The Reforming and Enhancing Sustainable Updates to Laboratory Testing Services Act, known as the RESULTS Act (H.R. 5269 in the House, S. 2761 in the Senate), is the bill the lab industry has coalesced around as a long-term replacement for the current PAMA reporting system. It builds on the earlier Saving Access to Laboratory Services Act, or SALSA, which was introduced in prior sessions but never passed.
Instead of relying on individual labs to self-report private payer rates, the RESULTS Act would have CMS contract with a third-party claims data entity to supply pricing information for widely available tests, and would cap future payment reductions at 5 percent per year once fully phased in, rather than the current 15 percent ceiling. The bill has bipartisan, bicameral sponsorship, five House members from both parties and two senators, one from each. As of this writing it has not been voted on by either chamber. ACLA, one of the industry groups pushing for the bill, said in February 2026 that its strategy is to attach the RESULTS Act to a year-end spending package, the same kind of vehicle that delivered the 2026 relief.
What Laboratories Should Do Now
The 2026 reporting window has closed, so for most labs the immediate compliance task is done. What’s left is preparation for what comes next:
- Confirm the data submitted during the May–July 2026 window was accurate and retain supporting documentation, since these submissions are regulatory filings subject to compliance review, not informal disclosures
- Track the RESULTS Act’s progress specifically, since its passage or failure will determine whether the 15 percent annual cap actually applies starting in 2027
- Model reimbursement exposure under both scenarios, RESULTS Act passage and the current law’s phase-in cap, rather than assuming either outcome; this is the kind of scenario planning laboratory analytics and reporting tools are built for
None of this requires immediate action beyond documentation and monitoring. But labs that wait until late 2026 to understand their 2027 exposure will have far less room to plan around it than labs tracking it now.
Staying Current on PAMA and CLFS Changes
PAMA reporting cycles and CLFS rate changes are exactly the kind of shifting regulatory landscape a laboratory billing partner should already be tracking. PGM’s laboratory billing and revenue cycle management team stays current on payer rate changes and reporting requirements as part of managing a lab’s day-to-day revenue cycle, so clients aren’t caught off guard by a compliance deadline or a rate change they didn’t see coming.
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Frequently Asked Questions About PAMA and CLFS Reporting
Is my laboratory an “applicable laboratory” under PAMA?
Generally, yes if more than 50 percent of your Medicare revenue during the data collection period came from the CLFS or the Physician Fee Schedule, and you received at least $12,500 in Medicare revenue from the CLFS during that period. Independent labs, hospital outreach labs, and physician office labs can all meet this definition depending on their billing structure.
Did the 2026 PAMA reporting deadline get delayed again?
It moved, but it wasn’t delayed indefinitely. The reporting window shifted to May 1 through July 31, 2026, and that window has already closed. Labs that were required to report needed to do so within that timeframe, using private payer data collected between January and June 2025.
What happens if a laboratory missed the PAMA reporting deadline?
PAMA authorizes significant civil monetary penalties for failing to report or for misrepresenting reported data, assessed per day of noncompliance. A laboratory that believes it missed a reporting obligation should consult with legal counsel or a billing compliance specialist promptly rather than waiting for CMS to raise the issue.
Will Congress pass the RESULTS Act before the 2027 cuts take effect?
There’s no way to know yet. The bill has bipartisan support in both chambers, and the industry groups backing it have said their strategy is to attach it to a year-end spending bill, the same mechanism that delivered the 2026 relief. It has not been voted on by either the House or Senate as of this writing, so its fate before January 1, 2027, remains genuinely uncertain.
How much could CLFS reimbursement change in 2027 if the RESULTS Act doesn’t pass?
Under current law, rates for affected tests could be reduced by up to 15 percent compared to the prior year, with that ceiling applying separately in 2027, 2028, and 2029. ACLA estimates roughly 800 to 820 commonly billed tests are exposed to these reductions, though that figure is an industry estimate rather than an official CMS projection.