Practice Guidance
RUC Process
The AMA/Specialty Society Relative Value Update Committee (RUC) is a unique multi-specialty committee tasked with making relative value recommendations to CMS for new and revised codes, as well as annually updating relative value units (RVUs) to reflect changes in medical practice.
RUC process: What you need to know
The purpose of the RUC process is to provide recommendations to CMS for use in annual updates to the new Medicare relative value scale. These recommendations are based on data collected from surveys of practicing physicians regarding the time, intensity and complexity of new and revised CPT codes.
The survey process requires physician input
For the RUC survey process to succeed, the cooperation and participation of practicing physicians is essential. It is only with your input that we can provide the RUC and CMS with accurate data so gastroenterology services can be fairly valued by Medicare. Many private insurers also base their rates on a percentage of Medicare, resulting in a wide and significant impact of this process.
We realize practicing physicians are faced with increasing demands on their time, but we believe this is an important, valuable and unique opportunity for any practicing gastroenterologist. By participating in a RUC survey, you will be able to have direct input on the valuation of the services you provide.
If you are contacted via email to participate in RUC surveys, we urge you to complete them.
The basics of the RUC survey process
When new codes are established or existing codes are revised, a survey of physicians providing that service is conducted by the relevant medical specialty society. The purpose of the survey is to measure physician work involved in performing the procedure to determine an accurate relative value recommendation for the service. AGA, ASGE and ACG conduct surveys for gastroenterology services, analyze the results and present recommendations to the RUC.
The AMA defines physician work as:
- Physician time it takes to perform a service.
- Physician mental effort and judgment.
- Physician technical skill and physical effort.
- Physician psychological stress that occurs when an adverse outcome has serious consequences.
In May of every year, the RUC submits its recommendations to CMS. In the summer, through the federal regulations process, CMS publishes proposed work values. After the public comment process, the new values are finalized and implemented on Jan. 1 of the following year.
How Medicare sets physician payment rates
In 1992, Medicare implemented a cost-based physician fee schedule. For each of the greater than 7,000 services on the fee schedule, an RVU is assigned based on the time and intensity of physician work, practice expense and cost of professional liability insurance necessary to provide the service. To determine the Medicare fee, a service’s RVUs are multiplied by a dollar conversion factor that is updated annually. A geographic adjustment is also made.
When Medicare transitioned to a physician payment system based on the Resource-Based Relative Value Scale (RBRVS), AMA anticipated the effects of this change and formulated a multi-specialty committee. This committee, known as the AMA RVS Update Committee (RUC), has made numerous recommendations to CMS that have significantly affected the Medicare physician payment schedule by giving physicians a voice in shaping Medicare relative values. The RUC, in conjunction with the Current Procedural Terminology Editorial Panel, has created a process through which specialty societies can develop relative value recommendations for new and revised codes. The RUC carefully reviews survey data presented by specialty societies and develops recommendations for consideration by CMS. AGA, ASGE and ACG are active participants in the RUC.
The purpose of the RUC process is to provide recommendations to CMS for use in annual updates to the new Medicare relative value scale. These recommendations are based on data collected from surveys of practicing physicians regarding the time, intensity and complexity of new and revised CPT codes.
The survey process requires physician input
For the RUC survey process to succeed, the cooperation and participation of practicing physicians is essential. It is only with your input that we can provide the RUC and CMS with accurate data so gastroenterology services can be fairly valued by Medicare. Many private insurers also base their rates on a percentage of Medicare, resulting in a wide and significant impact of this process.
We realize practicing physicians are faced with increasing demands on their time, but we believe this is an important, valuable and unique opportunity for any practicing gastroenterologist. By participating in a RUC survey, you will be able to have direct input on the valuation of the services you provide.
If you are contacted via email to participate in RUC surveys, we urge you to complete them.
The endoscopy survey timeline
| Procedure Family | Code Range | ICD-10 Descriptor |
|---|---|---|
| Esophagoscopy | 43200–43234 | Completed |
| EGD | 43235–43259 | Completed |
| Dilation | 43450–43458 | Completed |
| Upper GI EUS | Esophagoscopy: 43231, 43232 | Completed |
| EGD: 43237, 43238, 43242, 43259 | ||
| EGD/PEG | 43246 | Completed |
| ERCP | 43260–43273 | Completed |
| Pouchoscopy/Ileoscopy | 44380–44386 | Completed |
| Flexible Sigmoidoscopy | 45330–45345 | Completed |
| Colonoscopy | 44378–45392 | Completed |
| Colonoscopy through Stoma, Colotomy | 44388–44397, 45355 | Completed |
| Liver Elastography | 91200 | Completed |
| Trans-Oral Esophagogastric Fundoplasty | 43210 | Completed |
| Capsule Endoscopy | 91110 and 91111 | Completed |
| Moderate Sedation | 99152 | Completed |
| Change of Gastrostomy Tube | 43760 | March 2-16, 2017 |
The basics of the RUC survey process
The AMA defines physician work as:
- Physician time it takes to perform a service.
