CMS Updates Provisions of the Clinical Laboratory Fee Schedule for 2025

The Centers for Medicare & Medicaid Services (CMS) has delayed the Clinical Laboratory Fee Schedule (CLFS) data reporting period and the phase-in of payment reductions for 2025 and made updates to tests subject to the reasonable charge payment.

Passage of section 221 of the Continuing Appropriations and Extensions Act of 2025 (H.R.9747) delayed data reporting requirements for clinical diagnostic laboratory tests (CDLTs) that are not advanced diagnostic laboratory tests (ADLTs). This legislation also delayed the phase-in of payment reductions under the CLFS from private payer rate implementation.

The changes, effective Jan. 1, 2025, included:

• A data reporting period from Jan. 1, 2026, to March 31, 2026 (based on the original data collection period of Jan. 1, 2019, to June 30, 2019). Following this data reporting period, there will be a three-year data reporting cycle for CDLTs that are not ADLTs (starting in 2029).
• A zero percent payment reduction for calendar year 2025 for CDLTs. For calendar years 2026 to 2028, CMS will not reduce payment by more than 15 percent per year compared with the payment amount established for the test in the preceding year.

The minimum payment amount for 2025 is $18.19, a 2.4 percent increase from 2024, which is applicable for payments made on a reasonable charge basis according to the Consumer Price Index-Update. The affected codes for the national minimum payment amount are: 88142, 88143, 88147, 88148, 88150, 88152, 88153, 88164, 88165, 88166, 88167, 88174, 88175, G0123, G0143, G0144, G0145, G0147, G0148, Q0111, Q0115, and P3000.

The 2025 CLFS also includes separately payable fees for certain specimen collection methods (codes 36415, P9612, P9615, and G0471).

Sources:

https://www.cms.gov/files/document/mm13889-clinical-laboratory-fee-schedule-2025-annual-update.pdf