Get Credit for Unlisted CPT Codes: Compliant Approaches to wRVU Valuation

Most surgeons today work in employment arrangements where compensation is tied to production, often measured in work relative value units (wRVUs).  

Each Current Procedural Terminology (CPT^®)* code is assigned wRVUs by the US Centers for Medicare & Medicaid Services (CMS), based on recommendations from the American Medical Association/Specialty Society Relative Value Scale Update Committee (AMA RUC).^1-3 While the dollar value of each wRVU varies across payers and contracts, the wRVUs provide a relatively stable benchmark for measuring and rewarding surgeon productivity.

However, not all procedures correspond neatly to a CPT code descriptor. When this happens, coders will often rely upon “unlisted” codes to document the work performed. Because unlisted codes are a catchall for these orphan procedures, they are not assigned a value and reward exactly zero wRVUs. As a result, surgeons may not receive proper credit for their efforts. This article presents two methods to create fair wRVU values for unlisted codes, in an effort to assist both surgeons and institutions in recognizing the true value of the work performed.

Understanding Unlisted Codes: Institutional Perspective

Coders are required by corporate compliance and federal law to select the CPT code that most accurately describes the service provided.² When no code is appropriate, they are instructed to use an unlisted CPT code from the appropriate anatomic section (codes typically end in “99”). For unlisted codes, institutions also must submit:

• Key details regarding how the procedure was performed, anatomic area involved, and clinical indications
• Supplemental report describing the nature and extent of disease, indications, time and effort, and any special equipment used³

The payer then assigns both the payment and global period based on this documentation. A key insight that surgeons should be aware of is that it is possible to enhance reimbursement by including detailed explanatory text in the operative notes, which makes it easier for institutions to forward documentation to payers.

Claiming Your Value: Surgeon Perspective

The following provides two broad methods for assigning wRVUs to unlisted codes. The first, and simpler approach, uses a single crosswalk linking a known CPT code to the unlisted code. The second, slightly more labor-intensive process, assigns values using average wRVUs from a family of similar codes.

Both approaches are transparent, easy to understand, and comply with the Ethics in Patient Referrals Act (also known as Stark Laws I, II, and III),⁴ as they rely on predetermined methodology tied to established wRVUs, instead of service volume. Both of these methods are currently in use in US institutions where practices are receiving payment and the surgeons are receiving wRVU credit.

*All specific references to CPT codes and descriptions are © 2026, American Medical Association. All rights reserved. CPT is a registered trademark of the American Medical Association.

Method 1: Single-code crosswalk

Select a CPT code that best approximates the work involved with the unlisted procedure—this is identified as the “crosswalk” code. Next, assign the wRVU from the crosswalk code to the unlisted code.

Example 1: Minimally invasive oversewing of perforated ulcer

Crosswalk to: CPT 43840 (Open version of the same procedure)

This crosswalk method works well when there are one-to-one matches between an open and minimally invasive surgery. Other examples might include distal pancreatectomy or laparoscopic hepatectomy.

Example 2: Laparoscopic/robotic gastric/small bowel lesions or GIST removal

Crosswalk to wRVUs (see below): CPT 43610 (Excision of stomach lesion [if benign]) and CPT 43611 (Excision of stomach lesion [if malignant]) and CPT 44110 (Excise intestine lesion[s]) for all small bowel lesions.

Example 3: Multiple crosswalks

For procedures with several discrete steps:

1. Identify all applicable CPT codes.
2. Select codes that approximate the individual components of the operation.
3. Include 100% of highest wRVU value and 50% of remainder. This mirrors CMS’s multiple-procedure payment rule, ensuring that secondary components are appropriately discounted without undervaluing the overall operation.

The following depicts what this approach would look like for a complex breast operation with oncoplastic reconstruction.

Yellow highlights identify the unlisted CPT code and resultant calculated wRVU value.

Method 2: Average of a Family

This approach calculates an average wRVU across a group (“family”) of related CPT codes, then applies that value to the unlisted procedure. The method allows institutions to pre-assign wRVUs for unlisted codes prospectively, rather than determining values on a case-by-case basis:

1. Download the CMS Excel file that contains CPT codes and their wRVUs. https://www.cms.gov/medicare/payment/fee-schedules/physician/pfs-relative-value-files.
2. Sort the Excel file to exclude non-used HCPCS codes and other CPT codes.
3. Arrange the Excel file in CPT numerical order.
4. Construct “families” of similar organs and work-valued CPT codes.
5. Exclude dissimilar codes from each family (low value or ZZZ codes).
6. Calculate average value for each family and apply that value to the unlisted CPT code.

Example 4: Unlisted laparoscopic/robotic procedures on the esophagus

For examples 4, 5, and 6: Green highlights identify CPT codes used as a “family;” tan identifies codes excluded from the “family;” yellow identifies the unlisted CPT code and the resultant calculated wRVU value.

Example 5: Unlisted laparoscopic/robotic procedure on the stomach

Example 6: Unlisted laparoscopic/robotic procedures on the small bowel

This article provides two methods for assigning wRVU valuations to unlisted codes: single-code crosswalks and the average of the family. While there are other ways to assign these values, the methods presented are easy to understand and align with all the other requirements for physician compensation. These approaches currently are being used in institutions and surgeon practices for reimbursement and satisfy requirements for valuation. Ultimately, transparent and consistent assignment of wRVUs benefits both surgeons and institutions as it ensures fair compensation, accurate benchmarking, and recognition of the true value of surgical innovation.

Disclaimer

The thoughts and opinions expressed in this column are solely those of the authors and do not necessarily reflect those of the ACS.

Dr. Charles Mabry is a general surgeon in Pine Bluff, AR, as well as an associate professor in the Department of Surgery at the University of Arkansas for Medical Sciences in Little Rock. He is a long-term member of the ACS General Surgery Coding and Reimbursement Committee and has helped represent the ACS on the AMA RUC for 33 years.

References

1. American Medical Association. CPT code process. Available at: https://www.ama-assn.org/about/cpt-editorial-panel. Accessed October 18, 2025.
2. American Medical Association. RVS Update Committee. Available at: https://www.ama-assn.org/about/rvs-update-committee-ruc#:~:text=The%20RVS%20Update%20Committee%20(RUC,RUC%20does%20at%20the%20AMA. Accessed October 18, 2026.
3. Mabry CD, Nagle J. A Resource-Based Relative Value Scale (RBRVS) System.” In: Principles of Coding and Reimbursement for Surgeons. Authors: Savarise M, Senkowski C. Springer International Publishing, 2016.
4. Holland and Hart. Stark requirements for physician contracts. Available at: https://www.hollandhart.com/pdf/Stark-Requirements-for-Physician-Contracts.pdf. Accessed October 18, 2025.