Updates on Obstetric Codes and Setting the Record Straight

We hope you have enjoyed our bonus episodes derived from our live Town Halls on the new maternity care services codes! As the team continues to work with health plans and vendors and works to develop resources and curriculum on this new code set, we appreciate your patience with us. AND we need your help! This long episode tackles 2 important topics: how you can help get these codes over the finish line, and setting the record straight on some misinformation in the health care space. Get ready to get fired up, take action, and be a part of improving health systems for pregnant patients in the US!

https://www.regulations.gov/document/CMS-2026-2377-0002

ACOG's Payment Advocacy and Policy Portal

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SPEAKER_00 0:12

Hello and welcome to ACOG's Payment and Practice Podcast. I'm Lisa Satterfield, the lead of the health and payment policy team, and I'm flying solo today because I have a lot to say and I wanted to get this out ASAP to y'all. So this may be a long podcast. I'm going to split it into two, so let's get started. As I said, I have two big topics I want to cover today. Both are related to the two maternity care code services. But before we dive into that, I do want to ensure you all that we are not ignoring gynecology services. Our Committee on Health Economics and Coding, the Czech, includes ACOG representatives that are expert in MIGs, family planning, oncology, urogynecology, and we have liaisons from all the subspecialty groups making sure that all of the interests and issues are being addressed. We have been evaluating all of the CPT codes and are putting together a plan for future coding updates. The committee is meeting in early November to discuss all of these topics. So if you have any particular topics that you want to be considered, submit them through our payment advocacy and policy portal. The links at the show notes, but you can also go to ACOGCoding.freshdesk.com and under ask a coding question, there's a box that says request a new code, and you can put your request in there. So again, go to our portal under ACOG Coding at FreshDest.com and go to ask a coding question and put it under request a new code. And that will get it to the correct staff. We need it well before this November meeting to discuss it. So make sure you get it in there soon and check out all the other resources that we're trying to put in there to keep you guys updated. There's a lot going on. So if you've had a question in there for a bit and we haven't gotten to yet, please be patient with us. As you can imagine, we've gotten a lot of questions recently, especially with these new codes. So we are trying to staff up a little bit more to get those answers to you. And we are also working really hard to get some new resources out to you. So we're spread a little thin these days. So thanks for your patience as we get all this going, excuse me. And as you all know, we are also going to be at the ADM starting in a couple of weeks. I'm going to see you guys in Orlando and Detroit. And so many of my team members are going to see you at the other ADM. So be sure that you have registered because spots are filling. We're going to be at every single one of those district meetings in a separate coding course. And even if you are not a member, you can register just for the coding course separately. We're also going to be in Las Vegas while the state roundtable is going on. So again, if you are not one that is typically going to the state roundtable, you can still register for the coding course, which is separate from the state roundtable. And we have a team that's going out there. So check the ACA website for that as well and learn more about all these new codes. The New Orleans course that's in November that will include maternity codes, but it also will include gynecology and evaluation and management codes. So it's an all-day course that's going to be more broad. So if you are interested in a broader perspective that includes gynecology codes, be sure to sign up for that one. It is filling up very quickly. So sign up for that soon. Okay, two big topics. The first one is how we need your help with the CMS proposed rule and how you can help us. And the second one is I want to set the record straight on all kinds of misinformation that's been published in recent months about the OB codes. So this is going to be a long episode, so let's get going. All right. The Centers for Medicare and Medicaid Services, CMS, they are the final arbiters of the CPT codes. Let's give a little background. It's a little bit more complicated than they're just the final arbiters, but basically what happens is the AMA creates the codes through the CPT editorial panel, and then they publish the codes for use in the CPT professional edition every year. They own the codes. The law states, the federal law states, that the health plans must use a uniform coding system for billing, and the government has chosen through the years to use CPT codes. And this is all regulated by CMS. So basically, CMS every year proposes the code set to be used for the next year. And they in that code set they also propose the relative value units that they are going to use for Medicare. Then Medicaid programs and commercial payers can use those relative value units or they can adjust them according to their own budgets. 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. So you get about six weeks between the finalization of the codes in November to January for all plans to adopt these codes. And this has been the process for decades. This is just how it's been since uh the 90s, essentially. 