The Centers for Medicare & Medicaid Services (CMS) is implementing a significant modernization of the Clinical Laboratory Improvement Amendments (CLIA) program. Beginning March 1, 2026, CMS will discontinue paper fee coupons and paper CLIA certificates. Laboratories will no longer receive mailed documents, and payment of CLIA certification and survey fees will be required online. Paper checks will no longer be accepted.
This transition is part of CMS’s broader digital transformation efforts aimed at improving administrative efficiency, reducing delays, enhancing communication accuracy, and strengthening regulatory oversight.
Laboratories and providers that perform laboratory testing under a CLIA certificate must act immediately to enroll in electronic notifications and ensure their contact information is up to date. Failure to transition to electronic communication may result in billing issues, delayed certification processing, or compliance risks.
Overview of CLIA and Why This Change Matters
The Clinical Laboratory Improvement Amendments (CLIA) of 1988 establish quality standards for laboratory testing performed on human specimens for health assessment, diagnosis, prevention, or treatment of disease. CMS regulates laboratories under CLIA to ensure accuracy, reliability, and timeliness of test results.
All laboratories performing testing on human specimens must hold a valid CLIA certificate appropriate to the complexity of testing conducted. These include:
Certificate of Waiver
Certificate of Provider-Performed Microscopy Procedures (PPMP)
Certificate of Registration
Certificate of Compliance
Certificate of Accreditation
Maintaining active CLIA certification requires:
Timely payment of certification fees
Payment of survey fees (when applicable)
Successful completion of inspections or accreditation reviews
Ongoing compliance with federal laboratory standards
The shift to electronic fee coupons and certificates directly impacts these administrative and compliance processes.
What Is Changing on March 1, 2026?
Effective March 1, 2026:
CMS will no longer mail paper CLIA fee coupons.
CMS will no longer mail paper CLIA certificates.
Laboratories must pay CLIA certification and survey fees online.
Paper checks will no longer be accepted.
This means that laboratories relying on mailed invoices or physical certificates for compliance documentation will need to update their internal workflows immediately.
CMS has clarified that this is the final opportunity for eligible laboratories and providers to enroll in electronic notifications.
Why CMS Is Eliminating Paper CLIA Documents
The transition reflects CMS’s efforts to:
Reduce administrative delays caused by mailing and manual processing
Improve billing accuracy and real-time fee tracking
Decrease lost or delayed certificates
Enhance environmental sustainability
Strengthen digital compliance tracking
Paper-based systems have historically created delays in certification renewals and billing reconciliation. Electronic delivery ensures immediate access to required documentation and reduces the risk of lapses in certification due to misplaced mail.
Who Is Affected?
The transition applies to:
Independent clinical laboratories
Hospital-based laboratories
Physician office laboratories (POLs)
Home health agencies performing lab testing
Hospice agencies performing lab testing
Skilled nursing facilities conducting testing
Any provider performing laboratory testing under CLIA certification
Important Exception:
This change does not apply to CLIA-exempt states.
CLIA-exempt states operate under state laboratory programs that CMS has determined meet or exceed federal CLIA requirements. Laboratories in those states should verify whether this transition impacts their specific processes.
Risks of Not Switching to Electronic Notifications
Failure to enroll in electronic notifications or update email information may result in:
From a regulatory standpoint, an expired CLIA certificate can result in immediate operational consequences. Laboratories may not legally perform testing without a valid CLIA certificate corresponding to the testing complexity.
In addition, Medicare reimbursement for laboratory services may be impacted if certification lapses occur.
How to Switch to Electronic CLIA Notifications
Laboratories must proactively transition to electronic communication by completing one of the following steps:
Option 1: Contact Your State Agency
Email your state CLIA agency to:
Enroll in electronic notifications
Confirm your laboratory’s email address
Update contact information
Each state maintains a designated CLIA contact. Laboratories should ensure the email provided is monitored by compliance or billing personnel.
