The Centers for Medicare & Medicaid Services (CMS) released its CY2027 Medicare Physician Fee Schedule proposed rule (CMS-1848-P) on July 14, 2026. It addresses the implementation of the new CPT maternity care code restructuring, which unbundles traditional global OB codes 59400, 59510, 59610, and 59618 into separate antepartum, labor, delivery, and postpartum components. The rule also proposed 15 new HCPCS G-codes for 2027 that would preserve the existing global payment structure alongside the new unbundled codes. The comments period closed on September 14, 2026, with the final rule expected in early November.
Two paths for Medicare
The CPT restructuring is settled and takes effect on January 1, 2027, regardless of the final CMS decision. The operational groundwork required during 2026, from EHR template rebuilds to provider documentation training, is detailed in our earlier analysis of the 2027 maternity billing transition.
What remains undecided applies specifically to Medicare claims.
- Path one -Adopt the new CPT codes with an adjustment to the American Medical Association’s (AMA) valuation method.
- Path two – Create the 15 G-codes that carry the old global structure, including global period and payment conditions forward for Medicare while commercial plans and state Medicaid programs move to the new codes.
The comments/positions submitted by leading maternity care organizations
Leading maternity care organizations have presented a united front strongly supporting the new CPT codes while urging CMS to drop the parallel G-code pathway.
- American College of Obstetricians and Gynecologists (ACOG): ACOG welcomed the inclusion of the new CPT codes and the higher proposed values for labor and delivery. However, they opposed the G-codes pathway, arguing that operating parallel billing structures would force practices into dual workflows, create patient disparities based on coverage type and compromise price transparency.
- Ob Hospitalist Group (OBHG): Echoing ACOG, OBHG opposed the dual-structure approach, warning that maintaining two coding pathways increases administrative burden and leads to inconsistent care attribution.
- AMA: The AMA urged CMS to finalize the maternity code set without preserving the historical global structures, through G-codes, on the grounds that the parallel pathways adds unnecessary confusion to an already demanding transition.
- State Medicaid programs are running ahead of Medicare on this — many states have already unbundled maternity care payment or are in process, independent of how the Medicare rule resolves.
The valuation change worth modeling now
The AMA/Specialty Society Relative Value Scale Update Committee, the physician panel that recommends work values to CMS, valued the new code family based on 12 prenatal Evaluation and Management (E/M) visits bundled into historical global codes. ACOG’s current guidance recommends roughly eight visits for average-risk pregnancies and 13 for higher-risk cases. CMS proposed removing four visits from the utilization estimate and reallocating that value across the maternity family. Labor and delivery wRVU (Work Relative Value Unit) increase by about 15 percent, while antepartum and postpartum values decrease.
wRVU realignment may disproportionately affect practices whose patient cohorts and demographics don’t align with the statistical average CMS uses. A program with high delivery volume and employed OB hospitalists gains from the reallocation. A practice carrying long antepartum panels, high-risk patients requiring frequent visits, or patients who deliver elsewhere may experience reduced reimbursement under the reallocation.
What this means for your practice
Every published position supports the new codes and object only to the parallel Medicare pathway. The central debate, however, is over CMS’s proposed parallel G-code pathway, which ACOG and OBHG say creates a confusing dual-billing system rather than a clean transition.
CMS is expected to issue its final decision in November 2026. Successfully navigating this transition requires robust documentation that captures added clinical acuity, coding workflow that applies phase-specific rules correctly, and reliable payer crosswalks that hold across pregnancy milestones.
IKS Health’s specialized maternal-fetal coding team brings deep operational experience to practices navigating complex regulatory shifts. Let us help your organization prepare for a seamless transition by modeling the financial and operational impact of unbundled maternity care.
Reach out to us, we would be happy to help.