The proposed rule for the 2026 Physician Fee Schedule seeks suggestions to replace the AMA committee that assesses the resources necessary for physicians to provide high-quality services.
The leader of an American Medical Association (AMA) committee that collects information used to help the Centers for Medicare & Medicaid Services (CMS) set physician payments says the possibility of replacing the committee is misguided.
In the proposed rule for the 2026 Physician Fee Schedule released in July, CMS asks for suggestions to replace the AMA Specialty Society Relative Value Scale Update Committee (RUC).
The Physician Fee Schedule is based on a system called the Resource Based Relative Value Scale (RBRVS). The basic unit of the RBRVS is a relative value unit (RVU). The definition of an RVU goes back to the transformation of physician payment in the late 1980s and early 1990s. On the scale, a physician service with a higher number of RVUs has a higher resource need than a service with a lower number of RVUs.
The RUC collects information that informs the RBRVS for its relative value recommendations.
While the RUC does not set payment amounts for physician services, the committee plays an essential role in the process, according to Ezequiel Silva, MD, chair of the RUC.
"The RUC is informing the resources necessary for physicians to provide the best care possible for their patients," Silva says. "To be more specific, think about a service that a physician provides. By definition, providing a service involves some degree of physician work. That work includes several components, which can include the time it takes to perform a study, technical skill, and malpractice risk."
The RUC collects information from practicing physicians such as survey data to determine the resources necessary for physicians to provide a service at a high-quality level.
"The individuals who are best positioned to inform how relative determinations are made regarding the resources needed to provide a physician service or the absolute nature of those resources are practicing physicians," Silva says. "The AMA brings together the clinical expertise of practicing physicians through the RUC."
Conducting surveys of practicing physicians is a crucial part of the RUC's work.
"The RUC is composed of practicing physicians informing the recommendations it makes, but that is not enough," Silva says. "When we think about innovation and the 32 members of the RUC, there is no way they can understand all medical innovations and every service provided by all physicians. Therefore, we rely on practicing physicians to provide us with information."
For example, if there is a new service, the RUC wants to know what it takes to provide the highest quality for that service. That involves surveying practicing physicians who are providing the service.
"We ask physicians to compare a new service to existing services in the RBRVS," Silva says. "That comparison might involve comparisons regarding complexity. It might involve comparisons regarding intensity. It might involve comparisons regarding the amount of time necessary to perform a new service and the resources required."
Ezequiel Silva, MD, is chair of the American Medical Association's Specialty Society Relative Value Scale Update Committee. Photo courtesy of the American Medical Association.
Weighing the consequences of replacing the RUC
The RUC draws on clinical expertise that would be hard to substitute, according to Silva, since it is necessary to inform an adequate valuation of how physicians provide the best possible care.
"We are talking about a payment system that has been in place for 30 years," Silva says. "There needs to be expertise in the nature of that system, how that system is constructed, how value is determined within that system, and how that system can evolve in the future."
The work the RUC performs is transparent, Silva explains.
"Our meetings can be attended by any individual who makes a request to attend. As the chair of the RUC, I review those requests, and I cannot recall ever denying a request," Silva says. "The RUC's minutes are transparent—they are in the public domain, and they are published on our website."
An effort to replace the RUC could have negative consequences, according to Silva.
"The AMA believes that physicians provide the clinical expertise to inform innovation," Silva says. "If the clinical expertise that the RUC provides were replaced by a new entity that lacked its depth of clinical expertise, the potential shortcomings for CMS payment and the quality of care provided could be significant."
Christopher Cheney is the CMO editor at HealthLeaders.
KEY TAKEAWAYS
The AMA Specialty Society Relative Value Scale Update Committee (RUC) collects information on the components of physician work involved in providing a service such as the time it takes to perform a patient study.
The RUC gathers information from practicing physicians, including survey data.
The chair of the RUC says it would be hard to find a substitute for the clinical expertise that the committee draws upon and provides to the Centers for Medicare & Medicaid Services to help the agency set physician payments.