Transcrição completa de Updates on Obstetric Codes and Setting the Record Straight

they are going to use for Medicare. 00:05:36.959 --> 00:05:46.879 Then Medicaid programs and commercial payers can use those relative value units or they can adjust them according to their own budgets. 00:05:47.439 --> 00:05:59.199 The cycle is that CMS proposes the code set and the RVUs every July, and then they finalize the codes every November for use January 1st. 00:05:59.360 --> 00:06:09.360 So you get about six weeks between the finalization of the codes in November to January for all plans to adopt these codes. 00:06:09.600 --> 00:06:12.720 And this has been the process for decades. 00:06:12.879 --> 00:06:18.079 This is just how it's been since uh the 90s, essentially. 00:06:19.040 --> 00:06:34.079 So this year on July 16th, CMS published the proposed rule called calendar year 2027 payment policies under the physician fee schedule and other changes to Part B payment and coverage policies. 00:06:34.160 --> 00:06:35.600 Yada yada yada yada. 00:06:35.759 --> 00:06:38.800 It's an incredibly long title all the time. 00:06:39.040 --> 00:06:41.759 That's kind of the the crux of it. 00:06:42.000 --> 00:06:56.800 It is docket number CMS-2026-2377-0002 in regulations.gov. 00:06:57.680 --> 00:06:59.439 And stay with me here. 00:06:59.519 --> 00:07:00.639 That's going to be important. 00:07:02.000 --> 00:07:05.360 So ACOG, you may have seen us. 00:07:05.439 --> 00:07:07.120 We released a statement. 00:07:07.360 --> 00:07:07.680 Dr. 00:07:07.759 --> 00:07:13.040 Claire released a statement when the proposed rule came out. 00:07:13.439 --> 00:07:16.160 Um and we said the things. 00:07:16.319 --> 00:07:24.879 We said we are excited to report that CMS did include our new maternity care codes in the proposed 2027 coding tables. 00:07:25.040 --> 00:07:26.160 So that's really good news. 00:07:26.319 --> 00:07:29.920 They took the codes that we worked with the AMA. 00:07:30.399 --> 00:07:44.639 That includes the labor management codes and the delivery codes and the other four new codes, the two laceration codes, the uterine tampanon code, and the hysterectomy after cesarean code. 00:07:44.800 --> 00:07:55.199 So the 12 new codes they put in the code tables for 2027 and they proposed RVUs from the AMA. 00:07:55.279 --> 00:07:57.199 And so we are very pleased with all this. 00:07:57.360 --> 00:07:59.920 Thank you, thank you, thank you, CMS, for doing this. 00:08:00.240 --> 00:08:02.800 So we are happy about all of that. 00:08:02.959 --> 00:08:14.160 That means it will be a part of the Medicare program for 2027 and Medicare, Medicaid programs will be able to adopt it pretty easily. 00:08:14.319 --> 00:08:26.160 Benchmarks will be set and it and all and plans, all the things will happen relatively easily because Medicare will create files and they'll be available for everybody to adopt. 00:08:26.480 --> 00:08:28.240 Very excited about this. 00:08:33.840 --> 00:08:35.759 In fact, they increased a few of them. 00:08:35.919 --> 00:08:39.120 So that was shocking and

surprising. 00:08:39.279 --> 00:08:41.759 So we're very happy with the whole thing. 00:08:41.919 --> 00:08:45.360 So really want to thank CMS for their efforts there. 00:08:46.159 --> 00:09:00.720 So the disappointing part of this rule is that CMS asked for comments and about whether or not we should also keep the obstetric global codes. 00:09:01.039 --> 00:09:06.879 And because AMA is deleting those codes in the book, that that decision's been made. 00:09:06.960 --> 00:09:08.639 It was voted on by the panel. 00:09:08.799 --> 00:09:12.240 The codes are not going to be published in the professional edition. 00:09:12.320 --> 00:09:13.120 They're gone. 00:09:13.360 --> 00:09:19.039 So 59400 and all the other codes, they're gone, the 15 other codes. 00:09:19.279 --> 00:09:32.000 Um CMS is proposing to create G codes, um, which they can do to replace all 15 of those codes that the AMAs deleted. 00:09:32.159 --> 00:09:42.320 Um and they're asking if that's a good idea or not, essentially, because they've heard some rumblings that um that the other codes are going to be too hard to implement. 00:09:42.559 --> 00:09:49.279 And um they they think that maybe some people want the the global codes still. 00:09:49.919 --> 00:09:58.879 So it's not that they're saying global instead of maternity codes, they're saying global and maternity codes. 00:09:59.120 --> 00:10:02.639 Um and this is not good. 00:10:03.120 --> 00:10:14.639 This is not good for OBTYNs, this is not good for patients, it's not good for maternal outcomes, it it's not good. 00:10:14.799 --> 00:10:22.559 It it pretty much undermines everything that we've worked on since really uh 2022. 00:10:23.039 --> 00:10:34.399 Um, and since the survey that we um gave to all our members is that overwhelmingly said, you all want to get rid of these OB codes. 00:10:34.720 --> 00:10:43.360 Because what this does is it introduces um the idea that health plans can pick what system they want to use. 00:10:43.440 --> 00:11:00.639 They can pick um the new codes, or they can pick these G-code system, the old maternity global codes, or they can pick one or the other, or it just introduces a lot of chaos and instability. 00:11:01.120 --> 00:11:04.879 It it introduces insecurity for the whole system. 00:11:05.039 --> 00:11:14.480 It means that um physician offices would have to be prepared for just about anything for a health plan to do kind of whatever they wanted, right? 00:11:15.039 --> 00:11:22.960 Um and it it helps no one and it completely undermines the whole intent. 00:11:23.440 --> 00:11:58.080 Um, not the whole intent, I guess, um, but a lot of the intent of what we wanted the new OB codes to do was is was is to have uniform data collection across um all payers and all health plans, and um, so that we could start really looking at at um at data for prenatal visits and um and allowing pay and allowing physicians to see the patient when they wanted, how they wanted, at what level they wanted, um, complex versus

