CMS says preliminary 2027 lab rates come in about 16% lower. That sounds like new news. But run the first PAMA round through the same weighted-median formula — using its own raw file — and most lab tests were already being paid above what private payers paid in 2016. Here are 942 tests, one dot each.
Primary source:CMS, “Preliminary CY 2027 Medicare Clinical Laboratory Fee Schedule Payment Rates,” fact sheet, September 21, 2026 — 6,411 reporting labs, 1,528 of 1,947 codes with a weighted median, average potential change ~16% lower, cuts capped at 15% a year for 2027–2029. Data: CMS CLFS private-payer rate & volume raw file from the 2017 reporting round (collected Jan–Jun 2016), and the 2026 CLFS national rates (base rate, no modifier, nationally priced), both via MIMI Labs. The weighted median below is recomputed by us from the raw rows; it will not exactly match CMS’s official figures. The per-code 2027 file isn’t in this dataset yet.
tests where the 2016 private-payer median sat below Medicare’s 2026 rate
…
Every test, against its own median
Each dot is one lab test code. Up and down is how the recomputed 2016 private-payer weighted median compares with Medicare’s 2026 rate: below the zero line, private payers paid less. Left to right is how many private-payer price reports stand behind that median. Watch the shape: it’s a funnel. Hover any dot.
drag right to drop thin-sample codes
Test category (by CPT range)
Tests shown–
Median below 2026–
Median above 2026–
Volume-weighted gap–
Gap beyond 15%–
Gap = recomputed 2016 weighted median ÷ 2026 Medicare rate − 1. Values beyond +150% are pinned to the top edge. Dashed lines: the 15% one-year cap and the 38.6% three-year compounded cap.
What the funnel is telling you
At the thin end, where a median rests on a handful of reports, dots scatter above and below zero — including tests where private payers seemingly paid five times Medicare. Those are the noise. Drag the slider to 500 reports and the codes where private payers paid more nearly vanish: …. What’s left is a tight band sitting below zero. The high-volume tests — lipid panels, CBCs, TSH, A1c — were already priced above their own 2016 private-payer median, because the first round’s cuts were capped at 10% a year and then frozen from 2021 through 2026.
What a 15% cap does to any cut
The 2026 appropriations law caps each test’s drop at 15% per year for 2027–2029. Pick how far a test’s new weighted median sits below its 2026 rate and watch the phase-in.
2027 payment–
2028–
2029–
Reaches median–
Index: 2026 Medicare rate = 100. Each year pays the larger of the new weighted median or 85% of the prior year. Category averages are from the CMS fact sheet; a simple average hides codes cut far deeper.
Where this dataset is thin — read before quoting
It’s the old round. These private-payer prices were paid in the first half of 2016. The 2027 rates come from January–June 2025 data, which isn’t in this file. This chart shows the starting gap, not the new medians.
The reporters changed. In 2017, 1,942 labs reported and only 21 were hospital labs. In 2026, 6,411 reported, including 875 hospital labs (CMS fact sheet). A different set of labs can land on a different median.
Recomputed, not official. The raw file has no lab identifier, so CMS’s duplicate-removal rule can’t be reproduced. Our weighted median counts every row, including a handful of $0 and five-figure prices that look like entry errors.
Suppression. Tests with reported volume of 10 or fewer are absent. The raw file has 1,013 codes; 942 match a nationally priced 2026 rate. No PLA (proprietary) codes appear: most didn’t exist yet in 2016.
Volume isn’t Medicare volume. The “volume-weighted gap” weights by private-payer test counts, not Medicare spending.