Could the Foundation of U.S. Procedure Coding Eventually Change?
For decades, Current Procedural Terminology (CPT®) has been at the center of physician and outpatient procedure coding in the United States.
Medical coders learn it. Providers document services that are reported with it. Health plans process claims containing CPT codes. Medicare payment methodologies rely heavily on CPT and HCPCS coding.
Now, the Centers for Medicare & Medicaid Services (CMS) is asking significant questions about the current system.
In July 2026, CMS included a Request for Information (RFI) in the Calendar Year 2027 Medicare Physician Fee Schedule proposed rule seeking public input on potential reforms involving the CPT coding and Relative Value Scale Update Committee (RUC) processes.
For medical coders, auditors, billers, physicians, revenue cycle professionals, educators, and healthcare organizations, this deserves attention.
This does not mean CPT is being eliminated.
It means federal policymakers are examining important questions about how procedure codes and physician payment values are developed—and whether alternative approaches should be considered.
Why Is CMS Looking at the CPT System?
According to the August 11, 2026 report, CMS cited concerns involving the healthcare system’s reliance on a private organization that has a financial interest in the CPT and RUC processes.
The RFI seeks stakeholder feedback on issues including:
- CPT licensing and maintenance costs
- The current CPT and RUC processes
- Potential effects on healthcare innovation
- Potential effects on patient care
- Whether alternative coding and payment approaches could be developed
- Whether physician procedural services could potentially be grouped or bundled differently
These are significant policy questions because CPT is deeply embedded throughout the American healthcare reimbursement infrastructure.
The Most Interesting Question: Could ICD-10 Procedure Codes Play a Larger Role?
One particularly important issue raised in the RFI is whether physician procedural services could potentially be paid based on underlying ICD-10 procedure coding as an alternative approach, with services potentially grouped or bundled into payment categories.
This deserves careful attention.
Currently, U.S. coders generally associate:
ICD-10-CM → Diagnoses
CPT® → Physician and outpatient procedures/services
HCPCS Level II → Supplies, drugs, DME and additional services
ICD-10-PCS → Inpatient hospital procedures
These coding systems serve different purposes and are embedded in different payment methodologies.
A major change to this architecture would therefore have implications far beyond simply replacing one code book with another.
It could affect claims processing, reimbursement methodologies, electronic health records, coding software, payer systems, compliance programs, analytics, education, and the healthcare workforce.
Why Is Congress Also Interested?
The CMS inquiry is occurring alongside congressional scrutiny.
According to the report, the Senate Health, Education, Labor, and Pensions Committee has examined concerns regarding CPT licensing and associated healthcare costs.
The House Committee on Oversight and Government Reform has also raised questions about CPT coding complexity and the potential for improper billing, including upcoding and other abuses.
This introduces a broader question for the healthcare industry:
Can procedure coding become more transparent, efficient, objective, and resistant to inappropriate billing while still maintaining the clinical specificity required for modern healthcare?
That is not a simple problem to solve.
What Would Happen If CPT Changed?
Medical coders should avoid jumping to conclusions.
CMS has not announced the end of CPT.
An RFI is fundamentally a request for information and stakeholder feedback. Significant changes to national coding and payment standards would involve extensive policy, regulatory, operational, and technical considerations.
Nevertheless, even discussing alternatives is important because CPT is integrated into enormous portions of the U.S. healthcare system.
Potential reforms could eventually affect:
- Medical coding
- Physician reimbursement
- Hospital outpatient reimbursement
- Revenue cycle management
- Claims processing
- Medical billing
- Coding audits
- Compliance
- Clinical documentation
- Coding software
- Computer-assisted coding
- Artificial intelligence
- Healthcare analytics
- Payer policies
- Provider contracts
- Coding education and certification
Healthcare organizations therefore should follow the policy discussion carefully.
What Does This Mean for Medical Coders?
This development carries an important career lesson.
Do Not Become a One-Code-System Coder.