straightforward labor management. 00:11:58.240 --> 00:12:08.000 Um it just it it really um takes away um from the clinical guidance and the consistency with the clinical guidance and everything. 00:12:08.159 --> 00:12:10.480 So, so hear me out. 00:12:10.799 --> 00:12:20.559 Um, the complexities of this, like if you have multiple health plans in the contracts, it I don't know what you would do and how you would set up your offices. 00:12:20.720 --> 00:12:28.320 This could mean that you would have to pick um health plans that um adhere to one coding system or another. 00:12:28.799 --> 00:12:36.000 Or um like there could be an access issue with um offices only deciding to do that, right? 00:12:36.159 --> 00:12:45.759 And so patients would maybe have a hard time if their health plan decided to go with the global and offices didn't want to use the global or vice versa. 00:12:46.240 --> 00:13:07.919 Um and it would mean um implementing multiple systems in order to ensure that correct like how would you how would you start collecting the copayments if you had if you knew that you had um the enems with the prenatal visits, you know that you don't have to collect co-payments except for with the global. 00:13:08.080 --> 00:13:14.399 I mean, how how would you know what your copayments are supposed to be versus one versus the other? 00:13:14.799 --> 00:13:23.120 Um again, it's inconsistent with tailored prenatal care, and it's just too much to ask for you all to manage. 00:13:23.360 --> 00:13:35.440 Um, so all that said, we need your help to ensure that CMS does not move forward with the G codes and does move forward with the full adoption of the new maternity care services code set. 00:13:35.759 --> 00:13:38.720 And you can do this and it's gonna make a big difference. 00:13:38.960 --> 00:13:48.320 So you can write a letter or email CMS the appropriate way through the regulations.gov site. 00:13:48.559 --> 00:14:02.559 So you go just to that regulations.gov and you enter in the search box CMS dash 2026-2377-0002. 00:14:03.200 --> 00:14:09.360 And then there's a you'll see the title of the proposed regulation. 00:14:09.679 --> 00:14:29.519 And the full title is Medicare and Medicaid Programs Calendar Year 2027 Payment Policies under the physician fee schedule, and other changes to Part B payment and coverage policies, Medicare Shared Savings Program Requirements, and Medicare Prescription Drug Inflation Rebait Program. 00:14:29.840 --> 00:14:34.639 And I will tell you, ACOG, we read this document every year. 00:14:34.799 --> 00:14:42.799 We have a team that reads it, it's about 1,600 pages long, and um, we respond to the whole document. 00:14:42.960 --> 00:14:44.799 So don't worry about doing that. 00:14:44.960 --> 00:14:46.559 We got your back on that. 00:14:46.799 --> 00:14:52.720 But you can hit the blue comment box there, and I'll be sure to put the link in the show notes too. 00:14:52.879 --> 00:14:55.919 And then I'm gonna give you some tips on what you can do. 00:14:56.000 --> 00:15:02.000 You can either write a Word document and attach a letter, or you can just write a few comments. 00:15:02.159 --> 00:15:16.799 But what you really want to do is be very clear and say that you want to specifically ask CMS to finalize the maternity care services codes as proposed by the AMA. 00:15:17.279 --> 00:15:26.559 And you want to specifically ask that they do not finalize the G codes that mirror the antiquated bundled codes. 00:15:27.279 --> 00:15:31.120 Those two things need to be said no matter what you say. 00:15:31.360 --> 00:15:38.480 You can say other things about your concerns, you can share how it'll be a burden to you, whatever the things are. 00:15:38.960 --> 00:15:51.039 But if you want to say more, it's really helpful to thank a to thank them for adopting the new codes because that is really important. 00:15:51.440 --> 00:15:56.399 They did go the extra mile and they adopted the new codes, and we appreciate that. 00:15:56.799 --> 00:16:13.440 Um it's important to recognize that moving towards a uniform system that that recognizes the distinct care of antipartum, labor management, delivery, and postpartum services is going to improve patient care and maternal outcomes in the US. 00:16:13.759 --> 00:16:28.960 Um, that we need those data from what these codes are gonna do to help us study more, and that the delivery of maternity care has significantly changed over the past 30 years, and that's why these codes are so important. 00:16:29.279 --> 00:17:01.360 They're gonna be consistent with the clinical guidelines, and that the bundle was not created with those guidelines in mind, and it was causing burdensome administrative practices with transfers of care, with um with um unable to track patients, um, with the co-payment issue was a big issue for the transparency of patients not knowing how their copayment was being tracked. 