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The Centers for Medicare & Medicaid Services has opened a formal request for information questioning the Current Procedural Terminology coding system that determines how physicians bill Medicare, launching a CPT coding monopoly RFI buried inside the draft 2027 Medicare Physician Fee Schedule. The request examines the American Medical Association’s six-decade role in writing and pricing CPT codes, and asks whether that arrangement, unchanged since Congress passed HIPAA in 1996, still serves patients or practices. Additionally, it seeks input on the implications of AMA’s influence on coding practices, especially considering AMA’s historical impact on healthcare regulations.
The Legal Foundation Behind the CPT Coding Monopoly RFI
Kicking off the RFI, CMS notes that federal regulation, 45 CFR 162.1002, requires physician and other non-hospital services to be coded using HCPCS and CPT. But neither HIPAA nor the regulation specifies what the balance between the two systems must be, raising the question of why, to take an extreme example, the system couldn’t be 100 percent HCPCS and zero percent CPT.
Long-Standing Concerns About the RUC
CMS then turns to the AMA’s Relative Value Scale Update Committee, known as the RUC, which has no apparent place in statute; its role rests largely on administrative practice and tradition. CMS cites “longstanding concern” about reliance on the RUC. MedPAC has raised similar concerns for nearly 20 years, arguing that CMS has “over-relied on specialty societies with a financial stake in the process.”
How the CPT Coding Monopoly RFI Connects to Broader Health Goals
CMS goes further, suggesting that reliance on CPT and the RUC may be “a potential contributor” to the development of a U.S. “sick-care system,” with too little emphasis on prevention and lifestyle modification. In that sense, the AMA processes may inhibit progress toward the administration’s Make America Healthy Again goals. CMS also cites a 2025 National Academies report offering alternatives to dependence on AMA processes for valuing primary care services.
A History of Congressional Scrutiny
This isn’t the first time the AMA’s control over CPT has drawn political criticism. Sen. Bill Cassidy, R-Louisiana, publicly rebuked the AMA last October for what he described as abusing the CPT system and raising healthcare costs on American families, reflecting bipartisan-adjacent unease with the arrangement well before this CPT coding monopoly RFI was formally issued.
The Five Questions at the Heart of the CPT Coding Monopoly RFI
CMS closes its RFI with five unusually pointed questions. First, is CMS adequately considering the harms associated with the AMA’s monopoly over CPT, including licensing costs, barriers to innovation, and improvements in patient care that have been delayed or abandoned? Second, does the CPT code-development process meaningfully consider medical necessity, and could CMS learn from other populations, sites of care, or international health systems?
Questions About Structural Alternatives
Third, could HHS revisit the regulation that formally incorporates CPT into the national coding standard, and could another system replace CPT, or could private competition supplement what is now effectively a monopoly? Fourth, what alternatives could replace, or make more objective, the current CPT and RUC processes, and how would those alternatives affect innovation? Fifth, could physician procedures be coded and paid using ICD-10-PCS rather than CPT, and could procedures be grouped into broader payment categories, as Medicare already does with MS-DRGs and outpatient APCs, rather than pricing services one CPT code at a time?
Why This CPT Coding Monopoly RFI Matters for Physicians
The questions are not merely technical. CMS is openly reconsidering whether two privately controlled AMA processes, CPT coding and RUC valuation, should continue to occupy such central positions in federal coding and physician-payment policy. For physicians and practice administrators, the outcome of this CPT coding monopoly RFI could eventually reshape how services are coded, valued, and reimbursed under Medicare.
What Financial Stakes Are Involved
Given that the AMA generates significant licensing revenue from CPT code usage across the healthcare industry, and that RUC recommendations heavily influence which specialties receive higher or lower relative value units, any structural change stemming from this RFI could have significant financial implications both for the AMA itself and for how different physician specialties are compensated relative to one another.
What Comes Next for the CPT Coding Monopoly RFI
CMS is accepting public comments on the broader 2027 Physician Fee Schedule proposed rule, including this RFI, for 60 days from the rule’s publication. Given the pointed nature of the five questions and the political attention already directed at the AMA’s role in CPT coding, this CPT coding monopoly RFI is likely to draw significant comment activity from physician groups, specialty societies, the AMA itself, and health policy researchers.
What to Watch Going Forward
As comments come in, stakeholders will likely watch closely for how the AMA responds to direct questioning of its CPT licensing model and RUC process, given how central both have been to the organization’s role in federal healthcare policy for six decades. Whether this RFI ultimately leads to substantive regulatory change, or simply generates debate without action, may hinge on how strongly the comments received argue for concrete alternatives like ICD-10-PCS-based coding or expanded bundled payment categories.
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