ACOG Tells Health Plans to Move Antepartum Billing to E/M Codes by September 1, 2026
Key Dates & Details
What Happened
Alongside the April 23, 2026 AMA release of the new obstetric CPT codes, ACOG issued payer-facing transition guidance with a hard near-term date that has gone largely unreported. ACOG recommends that health plans begin accepting standard E/M codes (CPT 99202 to 99499) for antepartum visits, without visit limits or preauthorization, no later than September 1, 2026. The operative trigger is patient-level: for pregnancies whose first visit falls on or after September 1, 2026, providers should bill antepartum visits with E/M codes rather than the global obstetric codes, because those pregnancies will deliver in 2027 when the global codes no longer exist. ACOG further recommends appending the HCPCS TH modifier to flag the encounter as maternity care.
Who It Affects
Every payer that contracts for obstetric services: state Medicaid agencies, Medicaid MCOs, and commercial insurers. On the provider side it hits OB-GYN practices, midwifery practices, family medicine practices delivering maternity care, birth centers, and the hospital systems that employ them. For PHD's coverage perimeter, the exposed companies are the ones whose revenue depends on how prenatal encounters are counted and paid: remote monitoring and RPM vendors, prenatal screening and risk-stratification platforms, maternity care navigation, doula and community health worker networks billing as component services, and any value-based maternity contract priced off a global bundle.
Business Implications
This is the operational deadline that the January 1, 2027 date obscures. Unbundling does not arrive as a single switch on New Year's Day. It arrives as a rolling cohort problem starting September 1, 2026, because a pregnancy beginning in September delivers in 2027 and therefore straddles two incompatible billing regimes. A payer that has not stood up E/M acceptance for antepartum visits by September 1 will generate denials, rework, and provider abrasion on every pregnancy that starts after that date.
For vendors the read is straightforward. The September 1 date is when payer readiness becomes observable rather than theoretical. Plans that publish antepartum E/M guidance before then are committing to the CPT path; plans that stay silent are the ones most likely to take the CMS G-code escape hatch and preserve the global bundle. That divide is the market segmentation that matters for anyone selling maternity infrastructure in 2027, and it becomes legible in the next three weeks rather than after the CY2027 final rule.
The tension with CMS is unresolved and now dated. ACOG is telling plans to convert by September 1. CMS has proposed 15 HCPCS G-codes that would let those same plans keep the old global bundle through 2027, with comments due September 14. Payers are being asked to complete a conversion two weeks before the comment window closes on whether they will have to convert at all.
Sources
- ACOG: Payment for Obstetric Services (coding library)
- ACOG: After Years of ACOG Advocacy, AMA Releases New Obstetric Codes (April 23, 2026)
- AMA: CPT 2027 Maternity Care Services code changes