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Jaclyn Chapman, Senior Manager, Deloitte Consulting LLP; Katherine Gordon Backes, Senior Manager, Deloitte Consulting LLP; Sarah Garcia, Senior Consultant, Deloitte Consulting LLP
The first installment in our Health Forward blog series on maternity billing explores the changes taking effect January 1, 2027, and considerations for health systems, health plans, clinicians, and patients as they prepare for the transition
Nearly 3.6 million babies were born in the United States last year. i Behind many of those births stands the same arc of care: roughly 13 prenatal visits for an uncomplicated pregnancy, labor and delivery, and postpartum follow-up, totaling 16 or more clinical encounters spread across the better part of a year. ii
For more than three decades, American health care compressed that arc into a single line item. The global obstetrics (OB) bundle—one code, one claim, one payment—treated nine months of care into one bundled payment. iii High-risk monitoring, gestational diabetes management, laborist handoffs, telehealth check-ins, the work of the full care team: all aspects of prenatal care was combined into one charge.
On January 1, 2027, that reporting structure changes: the single line item becomes unbundled. The American Medical Association (AMA) and the American College of Obstetricians and Gynecologists (ACOG) are replacing the current global obstetrical package with a new itemized coding framework for reporting prenatal, labor management, delivery, and postpartum services. iv Pregnancy care will be billed the way it is delivered: visit by visit, clinician by clinician, and claim by claim.
Commercial insurance covers 52% of U.S. births, while Medicaid finances roughly 40%, with the remainder of individuals covered through other payment sources, self-pay or uninsured arrangements. v As a result, the transition has implications across virtually every segment of the maternity care ecosystem.
For revenue cycle leaders, this is likely to be the operational event of 2027.
There are potential opportunities to innovate care for better outcomes. Richer visit-level data, earlier identification of complications, and payment that rewards coordinated team-based care are levers for improving safety and quality for mothers and babies, the same data that helps a system negotiate is the data that can help a clinician catch a complication sooner.
A window that matters: September 2026
While the coding changes take effect on January 1, 2027, many organizations are likely already evaluating the operational activities involved in preparing. Payer contracts that reference global obstetric (OB) codes should be reviewed and, in many cases, amended before the new coding structure takes effect. ACOG recommends starting the transition to antepartum evaluation and management (E/M) coding in September and has been specific about what should be included: no visit limits and no prior authorization requirements for antepartum visits. vi Contract negotiations often take six to eight weeks or longer, making the month of September an important planning period for many organizations.
That cross-year cohort can be a risk. Patients who begin prenatal care this fall may ultimately deliver under the new code set. A patient who begins prenatal care in October 2026 and delivers in March 2027, for example, will span both coding structures, requiring organizations to address how those episodes will be attributed and submitted. Contracts left unamended past September may create reimbursement and claims processing challenges before go-live, while the organization is still, on paper, ahead of the deadline.
Beyond the bundle: greater visibility into maternal health needs
Moving from a bundled maternity payment to a more granular, encounter-level reimbursement and claims structure could provide greater visibility into the clinical, behavioral, and social needs that arise across pregnancy, delivery, and postpartum care. Rather than treating maternity care as a single episode, this approach may enable health systems, providers, and payers to better distinguish services associated with high-risk pregnancy management, gestational diabetes, pre-eclampsia monitoring, behavioral health, and social support. This additional transparency could support earlier identification of risk factors, more targeted interventions, improved care coordination, and a clearer understanding of the resources involved in serving patients with complex maternal health needs. However, greater granularity would not, by itself, ensure improved outcomes or adequate reimbursement; results would likely depend on coding quality, data completeness, payment design, and operational execution.
A more detailed reimbursement structure could also make the contributions of the broader maternal health care team more visible. Laborists, clinicians, midwives, community health workers, lactation consultants, mental health clinicians, and other professionals may be represented more clearly across the care journey. This could improve visibility into how care is delivered, which providers are contributing to patient outcomes, and where capacity or coordination gaps may exist and an opportunity to improve care as a result. The practical value would likely depend on consistent documentation, provider participation, appropriate attribution, and the ability to integrate data across settings.
