Video Preview
🎧 Podcast episode for paid subscribers only. Also available on Apple Podcasts and Spotify.
To listen to paid episodes in Apple or Spotify, link your Substack subscription via the show settings on those platforms (instructions inside the Substack app under Subscriptions → Podcast).
Table of Contents
The racket, in one paragraph
How a 1966 style guide became federal law
How a 1966 style guide became federal law
The money machine: what the licensing actually looks like
The RUC: where the fox prices the henhouse
Courtroom history: the copyright misuse landmine nobody defused
The 2026 pile-on: a lawsuit, an RFI, and a comment box
Can you own the law? The precedent problem
What replacement would actually look like, and why it is hard
Handicapping the outcomes
Why operators and investors should care
Table of Contents
• The AMA owns the copyright to CPT, the code set federal law effectively requires for nearly every physician billing transaction in the US
• CPT licensing generates north of 300 million dollars annually; the AMA reported 296.4 million in books and digital content revenue in 2025, with 267.5 million in net income on that line
• The same organization runs the RUC, the committee whose recommendations CMS historically adopts for the vast majority of physician payment values
• August 13, 2026: PatientRightsAdvocate.org sued to invalidate the copyright entirely, in the Northern District of Illinois, one month after CMS opened an RFI on alternatives to CPT and the RUC in the CY 2027 fee schedule rule
• HHS leadership is publicly soliciting comments, a senator has called the AMA a government backed monopoly, and the comment deadline is September 14, 2026
• The legal theory rests on Georgia v. Public.Resource.Org, Veeck, and a 1997 Ninth Circuit copyright misuse finding the AMA never fully escaped
• Bottom line: the moat held for six decades because nobody had the incentive and standing to attack it simultaneously; that changed this summer
The racket, in one paragraph
Here is the setup, stripped of politeness. A private trade association writes a dictionary. The federal government then requires, via regulation, that essentially every doctor, hospital, payer, clearinghouse, EHR vendor, RCM shop, and coding tool in the country use that dictionary for billing. The association charges everyone rent to use it. That rent runs somewhere north of 300 million dollars a year. And, as a kicker, the same association convenes the committee that tells Medicare how much the services described by those dictionary entries should cost, and Medicare historically says yes to most of it. Commercial payers then benchmark off Medicare, so the influence cascades through the entire 2 trillion dollar plus physician services and adjacent economy. If a tech company pulled this off it would be a case study in every antitrust seminar in the country. Because it is the AMA, and because the arrangement is 60 years old and wrapped in the language of clinical standardization, it mostly just sat there. Until this summer, when it stopped sitting there.


