What Are RUC Surveys and Why Should They Matter to Me?
As an Academy member, you’ve probably seen frequent requests distributed in “The News” asking for volunteers for upcoming AMA Relative Value Scale Update Committee (RUC) surveys of physician services. Many of you may have asked yourself, “what the RUC is and why are these surveys important?” During the last several years, the Academy has provided members with background on the RUC in an effort to educate and engage members in the annual RUC process. This year, we’d like to address the common questions that arise during the RUC survey process in hopes of outlining why member participation in these surveys is so critical. What is the RUC and Who Participates? The AMA RUC was developed in response to the transition to a physician payment system based on a Resource-Based Relative Value Scale (RBRVS). The RUC is a multispecialty committee that provides clinical expertise and input on the resources required to provide physician services. The RUC submits recommendations annually to the Centers for Medicare and Medicaid Services (CMS), which uses them to develop relative values for physician services provided to Medicare beneficiaries. The RUC, in conjunction with the Current Procedural Terminology (CPT®) Editorial Panel, has created a process where specialty societies can develop relative value recommendations for new and revised codes, and the RUC carefully reviews survey data presented by specialty societies to develop recommendations for consideration by CMS. CMS then issues final payment policies and values in the final Medicare Physician Fee Schedule rule, which is typically released around the first of November each year. The RUC is intended to represent the entire medical profession and includes the following medical specialties: anesthesiology, cardiology, dermatology, emergency medicine, family medicine, general surgery, geriatrics, internal medicine, neurology, neurosurgery, obstetrics/gynecology, ophthalmology, orthopedic surgery, otolaryngology, pathology, pediatrics, plastic surgery, primary care (rotating seat), pulmonary medicine (rotating seat), psychiatry, radiology, rheumatology (rotating seat), thoracic surgery, urology, and vascular surgery (rotating seat). Four seats rotate on a two-year basis, with two reserved for an internal medicine subspecialty: one for a primary care representative, and one for any other specialty. The RUC chair, the co-chair of the RUC Health Care Professionals Advisory Committee Review Board, and representatives of the AMA, American Osteopathic Association, the chair of the Practice Expense Review Committee and CPT Editorial Panel hold the remaining six seats. The AMA Board of Trustees selects the RUC chair and the AMA representative to the RUC. The individual RUC members are nominated by the specialty societies and are approved by the AMA. Who Represents the Academy at the RUC? The Academy actively participates in the RUC process and surveys codes for nearly every RUC meeting. Meetings take place every winter, spring, and fall. The Academy’s current RUC representatives are RUC panel member Charles F. Koopmann Jr., MD, MSHA, and panel member alternate, Jane T. Dillon, MD, as well as our RUC advisors Wayne M. Koch, MD, and advisor alternate John T. Lanza, MD. It is important to recognize that the RUC panel member representatives for each specialty are not advocates for their specialties, rather, they participate in an individual capacity and represent their own views and independent judgment while serving on the panel. In contrast, AAO-HNS’ RUC advisors are responsible for working with the Physician Payment Policy Workgroup (3P) and Academy staff to develop relative value recommendations and practice expense direct inputs for otolaryngology services that are presented to the RUC on behalf of the Academy. Why are RUC Surveys Conducted? Surveys are used by the AMA RUC to allow medical specialty societies to have an active role in ensuring that relative values assigned to medical procedures and services are accurately and fairly presented to CMS. These surveys are critical because the values derived by member survey responses are used by our RUC advisors to make valuation recommendations to the AMA RUC. The goal of the surveys is to obtain time and complexity estimates required when performing a specific medical procedure. This information is then used to estimate a recommended physician work value. How Does the Survey Generate a Recommended Value? The surveys will ask physician members to compare the time, complexity, and work required to perform the procedure being surveyed as compared to another existing medical procedure. A list of possible comparator, or reference, procedures is provided to survey respondents as part of the survey. What are the Key Components of the RUC Survey? First, it is critical that members carefully review the code descriptor and vignette. This is critical because code descriptors may have been modified and survey respondents will be asked if the descriptor and vignette match their typical (i.e., more than 50 percent of the time) patient. If the descriptor and vignette do not match the respondent’s typical patient, the respondent will be asked to write a brief rationale for how their typical patient differs from the survey descriptor or vignette. Next, surveyees will be asked to review and provide their basic contact information. They will then be asked to identify a reference procedure from the list of potential reference codes. Respondents should select the code from the list that is most similar in physician time and work to the new/revised CPT code descriptor and typical patient. The reference service does not have to be clinically similar to the procedure being surveyed, but must be similar in work required to perform the procedure. It is also important that respondents consider the global period of the service being reviewed. For CPT codes with 000, 010, or 090 day globals, physician services or visits provided within 24 hours prior are included and should be considered by respondents in their recommended value for the service. Likewise, for 010 and 090 globals, the post care following the procedure should be included in the estimate of physician work for a given procedure. Another key component to the RUC survey is estimating physician time. Respondents should base their recommendations of the time it takes them to perform the procedure under review on their own