00:17:01.440 --> 00:17:06.319 Um, the transparency of the copayment um happened under the ACA. 00:17:06.880 --> 00:17:14.400 There should not be a co-payment for prenatal visits, including screenings and postpartum care. 00:17:14.480 --> 00:17:16.799 And that happened under the ACA law. 00:17:16.960 --> 00:17:33.599 And for 93% of the patients in this country under commercial payers, 93% of commercial pairs patients, they should not be receiving a co-payment for prenatal care screenings and postpartum services. 00:17:33.759 --> 00:17:38.240 And with the global code, that's just too hard to calculate. 00:17:38.559 --> 00:17:42.319 So the unbundled codes is going to help with that. 00:17:42.480 --> 00:17:53.200 Um, labor delivery are subject to and have always been subject to co-payment, and ultrasounds are subject to and have always been subject to co-payment. 00:17:54.000 --> 00:17:58.799 So this will help clear billing for providers. 00:17:59.279 --> 00:18:08.799 And um the people, and as people move in and out of practices or change health insurance, this will just make

everything so much easier. 00:18:09.039 --> 00:18:17.759 So these are all very good things about the new codes, and and all you can talk about all the confusing things about the G codes. 00:18:18.079 --> 00:18:28.480 Um, in summary, we we want to finalize the maternity care codes set and not finalize, also finalize the G codes. 00:18:28.559 --> 00:18:33.359 We don't need two concurrent coding systems at the same time. 00:18:34.480 --> 00:18:34.799 Okay. 00:18:35.680 --> 00:18:41.200 One more point the comments must be submitted before 5 o'clock p.m. 00:18:41.680 --> 00:18:44.960 Eastern time on September 14th. 00:18:45.119 --> 00:18:46.160 That's really important. 00:18:46.319 --> 00:18:49.680 Once the comments period closes, that's it. 00:18:49.839 --> 00:18:52.079 There's there's no like extension. 00:18:52.240 --> 00:18:53.039 So that's it. 00:18:53.119 --> 00:18:53.920 It's final. 00:18:54.480 --> 00:18:58.559 So again, go to regulations.gov, find all those things. 00:18:58.640 --> 00:19:02.079 I'll put the link in and let's get going. 00:19:02.160 --> 00:19:04.000 Let's get some comments in there. 00:19:04.240 --> 00:19:05.599 Um, all right. 00:19:06.240 --> 00:19:11.279 I'm gonna take a little bit of a pause here because the next section is gonna get spicy. 00:19:15.279 --> 00:19:17.359 Okay, correcting the record. 00:19:17.519 --> 00:19:25.279 There have been several articles published the last few months um of people trying to figure out the maternity services codes. 00:19:25.359 --> 00:19:26.640 And we've been a part of some of them. 00:19:26.720 --> 00:19:28.000 They've interviewed us. 00:19:28.160 --> 00:19:31.440 Um, some things have come out that have not been exactly correct. 00:19:31.519 --> 00:19:35.200 We've tried to correct the record, and sometimes it's taken and sometimes it's not. 00:19:35.440 --> 00:19:42.640 So um I'm gonna use this platform to make sure the information, the correct information is out there for you all. 00:19:42.960 --> 00:19:46.480 Um, I have eight things to talk about here, so let's get started. 00:19:46.640 --> 00:19:53.759 The first one, unbundling will disincentivize the use of less expensive provider options such as doula's. 00:19:54.160 --> 00:20:03.759 Um, first of all, doula's as part of the the care team, of course, and ACOG is supportive of team-based care. 00:20:03.920 --> 00:20:08.880 As a matter of fact, um, we have a new document regarding partnering with doulas. 00:20:09.119 --> 00:20:13.759 So if you Google ACOG partnering with doulas, you should be able to find that document. 00:20:13.920 --> 00:20:17.359 It was just published a couple of weeks ago, I think. 00:20:17.680 --> 00:20:27.200 Um doula's are not medical providers, they are trained support people who offer emotional, physical, and educational support. 00:20:27.519 --> 00:20:46.000 So um that said, we these codes are for um our colleagues um within medicine, which include family practice, but also include certified nurse midwives,

and they all sat at the table with us through the um nursing association. 00:20:46.240 --> 00:21:07.119 So the PAs, the NPPs, the family medicine, um all the people who provide obstetric care as medical professionals were part of this application, and um the codes have nothing to do with less expensive provider options. 00:21:07.519 --> 00:21:10.160 Okay, let's move on. 00:21:10.400 --> 00:21:15.839 The bundled codes are value-based and moving backwards from alternative payment models. 00:21:16.000 --> 00:21:17.200 This is false. 00:21:17.680 --> 00:21:30.640 The global codes were developed outside of a value-based framework without any quality metrics or any other components that include value-based alternative payment model things. 00:21:30.960 --> 00:21:37.519 They are not risk-adjusted in any manner, and that's necessary for true alternative payment models. 00:21:37.680 --> 00:21:44.799 Um, they were developed too long ago, and they are not value based. 00:21:45.359 --> 00:21:55.920 Um, and also because there have only been bundled codes, we don't have the large data sets to appropriately risk adjust for value based payment. 00:21:56.160 --> 00:21:59.759 So, for example, we don't have the answers to how many prenatal value. 00:22:00.160 --> 00:22:08.880 Visits occur based on provider type, region, urban, rural conditions, health-related social needs, and so many other factors. 