Option 2: Contact Your Accreditation Organization
If your laboratory holds a Certificate of Accreditation, you must contact your Accreditation Organization (AO), such as:
Accredited laboratories should confirm that their AO has the correct email contact on file for CLIA communications.
Internal Compliance Action Plan for Laboratories
To prevent disruption, laboratories should implement the following internal controls:
1. Designate a Responsible Contact
Assign a compliance officer, laboratory director, or billing manager as the primary CLIA contact.
2. Update Contact Information
Ensure that:
Email addresses are accurate
Generic mailboxes (e.g., compliance@ or billing@) are monitored
Spam filters allow CMS communications
3. Revise Billing Procedures
Since paper checks will no longer be accepted:
Establish online payment access
Coordinate with finance departments
Update internal SOPs for fee processing
4. Update Policy and Procedure Manuals
Revise compliance manuals to reflect:
5. Maintain Electronic Records
Develop secure storage for:
These records may be required during inspections or audits.
Implications for Multi-Site and Corporate Laboratory Entities
Organizations operating multiple laboratory sites must ensure:
Each CLIA number is properly enrolled
Each location has accurate contact information
Corporate compliance teams coordinate with site-level leadership
Failure to enroll all sites may result in partial billing failures or certification discrepancies.
Corporate healthcare organizations, including home health and hospice providers operating under multiple CLIA certificates, should conduct a full inventory review of all active CLIA numbers.
Impact on Survey and Inspection Scheduling
CLIA certification cycles typically run every two years. Laboratories receive fee coupons before the certificate expiration date.
If electronic enrollment is incomplete:
Survey scheduling may be delayed
Certification renewal may not process timely
Risk of temporary suspension increases
Timely electronic enrollment ensures seamless survey coordination and uninterrupted certification cycles.
Financial and Regulatory Considerations
From a regulatory compliance perspective, laboratories must view this change as a mandatory modernization requirement, not an optional administrative update.
Key financial considerations include:
Ensuring timely online payments to avoid penalties
Reconciling electronic invoices with internal accounting systems
Budgeting for potential IT updates
Noncompliance could expose laboratories to:
Best Practices for Compliance Leaders
Compliance officers and laboratory directors should:
Conduct immediate readiness assessments
Communicate changes to executive leadership
Train administrative and billing teams
Audit CLIA certificate expiration dates
Document all communication with CMS or AOs
Proactive compliance management reduces regulatory risk and operational disruption.
Timeline Summary
Now – February 29, 2026
Laboratories must enroll in electronic notifications and update contact information.
March 1, 2026
Paper fee coupons and certificates are discontinued. Online payments required. Paper checks are no longer accepted.
After March 1, 2026
Laboratories not enrolled may experience billing or certification issues.
Strategic Considerations for Healthcare Organizations
For healthcare systems and compliance-driven organizations, this transition presents an opportunity to:
Centralize regulatory documentation
Digitize compliance workflows
Strengthen audit preparedness
Reduce reliance on manual processes
Organizations that integrate CLIA tracking into broader compliance dashboards will gain operational efficiencies.
Final Takeaway
CMS’s transition to electronic CLIA fee coupons and certificates represents a mandatory modernization effort that directly affects every laboratory operating under CLIA certification, except those in exempt states.
The deadline of March 1, 2026 is firm. Laboratories must:
Enroll in electronic notifications
Update email contact information
Prepare for mandatory online fee payment
Eliminate reliance on paper checks and mailed certificates
Failure to act may result in certification lapses, billing complications, and regulatory risk.
Compliance leaders should treat this change as an urgent administrative priority to ensure uninterrupted laboratory operations.
Official Resources
CMS CLIA Program Overview:
https://www.cms.gov/Regulations-and-Guidance/Legislation/CLIA
State Agency Contact Information (CLIA):
https://www.cms.gov/Regulations-and-Guidance/Legislation/CLIA/Downloads/CLIASA.pdf
Accreditation Organizations Approved by CMS:
https://www.cms.gov/Regulations-and-Guidance/Legislation/CLIA/Downloads/AOList.pdf
