Under the Protecting Access to Medicare Act (“PAMA”), certain laboratories must report private payor data to the Centers for Medicare & Medicaid Services (“CMS”). This data is in turn used by CMS to establish a single, national Clinical Laboratory Fee Schedule. For a more detailed discussion on PAMA and the types of laboratories that are required to report see our previous article available here.

Laboratories that qualify as “applicable laboratories” under PAMA are required to report private payor data every three years and were supposed to report data between January 1 and March 31, 2020. However, Section 105(a)(1) of the Further Consolidated Appropriations Act of 2020 delayed the reporting requirements by one year. Accordingly, applicable laboratories must now report private payor data between January 1 and March 31, 2021. It is important to note that although the data reporting period was delayed by one year, labs must still report data from the original data collection period of January 1 through June 30, 2019. Thereafter, data reporting will resume on a three-year cycle, beginning in 2024.

CMS issued updated instructions on the PAMA reporting requirements with the revised data, which is available here.