AHA comments to CMS on preliminary 2027 Medicare clinical laboratory fee schedule rates

The AHA submitted comments to the Centers for Medicare & Medicaid Services Oct. 21 on its preliminary calendar year 2027 Medicare clinical laboratory fee schedule rates. The AHA said the preliminary rates highlight the need for substantial reforms to CMS’ methodology, saying they are based on incomplete data. The AHA discussed the requirement under the Protecting Access to Medicare Act that called for hospital outreach laboratories and other clinical laboratories to report their private payer data to CMS between May 1 and July 31, 2026. Only 2% of laboratories paid under Medicare Part B reported any information at all to CMS. The AHA noted there was widespread confusion among laboratories that did report their data regarding whether they were suitably qualified as “applicable laboratories” and what data they needed to report. The AHA expressed concerns that the underreporting means CMS’ preliminary 2027 rates do not reflect the “market-based payments” that Congress mandated under PAMA, resulting in substantial proposed cuts to Medicare CLFS reimbursement for hundreds of codes. The AHA said these cuts threaten seniors’ access to essential clinical laboratory testing and continued investment in diagnostic innovation.

The AHA also said it was concerned that CMS’ approach to collecting applicable private payer information directly from clinical laboratories is inadequate for setting fully “market-based” rates. To help address these concerns, the AHA urged CMS to provide support and technical assistance to Congress as it considers the Reforming and Enhancing Sustainable Updates for Laboratory Testing Services (RESULTS) Act of 2025, which consists of efforts designed to improve private payer data collection by CMS to set Medicare Part B CLFS rates.