The future medical coder should understand the architecture of healthcare information, not simply memorize CPT codes.
A strong coding professional should understand how multiple terminology and classification systems interact:
ICD-10-CM + CPT + HCPCS + ICD-10-PCS + DRGs + HCCs + SNOMED CT + LOINC + emerging ICD-11 frameworks
Why?
Because healthcare coding is becoming increasingly connected with reimbursement, clinical documentation, data analytics, interoperability, artificial intelligence, quality measurement, and population health.
The professional who understands only “Which CPT code should I select?” may have a narrower skill set than the professional who understands:
What was performed? Why was it performed? How is it documented? How is it classified? How does it affect reimbursement? How is the information used downstream?
That distinction will become increasingly important.
AI Makes This Discussion Even More Important
Healthcare coding is also entering an era of rapidly expanding artificial intelligence and automation.
CMS itself is increasingly examining technology-enabled healthcare and the use of advanced technologies within Medicare programs.
Modern coding systems therefore need to function not only for human coders but also within increasingly sophisticated digital ecosystems.
Tomorrow’s coding professional may work alongside:
- AI-assisted coding systems
- Natural language processing
- Computer-assisted coding
- Automated claim validation
- Clinical decision-support systems
- Predictive analytics
- Automated auditing
- Interoperability platforms
This makes coding-system literacy more valuable—not less valuable.
Could CPT Actually Disappear?
At this stage, predicting that would be premature.
The correct interpretation is:
CMS is asking questions and seeking stakeholder input about potential reforms and alternatives. It has not announced that CPT will be abolished.
CPT and HCPCS remain deeply embedded in current U.S. healthcare coding and reimbursement.
Any substantial restructuring would require careful consideration of clinical, operational, regulatory, technological, reimbursement, and implementation consequences.
For today’s medical coder:
Keep learning CPT.
Keep mastering ICD-10-CM.
Learn HCPCS.
Understand ICD-10-PCS.
Understand reimbursement.
Learn auditing and compliance.
Understand healthcare data.
Prepare for AI.
Watch ICD-11.
The lesson is not to abandon CPT.
The lesson is to prepare for a future in which medical coding professionals may need to understand far more than CPT.
September 14, 2026: A Date to Watch
According to the report, the deadline for comments on the RFI and proposed rule is September 14, 2026.
Providers, professional organizations, healthcare technology companies, manufacturers, coding professionals, payers, and other stakeholders therefore have an opportunity to participate in the policy discussion.
What emerges from that process could help shape future conversations about physician coding and reimbursement in the United States.
PMBAUSA Perspective
At PMBAUSA, we believe medical coding education must evolve beyond memorizing codes and passing certification examinations.
The next generation of medical coding professionals should understand clinical documentation, coding guidelines, reimbursement, compliance, auditing, healthcare data standards, interoperability, artificial intelligence, and emerging global classification systems.
Whether CPT remains largely unchanged or undergoes future reform, one principle will remain:
Codes may change. Coding systems may evolve. Technology may automate tasks. But professionals who understand clinical documentation, classification logic, compliance, and healthcare data will continue to have value.
The future belongs to the coder who understands not only the code, but also the system behind the code.
Important Note
This article discusses an ongoing policy and regulatory development for educational purposes. CMS is seeking public input regarding potential reforms and alternatives. No conclusion should be drawn that CMS has decided to discontinue, replace, or abolish CPT®.
CPT® is a registered trademark of the American Medical Association (AMA). PMBAUSA LLC is not affiliated with or endorsed by the AMA, CMS, AAPC, or AHIMA.
PMBAUSA LLC | Advancing Medical Coding, Billing, Compliance, Healthcare AI & Global Coding Education
Source: CMS Scrutinizes AMA’s CPT Coding System, Seeks Public Input — J&R Report. The report states that the RFI was included in the CY 2027 Physician Fee Schedule proposed rule and identifies September 14, 2026 as the comment deadline. (J&R Health Care News)