00:22:09.119 --> 00:22:09.920 We don't know. 00:22:10.079 --> 00:22:15.119 Are there differences in the number of prenatal visits and maternal health outcomes? 00:22:15.359 --> 00:22:17.359 What factors are they influenced by? 00:22:17.519 --> 00:22:24.160 Are there differences in outcomes if the patients have fewer but longer, more complex office visits? 00:22:24.319 --> 00:22:28.960 How is telehealth, remote patient monitoring and digital health utilized? 00:22:29.200 --> 00:22:31.920 And is that impacting maternal health outcomes? 00:22:32.079 --> 00:22:41.920 We have some of those answers, but we don't have it in a large national data set to really sink our teeth into. 00:22:42.319 --> 00:22:47.680 Is there a relationship between visit data and the length of or complexity of labor? 00:22:48.559 --> 00:22:51.279 What is the average length or complexity of labor? 00:22:51.680 --> 00:22:57.440 That data is relatively relatively limited. 00:23:05.119 --> 00:23:06.799 Or is there something else we need to look at? 00:23:06.960 --> 00:23:08.559 This is something we don't know. 00:23:08.880 --> 00:23:13.359 How many deliveries end up being medically treated for hemorrhage management? 00:23:13.519 --> 00:23:16.400 Not something we're easily tracking right now. 00:23:18.079 --> 00:23:32.640 We don't know if postpartum visits are in-person or telehealth, or how many are occurring, or what are some natural, natural bundles of care for obstetric services. 00:23:32.960 --> 00:23:43.119 We need a large data set to study and risk adjust to get to the place of value-based care and

alternative payment models. 00:23:43.200 --> 00:23:44.960 And we just don't have that right now. 00:23:45.200 --> 00:23:48.720 But we will with the new maternity code set. 00:23:49.200 --> 00:24:00.000 So there's another statement that's a little bit similar that was said, we have enough data and technology to study maternity care in detail without changing the codes. 00:24:00.160 --> 00:24:02.799 And my argument again is not really. 00:24:03.119 --> 00:24:07.599 We have pockets of data in various health systems. 00:24:08.160 --> 00:24:20.079 But the reason why we don't have studies out there is because we have these pockets of data and they're not comparable to each other. 00:24:20.319 --> 00:24:28.079 We have Medicaid programs, but they're collecting that have unbundled, but they're collecting the data in different ways. 00:24:28.720 --> 00:24:37.359 We have inoperable EHR programs and we have some collecting some prenatal visits, but they're collecting it in different ways. 00:24:37.920 --> 00:25:04.400 We just don't have large data sets that are easily aggregated to say that we can widely say at a national level what these data look like, which again we will have if these codes are adopted as the only code set for use across the country. 00:25:05.039 --> 00:25:11.200 Everyone collects data differently, and the individual data are visit data are not collected the same. 00:25:11.359 --> 00:25:22.799 In fact, these codes are absolutely needed, and the G codes, again, if you listened before, are cannot be finalized or it's just gonna throw a wrench into everything. 00:25:23.119 --> 00:25:25.680 So there we are. 00:25:26.000 --> 00:25:28.559 We need these codes to move forward. 00:25:29.119 --> 00:25:29.440 Okay. 00:25:32.400 --> 00:25:33.920 Number four. 00:26:04.240 --> 00:26:11.440 So the fact that the codes are unbundled shouldn't be the reason for that. 00:26:12.319 --> 00:26:15.359 And let's move on to some more payment things. 00:26:16.480 --> 00:26:31.359 There will be an increase of cost to patients because more prenatal or postpartum visits will occur, andor there will be upcoding for those visits. 00:26:38.640 --> 00:27:06.640 And I say 93% because for people insured by commercial plans, 93% of them fall under the federal statute that says prenatal visits and postpartum visits and screenings for both do may not have, do not have a co-payment associated with them. 00:27:06.799 --> 00:27:28.160 They're only the only plans that can still associate a co-payment or any cost sharing with their services, with those services, prenatal screenings and prenatal, comma screenings, comma, and postpartum visits are grandfathered plants. 00:27:28.400 --> 00:27:30.640 So that should not be very much. 00:27:31.039 --> 00:27:36.720 Um, and the most recent statistic is from KFF and it's estimated at 93%. 00:27:38.480 --> 00:27:43.519 So let's get into this a little bit so that you have some information. 00:27:44.160 --> 00:28:01.119 Section 2713 of the Public Health Services Act, PHSA, which added was added by the Affordable Care Act, says this, and it is codified in Title 42 of the U.S. 00:28:01.279 --> 00:28:06.000 Code, section 300 GG-13. 00:28:06.319 --> 00:28:08.000 This is your reference. 00:28:08.400 --> 00:28:47.279 And it says a group health plan and a health insurance issuer offering group or individual health insurance coverage shall, at a minimum, provide coverage for and shall not impose any cost sharing requirements for, with respect to women, such additional preventive care and screenings not described in paragraph one as provided for in comprehensive guidelines supported by the Health Resources and Services Administration for the purposes of this paragraph. 