Comment on CMS-2026-2377-0002

The proposal to delay implementation of the new maternity care services CPT codes by replacing them with temporary G-codes and allowing individual health plans to determine whether to adopt them is based on inaccurate assumptions and is inconsistent with CMS's longstanding objectives to promote administrative simplification, improve quality measurement, and advance value-based care. The proposal characterizes implementation of the new maternity care services codes as potentially "disruptive for providers, payers, and billing systems." While any coding transition requires planning, this concern is overstated. Maintaining parallel coding systems would create greater disruption by requiring providers and health plans to navigate both legacy maternity CPT codes and temporary G-codes. This approach would increase administrative complexity, create inconsistencies in claims processing, raise implementation costs, and increase billing errors, payment delays, and claim denials. Rather than reducing burden, it institutionalizes unnecessary administrative fragmentation. CMS has consistently recognized administrative simplification as a core policy objective because standardized administrative processes reduce unnecessary costs and allow clinicians to spend more time delivering patient care. A national coding system achieves these objectives only when implemented consistently across payers. Allowing individual health plans to selectively adopt replacement G-codes would undermine standardization, create variation in billing and reimbursement, and conflict with CMS's efforts to promote uniformity and interoperability across the healthcare system. The proposal also fails to recognize the importance of updating coding infrastructure to reflect current clinical practice. CPT code revisions are developed through a rigorous multidisciplinary process involving specialty societies, practicing clinicians, payers, and other stakeholders to ensure coding accurately reflects contemporary care. Delaying implementation perpetuates an outdated coding framework that no longer represents modern obstetric practice, reducing the accuracy and clinical value of claims data. Accurate coding is fundamental to improving healthcare quality. Claims data support quality measurement, maternal health surveillance, utilization analyses, disparity identification, and quality improvement initiatives. When coding does not reflect contemporary maternity care, quality measures become less precise, provider comparisons become less meaningful, and opportunities to improve maternal and infant outcomes are diminished. The proposal also impedes CMS's transition to value-based care. Alternative payment models, episode-based payment, risk adjustment, and performance measurement all depend on accurate, clinically meaningful coding. Continuing to rely on outdated maternity codes limits CMS's ability to evaluate care delivery, measure value accurately, and implement payment reforms designed to improve maternal health outcomes. Maintaining obsolete coding structures also reduces transparency for patients. Modernized maternity care codes promote greater consistency in benefit design, claims adjudication, and reimbursement, helping patients better understand covered services and cost-sharing obligations. Allowing health plans to selectively adopt replacement G-codes would create unnecessary variation across payers, making it more difficult for patients to anticipate financial responsibility and compare coverage. Rather than delaying implementation through temporary G-codes and optional payer adoption, CMS should support timely, uniform implementation of the new maternity care services CPT codes across all payers. A single national coding framework reduces administrative burden, strengthens quality measurement through more accurate and clinically relevant data, and provides the infrastructure necessary to support value-based payment. These outcomes are fully aligned with CMS's statutory responsibilities and strategic priorities to improve healthcare quality, promote transparency, reduce administrative burden, and advance a more efficient and equitable healthcare system.