Bridging the Gaps in the RUC Process

The work of the American Medical Association’s (AMA’s) Specialty Society Relative Value Scale Update Committee (also known as RUC) has recently been the subject of some scrutiny in the press.  Some see the existence of a body of physicians that makes recommendations about the relative value units (RVUs) used to calculate Medicare payment as a conflict of interest (as described in a recent USA Today editorial). Others see it as the best way to accurately develop RVUs (as expressed in an USA Today editorial response from AMA President Ardis Dee Hoven, MD).

Some background information about the RUC and the process may help bridge the gaps and help keep us informed:

  • The RUC is an independent group exercising its First Amendment Right to petition the federal government.  It is not an advisory committee to the Centers for Medicare and Medicaid Services (CMS). CMS is entirely responsible for the Resource Based Relative Value Scales (RBRVS). All modifications to the RBRVS are made through rulemaking and open to public comment.
  • The RUC is an expert panel. Individuals exercise their independent judgment and are not advocates for their specialty.  It is not a political, representative committee. The RUC relies on socioeconomic expertise and objectivity. A common misperception is that members of the RUC vote en bloc. This is not true. The RUC requires a 2/3 vote to submit a recommendation to CMS. These votes are confidential and reviewed only by AMA staff. RUC members have voted against their own specialty’s recommendations when they thought those recommendations were inappropriate. AMA staff observe that voting does not usually align in blocs, and that voting often is contrary to the apparent self-interest of individual RUC members.
  • The RUC is not a closed process. The RUC Chairman accepts requests for attendance at each meeting, including MedPAC staff, the U.S. Government Accountability Office (GAO) staff, and international delegations. However, the RUC has a strict conflict of interest policy and does not want the influences of industry involved in the process. The RUC looks to each specialty society to provide accurate time and survey data. An attestation statement of accuracy and potential conflict of interest is now required of each advisor presenting to the RUC.
  • The RUC listens to feedback from CMS, MedPAC, or others to improve the committee’s recommendations.
  • The RUC constantly updates its methodology and processes. While relying on the core principle of magnitude estimation from the Harvard/Hsiao studies, the RUC continuously looks to improve its ability to assess relativity across the RBRVS.
  • The Committee has worked vigorously over the past several years to identify and address misvaluations in the RBRVS through provision of revised physician time data and resources cost recommendations to CMS. The Committee fully acknowledges that there are services that are now performed more efficiently and these codes have been or will be addressed.
  • Transparency is important to the Committee, and they have implemented processes to improve transparency. However, the Committee is not a political process and has no intent to influence markets or private payors. The Committee’s recommendations are intended to provide clinical expertise to CMS to utilize as one source of data in developing relative values.
The ACC is involved in the work of the RUC in two ways: a cardiologist is a voting member of the RUC, and other cardiologists serve on the advisory panel that presents recommendations to the RUC.  We also have staff dedicated to ensuring the voice of cardiology is heard and our member’s needs are represented.

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