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. Yada yada yada yada. It's an incredibly long title all the time. That's kind of the the crux of it. It is docket number CMS-2026-2377-0002 in regulations.gov. And stay with me here. That's going to be important. So ACOG, you may have seen us. We released a statement. Dr. Claire released a statement when the proposed rule came out. Um and we said the things. We said we are excited to report that CMS did include our new maternity care codes in the proposed 2027 coding tables. So that's really good news. They took the codes that we worked with the AMA. 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. So the 12 new codes they put in the code tables for 2027 and they proposed RVUs from the AMA. And so we are very pleased with all this. Thank you, thank you, thank you, CMS, for doing this. So we are happy about all of that. 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. 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. Very excited about this. In fact, they increased a few of them. So that was shocking and surprising. So we're very happy with the whole thing. So really want to thank CMS for their efforts there. 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. And because AMA is deleting those codes in the book, that that decision's been made. It was voted on by the panel. The codes are not going to be published in the professional edition. They're gone. So 59400 and all the other codes, they're gone, the 15 other codes. Um CMS is proposing to create G codes, um, which they can do to replace all 15 of those codes that the AMAs deleted. 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. And um they they think that maybe some people want the the global codes still. So it's not that they're saying global instead of maternity codes, they're saying global and maternity codes. Um and this is not good. This is not good for OBTYNs, this is not good for patients, it's not good for maternal outcomes, it it's not good. It it pretty much undermines everything that we've worked on since really uh 2022. 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. Because what this does is it introduces um the idea that health plans can pick what system they want to use. 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. It it introduces insecurity for the whole system. 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? Um and it it helps no one and it completely undermines the whole intent. 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. Um it just it it really um takes away um from the clinical guidance and the consistency with the clinical guidance and everything. So, so hear me out. 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. This could mean that you would have to pick um health plans that um adhere to one coding system or another. Or um like there could be an access issue with um offices only deciding to do that, right? 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. 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. I mean, how how would you know what your copayments are supposed to be versus one versus the other? Um again, it's inconsistent with tailored prenatal care, and it's just too much to ask for you all to manage. 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. And you can do this and it's gonna make a big difference. So you can write a letter or email CMS the appropriate way through the regulations.gov site. So you go just to that regulations.gov and you enter in the search box CMS dash 2026-2377-0002. And then there's a you'll see the title of the proposed regulation. 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. And I will tell you, ACOG, we read this document every year. We have a team that reads it, it's about 1,600 pages long, and um, we respond to the whole document. So don't worry about doing that. We got your back on that. But you can hit the blue comment box there, and I'll be sure to put the link in the show notes too. And then I'm gonna give you some tips on what you can do. You can either write a Word document and attach a letter, or you can just write a few comments. 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. And you want to specifically ask that they do not finalize the G codes that mirror the antiquated bundled codes. Those two things need to be said no matter what you say. You can say other things about your concerns, you can share how it'll be a burden to you, whatever the things are. 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. They did go the extra mile and they adopted the new codes, and we appreciate that. 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. 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. 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. Um, the transparency of the copayment um happened under the ACA. There should not be a co-payment for prenatal visits, including screenings and postpartum care. And that happened under the ACA law. 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. And with the global code, that's just too hard to calculate. So the unbundled codes is going to help with that. 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. So this will help clear billing for providers. 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. 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. Um, in summary, we we want to finalize the maternity care codes set and not finalize, also finalize the G codes. We don't need two concurrent coding systems at the same time. Okay. One more point the comments must be submitted before 5 o'clock p.m. Eastern time on September 14th. That's really important. Once the comments period closes, that's it. There's there's no like extension. So that's it. It's final. So again, go to regulations.gov, find all those things. I'll put the link in and let's get going. Let's get some comments in there. Um, all right. I'm gonna take a little bit of a pause here because the next section is gonna get spicy.