00:28:47.519 --> 00:28:47.839 Okay. 00:28:48.640 --> 00:29:26.960 Then we go to the HERSA website, and it says for those purposes of this paragraph, the things that are included on this are well woman visits, which also include pre-pregnancy, prenatal, postpartum, and interpregnancy visits, screening pregnant women for gestational diabetes, screening for type 2 diabetes in women with a history of gestational diabetes, screening for anxiety, screening intimate partner violence, and comprehensive lactation support services. 00:29:27.200 --> 00:29:29.519 So there's a whole list of things here. 00:29:29.680 --> 00:29:45.039 It continues of all the things, but pre-pregnancy, prenatal, postpartum, and interpregnancy visits are very clear, not any cost sharing requirements. 00:29:45.599 --> 00:29:57.759 So if you are receiving or have patients who are receiving bills for these services, that should be questioned or strongly questioned. 00:29:58.000 --> 00:29:58.319 Okay. 00:30:00.079 --> 00:30:09.279 So all of this means that overwhelmingly, you should not have patients getting any cost sharing for your visits. 00:30:09.599 --> 00:30:16.480 And when the new codes come out, patients should get an EOB that's very clear and transparent. 00:30:16.880 --> 00:30:20.079 What the prenatal cost sharing should be, zero. 00:30:20.319 --> 00:30:24.240 What the postpartum cost sharing should be, zero. 00:30:24.480 --> 00:30:29.200 And then what labor and delivery cost sharing should be, which should be something. 00:30:29.440 --> 00:30:36.799 So the costs will be better delineated with these new visits because they will not no longer be bundled. 00:30:36.880 --> 00:30:38.240 It should be no question. 00:30:38.480 --> 00:30:38.799 Okay. 00:30:39.359 --> 00:30:41.200 Let's talk about the upcoding part. 00:30:41.359 --> 00:30:57.680 One of the upcoding um, one of the upcoding um considerations was uh because the use of AI, the claim was that because of the use of AI, there will be upcoding. 00:30:57.920 --> 00:31:00.160 And that they cited an article. 00:31:00.319 --> 00:31:10.720 I went to the article, and there wasn't it, it was an article about hospitals were found to be using AI to upcode their claims. 00:31:11.039 --> 00:31:14.079 So I have a

little problem with this. 00:31:14.400 --> 00:31:39.039 So the a person claimed that OBGYNs would be upcoding their ENM visits, which would result, first of all, in more cost to patients, which we've established it shouldn't, and more cost to payers, which the upcoding, because the upcoding would be done by AI. 00:31:39.359 --> 00:31:47.839 Um, but the article went back to hospitals using AI to upcode their EM visits. 00:31:48.400 --> 00:31:55.759 Um, we surveyed ACOG members this year for a business and medicine report, which has not yet been published. 00:31:56.000 --> 00:32:05.680 But I can tell you only about a third of OBGYNs reported using AI for documentation in the medical record. 00:32:05.920 --> 00:32:19.920 And then I looked up, and the Healthcare Financial Management Association reported in 2025 that about 48% of healthcare systems were using AI for revenue cycle management. 00:32:20.160 --> 00:32:44.559 So given those two data points, which is only two, granted, um, but is two more than a hospital article, um, I'm not convinced that um the use of AI to OBGYN practices um is going to create upcoding um for EM services. 00:32:44.720 --> 00:32:53.279 Um I don't think it's fair to presume that EM codes are gonna be upcoded by OBGYNs and that it's gonna cost everybody more money. 00:32:53.440 --> 00:32:56.880 I mean, we've established it's not gonna cost patients more money. 00:32:57.039 --> 00:33:01.440 Um, so I'm not sure it's gonna cost health plans more money either. 00:33:01.599 --> 00:33:07.119 So I'm going to say um that is probably a false claim. 00:33:07.279 --> 00:33:08.799 So let's say that's false. 00:33:09.119 --> 00:33:09.759 All right. 00:33:10.640 --> 00:33:12.559 Let's go on to the next thing. 00:33:12.720 --> 00:33:13.599 We're almost done. 00:33:13.759 --> 00:33:16.400 My blood pressure is getting a little high. 00:33:17.200 --> 00:33:19.039 Okay, deep breath. 00:33:19.519 --> 00:33:21.680 Number six out of eight. 00:33:22.400 --> 00:33:31.920 The cost of health to healthcare systems and insurers will exponentially increase because of the new codes. 00:33:32.960 --> 00:33:34.559 Okay, really? 00:33:35.519 --> 00:33:35.839 Okay. 00:33:36.799 --> 00:34:05.039 Let's set aside that during the AMA RUC process, we worked really hard with the AMA and as a RUC team to ensure that the relative value units, the RVUs, would be budget neutral to the health systems, utilizing the existing RVUs of the global codes and CDC data, birth data conditions. 00:34:05.599 --> 00:34:08.559 We studied a lot of data. 00:34:08.719 --> 00:34:13.039 And I can promise you, because I did those studies. 00:34:13.679 --> 00:34:14.000 Okay. 00:34:14.960 --> 00:34:20.239 So those who are claiming increased costs are making some assumptions. 00:34:20.880 --> 00:34:27.519 One, there um are assuming that everyone will suddenly increase the number of prenatal visits. 00:34:27.760 --> 00:34:28.079 Okay. 00:34:29.599 --> 00:34:39.280 Why do we think when there's a shortage of obstetric providers, that all of a sudden there will be an increase in the number of visits for everyone? 00:34:39.599 --> 00:34:43.199 Um, I need somebody to show me that. 00:34:43.679 --> 00:34:52.480 Um, when I've asked a couple of Medicaid programs who've already unbundled, um, did your visits increase? 