The RUC is the main advisory body to the CMS on relative values for new and revised CPT codes. The RUC's main focus is physician work RVUs although it also deals with direct practice expense inputs. CMS handles professional liability insurance RVUs without input from the RUC.
The AMA manages the RUC although its activities are a collaborative venture between the AMA, national medical specialty societies, limited license and allied health provider organizations and the Centers for Medicare and Medicaid Services (CMS).
The RUC has 29 seats, with 23 seats consisting of representatives from major national medical specialty societies, including the AAOS. Most of these seats are held on a permanent basis by the participating specialty societies. Three seats are rotating seats with 2-year terms. The remaining seats are held by the RUC Chair and representatives of other groups involved in RUC activities. (See Appendix B for past and current orthopaedic members of the RUC.)
Over its history, the RUC has used different methodologies to arrive at relative value recommendations. The most commonly used method currently is the survey method. However, in the past, they used methodologies such as magnitude estimation and Rosch analysis.
RUC Advisory Committee
There are 114 specialty societies represented in the AMA House of Delegates. Each of these societies has the option of appointing a representative to the RUC Advisory Committee; however not all specialty societies have appointed a RUC advisor.
Advisory Committee members represent the interests of their specialty societies when codes used by their societies' members are being presented to the RUC for valuation. In essence, the "Advisors" help manage the process through which proposals are presented to the RUC before its meetings and then orally presented in person at the meetings.
Practice Expense Review Committee (PERC)
The PERC is responsible for developing recommendations on practice expense RVUs for codes before the RUC. The PERC meets on the day prior to the full RUC meeting whenever the RUC meets. The members of the PERC are assigned as individuals and not as representatives of a specific sub-specialty and therefore if/when a PERC member resigns, his or her specialty society is not necessarily entitled to appoint a replacement. Appointments are at the discretion of the full RUC panel.
Annual Process for Developing Relative Value Recommendations to CMS for New and Revised Codes
Step 1: The CPT Editorial Panel submits new and revised codes to the RUC staff.
Step 2: RUC staff send "Level of Interest" forms to RUC Advisory Committee members and specialty society staff.
Step 3: Advisory Committee members review the codes that need valuation and then indicate their societies' level of interest in developing a RVU recommendation for the RUC on the new and/or revised code at hand.
Step 4: AMA staff distributes survey instruments for interested specialty societies to evaluate the work involved in the new or revised code.
Step 5: The specialty relative value scale committees conduct the surveys, review the results and prepare their recommendations to the RUC.
Step 6: The specialty society Advisors present the recommendations at the RUC meeting.
Step 7: The RUC may decide to adopt a specialty society's recommendation, refer it back to the specialty society or modify it before submitting it to CMS.
Step 8: The RUC's recommendations are forwarded to CMS in May of each year.
Step 9: In the late Fall, CMS publishes its decisions in the Medicare Physician Fee Schedule Final Rule for the following year.
Step 10: If CMS does not agree with any of the RUC's recommendations, the AMA, interested specialty societies and all other interested parties may ask CMS to re-consider its decisions for the following year's fee schedule.
The RUC history and process is also outlined in a pamphlet provided by the AMA.
Five Year Review Process
By law, CMS is required to conduct a comprehensive review of all relative values at least every 5 years. Even though this process is very similar to the annual process, it is has additional features that make it more complicated and more lengthy.
Specialty societies can propose a review of codes that they believe are undervalued. CMS usually proposes to review codes it believes are overvalued. Most of the codes that both the specialty societies and CMS propose be re-valued are put into this process.
The last five-year review occurred in 2010. In the 2012 Medicare Physician Fee Schedule Final Rule, CMS announced they would no longer use the five-year method for evaluating existing code values but will instead conduct annual reviews with the same processes for identifying codes for review.