Every autumn, a coder in an independent practice opens the new CPT book, finds that a code she uses every day has been deleted, and asks the reasonable question of how a CPT code gets made: who decided this, and when? The answer is that it was decided about 18 months earlier, in a hotel meeting room, by a panel of 21 people, after an application process that most practices never see. The decision was public the whole time. Almost nobody outside the specialty societies was watching.
This month gives us a live example. The CPT Editorial Panel held its May 2026 meeting earlier this month, the second of three meetings in the cycle that produces the CPT 2028 code set, and the AMA posted the summary of panel actions on May 15. Requests for reconsideration of any action are due to AMA staff by May 29, fourteen days after posting. For most of the services an office practice bills, nothing in that summary will matter. For a few practices, something in it will change a code they use in 2028, and this is the earliest point at which they could know.
So this is a piece about how a CPT code gets made, using the May meeting as the example: who applies, how the Panel decides, what the summary of actions does and does not tell you, how valuation happens afterward, and how to keep an eye on the process without making it anyone's full-time job. A glossary line for physicians: CPT is Current Procedural Terminology, the AMA-owned code set for procedures and services that Medicare and nearly all payers use for physician claims. The CPT Editorial Panel is the AMA body that adds, revises and deletes codes.
Key takeaways
- The Panel meets three times a year (typically February, May and September); the May 2026 meeting was the second of three feeding the CPT 2028 code set, which takes effect January 1, 2028.
- The summary of panel actions, posted May 15, 2026, lists each proposal as accepted, rejected, withdrawn, postponed or referred, without the code numbers or descriptors, which are released with the book.
- Acceptance is only half the process; the RUC then recommends relative values, and CMS decides payment in the Physician Fee Schedule rule for that year.
- A practice does not need to follow the Panel closely, but its specialty society does, and a twice-yearly check of society coding alerts is enough.
- Category III codes and Proprietary Laboratory Analyses codes move on faster schedules, which is why some new codes appear mid-year.
Who applies and what an application contains
Anyone can submit a code change application: a specialty society, a device or drug company, a hospital, an individual physician. In practice, most successful applications come from or with the support of a national specialty society, because the Panel expects clinical evidence and because the society's advisors will be asked to comment. The application has to describe the service, explain why existing codes do not describe it, show that it is performed by many physicians across the country, present peer-reviewed evidence of safety and effectiveness for Category I status, and, for revisions and deletions, explain what has changed in practice.
Applications are posted publicly before each meeting in the form of an agenda, with the specialty and a short description of each item, and interested parties can comment. Many of the items on the May 2026 agenda concerned imaging, remote and digital services, and procedure families where technology has changed, which has been the pattern for several cycles. A radiology-related set of proposals at this meeting, for example, was sent back for refinement and resubmission rather than accepted, which is a common outcome for first-time applications with novel technology.
How a CPT code gets made: the meeting itself
The Panel has 21 voting members: physicians nominated by the AMA and by national medical specialty societies, plus representatives from the health insurance industry, hospitals and CMS. Two advisory groups sit alongside it: the CPT Advisory Committee, with a representative from each specialty society in the AMA House of Delegates, and the Health Care Professionals Advisory Committee for non-physician professions. Advisors comment on applications before the meeting and testify at it, but they do not vote.
Each application gets a presentation, questions, testimony from advisors and interested parties, and a vote. The possible outcomes are accept (sometimes with modifications made in the room), reject, table for a later meeting, refer to a workgroup, or the applicant withdraws before a vote. The meeting is open to registered observers, and since the Panel's transparency changes in recent years, the agenda, the summary of actions and the code descriptors have been made public earlier than they used to be.
What the summary of actions tells you, and what it does not
| Document | When it appears | What it contains | What it lacks |
|---|---|---|---|
| Meeting agenda | About six weeks before the meeting | Each application by tab number, specialty and short description | Applicant identity in some cases; detailed descriptors |
| Summary of panel actions | Within about a month after the meeting (May 15, 2026 for this meeting) | Each tab's outcome: accepted, rejected, withdrawn, postponed, referred | Code numbers, final descriptors, guideline text |
| Reconsideration window | 14 days after posting (May 29, 2026 for this meeting) | Applicants and interested parties may request the Panel revisit an action | Public visibility of the requests |
| Early release of descriptors | For some categories, before the book; Category III and PLA codes semi-annually | Code number and descriptor for early-effective codes | Payment information |
| CPT code set release | Early September of the year before the effective date (September 2027 for CPT 2028) | Full code numbers, descriptors, guidelines, deletions and cross-walks | Medicare payment, which comes in the final Physician Fee Schedule rule in November |
The summary of actions is deliberately spare. It tells you that a proposal to add codes for a particular service was accepted; it does not tell you the code numbers or exact wording, which are still subject to editorial work. For a practice, the useful reading is: did anything in my specialty get accepted for revision or deletion? If so, the specialty society's coding staff will publish an explanation within weeks, and that is the document to read.