00:34:52.639 --> 00:34:55.199 That the the answer has actually been no. 00:34:55.679 --> 00:35:08.320 Um, they have found that the number has been closer to seven visits than to the 13 that was in the global code when providers were given the opportunity to select. 00:35:08.480 --> 00:35:13.679 So the average has been closer to seven to eight visits than to 13. 00:35:14.239 --> 00:35:18.960 This is not, this is like an NF3 um program. 00:35:19.440 --> 00:35:23.360 So not a large sample, but it's something. 00:35:23.519 --> 00:35:25.280 Um, and not published data. 00:35:25.440 --> 00:35:28.000 I'm going by what they're telling me, right? 00:35:28.320 --> 00:35:51.199 Um, part of the intent of this, of the new codes was to shift visits based on our new guidelines to tailored prenatal care, so that people who need more visits could get more visits, and people who can um safely do with less visits, or maybe do with more telehealth visits and less in-person visits could get that. 00:35:51.440 --> 00:35:53.280 So that's what we're hoping for. 00:35:53.519 --> 00:35:55.599 We're not gonna know until we get there. 00:35:55.760 --> 00:36:07.599 Um, but I don't know that OB um gynecologists and other obstetric providers all of a sudden have more visits in their schedule to offer everybody. 00:36:07.760 --> 00:36:09.039 So let's just see. 00:36:09.280 --> 00:36:09.599 Okay. 00:36:10.320 --> 00:36:19.039 There's also an assumption that everyone will have um more intense visits of the prenatal visits. 00:36:19.280 --> 00:36:29.920 Okay, so the global code included the 99213 was the the code that was included in the in the global code. 00:36:30.159 --> 00:36:34.320 Um, okay, so that's a low-level complexity visit. 00:36:34.559 --> 00:36:39.920 And yes, there may be an increase in it in the intensity or the length of the visit. 00:36:40.400 --> 00:36:45.360 Um, and yes, that might happen because maybe you're seeing the patient less often. 00:36:45.519 --> 00:36:49.119 So maybe you're seeing them longer, but less often. 00:36:49.519 --> 00:37:07.760 But is it not fair and equitable that an OB or an obstetric provider is paid for the intensity and time and the services that they provide, just like their colleagues across the House of Medicine are. 00:37:08.480 --> 00:37:23.519 If you go to your family practice provider and you're seen and they provide a 99214 and they bill a 99214 and they get paid for the 99214, should not also the obstetric provider. 00:37:23.760 --> 00:37:26.000 So that's all I'm gonna say about that. 00:37:26.559 --> 00:37:26.880 Okay. 00:37:27.760 --> 00:37:33.679 Um, there's also the assumption that more services

will be ordered and billed for, like ultrasounds. 00:37:33.760 --> 00:37:39.199 We've already talked about that, and then also the upcoding assumption, and we've already talked about that. 00:37:39.360 --> 00:37:47.840 So the cost of health systems, mmm, maybe, but let's see. 00:37:48.320 --> 00:37:48.639 Okay. 00:37:49.360 --> 00:38:07.039 Then there's been in this cost to health system thing, um, there's been a couple of times when they've referred to OB payment and the overall cost of pregnancy in the US has been cited. 00:38:07.280 --> 00:38:18.480 And sometimes they cite the overall cost, um, and they and they forget to mention that they're citing the overall cost, including the hospital care, and sometimes they don't. 00:38:18.639 --> 00:38:20.239 So I want to be fair. 00:38:20.480 --> 00:38:30.800 Um, so the they'll say like 15k for a vaginal delivery and 25k for a cesarean, and they sometimes they say and that includes everything, and sometimes they forget. 00:38:31.039 --> 00:38:44.960 Um, I just want to make sure we all understand that 15k is including typically the hospital anesthesia, everything, 28k, same hospital and everything. 00:38:45.199 --> 00:38:50.000 So that made me look decide to look up, and my team has already they looked up. 00:38:50.079 --> 00:38:56.800 I'll just say my team looked up all the data, and I went through the data that they looked up. 00:38:57.119 --> 00:38:57.440 Okay. 00:38:58.159 --> 00:38:59.920 So you all know the global codes. 00:39:00.079 --> 00:39:04.960 59400 is the vaginal code and five. 00:39:05.920 --> 00:39:08.480 Um, I'm embarrassed. 00:39:08.719 --> 00:39:12.639 59510, the Caesarean global. 00:39:12.800 --> 00:39:14.480 That's what we're talking about here. 00:39:14.800 --> 00:39:21.920 Um, we looked up those codes for Medicaid, and we also now have the rate navigator tool. 00:39:22.079 --> 00:39:28.159 Um, if you're not aware of this, type in Google ACOG rate navigator. 00:39:28.320 --> 00:39:32.320 It's private payer data, and you can get your free report. 00:39:32.559 --> 00:39:34.400 So you need to know about that. 00:39:34.559 --> 00:39:44.880 Um, type that in or go to the payment advocacy and policy portal, and there's a rate navigator icon at the top of the page, and you can click that and learn more about that there. 00:39:45.119 --> 00:39:50.079 But the rate navigator tool gives my team some data that we can share. 00:39:50.400 --> 00:39:52.400 Um, Medicaid. 00:39:52.559 --> 00:39:57.360 For Medicaid, the payment ranges from$815 to$4,200. 00:39:57.679 --> 00:40:00.800 And that$4,200 is like Alaska. 00:40:01.119 --> 00:40:06.960 Um, the average payment for the bundled codes being around$2,300. 00:40:07.760 --> 00:40:14.480 Um, that's again the global code from the first prenal visit to 60 days postpartum, right? 