- Physician mental effort and judgment.
- Physician technical skill and physical effort.
- Physician psychological stress that occurs when an adverse outcome has serious consequences.
In May of every year, the RUC submits its recommendations to CMS. In the summer, through the federal regulations process, CMS publishes proposed work values. After the public comment process, the new values are finalized and implemented on Jan. 1 of the following year.
How Medicare sets physician payment rates
In 1992, Medicare implemented a cost-based physician fee schedule. For each of the greater than 7,000 services on the fee schedule, an RVU is assigned based on the time and intensity of physician work, practice expense and cost of professional liability insurance necessary to provide the service. To determine the Medicare fee, a service’s RVUs are multiplied by a dollar conversion factor that is updated annually. A geographic adjustment is also made.
When Medicare transitioned to a physician payment system based on the Resource-Based Relative Value Scale (RBRVS), AMA anticipated the effects of this change and formulated a multi-specialty committee. This committee, known as the AMA RVS Update Committee (RUC), has made numerous recommendations to CMS that have significantly affected the Medicare physician payment schedule by giving physicians a voice in shaping Medicare relative values. The RUC, in conjunction with the Current Procedural Terminology Editorial Panel, has created a process through which specialty societies can develop relative value recommendations for new and revised codes. The RUC carefully reviews survey data presented by specialty societies and develops recommendations for consideration by CMS. AGA, ASGE and ACG are active participants in the RUC.
Understanding the RUC survey instrument
A presentation from AMA that explains what the survey is, who does what and a step-by-step breakdown of the survey.
RUC survey instrument FAQ
It is only with your input that we can obtain accurate data so that gastroenterology services can be fairly valued by Medicare and those who base their fee schedules on Medicare’s rates.
Why do I need to provide my contact information?
We ask for your contact information in case we need additional information about a specific survey response or if we receive an incomplete survey submission. We never share your information with the AMA, Medicare or other entities, or retain it for tracking purposes.
Once I start the survey process online, do I have to complete it in one session?
You can save the survey and complete it later. Be sure to complete it by the deadline listed in your survey invitation.
The survey states that a financial ownership interest in an organization that contributes materially to my income constitutes a direct financial interest. I have ownership in an Ambulatory Surgery Center (ASC). Does this constitute a financial interest that would prevent me from taking the survey?
No. Ownership or part-ownership of an ASC does not constitute a direct financial interest.
What constitutes a “financial ownership interest in an organization that contributes materially to my income”?
An “organization” is any entity that makes or distributes the product that is utilized in performing the service, not the physician group or facility in which you work or perform the service. The survey instructions define what constitutes a material financial interest.
Do I count the time my staff spends scheduling the procedure and providing instructions to the patient toward the pre-service, intra-service and/or post-service work?
No. These surveys measure physician work only. Do not include staff time in your estimates. The definitions of pre-service, intra-service and post-service periods are included in the survey instrument and also in the RUC educational presentation. View the presentation.
What is the intra-service work period?
The intra-service period includes all “skin-to-skin” work that is a necessary part of the procedure. For GI endoscopy procedures it includes the time from then when the first scope is inserted to when the last scope was withdrawn.
Can you provide examples of work that should be included in the pre- and post-service periods?
The definitions and examples of pre-service, intra-service and post-service periods are included in the survey instrument and in the RUC educational presentation. View the presentation.
The pre-service period includes physician services provided from the day before the operative procedure until the time of the operative procedure. Examples include preparing to see the patient, reviewing records, and communicating with other professionals.
The post-service period includes dictation of report and arranging for further services communicating (written or verbal) with the patient, family and other professionals.
Where do I count the time I spend administering conscious sedation?
Do not count the time involved in administration of moderate (conscious) sedation. Moderate sedation services are separately reported with CPT codes 99151-99157 or G0500 for Medicare.
I’m still not sure how I should determine a work relative value unit (RVU) for the survey code. Do you have additional guidance?
Think about the amount of physician work involved in the survey code compared to the reference code you selected. If you estimate that the survey code is exactly equivalent in terms of physician work, then you could choose to assign the same work RVU to the survey code. If you estimate the survey code requires more or less physician work, then you must decide approximately how much. For example, if you estimate that the survey code involves half as much physician work as your reference code, then you could choose to assign a work RVU that is half that of your reference code. If you estimate that the survey code involves one and a half times as much physician work as your reference code, then you could choose to assign a work RVU that is one and a half times that of your reference code.
