Beyond the Global Maternity Package: Evaluating the Financial Impact of the Proposed CY 2027 Medicare Payment Changes

Key Takeaways:

• Recent CPT code restructuring, along with the recently released CY 2027 Medicare Physician Fee Schedule Proposed Rule, has provided healthcare organizations with a glance at how maternity services may be coded and reimbursed under the newly proposed framework.
• The financial impact is unlikely to be the same for every organization. For example, reimbursement under the proposed model will depend on a variety of factors. Healthcare organizations have enough detail to begin practice-specific financial modeling before the policy is finalized.
• Organizations that understand how the proposed methodology aligns with their own utilization patterns will be better positioned to make informed decisions regarding reimbursement, physician compensation, operational planning, and future budgeting.

The American Medical Association (AMA) CPT Editorial Panel recently approved a significant restructuring of the CPT® codes used to report maternity care, replacing the longstanding global maternity package with a component-based reporting methodology beginning January 1, 2027.

Building on those coding changes, the Centers for Medicare & Medicaid Services (CMS) recently released the CY 2027 Medicare Physician Fee Schedule Proposed Rule, which proposes how these new CPT codes would be valued and reimbursed under Medicare.

Together, these actions provide healthcare organizations with the first comprehensive view of how maternity services may be coded and reimbursed under the proposed framework. While the Medicare payment policies remain subject to public comment and may change before the final rule is issued, organizations now have sufficient information—including proposed payment policies, relative value units (RVUs), and reimbursement values—to begin evaluating the potential financial impact using their own historical data.

For physician practices and health systems, this represents an opportunity to move beyond speculation and begin understanding how the proposed changes could affect reimbursement, physician compensation, and operational planning.

Every Practice’s Financial Impact Will Be Different

Although CMS has proposed a single payment methodology, the financial impact is unlikely to be the same for every organization.

Reimbursement under the proposed model will depend on each practice’s historical utilization patterns, staffing model, and payer mix. Factors that may influence financial results include:

• Prenatal visit utilization and coding patterns
• Delivery mix, including vaginal, VBAC, primary cesarean, and repeat cesarean deliveries
• Labor management utilization and patient complexity
• Postpartum visit utilization
• Commercial payer reimbursement methodologies
• Physician staffing models and the use of Advanced Practice Providers (APPs)

Practices utilizing APPs for prenatal care while physicians perform deliveries should pay particular attention to the proposal. Because prenatal evaluation and management services billed by APPs are generally reimbursed at 85% of the physician fee schedule amount, organizations using this care model may experience different financial outcomes than practices where physicians provide the prenatal care.

Why Financial Modeling Matters

The publication of the proposed rule provides healthcare organizations with sufficient detail to begin practice-specific financial modeling before the policy is finalized.

Rather than relying on national estimates or generalized assumptions, organizations can compare their historical utilization with the proposed payment methodology to better understand how reimbursement may change. A financial impact assessment can help practices:

• Estimate potential reimbursement changes
• Identify the services that have the greatest financial impact
• Evaluate operational and documentation implications
• Assess potential effects on physician compensation models
• Support budgeting and strategic planning

Beginning this analysis before the final rule is issued provides organizations with additional time to educate providers and coding staff, evaluate operational workflows, and prepare for implementation should the proposal be finalized.

Looking Ahead

The proposed CY 2027 maternity payment methodology represents one of the most significant changes to obstetric reimbursement in decades. While the final Medicare policy may differ from the proposed rule, healthcare organizations no longer need to wait before beginning to assess the potential impact.

Organizations that understand how the proposed methodology aligns with their own utilization patterns will be better positioned to make informed decisions regarding reimbursement, physician compensation, operational planning, and future budgeting.

Every obstetric practice is unique. Differences in patient populations, provider staffing models, payer contracts, and historical utilization patterns mean that the financial impact of the proposed changes will vary from one organization to another. Practice-specific analysis can help leadership better understand potential revenue implications, identify operational considerations, and support informed decision-making before implementation.

If your organization would like to better understand how the proposed CY 2027 Medicare maternity payment changes may affect your practice, the Healthcare Consulting professionals at EisnerAmper can help evaluate your historical utilization and reimbursement data, model potential financial outcomes, and develop strategies to prepare for implementation.

This article was prepared with AI assistance and edited and enhanced by EisnerAmper professionals for accuracy and completeness. All technical content, analysis, and recommendations reflect the knowledge of our team.