The shift could create opportunities to evaluate and potentially expand care models that support patients throughout pregnancy and postpartum. Telehealth visits, remote patient monitoring, group prenatal care, and multidisciplinary support services may become more sustainable within reimbursement models, allowing women to access care in ways that are more convenient, continuous, and responsive to their individual needs.
Replacing a single bundled payment with encounter-level claims data may provide health systems and health plans with deeper insights into utilization, outcomes, and care gaps, helping identify opportunities to improve maternal health outcomes, care coordination, and future maternity contract negotiations.
Payers have a parallel opportunity. Consumers' needs are about to change shape, with multiple bills, new cost-share patterns, and new access points like telehealth and team-based care, and plans should consider anticipating those needs. By evaluating health plan readiness, strengthening care coordination, and identifying high-risk pregnancies earlier, payers could be better positioned to control costs while sustaining high-quality care. vii
This could be an opportunity to improve transparency and coordination without creating unnecessary administrative burden, affordability concerns, fragmented care, or confusion for pregnant and postpartum patients.
Potential unintended consequences
Denials are likely the single largest preventable financial and health outcome impact of this transition, and the mechanics can be stated plainly.
When major CPT coding transitions occur, claims submitted using retired or invalid codes may be denied if payer contracts have not been updated accordingly. viii Because adjudication systems validate claims against current coding requirements, outdated codes are often flagged as invalid, resulting in denials, reimbursement delays, and additional administrative burden.
Organizations may experience claim denials and reimbursement delays as they adapt contracts, systems, and workflows to support new coding requirements. ix
Two characteristics of the transition can make this exposure particularly challenging:
When radiation oncology moved away from bundled payment structures, the transition brought its own set of challenges, including documentation burden, billing complexity, and access issues that outlasted the policy change itself. xii
The closest recent analogue in scale, the 2021 E/M overhaul, produced a similar pattern of undercoding as clinicians continued to rely on familiar coding practices rather than fully adopting the new coding framework. xiii
Across these precedents, a consistent pattern emerges: organizations experience challenges at the end state. The greatest challenges tend to occur during the transition itself, in the months when contracts, systems, documentation habits, and payer logic are all mid-migration, and gaps between them is a claim that doesn't get paid, rather than after the new model is fully implemented.
Other factors and considerations
A transition that is not adequately planned and coordinated can create four distinct risks, each landing on a different constituency.
Then there is the potential consequence that extends beyond the ledger. Coverage churn and billing friction can create additional obstacles to prenatal care, with the potential for missed visits, interrupted monitoring, and gaps in continuity of care. xiv
Roughly one in ten U.S. births is preterm. xv While many factors contribute to maternal and neonatal outcomes, consistent access to prenatal care remains important throughout pregnancy. xvi A transition that disrupts prenatal continuity can carry stakes measured in outcomes for families and, for health systems and payers, in the broader costs associated with complex maternal and neonatal care.
90-day revenue cycle considerations
For revenue cycle leaders, the period leading into transition presents an opportunity to evaluate organizational readiness and identify areas requiring attention.
Considerations:
Assess potential impacts. Convert current global-OB revenue into visit-level E/M equivalents by payer, volume, and coding behavior. This model can be the foundation for every negotiation that follows; organizations that walk into payer conversations without it are likely to negotiate from a deficit.
Review and prioritize contracts. Identify every contract referencing global OB codes, rank by exposure and deadline urgency, and direct contracting bandwidth to the highest-risk payers first. Establish interim billing protocols so claims submitted mid-renegotiation remain defensible.
Retrain coders, billers, and the clinicians upstream of them. New claim structures, new charge capture logic, and new clearinghouse edits—teams could use hands-on practice before claims flow. ACOG's recommendation to begin using E/M codes now for early antepartum visits is, in effect, a free rehearsal.
Establish denial monitoring. Leakage from this transition could compound silently. Real-time denial tracking, undercoding surveillance, and revenue-versus-projection monitoring should be live at go-live. Discovering the problem in a quarterly report likely means discovering it after the timely-filing clock has run out.