00:40:14.880 --> 00:40:21.119 So that's that's aggregate for the Medicaid, that's vaginal and cesarean kind of mixed up. 00:40:21.280 --> 00:40:35.599 I did some goofy math, but basically$2,300 for the entire, um, for the physician obstetric provider payment for the entire course of care throughout the pregnancy. 00:40:35.840 --> 00:40:38.239 All right, we all kind of knew that. 00:40:38.480 --> 00:40:41.599 Um, okay, for our private payer data. 00:40:41.840 --> 00:40:52.480 I looked at that and we looked at the average payment for um the top five payers to physician practices. 00:40:52.559 --> 00:40:57.360 So we we did not look at payment that's going to hospital systems. 00:40:57.519 --> 00:41:01.760 We did not look at these are physician practices, right? 00:41:02.400 --> 00:41:06.079 Um, across 912 geographic regions. 00:41:06.159 --> 00:41:25.519 So the average in the average payment in each 900 in each geographic region across the country of 912 of these regions for 59400 and 59510. 00:41:26.719 --> 00:41:41.119 Um so for the vaginal code, the range was from commercial payers was$1,885 to$7,249. 00:41:41.920 --> 00:41:46.960 That's the range of payment for the vaginal global code. 00:41:47.280 --> 00:42:08.000 Here's the interesting part of that 35% of the of the contracted payments from commercial payers are in the$2,000 to$2,999 range, and 45% are in the$3,000 to$3,999 range. 00:42:08.159 --> 00:42:20.719 So essentially, 80% of payments from commercial payers for the global code are between$2,000 and$4,000. 00:42:21.519 --> 00:42:25.039 And the rest are outliers, right? 00:42:25.920 --> 00:42:33.519 Um, so nobody's really getting more much more than$4,000 for the vaginal global code. 00:42:33.760 --> 00:42:42.800 Similarly, for the cesarean global code, the range was$1,368 to$8,013. 00:42:43.199 --> 00:42:58.639 So a bigger range, 53% of the contracted payments were in the$3,999 range and 25% of the payments in the$2,000 range. 00:42:58.880 --> 00:43:13.519 So again, we're looking at 78% of payments in the$2,000 to$4,000 range for physician offices for cesarean payment. 00:43:13.920 --> 00:43:16.639 So from commercial payers. 00:43:16.880 --> 00:43:23.039 So really not far, like not much more than your Medicaid rates. 00:43:23.360 --> 00:43:32.960 If your Medicaid rates are$2,300 on average, not looking like a lot more coming from your on average from your commercial payers. 00:43:33.360 --> 00:43:44.639 So if if we're worried about more costs to the health system and health insurers from the new codes, I mean, we'll see. 00:43:44.960 --> 00:43:50.159 Uh uh it it will depend on contract negotiation for sure. 00:43:50.559 --> 00:43:59.360 Um, but uh I'm not sure why it would be because because of the new codes. 00:44:00.159 --> 00:44:00.960 Again, we'll see. 00:44:01.360 --> 00:44:07.519 I I it's not it's not a huge amount as it is already. 00:44:07.679 --> 00:44:09.199 Let's just say that, right? 00:44:10.000 --> 00:44:10.320 Okay. 00:44:11.199 --> 00:44:12.639 Hey, I'm almost done. 00:44:12.880 --> 00:44:14.320 Okay, number seven. 00:44:15.199 --> 00:44:18.159 One of the big one of the big angsty things.

00:44:18.320 --> 00:44:21.679 There's not enough time to implement these codes. 00:44:21.840 --> 00:44:24.800 I believe this is absolutely false. 00:44:25.199 --> 00:44:28.000 Um, and here are my arguments. 00:44:28.639 --> 00:44:47.280 Every year the US health system goes through this process for over 200 new codes, more like 250 new codes a year are introduced into the payment system. 00:44:47.360 --> 00:45:01.119 And there are deletions and changes and new codes, all kinds of things happening every single year, same process all the time, for decades every year. 00:45:01.440 --> 00:45:04.239 Some years, admittedly, are more intense than others. 00:45:04.400 --> 00:45:19.199 Take, for example, we've had years that the EM codes were updated, 2021, 2023, um, or even in this past year, 40 new vascular codes were introduced. 00:45:19.440 --> 00:45:26.960 And there were years where there were entire new sets of genetic laboratory codes that were introduced and adopted. 00:45:27.119 --> 00:45:28.800 Those those are intense years. 00:45:28.960 --> 00:45:33.599 This is an intense 2027 intense year with the new maternity codes. 00:45:33.920 --> 00:45:36.480 Absolutely, I want to recognize that. 00:45:40.559 --> 00:45:58.800 And to to mitigate some of these concerns, the AMA released the technical specifications for this, these 12, 12 new codes in February and assigned the new code numbers in April. 00:45:58.960 --> 00:46:00.960 This is unprecedented. 00:46:01.280 --> 00:46:06.880 Typically, the new codes are published in September. 00:46:08.000 --> 00:46:08.800 September. 00:46:08.960 --> 00:46:12.000 They released February and April. 00:46:12.480 --> 00:46:17.599 Everything was available to all of us in February and April. 00:46:18.239 --> 00:46:24.880 So we've had the information that we needed for a long time. 00:46:25.199 --> 00:46:27.360 And the AMA has been working really hard. 00:46:27.519 --> 00:46:29.519 They and we've been working really hard. 00:46:29.599 --> 00:46:42.480 We've had the town halls, they've had, they've had um webinars, they have their CPT assistant articles out there already before they even would have typically even talked about the codes. 00:46:42.800 --> 00:46:54.960 So they've made really strong headway to make sure everybody had what they needed to get these things ready and out there so that everybody had what they needed. 