The commenter supports the proposed 15% increase in work RVUs for labor management and delivery codes but argues that the overall valuation of maternity care remains undervalued. They also oppose the creation of new HCPCS G-codes, citing concerns over administrative burden and reimbursement fragmentation across different payers.

Remo Medical Group, a virtual dementia specialty practice, strongly supports the creation of HCPCS codes GACP1 and GACP2 and their inclusion on the Medicare Telehealth Services List. They argue that these codes are necessary to compensate clinical staff for advance care planning and advocate for the retention of separate codes to ensure clear tracking of physician versus clinical staff time.

The commenter, an administrator of an OB/GYN practice and certified coder, opposes the adoption of new G codes for maternity care. They argue that adding these codes would cause confusion for providers and patients, increase the burden of training and staffing, and complicate the claims process with payers.

Jessica Miller, representing Women's Healthcare Associates, argues that the proposed maternity care code restructuring results in a significant reduction in work RVUs for typical uncomplicated maternity episodes compared to the current global code. While they support the 15% increase in certain codes, they urge CMS to ensure the cumulative valuation remains equivalent to the current global value and strongly oppose the creation of new HCPCS G-codes due to potential administrative complexity and fragmentation.

A compliance officer for an EHR company and OB/Gyn subject matter expert supports the proposed changes. They argue that the current changes are necessary to resolve issues with Medicaid secondary payments and urge the agency not to introduce additional new codes.

The commenter opposes the proposal to delay the implementation of new maternity care services CPT codes by using temporary G-codes and allowing individual health plans to choose whether to adopt them. They argue that this approach creates administrative fragmentation, undermines standardization, and hinders CMS's goals for accurate quality measurement and value-based care.

The commenter opposes the creation of 15 new HCPCS G-Codes for CY 2027. They argue that a dual coding system will lead to payer exploitation, consumer confusion, and increased billing complexity for providers.

Colleen M. Mathias, Practice Administrator for Virginia Beach Obstetrics & Gynecology, argues that the proposed maternity care code restructuring results in an inadequate valuation of work RVUs for typical maternity episodes compared to the current global code. She also opposes the creation of new HCPCS G-codes, arguing they would create administrative burdens and fragmentation across different payers.

The commenter supports the proposed 15% increase in work RVUs for labor management and delivery codes but argues that the overall valuation of maternity care remains undervalued compared to the current global code. They also oppose the creation of new HCPCS G-codes, citing concerns over administrative burden and reimbursement fragmentation across different payers.

An OB/GYN is urging the agency to adopt the newly proposed codes and move away from the antiquated billing model. The commenter argues that the current system leads to payment denials and that the new codes are essential for providing adequate patient care.