UnitedHealthcare Is Waiting on a Rule CMS Never Proposed
The October commercial bulletin gives OB practices two branches for January 1: use CMS's maternity G-codes if they are finalized as proposed, otherwise switch to phase-based reporting. CMS never proposed the G-codes. It asked a question about them, the comment window closed 26 days ago, and the branch UnitedHealthcare files under 'if not' is the only one on the table.
UnitedHealthcare's Payment Policy Group approved its obstetrical policy on July 1, 2001.
The global OB package it describes has survived twenty-five years of code-set churn, and on January 1 it stops describing how anyone bills. The instruction that ends it is four bullets in a two-page PDF.
The October 2026 Commercial Reimbursement Policy Update Bulletin posted on the first of this month with one maternity row under "Revised," effective 1/1/2027. The Individual Exchange bulletin carries the identical row, the Medicare Advantage and Community Plan bulletins carry none, and the obstetrical policy itself, 2026R0064B, last version-changed September 20, says nothing about any of it.
So the whole transition for two lines of business lives in a bulletin row, and there is a fork in it:
"If CMS finalizes its proposed 2027 maternity HCPCS G-codes as originally proposed, including being effective January 1, 2027, providers should report maternity services using the applicable CMS-designated HCPCS G-codes."
And then the other branch:
"If the CMS proposal is not finalized as proposed, effective Jan. 1, 2027, CPT maternity care services will transition from global obstetric reporting to phase-based reporting."
One of those is written as the condition and the other as the fallback. That ordering is backwards.
What CMS Actually Filed
Section 27 of the CY2027 physician fee schedule proposed rule has two subsections, and they are not the same kind of thing.
Subsection (a) is headed "Background and Proposal." It accepts the AMA RUC's January 2026 restructuring (17 legacy codes deleted, 12 created, 9 revised, per the rule's own count) and refines the valuation. A proposal, with values and a comment period.
Subsection (b) is headed "Comment Solicitation on Maintaining Current Coding Through Creation of HCPCS G-codes."
Watch CMS's verbs in it. "We are considering, and are seeking comment on, the creation of 15 new HCPCS G-Codes for CY 2027."
And, after comment, CMS "could finalize payment for these codes."
Then the framing that settles it: the G-codes are offered "as an alternative to the revaluation of the codes as discussed in Section (a)."
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