Comment on CMS-2026-2377-0002

RE: CMS-1848-P — CY 2027 Physician Fee Schedule Proposed Rule Maternity Care Services I am the Certified Billing and Coding Specialist for Women's Healthcare Associates, a large OB/GYN practice in Amarillo, Texas, providing comprehensive maternity care. I am submitting these comments on behalf of our physicians and practice. We appreciate the opportunity to comment on CMS's proposals concerning the restructured maternity care codes. We support CMS's proposal to increase the work RVUs for the new labor-management and delivery codes by 15%. CMS correctly recognized that the RUC-recommended values would undervalue these services. However, the proposed increase does not fully address the substantial reduction in work RVUs for a typical uncomplicated maternity episode. Applying CMS's eight-visit utilization assumption, a representative uncomplicated pregnancy and vaginal delivery may include: * Eight prenatal visits reported as CPT 99213: 10.40 wRVUs * Straightforward initial-day labor management, CPT 59XX1: 4.03 wRVUs * Vaginal delivery, CPT 59XX5: 9.20 wRVUs under CMS's proposal * Subsequent hospital care, CPT 99232: 1.59 wRVUs * Hospital discharge management, CPT 99238: 1.50 wRVUs * One postpartum office visit, CPT 99214: 1.92 wRVUs These services total only 28.64 wRVUs, compared with 37.00 wRVUs for current global maternity CPT code 59400. This represents a reduction of 8.36 wRVUs, or approximately 22.6%, for a representative uncomplicated maternity episode. This calculation assumes that subsequent hospital care and discharge management occur on separate dates. If the patient is discharged on the first postpartum day and only discharge management is reported, the total work RVUs for the episode would be even lower. Under the original RUC-recommended value of 8.00 wRVUs for vaginal delivery code 59XX5, the same episode would total only 27.44 wRVUs—a reduction of 9.56 wRVUs, or approximately 25.8%, from the current global value. CMS's proposed 15% increase is therefore an important first step, but the resulting valuation remains inadequate. Although CMS seeks budget neutrality across the maternity code family, budget neutrality at the code-family level does not ensure adequate valuation of the typical maternity episode. A reduction of this magnitude could be financially harmful to obstetrical practices already facing substantial staffing, malpractice, and operational costs. We urge CMS to reevaluate the component values at the episode-of-care level and ensure that cumulative work RVUs for typical prenatal care, labor management, delivery, hospital postpartum care, discharge management, and office postpartum care are reasonably equivalent to the current global maternity valuation. We also oppose the proposed HCPCS G-codes that would preserve the former global maternity coding structure. Although proposed through the Medicare Physician Fee Schedule, G-codes are part of the national HCPCS Level II code set and may be adopted by other payers. Because relatively few pregnant patients are covered by Medicare, the direct Medicare benefit would be limited, while the broader consequences could be substantial. Medicaid finances a significant portion of maternity care, frequently through Medicaid managed care organizations. Creating these G-codes could enable state Medicaid programs, Medicaid MCOs, and commercial insurers to continue requiring global billing after the corresponding CPT global codes are deleted. Some commercial payers could continue using the G-codes indefinitely, effectively preserving global maternity billing long after the new component-based CPT structure takes effect. This would create an administrative nightmare for obstetrical practices. Practices may be required to maintain parallel coding, billing, patient-estimate, financial-counseling, payment-plan, and accounts-receivable workflows to meet each payer's requirements. Some payers could require the new component CPT codes, while others could require global G-codes or impose their own bundling rules. This fragmentation would increase claim denials, coding errors, staff training requirements, and patient confusion while undermining the purpose of the maternity coding reforms. We urge CMS not to finalize the proposed maternity G-codes. If CMS nevertheless retains them, they should be strictly limited to Medicare fee-for-service claims, subject to a defined sunset date. They should not be permitted for state Medicaid fee-for-service programs, CHIP programs, or Medicaid MCOs. CMS should coordinate with the Center for Medicaid and CHIP Services to prevent state Medicaid agencies and their contracted MCOs from adopting these G-codes in place of the new component-based CPT structure. CMS should also expressly state that the G-codes are transitional Medicare codes and are not intended for adoption by commercial payers. Thank you for considering these comments. Jessica Miller A.A.S., CBCS Certified Billing and Coding Specialist