PAMA Reporting Is Over: What Independent Labs Should Fix Before 2027

Independent clinical laboratories spent much of 2026 preparing for one major date: July 31. That was the close of the latest PAMA private payer reporting window. Applicable laboratories submitted rate and volume information that CMS will use to help establish Clinical Laboratory Fee Schedule payment rates for 2027 through 2029.

The reporting may be finished, but the financial work is not. September is the right time for laboratory leaders to ask a more practical question: how prepared is our revenue cycle for what comes next?

For molecular, pathology, toxicology, genetic, clinical and NGS laboratories, the answer will not be found only in Washington. It will be found in denials, underpayments, aging A/R, payer behavior, claim edits, incomplete documentation and claims that never reached the payer.

Why the 2026 PAMA Reporting Cycle Matters

According to CMS CLFS guidance, the 2026 PAMA reporting period ran from May 1 through July 31 and covered applicable information collected from January 1 through June 30, 2025. CMS will use that data to help establish rates for 2027 through 2029.

For 2026, laboratories received temporary protection from additional phase in reductions. Under current law, reductions can resume in 2027, subject to the statutory annual limit.

What About the RESULTS Act?

The laboratory industry continues supporting PAMA reform through the RESULTS Act. The important note is simple: the RESULTS Act is proposed legislation. It has not become law. Laboratories should not build financial plans around the assumption that legislative relief will arrive before 2027.

The Bigger September Story Is Revenue Leakage

Reimbursement pressure is visible when Medicare changes a fee schedule. Revenue leakage is often harder to see because it happens in smaller steps throughout the billing process.

• Coverage is not verified before the claim is submitted
• The payer ID or subscriber information is incorrect
• Diagnosis information does not support the test ordered
• Prior authorization is missed or not documented
• A required modifier is missing
• A completed test never becomes a submitted claim
• A payer reimburses less than the contracted amount
• A denied claim does not receive timely follow up

None of these requires a Medicare reimbursement cut to harm profitability. At laboratory volume, even small workflow gaps can become meaningful losses.

Look Beyond the Overall Denial Rate

A laboratory wide denial rate is useful, but it can hide the real issue. Segment the numbers by payer, CPT code, test type, location, ordering provider, denial reason, authorization status and medical necessity issue.

One commercial payer may account for a disproportionate share of denied dollars. One high value molecular test may create far more financial exposure than a larger number of low dollar denials. One ordering location may consistently send incomplete information.

The goal is not only to work denials faster. The goal is to identify which workflow is creating the denials in the first place.

Do Not Ignore Claims That Were Never Submitted

Denials appear on reports. Unsubmitted claims can be easier to miss. Laboratories should know how many completed tests are tied to claims that have not gone out the door, why those claims are sitting, how long they have been there and what the dollar value is.

Paid Does Not Always Mean Paid Correctly

Underpayments are another source of leakage. A claim can be marked as paid while the payer reimburses less than the expected contract amount. That may result from incorrect contract rates, payer processing errors, bundling issues, posting mistakes or payer methodology changes.

A simple example makes the point. If a lab performs 10,000 instances of a test annually and an unnoticed reimbursement variance averages only $7 per claim, the difference is $70,000. The lab already performed the work. The question is whether the revenue cycle can identify the variance.

Build a September Revenue Scorecard

Before Q4, leadership should establish a baseline for clean claim rate, initial denial rate, days in A/R, A/R over 90 days, appeal success rate, underpayment variance, authorization denials, medical necessity denials and claims never submitted.

Do not measure simply to create another report. Use the numbers to choose a problem that can be corrected before 2027.

What Laboratories Can Control Before 2027

Independent laboratories cannot control every CMS decision, payer rule or congressional timeline. They can improve what happens between the order and the payment.

• Improve eligibility workflows
• Find recurring denial patterns
• Identify claims that were never submitted
• Review old accounts receivable
• Audit underpayments
• Catch documentation and medical necessity issues earlier
• Measure revenue risk by payer, test and location

That work should not wait until January. It should begin now.

Find Out Where Your Lab Stands

Advanced Data Systems has worked with healthcare organizations since 1977. The ADS laboratory billing platform supports clinical, toxicology, pathology, genetic, molecular and NGS laboratories with billing software, RCM services, eligibility verification, prior authorization options, denial prevention, EOB reconciliation, analytics and integration with virtually any LIS or LIMS.