personal experience. It is important to note that time estimates provided should be based on the typical patient and not the most straightforward or most complex case the physician respondent has encountered. There are three components to time estimates. First, the pre-service time, which begins the day prior to the procedure and lasts until the time of the operative procedure. Pre-service time is divided into three activities: evaluation; positioning; and scrub, dress, and wait time. Second, the intra-service time, which includes all “skin to skin” work that is a necessary part of the procedure. And last, the post-service time, which includes the physician services provided on the day of the procedure after the procedure has been performed.One common source of confusion is the component of moderate sedation. Moderate sedation is a service provided by the operating physician or under the direct supervision of the physician performing the procedure. If anesthesia is provided separately by an anesthesiologist who is not performing the primary procedure, this work should not be included in the valuation of the procedure for the purposes of the RUC survey. Finally, survey respondents will be asked to evaluate physician work and assign a recommended relative value unit for the work required to perform the procedure. Physician work includes the time it takes the physician to perform the procedure. Physician work should also include the mental effort and judgment necessary, as well as the technical skill required to perform the procedure. Note, time and work valuation should not include any work or service provided by clinical staff that are employed by the physician’s practice and cannot bill separately. It is important to keep in mind that the survey methodology aims to set the work RVU for the procedure under review “relative” to the comparable reference procedure selected at the outset of the survey, and respondents may want to print out the reference service list to refresh them on the value of the comparator code selected. What About the Practice Expense Portion of My Payment? As part of its role in the RUC process, the Academy RUC team is asked to provide the AMA RUC and CMS with information regarding the direct practice expense inputs for all procedures that undergo RUC review. This includes recommendations on clinical staff time needed during the procedure, as well as equipment and supplies required for the procedure. These recommendations are reviewed by the Practice Expense Advisory Committee (PEAC) of the RUC and approved or modified prior to being submitted to CMS for acceptance in the final CY MPFS. What About the Malpractice Portion of My Payment? The AMA RUC sends recommendations to CMS on practice liability crosswalks for each procedure reviewed by the AMA RUC. This occurs in May of each year and, similar to the practice expense and physician work recommendations submitted by the AMA RUC, are approved or modified by CMS in the MPFS for that calendar year. All values finalized in the final rule then take effect the following January. Still Have Questions? For more background on the RUC survey process, members can access the following PowerPoint presentation on the Academy website: http://www.entnet.org/Practice/upload/2012-ruc-survey-presentation.pdf. Members can also email any questions to Jenna Minton at Jminton@entnet.org. We hope this information will assist members in better understanding the composition of the RUC surveys as well as the importance of your participation in future surveys and the valuation of otolaryngology-head and neck surgery procedures.
As an Academy member, you’ve probably seen frequent requests distributed in “The News” asking for volunteers for upcoming AMA Relative Value Scale Update Committee (RUC) surveys of physician services. Many of you may have asked yourself, “what the RUC is and why are these surveys important?” During the last several years, the Academy has provided members with background on the RUC in an effort to educate and engage members in the annual RUC process. This year, we’d like to address the common questions that arise during the RUC survey process in hopes of outlining why member participation in these surveys is so critical.
What is the RUC and Who Participates?
The AMA RUC was developed in response to the transition to a physician payment system based on a Resource-Based Relative Value Scale (RBRVS). The RUC is a multispecialty committee that provides clinical expertise and input on the resources required to provide physician services. The RUC submits recommendations annually to the Centers for Medicare and Medicaid Services (CMS), which uses them to develop relative values for physician services provided to Medicare beneficiaries. The RUC, in conjunction with the Current Procedural Terminology (CPT®) Editorial Panel, has created a process where specialty societies can develop relative value recommendations for new and revised codes, and the RUC carefully reviews survey data presented by specialty societies to develop recommendations for consideration by CMS. CMS then issues final payment policies and values in the final Medicare Physician Fee Schedule rule, which is typically released around the first of November each year.
The RUC is intended to represent the entire medical profession and includes the following medical specialties: anesthesiology, cardiology, dermatology, emergency medicine, family medicine, general surgery, geriatrics, internal medicine, neurology, neurosurgery, obstetrics/gynecology, ophthalmology, orthopedic surgery, otolaryngology, pathology, pediatrics, plastic surgery, primary care (rotating seat), pulmonary medicine (rotating seat), psychiatry, radiology, rheumatology (rotating seat), thoracic surgery, urology, and vascular surgery (rotating seat). Four seats rotate on a two-year basis, with two reserved for an internal medicine subspecialty: one for a primary care representative, and one for any other specialty. The RUC chair, the co-chair of the RUC Health Care Professionals Advisory Committee Review Board, and representatives of the AMA, American Osteopathic Association, the chair of the Practice Expense Review Committee and CPT Editorial Panel hold the remaining six seats. The AMA Board of Trustees selects the RUC chair and the AMA representative to the RUC. The individual RUC members are nominated by the specialty societies and are approved by the AMA.
Who Represents the Academy at the RUC?