00:46:55.280 --> 00:47:00.320 ACOG has been pushing information out to everybody we know, all our contacts. 00:47:00.400 --> 00:47:14.639 We have over 300 health plan contacts in all of our Medicaid contacts since March, including everybody in the national organization, so that they could trickle the information down. 00:47:14.960 --> 00:47:19.039 Medicaid programs are under so much pressure right now. 00:47:19.280 --> 00:47:27.920 They have so much financial burden and so many changes coming under HR1, and they have less resources than anybody else. 00:47:28.159 --> 00:47:33.280 And they appear more ready than so many of our other counterparts. 00:47:33.519 --> 00:47:55.280 So I fully believe that this is doable with history on our side, with everything that we're all working towards, with with with CMS being so supportive and putting the coat and putting the codes in the proposed rule, with AMA getting everything out so quickly, I believe we can do this together. 00:47:55.440 --> 00:47:59.920 We're working with Epic and others, um, and we are here to provide support. 00:48:00.079 --> 00:48:05.360 So, and we will continue to provide support to whoever wants to talk to us. 00:48:05.599 --> 00:48:12.000 We are here to help and help with implementation in any way we can. 00:48:12.320 --> 00:48:16.880 So that said, I think we have plenty of time. 00:48:17.119 --> 00:48:21.440 It's still July, we still have lots to do, but we can do this. 00:48:21.840 --> 00:48:22.480 All right. 00:48:23.599 --> 00:48:31.280 And the last one, I'm not gonna spend a lot of time on this because these last couple of statements were just so objectionable. 00:48:31.519 --> 00:48:42.159 Um, I don't want to give it a lot of time, but um there's been a couple of things that said uh the experts were not involved. 00:48:42.400 --> 00:48:46.719 And this is just untrue. 00:48:47.039 --> 00:48:50.960 Health policy experts have been involved since the beginning of the process. 00:48:51.199 --> 00:49:01.199 Experts with decades of experience with health insurance, Medicaid, code development, regulatory practice have been involved since the beginning. 00:49:01.440 --> 00:49:10.079 The CPT editorial panel included representatives from health plans of various sorts. 00:49:10.320 --> 00:49:15.039 Um we took a lot of time doing this. 00:49:15.199 --> 00:49:18.320 Like I said, we started this in 2022. 00:49:18.960 --> 00:49:22.559 The first proposal was February 2024. 00:49:23.119 --> 00:49:26.159 It wasn't passed until September 2025. 00:49:26.239 --> 00:49:27.840 There were open meetings. 00:49:28.000 --> 00:49:32.880 We shared those open meetings, there were comment periods, there were surveys. 00:49:33.440 --> 00:49:44.320 Um, this was an open process that anybody could have participated in and listened in, and it was transparent throughout. 00:49:44.559 --> 00:49:57.119 Um so there were so many experts that um it's a little bit insulting to hear people think that there were not. 00:49:57.519 --> 00:49:59.519 So there were. 00:50:00.000 --> 00:50:00.320 Okay. 00:50:00.800 --> 00:50:21.760 And the final point if and I know you all out there, um, there was a person who said OBs were trying to game the system with this, and of course you know yourselves, and this is absolutely untrue. 00:50:22.000 --> 00:50:35.840 Um okay, at no time has ACOG or yourselves, um, but most definitely I can speak on behalf of ACOG. 00:50:36.559 --> 00:50:46.559 And at no time has ACOG advocated for more payment through the development of these codes. 00:50:46.880 --> 00:51:09.840 We have been advocating for OBGYNs and other obstetric providers to get paid for the services they provide, whether they are providing care for straightforward or complex pregnancies, whether they are providing care for long visits or short visits, cesarean or vaginal, it does not matter the care that they provide. 00:51:10.079 --> 00:51:25.360 We have been advocating for and are advocating for more transparency for patients to know what they are getting billed for and what their code pays should be for ultrasounds in labor and delivery and not some mystery mix of a global code. 00:51:25.599 --> 00:51:42.480 We are advocating for data to be used to better study visit numbers and modality and social determinants of health and patient complexity and maternal outcomes so that we can improve something that has vexed this nation for too long. 00:51:43.360 --> 00:51:53.280 We are advocating for our billing system to be consistent with evidence-based clinical guidelines to move us forward and not keep us stuck in the past. 00:51:53.679 --> 00:52:02.159 We are asking for everyone to come alongside us so that we can better improve the health of families in our communities. 00:52:03.280 --> 00:52:17.199 This work has and continues to be aligned with ACOG's mission, vision, and core values so that all can receive exceptional and respective obstetric and gyneclotic care. 00:52:17.360 --> 00:52:25.280 And that is what we have been working on as your ACOG check and health and payment policy team. 00:52:25.360 --> 00:52:29.280 And that's what we will continue to work on moving forward. 00:52:30.880 --> 00:52:32.719 So thanks for your time. 00:52:33.840 --> 00:52:39.599 And use our portal and submit your comments to CMS. 00:52:40.480 --> 00:52:45.440 And I'll see you in Orlando and Detroit.