Public Comment Moves CMS Toward AMA Relative Value Scale Update Committee Values: The Case For Independent Data

Medicare's Physician Fee Schedule sets prices for roughly 9,000 services, and those prices ripple through the entire US health system. The analysis by Sarah Tingley, Sanket Dhruva, and Rita Redberg of 2023-25 fee schedule rulemaking fills an important gap in our understanding of what happens after the American Medical Association/Specialty Society Relative Value Scale Update Committee (RUC) makes recommendations and how the Centers for Medicare and Medicaid Services (CMS) addresses public comments on those values. The authors show that stakeholder engagement is high when CMS proposes reductions but that comments and subsequent revisions tend to raise valuations and move CMS back toward RUC recommendations. Although notice-and-comment rulemaking, beginning in 2016, made the process more open and accountable, the greatest technical capacity and financial stake in preserving higher values remain with groups opposing valuation reductions. I suggest reforms that would give CMS independent data, broader stakeholder input, and stronger technical capacity when it evaluates physician work values.