(May 1, 2026) – Congressional action to delay scheduled Medicare laboratory payment cuts also updated the timeline for Clinical Laboratory Fee Schedule data reporting under the current payment system. Applicable laboratories, including hospital outreach laboratories, will be required to report private payer data for Jan. 1 through June 30, 2025, during the reporting window of May 1 through July 31, 2026. The Centers for Medicare & Medicaid Services will use this data to set Medicare payment rates that will take effect in 2027.
"Applicable laboratories" must report detailed information on private payer rates, associated test volumes and corresponding HCPCS codes. Reporting must reflect final payment amounts, including patient cost-sharing. Additional details on "applicable laboratories" and reporting requirements are available here.
CMS requires data submissions through its Enterprise Portal using a standardized reporting template. Each reporting entity must designate a submitter and a certifier and complete registration before the reporting period begins. Given the complexity of data collection and validation, especially for organizations with multiple payer contracts or decentralized systems, early preparation is critical.
The reported data will be used to develop 2027 Medicare CLFS rates, which are weighted medians of private-payer rates and may result in rate reductions of up to 15 percent for certain tests. Hospital outreach laboratories should assess their reporting readiness now and review detailed implementation guidance to ensure compliance and mitigate financial risk.
The presentation provides an overview of the reporting requirements. The American Clinical Laboratory Association has been lending its expertise to cohost educational sessions for federal and state associations, helping members understand their obligations.
--Shannan Flach