The Panel Voted Gapfill 160 Times and Won 22
Four hundred eleven lab codes went through Medicare's 2026 reporting window without a single private payor rate reported. The expert panel the statute tells CMS to consult voted to gapfill 160 of them, CMS substituted a crosswalk on 138, and $140,591 of rate value is riding on a comment window that closes November 19.
Eleven people sat through a two-day video meeting on September 15 and 16 and voted, code by code, on how Medicare should price 411 clinical laboratory tests that nobody reported a private payor rate for.
On 160 of them the panel's answer was gapfill. Don't guess at a price from some other test, make the contractors build one.
CMS kept 22 of those.
The file carrying that result went up on the CLFS annual public meetings page on October 19 with no posting date beside it, while the rows above and below it are stamped. The only timestamp it carries is an HTTP header.
Inside is the CY 2027 preliminary determination for every code that received no applicable information during the May 1 to July 31 reporting period that section 6226 of the Consolidated Appropriations Act, 2026 set.
CMS's split across the 411 is 389 crosswalk, 22 gapfill.
And the disagreement runs one direction only (chart below). Where the panel voted crosswalk, CMS took it, all 251 times.
Where the panel voted gapfill, CMS took it 22 times and substituted a crosswalk on the other 138. Not one crosswalk was converted into a gapfill.
133 of those 138 carried a unanimous panel vote, 11 out of 11.
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