Comment on CMS-2026-2377-0002

I appreciate CMS's efforts to improve valuation of maternity services and support the proposed 15% increase in the RUC-recommended work RVUs for the new labor management and delivery codes. This adjustment represents meaningful progress toward recognizing the physician work involved in obstetrical care. However, I remain concerned that the overall valuation of maternity care remains substantially below the work required to provide comprehensive care throughout pregnancy, delivery, and the postpartum period. Using CMS's assumption of eight prenatal visits, a representative uncomplicated vaginal delivery episode would include: Eight established outpatient prenatal visits (99213): 10.40 work RVUs Straightforward initial-day labor management (59XX1): 4.03 work RVUs Vaginal delivery (59XX5): 9.20 work RVUs Subsequent hospital care (99232): 1.59 work RVUs Hospital discharge management (99238): 1.50 work RVUs One postpartum office visit (99214): 1.92 work RVUs This totals only 28.64 work RVUs, compared with 37.00 work RVUs for the current global maternity code (59400), representing a reduction of 8.36 work RVUs (approximately 22.6%). Although the proposed 15% increase improves individual code values, budget neutrality across the code family does not ensure appropriate valuation of the typical maternity episode. The cumulative physician work associated with routine prenatal care, labor management, delivery, inpatient care, and postpartum follow-up remains substantially undervalued. I also oppose the proposal to create 15 HCPCS G-codes that would preserve the current global maternity coding structure. Because Medicare covers relatively few pregnant patients, these G-codes would provide limited benefit within the Medicare program itself. However, once incorporated into the national HCPCS Level II code set, they could readily be adopted by state Medicaid programs, Medicaid managed care organizations, and commercial insurers. This would likely result in a fragmented reimbursement environment in which some payers continue requiring global billing while others adopt the new CPT component codes or develop their own hybrid payment policies. Such inconsistency would create significant administrative burden for physician practices. Practices would need separate coding and billing workflows depending on payer requirements, along with different patient estimates, financial counseling processes, payment plans, and accounts receivable procedures. This fragmentation would increase coding errors, claim denials, staff training requirements, and patient confusion while undermining the primary objective of modernizing maternity coding to better reflect how obstetrical care is delivered today. Accordingly, I respectfully recommend that CMS: Finalize the proposed 15% increase in labor management and delivery work RVUs. Further reevaluate the component code values at the episode-of-care level to ensure that the cumulative physician work for a typical maternity episode is not substantially lower than the current global valuation. Do not finalize the proposed maternity HCPCS G-codes. If CMS determines that the G-codes must be retained, limit their use to Medicare fee-for-service, prohibit their adoption by Medicaid programs and Medicaid managed care organizations, establish a defined sunset date, and clearly state that these G-codes are not intended for adoption by commercial insurers. These recommendations would better recognize the work involved in providing comprehensive maternity care while avoiding unnecessary administrative complexity and preserving a more consistent reimbursement framework across payers. Thank you for your consideration of these comments.