UPDATE: CMS Finalizes Payment Rule for Unbundling Maternity Services
On November 4, 2026, the Centers for Medicare & Medicaid Services (CMS) released CMS-1848-F, the Calendar Year (CY) 2027 Medicare Physician Fee Schedule Final Rule, which finalizes payment policies and addresses comments on the proposed rule issued July 16, 2026, including the 2027 maternity payment unbundling. Key takeaways include:
- CMS will not create an interim system of G-codes, which had previously been considered for use during the transition to the unbundled codes and which most commenters on the proposed rule opposed. CMS notes that it “may consider the creation of bundled codes describing maternity care services in future rulemaking using the information on the billing patterns associated with the unbundled visit codes.”
- CMS notes that there is temporary flexibility in coding and billing for pregnancies spanning 2026–2027, deferring to American Medical Association (AMA) and American College of Obstetricians and Gynecologists (ACOG) guidance. The rule states that “Payers and health plans may issue business rules in advance of January 1, 2027, instructing providers, clearinghouses and other trading partners regarding CPT [Current Procedural Terminology] code use when billing for Maternal Care Service episodes of care in which services begin in 2026 and end in 2027.”
- CMS is enacting the redistribution of Relative Value Units (RVUs) from prenatal visits to labor and delivery codes that the agency outlined in the proposed rule, which would reallocate about 15 percent of the relative value of services from prenatal visits to labor and delivery. RVUs are used to measure the relative resources involved in providing a service and to calculate payment rates. This change will remove four of the previously assumed 12 prenatal evaluation and management (E/M) visit codes that were covered in the global payment approach from the utilization estimate calculation and reallocate the RVUs within the code family to the new labor and delivery codes. This adjustment is intended to reflect a more current view of how resources and services are typically used. With services and payment unbundled across the course of care, this change may shift additional reimbursement toward providers that offer labor and delivery services, although it is not intended to affect the number of prenatal visits provided. The final rule reiterates that the number of prenatal visits should be determined by medical necessity and that the change aligns with more recent guidance from ACOG.[1] CMS stated that it “is not endorsing a reduced number of prenatal visits for pregnant women. Our recalculation of the utilization estimates in the valuation of these services should not be used to determine the appropriate number of visits to provide reasonable and necessary care” for enrollees.
HMA can help your organization understand the impact of these changes and prepare for implementation in January 2027.
[1] CMS noted in the proposed rule that: The previous MMM global period included 12 prenatal E/M visits bundled into CPT codes 59400, 59510, 59610, and 59618. In May 2025, the American College of Obstetricians and Gynecologists (ACOG) published new clinical guidelines, recommending that obstetrician-gynecologists and other maternity care professionals tailor the visit frequency and monitoring schedule to the needs of the pregnant woman. These new clinical guidelines provide a sample schedule for prenatal care services and visit frequency, which describes 8 visits for average-risk pregnant women without medical or pregnancy complications, and 13 visits for pregnant women with greater-than- average risk.
What the shift away from global obstetric billing may mean for care delivery, coding and documentation, reimbursement, quality measurement, and more.
AT A GLANCE: Beginning January 1, 2027, maternity care reimbursement will change from bundled global obstetric codes toward more granular, service-level reporting for antepartum care, labor management, delivery, and postpartum care. The new approach is intended to more accurately capture how maternity care is delivered today across multiple clinicians, settings, modalities, and risk profiles. Organizations should begin assessing operational, financial, contracting, and data implications now.
What Is Changing?
Under the new approach, maternity services will be recognized and reported at the service level rather than through a single global obstetric payment. The impacts will unfold over time and will depend on final policy, coding guidance, fee schedules, contracts, and implementation decisions specific to payers, providers, and local markets.
What This Will Mean?
This change is more than a coding update. It will affect payment policy, claims systems, documentation workflows, actuarial assumptions, provider contracts, quality and access monitoring, data reporting, and patient care models. For Medicaid agencies, health plans, federally qualified health centers (FQHCs), hospitals, physician and midwifery practices, and professional associations, the transition creates implementation risks and uncertainties as well as opportunities to modernize maternity care financing around person-centered perinatal care, social needs screening and management, telemedicine, home monitoring, and postpartum support. Early preparation can reduce disruption and enable increased visibility into access, quality, equity, outcomes, and total cost.
New Questions Stakeholders Will Need to Answer
- How will payment rates, fee schedules, and contracts change when maternity care is no longer paid as a single global payment?
- What documentation, coding, and billing workflows will providers need to update before the new codes (and/or potential interim codes, depending on the Centers for Medicare & Medicaid Services (CMS) decision-making) take effect in order to ensure that care is correctly reimbursed?
- What systems changes and staff training will be needed?
- What claims edits, utilization management rules, encounter data processes, and reporting systems will need to be revised?
- How will payers distinguish routine care, higher-risk care, care coordination, social needs services, telehealth, and home monitoring?
- How can stakeholders use new data to assess access, quality, equity, outcomes, and total cost of maternity care?
Supporting Next Steps
HMA can help stakeholders understand the implications of the new coding structure, evaluate policy and operational options, create a practical path forward, and operationalize that plan across programs, systems, contracts, and care delivery models.
| Stakeholder | How HMA Can Help | HMA Services Include |
|---|---|---|
| States | Assess Medicaid policy impacts, update provider guidance, model budget and rate implications, align managed care contracts, and design monitoring strategies for access, quality, equity, and outcomes | Revenue Cycle Management Actuarial Analysis Market Analysis and Strategic Planning Financial Modeling Operational Planning and Implementation Support Research and Evaluation Contract Review and Negotiation Support Business Analytics Clinical and Health-Related Social Needs Service Model Development Quality Measurement and Accreditation Support Information Technology Advisory Services |
| Providers: FQHCs, hospitals, physician practices, and midwifery groups | Help organizations prepare for coding, documentation, billing, revenue cycle, and clinical workflow changes; identify training needs; and evaluate how new payment rules affect service delivery and financial sustainability | |
| Health plans | Revise payment policies, claims logic, provider communications, contract terms, encounter data processes, and network oversight approaches to support a smooth transition | |
| Associations and coalitions | Translate the changes for members, develop implementation roadmaps, convene stakeholders, identify advocacy priorities, and support coordinated action across the maternity care environment |
Frequently Asked Questions
What is changing in maternity care reimbursement in 2027?
Maternity care reimbursement is shifting from bundled global obstetric billing toward more granular, service-level reporting for antepartum care, labor management, delivery, and postpartum care.
Who will be affected by the maternity care coding changes?
OB/GYN practices, hospitals, FQHCs, midwifery groups, health plans, Medicaid agencies, professional associations, and other organizations involved in maternity care financing, delivery, claims, contracting, or oversight will be affected by these significant changes.
What should organizations do first?
Start with an impact assessment: inventory current payment arrangements, map services and documentation, identify systems changes and training needs, model financial effects, review contracts, and develop implementation roadmaps.