Setting the Record Straight

SPEAKER_00 19:15

Okay, correcting the record. There have been several articles published the last few months um of people trying to figure out the maternity services codes. And we've been a part of some of them. They've interviewed us. Um, some things have come out that have not been exactly correct. We've tried to correct the record, and sometimes it's taken and sometimes it's not. So um I'm gonna use this platform to make sure the information, the correct information is out there for you all. Um, I have eight things to talk about here, so let's get started. The first one, unbundling will disincentivize the use of less expensive provider options such as doula's. Um, first of all, doula's as part of the the care team, of course, and ACOG is supportive of team-based care. As a matter of fact, um, we have a new document regarding partnering with doulas. So if you Google ACOG partnering with doulas, you should be able to find that document. It was just published a couple of weeks ago, I think. Um doula's are not medical providers, they are trained support people who offer emotional, physical, and educational support. 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. 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. Okay, let's move on. The bundled codes are value-based and moving backwards from alternative payment models. This is false. 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. They are not risk-adjusted in any manner, and that's necessary for true alternative payment models. Um, they were developed too long ago, and they are not value based. 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. So, for example, we don't have the answers to how many prenatal value. Visits occur based on provider type, region, urban, rural conditions, health-related social needs, and so many other factors. We don't know. Are there differences in the number of prenatal visits and maternal health outcomes? What factors are they influenced by? Are there differences in outcomes if the patients have fewer but longer, more complex office visits? How is telehealth, remote patient monitoring and digital health utilized? And is that impacting maternal health outcomes? We have some of those answers, but we don't have it in a large national data set to really sink our teeth into. Is there a relationship between visit data and the length of or complexity of labor? What is the average length or complexity of labor? That data is relatively relatively limited. Or is there something else we need to look at? This is something we don't know. How many deliveries end up being medically treated for hemorrhage management? Not something we're easily tracking right now. 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. We need a large data set to study and risk adjust to get to the place of value-based care and alternative payment models. And we just don't have that right now. But we will with the new maternity code set. 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. And my argument again is not really. We have pockets of data in various health systems. 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. We have Medicaid programs, but they're collecting that have unbundled, but they're collecting the data in different ways. We have inoperable EHR programs and we have some collecting some prenatal visits, but they're collecting it in different ways. 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. Everyone collects data differently, and the individual data are visit data are not collected the same. 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. So there we are. We need these codes to move forward. Okay. Number four. So the fact that the codes are unbundled shouldn't be the reason for that. And let's move on to some more payment things. 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. 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. 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. So that should not be very much. Um, and the most recent statistic is from KFF and it's estimated at 93%. So let's get into this a little bit so that you have some information. 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. Code, section 300 GG-13. This is your reference. 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. Okay. 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. So there's a whole list of things here. It continues of all the things, but pre-pregnancy, prenatal, postpartum, and interpregnancy visits are very clear, not any cost sharing requirements. So if you are receiving or have patients who are receiving bills for these services, that should be questioned or strongly questioned. Okay. So all of this means that overwhelmingly, you should not have patients getting any cost sharing for your visits. And when the new codes come out, patients should get an EOB that's very clear and transparent. What the prenatal cost sharing should be, zero. What the postpartum cost sharing should be, zero. And then what labor and delivery cost sharing should be, which should be something. So the costs will be better delineated with these new visits because they will not no longer be bundled. It should be no question. Okay. Let's talk about the upcoding part. 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. And that they cited an article. 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. So I have a little problem with this. 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. Um, but the article went back to hospitals using AI to upcode their EM visits. Um, we surveyed ACOG members this year for a business and medicine report, which has not yet been published. But I can tell you only about a third of OBGYNs reported using AI for documentation in the medical record. 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. 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. 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. I mean, we've established it's not gonna cost patients more money. Um, so I'm not sure it's gonna cost health plans more money either. So I'm going to say um that is probably a false claim. So let's say that's false. All right. Let's go on to the next thing. We're almost done. My blood pressure is getting a little high. Okay, deep breath. Number six out of eight. The cost of health to healthcare systems and insurers will exponentially increase because of the new codes. Okay, really? Okay. 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. We studied a lot of data. And I can promise you, because I did those studies. Okay. So those who are claiming increased costs are making some assumptions. One, there um are assuming that everyone will suddenly increase the number of prenatal visits. Okay. 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? Um, I need somebody to show me that. Um, when I've asked a couple of Medicaid programs who've already unbundled, um, did your visits increase? That the the answer has actually been no. 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. So the average has been closer to seven to eight visits than to 13. This is not, this is like an NF3 um program. So not a large sample, but it's something. Um, and not published data. I'm going by what they're telling me, right? 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. So that's what we're hoping for. We're not gonna know until we get there. 