I've seen academic papers on microcosting of genomic testing that ignored or under-weighted fully loaded costs. I once heard, "We weren't sure how to assign overhead so we ignored it in our publication." Ouch.
See a Swedish paper on "fully burdened cost" for standard of care CGP as well as WGS-based tumor testing (e.g. at 90X depth). Note that I find this very confusing, because they state in one place the costs are "fully burdened" and in other places, costs for overhead were "excluded."
Costs come into the range of €2500 for SOC and €3500 for WGS (e.g. $3000 and $4000 range). Actual costs (including regulatory, marketing, medicolegal) may be higher. But this clearly sets a benchmark that the lowball prices that CMS has sometimes proposed reflect a poor grasp of total costs.
See Thangavelu et al., J Medical Economics, here:
https://www.tandfonline.com/doi/full/10.1080/13696998.2024.2387515#abstract