Wednesday, November 11, 2026

PAMA: The Secret Data Views that CMS Never Displays (for GSP Genomic Sequencing Procedures)

Medicare genomic sequencing pricing under PAMA is based on anywhere from 200 to 275,000 claims for the "GSP" service type.   For Exome and Genome, a large body of claims were paid at about half the Medicare CLFS rate.

Note that none of this data is Medicare data; it's private payer data...the behavior of private payers

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Goodbye to a myth?

Are CMS CLFS prices a benchmark that strongly drive the market?   Well, the data shows that for some  codes (from 81408 to 81425) the actual market prices can be skewed or centered quite a distance from the CLFS benchmark at the time.

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What's Up?

Medicare's public raw data files for PAMA 2026 provide interesting data views.  Here, I reveal some more, using simple commands and Chat GPT 6.

Case Study: GeneDx (ticker WGS)

The information is relevant. Over the past year, GeneDx has been battling reimbursement issues, with share price varying in that time from around $33 to around $170.  On one day in May, the share price dropped 50%.   

PAMA Prices Trend Down for Exome, Genome

Not helping is the downward trend in the latest PAMA data for genomic procedures, including 81415 exome and 81425 genome.   Here's some data; I include the $2000 (CLFS) rare gene code 81408.

In each case below, the current CMS CLFS price is in the fourth column.  But a lot of the reported payments are cheaper: most of the claims for 81415 (exome, middle row) and 81425 (genome, bottom row) are in the second and third columns.  Those are claims at $1400-2800 [second column] and $2800-4200 [third column.] 

Note that exome, but not genome, has a significant bump to-the-right (blue bar in column 6).  We showed earlier that such behavior, high-paying plans, can really drive free cash flow and profit.  


Star - CLFS price

The skew to the left is even more prominent for 81408, where many payments populate the far left bar ($0-550, while CMS price, $2000).

So if my market depended on the price of Genome being $5000 or nearby, and the largest bucket was column 2, $1400-2800... eeek.

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Also in the 814nn series, GSP or Genomic Sequencing Procedures, CMS let us count how many services or claims were reported for about 36 GSP codes.   Here is a sample screen shot:


Here's the full table:


Here's the Tier 2 claims, 81400 to 81408 as a bar chart.