CMS Proposes 15 Maternity G-Codes in CY2027 PFS, Preserving the Global Fee Alongside Unbundling
Key Dates & Details
What Happened
CMS issued the CY2027 Medicare Physician Fee Schedule proposed rule on July 14, 2026. It does two things at once. It recognizes the new AMA/ACOG obstetric CPT codes (which restructure maternity billing into four distinct phases: antepartum, labor management, delivery, and postpartum) and proposes increased values for the new labor and delivery codes. But it also proposes creating 15 new HCPCS G-codes that would replicate the existing bundled global maternity payment structure, so that payers uncomfortable with unbundling could keep billing the old way. Both code sets would take effect January 1, 2027. Comments are due September 14, 2026.
ACOG President Camille A. Clare, MD, MPH, CPE, FACOG, issued a statement objecting to the G-codes while welcoming the rest. Her argument: running two billing structures simultaneously would raise administrative burden, undercut the price transparency the new codes were designed to create, and split patients into two groups based on whether their insurer chose to unbundle. "We urge CMS to adopt the new obstetric codes and make a clean break by not implementing the proposed G-codes," Clare said. Mark Simon, MD, Chief Medical Officer of Ob Hospitalist Group, echoed the concern, noting the G-codes would fail to account for the work of maternal care clinicians such as OB hospitalists who manage labor without performing the delivery.
Who It Affects
OB-GYN practices, OB hospitalist groups, health systems with maternity service lines, Medicaid managed care plans, and commercial insurers. Downstream, this affects every maternal-health company whose revenue depends on whether a discrete prenatal, monitoring, behavioral, or postpartum service has a billable home: remote monitoring vendors, virtual maternity care groups, postpartum recovery and pelvic health platforms, doula and community birth-worker networks, and maternal mental health providers.
Business Implications
This is the fork in the road for the unbundling thesis. The AMA code restructure alone implied that maternity services previously absorbed by the global fee would get their own codes, prices, and therefore their own procurement logic. The G-code proposal makes that outcome optional for payers rather than universal.
If CMS finalizes the G-codes, unbundling becomes payer-by-payer and state-by-state rather than a market-wide reset. That is materially worse for vendors selling a single national product story, and it favors companies already contracting payer-by-payer (Wildflower, Maven, Pomelo Care) over companies whose economics assume a uniform billing environment. It also means the state Medicaid agencies become the swing vote: Michigan has already published an implementation timeline (see Michigan Medicaid maternity unbundling policy page), and whether other state Medicaid programs follow the CPT path or the G-code path will decide how much of the Medicaid maternity book actually unbundles.
If CMS drops the G-codes, January 1, 2027 becomes a genuine reset of maternity economics, and the component rates become the entire story. The rates CMS proposed for labor and delivery went up roughly 15%. What CMS proposed for antepartum and postpartum components is the number that determines whether screening, monitoring, and postpartum recovery services get a viable price.
The September 14 comment deadline is now the most consequential date on the maternal health tech calendar.
Key Dates
- 2026-04-23: AMA and the CPT Editorial Panel announced the maternity coding restructure
- 2026-07-14: CMS issued the CY2027 PFS proposed rule with the 15 proposed maternity G-codes
- 2026-07-16: ACOG statement published objecting to the G-codes
- 2026-09-14: Public comments due
- 2027-01-01: Both the new AMA/ACOG obstetric CPT codes and (if finalized) the G-codes take effect
Sources
- CMS: CY2027 Medicare Physician Fee Schedule proposed rule fact sheet
- ACOG: Statement on new maternity codes in the 2027 Medicare PFS proposed rule
- Contemporary OB/GYN: CMS proposed G-codes for obstetric billing draw concern from ACOG
Covered In
- Pediatric Health Dispatch, August 4, 2026 — The drought correction: ~$87.5M across five rounds plus two acquisitions
- The G-Code Escape Hatch: Maternity Billing's Biggest Overhaul in Decades Just Became a Payer Choice, Not a Market Reset (August 5, 2026)