Medicare Billers Face First New Pricing in Years and Compressed CLFS Timelines

On May 1, 2026, CMS published three interconnected Federal Register notices that set the stage for how Medicare will price clinical laboratory tests in calendar year 2027. They announce the rechartering and new membership of the Medicare Advisory Panel on Clinical Diagnostic Laboratory Tests, schedule the annual clinical laboratory fee schedule (CLFS) public meeting for June 10, and announce a separate September meeting focused on tests for which CMS received no private payor data. Of note, May 29, 2026, is the fast-approaching registration deadline for presenting at two upcoming meetings.

Entities that bill Medicare under the CLFS may want to keep a few things in mind.

1. The CLFS Annual Public Meeting is June 10, registration and presentation deadline is May 29.
CMS will hold its annual public meeting on June 10, 2026, in a hybrid format at the CMS campus in Baltimore and online. This is the primary forum for the public to present comments and recommendations on the appropriate basis for establishing payment amounts for new and reconsidered Healthcare Common Procedure Coding System codes under the CLFS. Laboratory or diagnostics companies wishing to have a stake in how a new or substantially revised test code is priced should consider providing input at this meeting. Presenters must register and submit their presentations electronically by May 29, 2026, at 5 p.m. EDT. Written comments from nonpresenters are due by the same deadline. Presentations are limited to 10 minutes and should address the code descriptor, test purpose and method, test costs, charges, and a recommendation for crosswalking or gapfilling with supporting rationale.

2. The CDLT Advisory Panel has been rechartered and has new members and a new chair.
HHS Secretary Robert F. Kennedy Jr. rechartered the Medicare Advisory Panel on Clinical and Diagnostic Laboratory Tests effective April 24, 2025, through April 24, 2027. A new panel chair and several other new members have been appointed. The panel’s role is to provide recommendations to CMS on whether to use crosswalking or gapfilling to establish payment rates for new tests, the factors used in coverage and payment processes, and other aspects of the CLFS payment system. The panel will meet on July 14 and 15, 2026, to discuss and make recommendations on the codes presented at the June 10 public meeting. Standby speakers for the July meeting must also register by May 29.

3. A separate September meeting will address tests with no applicable private payor data, directly tied to the PAMA reporting period finally happening.
After years of Congressional delays, the private payor data reporting period under section 1834A of the Protecting Access to Medicare Act (PAMA) is now underway: reporting entities must submit applicable information collected from January 1 through June 30, 2025, during the reporting window of May 1 through July 31, 2026. For tests where CMS receives no applicable information through this process, CMS will use crosswalking or gapfilling to set rates. The list of those codes will be posted in early August 2026, and a virtual public meeting on Sept. 15 and 16, 2026, will give the public and the CDLT Advisory Panel an opportunity to present and discuss recommendations for those specific tests. Registration and presentations for the September meeting are due by Aug. 21.

4. Timeline is compressed, and deadlines are stacked.
The practical reality of these three notices is a series of overlapping deadlines and action items between now and the fall. The May 29 deadline covers the June public meeting registration and the July CDLT Advisory Panel meeting standby speaker registration. Proposed determinations for new and reconsidered codes are expected in September, with a public comment period closing in October. Final determinations are expected in November 2026. For laboratories, diagnostics companies, and pathology groups with codes in play, this timeline requires advance effort to prepare presentations as well as assembling the cost, charge and rationale data that CMS expects.

5. The CLFS pricing landscape may shift meaningfully for the first time in years.
The convergence of the first PAMA private payor data reporting period since 2017, new panel membership and the standard crosswalk-and-gapfill process for new codes makes 2027 a consequential year for laboratory reimbursement under Medicare. Laboratories that rely on the CLFS for a significant portion of their revenue should be monitoring the code lists as they are posted, evaluating whether to submit comments or presentations, and understanding how the crosswalking and gapfilling determinations could affect their test menus. CMS has historically considered substantive input during public comment periods when making final determinations.

The window for engagement is open now and closing fast. The June, July and September meetings are the primary forums for influencing 2027 CLFS pricing, with the May 29 deadline for the first two of those meetings quickly approaching.