Valuation: the half of the process practices care about most
Acceptance by the Panel creates a code. It does not create a payment. After the meeting, accepted codes go to the AMA/Specialty Society RVS Update Committee, the RUC, which surveys physicians who perform the service about the time and intensity involved, reviews practice expense inputs, and recommends relative value units to CMS. The RUC meets three times a year as well, on a schedule that follows the Panel's by a few months.
CMS then decides. It publishes proposed values in the Physician Fee Schedule proposed rule each July and final values in the final rule around November 1, for codes effective the following January. CMS accepts most RUC recommendations but not all, and the ones it changes are often the codes with the largest payment impact. For a code accepted at the May 2026 meeting, the sequence is roughly: RUC survey and recommendation later in 2026 or early 2027, proposed values in the July 2027 PFS proposed rule, final values in November 2027, and payment beginning January 1, 2028.
This is why a two-year lag is built in, and why a practice cannot bill a new service the moment the Panel accepts it. It is also why the practices that are least surprised in January are the ones whose billing lead reads the specialty society's summary of the proposed rule every July. Our coding courses walk through one full cycle for exactly this reason.
Category III, PLA and the mid-year surprises
Not everything waits for January. Category III codes, the temporary "T" codes for emerging technology, are released twice a year and become effective six months after release; a Category III code accepted at a May meeting can be effective the following January but is released in the interim. Proprietary Laboratory Analyses codes, the "U" codes for specific lab tests, are handled by a separate PLA Editorial Panel process on a quarterly cycle and can appear in the middle of a year with little notice to practices that order the tests.
These are the codes behind the mid-year "why did this claim reject for an invalid code" calls. Any practice that performs or bills emerging procedures or orders proprietary lab tests should have someone check the AMA's Category III and PLA release pages each quarter, or rely on a clearinghouse edit that flags codes not yet in the payer's system.
How much attention an independent practice should pay
Honestly, not much, but not none. The Panel's work matters to a practice at two moments: when a code the practice bills is up for revision or deletion, and when a service the practice performs without a specific code gets one. Both are visible in the agenda and the summary of actions, and both are explained by the specialty society within weeks. A coder who reads the society's coding alerts after each of the three meetings and the AMA's September code set release will catch everything that matters. The rest of the process can be left to the people paid to attend.
What a practice should not do is wait for the book. By the time the CPT 2028 book arrives in the autumn of 2027, decisions taken this month are two years old, and the practice has lost the chance to comment through its society, to plan documentation changes, or to model the payment effect. The May 15 summary is the earliest warning the process offers, and it is free.
Questions we hear
Can our practice comment on a proposal?
Yes. The agenda is posted before each meeting, and anyone may submit comments to AMA staff on an application by the stated deadline. In practice, comments carry more weight when they go through the specialty society, whose advisor speaks at the meeting. If a proposal would delete or restructure a code you rely on, tell your society's coding committee as soon as the agenda appears.
Why does the summary say a code was accepted but the September release shows something different?
Between acceptance and publication, the code undergoes editorial work, the descriptor can be refined, and reconsideration requests can alter or reverse an action. The summary is updated when that happens (the May 2026 summary itself carries an updated date), which is why the society's explanation after the September release is the version to trust.
Is there a way to know the payment before January?
The proposed Physician Fee Schedule rule each July includes proposed RVUs for new and revised codes for the following year, and the final rule around November 1 sets them. Between July and November a practice can model the effect on its own volumes. Commercial payers usually follow the Medicare RVUs with a lag of a few months, and some do not adopt new codes until their annual fee schedule update.
What to do this week
- Find your specialty society's coding alert or summary of the May 2026 Panel meeting and read it; if none exists yet, put a reminder for mid-June.
- Check the AMA's summary of panel actions for any item in your specialty marked accepted, and note it in a running "CPT 2028 watch" list.
- Subscribe one person to the AMA's Category III and PLA release notices if your practice performs emerging procedures or orders proprietary lab tests.
- Put the September 2027 CPT 2028 release and the November 2027 final Physician Fee Schedule rule on the practice calendar now.
- Ask your clearinghouse whether its scrubber flags codes not yet loaded by each payer, which is the practical defense against mid-year code rejections.
