In part one of this four-part series, we reviewed what is changing with the American Medical Association’s (AMA) sweeping changes to maternity care coding effective January 1, 2027.
For the first time in decades, prenatal visits, delivery, and postpartum care will no longer be bundled under a single code as the AMA seeks to ensure greater visibility into the individual services provided throughout a pregnancy.
In this installment, we’ll take a closer look at the opposing views on response to these changes between the Centers for Medicare & Medicaid Services (CMS) and the American College of Obstetricians & Gynecologists (ACOG), as well as the added complexities of state-by-state variance with Medicaid.
Misalignments
In July of this year, CMS proposed a potential dual billing methodology and requested feedback on the creation of 15 new Medicare-specific HCPCS G-codes. ACOG expressed its opposition, and health plans are left needing to comply with the 2027 maternity code restructuring while prepared for change as federal and state requirements are finalized.
CMS
On July 14, 2026, CMS released its proposed 2027 Medicare Physician Fee Schedule, including proposed valuations for the new maternity CPT codes. At the same time, CMS requested public comment on the potential creation of 15 Medicare-specific HCPCS G-codes that would preserve the traditional global maternity payment model for Medicare claims.
If finalized, the proposal could result in two maternity billing methodologies operating simultaneously:
- The encounter-based CPT framework used by some payers
- A global Medicare framework supported by HCPCS G-codes
This possibility has generated significant industry discussion and debate.
ACOG
ACOG supports the new maternity CPT codes but has urged CMS not to create a separate set of Medicare G-codes, expressing concerns that maintaining both the new encounter-based structure and the legacy global model would require providers and payers to manage multiple billing methodologies. ACOG has also warned that a dual-system approach could increase administrative complexity and create variation in how maternity services are reported across payers.
ACOG’s response raised concern that separating patients according to insurer requirements could contribute to disparities in access to and quality of obstetric care. The CMS public comment period ended September 14, 2026, and final guidance may affect how Medicare maternity services are reported and reimbursed beginning in 2027.
Medicaid variance by state
Medicaid adds another layer of complexity. State programs may adopt different guidelines, which means health plans must evaluate the maternity changes across individual markets and lines of business rather than treat implementation as a single national configuration. As CMS, AMA, ACOG, and state programs continue to shape implementation guidance, health plans need an approach that supports the approved 2027 CPT code set while remaining flexible enough to accommodate final federal and state requirements.
Final thoughts
The 2027 maternity coding changes are moving forward, but the possibility of different Medicare, Medicaid, and commercial payer approaches creates significant implementation uncertainty. Cotiviti will continue to report on the latest developments for this new encounter-based framework. In part three of this series, we’ll look at the impact these changes have on health plans.
If you have questions around maternity coding changes or would like to learn how Cotiviti is helping our clients with January 1 maternity code compliance readiness, request a conversation, speak to your primary representative, or share your questions at answers@cotiviti.com.
