Comment on CMS-2026-2377-0002

I am submitting these comments on behalf of Birmingham Obstetrics Gynecology, P.C., an independent Alabama practice expecting to care for more than 1,300 deliveries during the next 12 months. Approximately 30% of our deliveries involve patients from rural counties. We support CMS’s adoption of the new maternity care CPT codes for 2027. We strongly oppose creating HCPCS G-codes that recreate the deleted global maternity codes. CMS is concerned that the new codes may be disruptive. The greater disruption, however, would come from maintaining two fundamentally different maternity billing systems. If some payers adopt the new CPT codes while others retain global billing through G-codes, practices will have to maintain separate coding rules, fee schedules, claim edits, workflows, and training based on each patient’s insurance. The result will be more denials, greater administrative expense, increased confusion when patients change coverage during pregnancy, and less reliable cost estimates for patients. The global maternity codes also no longer reflect contemporary care. Prenatal services are increasingly individualized according to each patient’s risk, clinical needs, and access barriers. The new codes more accurately report the care actually provided and create better data for measuring prenatal access, postpartum completion, rural maternity care, clinical outcomes, and future value-based payment models. CMS should establish one clear national direction: Adopt and appropriately value the new maternity CPT codes. Do not create G-codes that preserve the deleted global structure. Provide clear transition rules for pregnancies spanning 2026 and 2027. Encourage Medicaid and commercial payers to implement the new codes consistently. Modernizing maternity coding will require preparation. Creating parallel coding systems will not simplify that transition—it will make it substantially more burdensome. For these reasons, Birmingham Obstetrics & Gynecology urges CMS to adopt the new maternity CPT code structure and not finalize the proposed HCPCS G-codes. Sincerely, David G. Carmichael Executive Administrator/CEO Birmingham Obstetrics & Gynecology, P.C. Birmingham, Alabama