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PAMAwatch

The PAMA window closed July 31, 2026. What now?

The direct answer first. The reporting window for the current PAMA cycle ran May 1, 2026 through July 31, 2026 and is over; CMS’s reporting resources page (last modified August 3, 2026, read 2026-08-25) now opens with “The 2026 data reporting period ended on July 31, 2026. Thank you for reporting your data.” Whether that closure matters to your laboratory depends on a status only your own 2025 revenue records can establish. If your determination comes out negative, nothing was owed and nothing follows. If it comes out positive and no report was filed, the regulation carries a civil monetary penalty authority, quoted below exactly as written, and CMS’s public documents, as of the dates on this page, publish no procedure for reporting late. The rest of this page is the evidence for each of those clauses, and nothing else.

What the closed window was

Section 6226 of the Consolidated Appropriations Act, 2026 (Public Law 119-75, enacted February 3, 2026) set this cycle’s dates: reporting “May 1, 2026, and ending July 31, 2026” (the words its amendment inserts into section 1834A(a)(1)(B) of the Social Security Act), on data collected January 1, 2025 through June 30, 2025. CMS’s PAMA FAQ (updated July 14, 2026, read 2026-08-25) confirms both in its A1.1.

Note what the obligation attached to: not to “labs” generally, but to reporting entities for their component applicable laboratories, a status each entity determines for itself from its own Medicare revenue composition. No list of who owed a report exists anywhere, which also means no list of who missed one exists anywhere. A page telling a named lab it failed to report would be inventing both halves.

The penalty authority, exactly as written

42 CFR 414.504(e) (eCFR text as of August 20, 2026, read 2026-08-25):

If the Secretary determines that a reporting entity has failed to report applicable information for its applicable laboratories, or made a misrepresentation or omission in reporting applicable information for its applicable laboratories, the Secretary may apply a civil monetary penalty to a reporting entity in an amount of up to $10,000 per day, as amended by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015 (Sec. 701 of the Bipartisan Budget Act of 2015, Pub. L. 114-74, November 2, 2015), for each failure to report or each such misrepresentation or omission.
42 CFR 414.504(e)

Three readings of that text, staying inside it. First, “may”, not “shall”: it is an authority, and this page has no information about how CMS exercises it. Second, it covers misreporting as much as silence: an inaccurate filing is inside the same sentence as no filing. Third, the $10,000 is indexed. The current adjusted ceiling is published in the HHS penalty table at 45 CFR 102.3 (eCFR text as of August 20, 2026, read 2026-08-25), which lists this authority, cross-referenced to 42 CFR 414.504(e), at a 2025 maximum adjusted penalty of $13,295 per day, up from $12,958 for 2024. The same section states the cadence: “The civil monetary penalty amounts are adjusted annually.”

CMS’s own FAQ words the authority the same way (Q6.1): “The statute authorizes CMS to impose civil monetary penalties of up to $10,000 per day, adjusted for inflation as required by the Inflation Adjustment Act Improvements Act of 2015, for each failure to report or each misrepresentation or omission in reporting applicable information.” That is the entirety of the FAQ’s penalties section.

What CMS’s public pages do not say

Two absences are worth stating precisely, as observations about documents on their read dates, not as predictions. The reporting resources page (August 3, 2026 version) and the 18-page FAQ (July 14, 2026 version) publish no late-reporting procedure, no grace period, and no statement about enforcement posture for this cycle. And neither document publishes a correction path for a filing an entity later believes was wrong. Both documents route questions to CMS’s CLFS inbox, clfs_inquiries@cms.hhs.gov, which is where a question those pages do not answer belongs. If CMS publishes guidance on either point, it supersedes this paragraph; the dates above say exactly which versions were read.

What is still in a lab’s control in August 2026

The determination itself, and its paper. The two revenue tests run on services furnished January 1, 2025 through June 30, 2025, out of records a laboratory already holds, so the status question is answerable today with certainty, in either direction. A written determination, dated and kept with its revenue extract, is worth more after a window than before it: it is the difference between “we assessed this and were out of scope” and silence. The public half of the picture, what CMS’s published payment file shows for a given NPI against the one threshold that is public, is what pamawatch.com/check displays, and it stops at that boundary because the other test is not computable from outside.

The calendar is also known. CMS’s FAQ: “After this data reporting period, the three-year data reporting cycle for these tests will resume (that is 2029, 2032, etc.).” The FAQ does not state the collection window that will feed the 2029 reporting, and this page will not guess it; by the regulation’s standing definition the collection period is a January through June window preceding the reporting period, and which year’s becomes knowable when CMS says so. ADLTs run on their own annual track (42 CFR 414.504(a)(2)) and none of this page’s cycle arithmetic applies to them.

Sources, each read this session

CMS, CLFS and PAMA Reporting and Resources page, last modified August 3, 2026, read 2026-08-25. CMS, Private Payor Rate-Based CLFS FAQs, updated July 14, 2026, read 2026-08-25. 42 CFR 414.504 and 45 CFR 102.3, eCFR text as of August 20, 2026, read 2026-08-25. Section 6226 of Public Law 119-75 (140 Stat. 684), enacted February 3, 2026, read 2026-08-25 on govinfo. Quotes verbatim, with this site’s standing substitution: no dash characters anywhere, so any dash inside a source is rendered as a colon or the quote is split around it.

Published by Neige AI, Inc. See the method and sources.

This page is independent research, not legal or financial advice. It quotes 42 CFR part 414, 45 CFR 102.3 and Public Law 119-75 with pinpoint citations. Verify anything load-bearing against the primary text itself before acting on it.

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