Medicare Might Not Take the New OB Codes at All

Two facing pages of the CY 2027 physician fee schedule do opposite things.

On page 43881, CMS publishes proposed work RVUs for all 21 codes in the restructured maternity family, refining the RUC's numbers upward on the delivery side. On page 43882, it asks whether it should adopt those codes at all, and floats fifteen HCPCS G-codes that would keep the global obstetric package running inside Medicare as if the CPT Editorial Panel had never touched it.

"Which code set are you billing OB with on January 1, 2027?"

Nobody can answer that yet, and the answer lands in the final rule this fall. CMS's own fact sheet on the proposed rule does not mention maternity care once.

Four Visits, Moved Into the Delivery Room

At the January 2026 AMA RUC meeting the maternity globals were revised to delete 17 legacy CPT codes, create 12 new ones and revise nine, pulling the family out of the MMM global period and into four separately reported phases. The old bundle assumed 12 prenatal E/M visits folded into 59400, 59510, 59610 and 59618.

The RUC priced the new set against that same 12-visit assumption to make the change budget neutral: two level 2 established visits, eight level 3s, and two level 4s.

CMS looked at that and said the assumption is stale.

ACOG's May 2025 guidance describes 8 visits for an average-risk pregnancy and 13 for a higher-risk one. So CMS proposes to strike four visits from the utilization crosswalk, the two level 2s and the two level 4s, and move the freed RVUs to the other end of the episode: 11,810 work RVUs reallocated to the eight new labor and delivery codes, which works out to a 15 percent increase on every one of them (chart below).

The 15 percent is applied with a ruler. Vaginal delivery goes 8.00 to 9.20, primary cesarean 12.00 to 13.80, repeat cesarean 14.66 to 16.86. Not one antepartum, postpartum or ancillary code in the family moved a hundredth: cerclage stays at 3.02, postpartum curettage at 2.93, third-degree laceration repair at 2.47.

Spread across the RUC's utilization estimate of 12,791 services, the transfer is 0.92 work RVUs per labor and delivery service.

CMS attaches a warning to its own arithmetic, and it is worth reading twice: "we are not endorsing a reduced number of prenatal visits for pregnant women." The recalculation is a valuation input. It is also, functionally, Medicare pricing an 8-visit pregnancy.