Advocacy - Comment Letter
ADLM recently joined stakeholder allies advocating for the RESULTS Act (S. 2761 / H.R. 5269), bipartisan legislation aimed at preventing imminent cuts to Medicare Clinical Laboratory Fee Schedule (CLFS) rates and addressing persistent challenges stemming from PAMA implementation. Under current law, nearly 800 tests are slated for reimbursement reductions of up to 15% beginning January 31, 2026, which could further strain laboratories already operating under tight margins and threaten patient access to essential diagnostic services.
Since the Protecting Access to Medicare Act (PAMA) was implemented, Medicare has based CLFS rates on private-payer data submitted by a small subset of laboratories. Because that data did not reflect the full laboratory marketplace, payment rates have often been artificially suppressed, resulting in significant reductions for many widely used tests. While Congress has repeatedly delayed both payment cuts and reporting requirements, those temporary actions have not resolved the underlying flaws in the rate-setting methodology.
Without legislative reform, laboratories may face both the resumption of payment cuts and a new round of PAMA data reporting in 2026. Under the current timeline, applicable laboratories will be required to report private-payer rates and volume data during the February 1 through April 30, 2026 reporting period, based on payment data from the first half of 2019. CMS will then use this outdated, pre-pandemic data to update CLFS rates effective January 1, 2027, potentially locking in reimbursement levels that do not reflect today’s testing environment, costs, or operational realities.
The RESULTS Act seeks to modernize and stabilize the CLFS by broadening the types of laboratories that report data, reducing administrative burden, improving the representativeness of the data used to set payment rates, and helping avert steep, recurring cuts. ADLM is actively supporting this legislation and working with allied organizations to present a unified, evidence-based message to lawmakers.
ADLM will continue coordinating with coalition partners and engaging congressional offices on the urgent need for sustainable Medicare payment policy and will keep members informed as advocacy efforts continue.