The Devaluation of Otolaryngology: An Evaluation of CMS’s Involvement in Physician Reimbursement

CLINICAL QUESTION

How often does the Centers for Medicare and Medicaid Services (CMS) change the Relative Value Scale Update Committee (RUC)–recommended RVU values for otolaryngology procedures, and has this pattern changed over time?

BOTTOM LINE

Between 1995 and 2021, CMS altered more than one-quarter of RUC-recommended RVUs for otolaryngology procedures, with modification rates increasing significantly from 12% before 2008 to 33% after 2009. This trend suggests a growing role for CMS in determining procedural valuation, raising implications for reimbursement and specialty advocacy.

BACKGROUND: Medicare reimbursement for physician services is tied to relative value units (RVUs), which reflect the work, practice expense, and malpractice components of a given procedure. The American Medical Association’s RUC—composed largely of specialty society representatives— traditionally evaluates and recommends these values. Historically, CMS accepted most RUC recommendations; however, recent anecdotal concerns suggest increasing CMS intervention, prompting evaluation of how otolaryngology codes are valued in practice.

STUDY DESIGN: A retrospective review of Medicare Final Rules published in the Federal Register from 1995 through 2021. Authors identified all otolaryngology-related CPT codes reviewed by the RUC, compared RUC-recommended RVUs with CMS final valuations, and analyzed trends between two time periods (1995-2008 versus 2009-2021).

SETTING: National policy analysis using publicly available Medicare regulatory data

SYNOPSIS: Across 27 years, 271 otolaryngology-related CPT codes were reviewed by the RUC. CMS accepted RUC recommendations for 201 codes (74%) and altered values for 70 codes (26%). A temporal shift was evident: Between 1995 and 2008, only 12% of values were altered, but from 2009 to 2021, 33% underwent CMS modification. This difference was statistically significant and reflects a growing divergence between RUC recommendations and CMS final determinations.

Modifications varied widely, with reductions ranging from 2% to 100%, and an average change of 5%. Subspecialty impact also varied. Laryngology codes were most frequently altered, including those related to flexible laryngoscopy and esophagoscopy. In contrast, otology and pediatric otolaryngology codes were not modified during the study period.

The authors discuss how RUC deliberations rely on specialty-driven surveys assessing time, complexity, and intensity for each procedure. CMS participation in meetings has traditionally been observational, but the growing modification rate suggests increased administrative influence in valuation. While CMS has the authority to determine final RVUs, frequent deviations from the physician-informed RUC process raise concerns about undervaluation and financial implications for otolaryngology practices.

CITATION: Manes RP, Vasandani S. The devaluation of otolaryngology: an evaluation of CMS’ involvement in physician reimbursement. Laryngoscope. 2025;135:3134-3138. doi:10.1002/lary.32170

COMMENT: The study clearly documents a significant increase in CMS’s intervention in physician payment valuation, marking a shift from earlier deference to RUC’s findings. This devaluation trend has important consequences for procedural reimbursement in otolaryngology and raises critical questions about the influence of specialty societies on national physician payment policy.— Sarah Rapoport, MD