The Academy actively participates in the RUC process and surveys codes for nearly every RUC meeting. Meetings take place every winter, spring, and fall. The Academy’s current RUC representatives are RUC panel member Charles F. Koopmann Jr., MD, MSHA, and panel member alternate, Jane T. Dillon, MD, as well as our RUC advisors Wayne M. Koch, MD, and advisor alternate John T. Lanza, MD. It is important to recognize that the RUC panel member representatives for each specialty are not advocates for their specialties, rather, they participate in an individual capacity and represent their own views and independent judgment while serving on the panel. In contrast, AAO-HNS’ RUC advisors are responsible for working with the Physician Payment Policy Workgroup (3P) and Academy staff to develop relative value recommendations and practice expense direct inputs for otolaryngology services that are presented to the RUC on behalf of the Academy.
Why are RUC Surveys Conducted?
Surveys are used by the AMA RUC to allow medical specialty societies to have an active role in ensuring that relative values assigned to medical procedures and services are accurately and fairly presented to CMS. These surveys are critical because the values derived by member survey responses are used by our RUC advisors to make valuation recommendations to the AMA RUC. The goal of the surveys is to obtain time and complexity estimates required when performing a specific medical procedure. This information is then used to estimate a recommended physician work value.
How Does the Survey Generate a Recommended Value?
The surveys will ask physician members to compare the time, complexity, and work required to perform the procedure being surveyed as compared to another existing medical procedure. A list of possible comparator, or reference, procedures is provided to survey respondents as part of the survey.
What are the Key Components of the RUC Survey?
First, it is critical that members carefully review the code descriptor and vignette. This is critical because code descriptors may have been modified and survey respondents will be asked if the descriptor and vignette match their typical (i.e., more than 50 percent of the time) patient. If the descriptor and vignette do not match the respondent’s typical patient, the respondent will be asked to write a brief rationale for how their typical patient differs from the survey descriptor or vignette.
Next, surveyees will be asked to review and provide their basic contact information. They will then be asked to identify a reference procedure from the list of potential reference codes. Respondents should select the code from the list that is most similar in physician time and work to the new/revised CPT code descriptor and typical patient. The reference service does not have to be clinically similar to the procedure being surveyed, but must be similar in work required to perform the procedure. It is also important that respondents consider the global period of the service being reviewed. For CPT codes with 000, 010, or 090 day globals, physician services or visits provided within 24 hours prior are included and should be considered by respondents in their recommended value for the service. Likewise, for 010 and 090 globals, the post care following the procedure should be included in the estimate of physician work for a given procedure.
Another key component to the RUC survey is estimating physician time. Respondents should base their recommendations of the time it takes them to perform the procedure under review on their own personal experience. It is important to note that time estimates provided should be based on the typical patient and not the most straightforward or most complex case the physician respondent has encountered.
There are three components to time estimates. First, the pre-service time, which begins the day prior to the procedure and lasts until the time of the operative procedure. Pre-service time is divided into three activities: evaluation; positioning; and scrub, dress, and wait time. Second, the intra-service time, which includes all “skin to skin” work that is a necessary part of the procedure. And last, the post-service time, which includes the physician services provided on the day of the procedure after the procedure has been performed.One common source of confusion is the component of moderate sedation. Moderate sedation is a service provided by the operating physician or under the direct supervision of the physician performing the procedure. If anesthesia is provided separately by an anesthesiologist who is not performing the primary procedure, this work should not be included in the valuation of the procedure for the purposes of the RUC survey.
Finally, survey respondents will be asked to evaluate physician work and assign a recommended relative value unit for the work required to perform the procedure. Physician work includes the time it takes the physician to perform the procedure. Physician work should also include the mental effort and judgment necessary, as well as the technical skill required to perform the procedure. Note, time and work valuation should not include any work or service provided by clinical staff that are employed by the physician’s practice and cannot bill separately. It is important to keep in mind that the survey methodology aims to set the work RVU for the procedure under review “relative” to the comparable reference procedure selected at the outset of the survey, and respondents may want to print out the reference service list to refresh them on the value of the comparator code selected.
What About the Practice Expense Portion of My Payment?
As part of its role in the RUC process, the Academy RUC team is asked to provide the AMA RUC and CMS with information regarding the direct practice expense inputs for all procedures that undergo RUC review. This includes recommendations on clinical staff time needed during the procedure, as well as equipment and supplies required for the procedure. These recommendations are reviewed by the Practice Expense Advisory Committee (PEAC) of the RUC and approved or modified prior to being submitted to CMS for acceptance in the final CY MPFS.
What About the Malpractice Portion of My Payment?
The AMA RUC sends recommendations to CMS on practice liability crosswalks for each procedure reviewed by the AMA RUC. This occurs in May of each year and, similar to the practice expense and physician work recommendations submitted by the AMA RUC, are approved or modified by CMS in the MPFS for that calendar year. All values finalized in the final rule then take effect the following January.
Still Have Questions?
For more background on the RUC survey process, members can access the following PowerPoint presentation on the Academy website: http://www.entnet.org/Practice/upload/2012-ruc-survey-presentation.pdf. Members can also email any questions to Jenna Minton at Jminton@entnet.org. We hope this information will assist members in better understanding the composition of the RUC surveys as well as the importance of your participation in future surveys and the valuation of otolaryngology-head and neck surgery procedures.