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Dear ASHI Members,
Recent federal legislation has delayed the next round of Medicare payment reductions under PAMA until 2027. While the cuts are on hold, data collection and reporting requirements are moving forward, and applicable histocompatibility and immunogenetics laboratories should begin preparing now.
Click here to determine if your laboratory is an “applicable laboratory”.
The American Society for Histocompatibility and Immunogenetics wants to ensure its members are aware of the upcoming obligations.
What Data Must Be Collected
Laboratories that meet the definition of an applicable laboratory under revised PAMA rules must collect private payer payment rates for applicable laboratory tests from January 1 – June 30, 2025. This includes the final payment amount received from private payers, not billed charges.
When to Report
Required data must be submitted to the Centers for Medicare & Medicaid Services (CMS) between May 1 – July 31, 2026. Failure to report, if required, may result in civil monetary penalties.
Next Steps
- Determine whether your laboratory qualifies as an “applicable laboratory” under CMS rules.
- Confirm your billing and finance systems can accurately capture private payer payment data.
- Coordinate internally to ensure appropriate data extraction and validation processes are in place.
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Monitor CMS guidance for additional technical reporting instructions.
Although reimbursement reductions have been postponed, the 2025 data collected will directly influence future Medicare payment rates under the Clinical Laboratory Fee Schedule.
ASHI will continue to monitor federal developments and provide updates relevant to histocompatibility and immunogenetics laboratories.
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