For clinicians, documentation now could directly determine what the organization collects. Every visit should support the E/M level billed; coding gaps at the physician level are likely to cause revenue losses at the system level.
For women and families, a single bundled charge may become multiple bills with new cost-share patterns, making proactive communication an important component of the transition.
Organizations may also consider investing in plain-language communications and financial counseling resources to help patients understand what is changing, what remains the same, and where to seek support. Clear expectations can help reduce confusion and support a positive patient experience throughout the transition.
Preparing for the next phase of maternity care
Organizations that view January 1, 2027 as a broader shift in how maternity care is measured and reported may gain greater visibility into care delivery, utilization patterns, and patient needs across the maternity journey. That visibility may support stronger decision-making around care coordination, quality, access, workforce planning, and reimbursement.
September represents an important readiness window. The months leading up to the transition provide an opportunity to review contracts, prepare operational teams, evaluate systems and workflows, and establish the monitoring capabilities needed to support a smoother implementation.
Acknowledgments: Jennifer Radin, Andrew Davis, Anne Phelps, Vivian Monitto, Jessica Qian, Catherine Gergen
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Endnotes:
iHamilton BE, Osterman M, Gregory E. Births: Provisional Data for 2025. CDC/NCHS VSRR. 2025(43):2 — 3,606,400 US births in 2025.
iiMorgan J, Bauer S, Whitsel A, et al. Society for Maternal-Fetal Medicine Special Statement: Postpartum visit checklists for normal pregnancy and complicated pregnancy. American Journal of Obstetrics & Gynecology, 2022; 227, B2-B8
iiiACOG, After Years of ACOG Advocacy, AMA Releases New Obstetric Codes. Published April 2026
ivAMA, FAQs: CPT 2027 Maternity Cares Services code changes. Published August 11, 2026.
vOsterman MJK, Hamilton BE, Martin JA, Driscoll AK, Valenzuela CP. Births: Final Data for 2024. National Vital Statistics Reports. 2026 Jun;75(2):1–48. doi:10.15620/cdc/252440.
viAmerican College of Obstetricians and Gynecologists. Payment for Obstetric Services. Accessed September 2026.
viiBower L, Bono B. What 2027 Maternity Billing Changes Mean for Employer Health Plans. Mercer US Health News. Published June 24, 2026.
viiiBower L, Bono B. What 2027 Maternity Billing Changes Mean for Employer Health Plans. Mercer US Health News. Published June 24, 2026.
ixAmerican Medical Association. FAQs: Preparing for the CPT® 2027 Maternity Care Services code changes. Published September 17, 2026; Centers for Medicare & Medicaid Services. Medicare Administrative Contractor Beneficiary and Provider Communications Manual. Pub. 100-09, ch. 6, §20.3.4, rev. 13683, issued April 8, 2026
xElectronic Code of Federal Regulations. 42 CFR § 424.44, Time limits for filing claims. Available at: https://www.ecfr.gov/current/title-42/chapter-IV/subchapter-B/part-424/subpart-C/section-424.44 . Accessed September 2026.
xiAmerican Medical Association. Payer evaluation and management (E/M) downcoding programs: What you need to know. Accessed September 2026
xiiAmerican Society of Clinical Oncology, What Radiation Oncology Practices Need to Know About 2026 Coding and Reimbursement Changes. Published April 7, 2026
xiiiScott S. Looking Back on 2021 E/M Challenges. AAPC. Published March 31, 2022.
xivKaiser Family Foundation. 5 Key Facts About Medicaid and Pregnancy. Published May 2025
xvOsterman MJK, Hamilton BE, Martin JA, Driscoll AK, Valenzuela CP. Births: Final Data for 2024. National Vital Statistics Reports. 2026 Jun;75(2):1–48. doi:10.15620/cdc/252440.
xviAlbarqi MN. The Impact of Prenatal Care on the Prevention of Neonatal Outcomes: A Systematic Review and Meta-Analysis of Global Health Interventions. Healthcare (Basel). 2025 May 6;13(9):1076. doi: 10.3390/healthcare13091076. PMID: 40361853; PMCID: PMC12071573.
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