Tuesday, March 24, 2026

Nerd Note: 2017 PAMA Raw Data File is Still Posted

Header:  CMS still stores publicly available cloud data on lab test pricing surveyed in 2017 and representing CY2016.

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 Congress and CMS are re-activating the PAMA reporting process.  For reporting laboratories who had >$12500 in Medicare payments in 1H 2025, they will report data on all claims paid by commercial payors in 1H2025, and they will report in May-June-July 2025.  See websites and announcements at CMS.

https://www.cms.gov/medicare/payment/fee-schedules/clinical-laboratory-fee-schedule/clfs-reporting

The prior survey reporting 1H2016, reported and posted in 2017.  This set a new fee schedule for 2018 forward.

See the 2016/2017 Cloud Data 

At the time, CMS published a gigantic cloud database of reported prices.  I thought that was no longer available, but it seems it is.   The data can be pretty interesting.

On this page:

https://www.cms.gov/medicare/payment/fee-schedules/clinical-laboratory-fee-schedule-clfs

see "CLFS Applicable Raw Data File from 2017 Reporting."


That sends you here:

https://data.cms.gov/provider-characteristics/hospitals-and-other-facilities/medicare-clinical-laboratory-fee-schedule-private-payer-rates-and-volumes


For example, if you search 81211 (a popular BRCA code in 2016), you get 374 rows of data.   

I wasn't sure how that squares with a contemporary old 2017 data file I havea for PAMA 81211, which has 2364 rows of pricing data for 81211.  I think the current cloud data leaves out all price reporting with less than 10 units per line, and my old file with 2364 lines includes many lines with only 1 or 2 payments at that price.  The overall shape of the data would be the same, just scaled down.

For example, the 2016 data I have (with 2364 lines) for BRCA 81211 shows a large price peak around $2900, which I assume reflect Myriad payments (this was not long after the BRCA Supreme Court case), and relatively few commercial payments at the CMS rate back then (around $2200) but another peak of payments around $1800, which was 85% of the CLFS at the time.   So I inferred (this is just armchair guessing) that Myriad was cruising along with numerous legacy contracts in the $3000 range for BRCA 81211, while new entrants were entering the newly opened BRCA market often at 85% of the CLFS.   

It was also notable that the thin tail of cheapest payments went below $100 and thin thin top end had the rare payment over $6000.