This pilot project developed a validation process for the work relative value units (RVUs) used in the Medicare Physician Fee Schedule (PFS). We collected empirical time estimates for 60 physician services, not including evaluation and management services. Overall, our results suggest that current PFS physician intraservice time values tend to be higher than the empirical data we collected through direct observation and EHRs for the services we studied. The findings of this pilot study suggest that the current approach to estimating time and work results in differentially inflated time and work values throughout the PFS, causing inconsistently inaccurate payment rates for physician services.