Medicare Program: Five Year Review of Work Relative Value Units Under the Physician Fee Schedule
- The apparent shift away from a concerted evaluation of the survey results could result in “work estimate inflation” by respondents.
- By ignoring RUC recommendations across all specialties, CMS will incentivize respondents to inflate their work estimates and create rank order anomalies thereby decimating the relativity of the existing physician fee schedule.
The RUC makes annual recommendations regarding new and revised physician services to CMS and performs broad reviews of the Resource-Based Relative Value Scale (RBRVS) every five years. RUC participants include members, advisors, staff, and other designated specialty society representatives. This past year, the RUC completed its fourth, Five-Year Review.
In its proposed rule (May 24), CMS ignored RUC recommendations pertaining to cardiothoracic surgery with (16/29) rejected and (11/12) proposed at the survey 25th percentile. Only one RUC-recommended value was accepted based on the median survey result. If finalized, these values will have pernicious effects on the relative valuation system.
Cardiothoracic surgery codes assessed under the Fourth Five-year Review include procedures that are highly technical, sensitive, and demanding for the surgeon to undertake. These procedures are also mainly performed on sick and vulnerable patients who need a successful surgery in order to survive. They are certainly not surgeries that should be performed under the threat of improper Medicare payments and time limitations.
STS has made a concerted effort to ensure that recommended values maintain relativity within and across specialties. Each of the RUC-recommended values is amply supported by survey results, expert multidisciplinary opinion, and crosswalks or comparison to Multispecialty Points of Comparison (MPC) codes and comparable cardiothoracic surgery codes.