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. So let's just see. Okay. There's also an assumption that everyone will have um more intense visits of the prenatal visits. Okay, so the global code included the 99213 was the the code that was included in the in the global code. Um, okay, so that's a low-level complexity visit. And yes, there may be an increase in it in the intensity or the length of the visit. Um, and yes, that might happen because maybe you're seeing the patient less often. So maybe you're seeing them longer, but less often. 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. 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. So that's all I'm gonna say about that. Okay. Um, there's also the assumption that more services will be ordered and billed for, like ultrasounds. We've already talked about that, and then also the upcoding assumption, and we've already talked about that. So the cost of health systems, mmm, maybe, but let's see. Okay. 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. 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. So I want to be fair. 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. Um, I just want to make sure we all understand that 15k is including typically the hospital anesthesia, everything, 28k, same hospital and everything. So that made me look decide to look up, and my team has already they looked up. I'll just say my team looked up all the data, and I went through the data that they looked up. Okay. So you all know the global codes. 59400 is the vaginal code and five. Um, I'm embarrassed. 59510, the Caesarean global. That's what we're talking about here. Um, we looked up those codes for Medicaid, and we also now have the rate navigator tool. Um, if you're not aware of this, type in Google ACOG rate navigator. It's private payer data, and you can get your free report. So you need to know about that. 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. But the rate navigator tool gives my team some data that we can share. Um, Medicaid. For Medicaid, the payment ranges from $815 to $4,200. And that $4,200 is like Alaska. Um, the average payment for the bundled codes being around $2,300. Um, that's again the global code from the first prenal visit to 60 days postpartum, right? So that's that's aggregate for the Medicaid, that's vaginal and cesarean kind of mixed up. 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. All right, we all kind of knew that. Um, okay, for our private payer data. I looked at that and we looked at the average payment for um the top five payers to physician practices. So we we did not look at payment that's going to hospital systems. We did not look at these are physician practices, right? Um, across 912 geographic regions. 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. Um so for the vaginal code, the range was from commercial payers was $1,885 to $7,249. That's the range of payment for the vaginal global code. 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. So essentially, 80% of payments from commercial payers for the global code are between $2,000 and $4,000. And the rest are outliers, right? Um, so nobody's really getting more much more than $4,000 for the vaginal global code. Similarly, for the cesarean global code, the range was $1,368 to $8,013. 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. So again, we're looking at 78% of payments in the $2,000 to $4,000 range for physician offices for cesarean payment. So from commercial payers. So really not far, like not much more than your Medicaid rates. If your Medicaid rates are $2,300 on average, not looking like a lot more coming from your on average from your commercial payers. 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. Uh uh it it will depend on contract negotiation for sure. Um, but uh I'm not sure why it would be because because of the new codes. Again, we'll see. I I it's not it's not a huge amount as it is already. Let's just say that, right? Okay. Hey, I'm almost done. Okay, number seven. One of the big one of the big angsty things. There's not enough time to implement these codes. I believe this is absolutely false. Um, and here are my arguments. 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. 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. Some years, admittedly, are more intense than others. 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. And there were years where there were entire new sets of genetic laboratory codes that were introduced and adopted. Those those are intense years. This is an intense 2027 intense year with the new maternity codes. Absolutely, I want to recognize that. 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. This is unprecedented. Typically, the new codes are published in September. September. They released February and April. Everything was available to all of us in February and April. So we've had the information that we needed for a long time. And the AMA has been working really hard. They and we've been working really hard. 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. 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. ACOG has been pushing information out to everybody we know, all our contacts. 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. Medicaid programs are under so much pressure right now. They have so much financial burden and so many changes coming under HR1, and they have less resources than anybody else. And they appear more ready than so many of our other counterparts. 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. We're working with Epic and others, um, and we are here to provide support. So, and we will continue to provide support to whoever wants to talk to us. We are here to help and help with implementation in any way we can. So that said, I think we have plenty of time. It's still July, we still have lots to do, but we can do this. All right. 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. 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. And this is just untrue. Health policy experts have been involved since the beginning of the process. Experts with decades of experience with health insurance, Medicaid, code development, regulatory practice have been involved since the beginning. The CPT editorial panel included representatives from health plans of various sorts. Um we took a lot of time doing this. Like I said, we started this in 2022. The first proposal was February 2024. It wasn't passed until September 2025. There were open meetings. We shared those open meetings, there were comment periods, there were surveys. Um, this was an open process that anybody could have participated in and listened in, and it was transparent throughout. Um so there were so many experts that um it's a little bit insulting to hear people think that there were not. So there were. Okay. 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. Um okay, at no time has ACOG or yourselves, um, but most definitely I can speak on behalf of ACOG. And at no time has ACOG advocated for more payment through the development of these codes. 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. 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. 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. 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. We are asking for everyone to come alongside us so that we can better improve the health of families in our communities. 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. And that is what we have been working on as your ACOG check and health and payment policy team. And that's what we will continue to work on moving forward. So thanks for your time. And use our portal and submit your comments to CMS. And I'll see you in Orlando and Detroit.