APA WF #26-12 Obstetric Unbundling
The proposed policy changes revise billing policy for obstetric services to align with upcoming changes to the Current Procedural Terminology (CPT) codes. CPT codes, which are maintained by the American Medical Association (AMA), are the foundation of claims-based billing. The AMA has proposed comprehensive changes to the way maternity and obstetric services are billed and reimbursed. Currently, obstetric services are billed and reimbursed using a single bundled code. The bundled code will be discontinued on January 1, 2027. The AMA is developing and revising codes for each obstetric service. The proposed policy changes update billing guidance to reflect the new obstetric billing structure.
Please view the draft regulatory here.
Comments may be submitted via the comment box or to federal.authorities@okhca.org.
Circulation Date: 9/1/2026
Tribal Consultation: 5/6/2026
Comment Due Date: 9/15/2026
OHCA Board Date: 9/16/2026
Requested Effective Date: 1/1/2027
Submit a Comment
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Please note that all comments must be reviewed and approved prior to posting. Approved comments will be posted Monday through Friday between the hours of 7:30 a.m. – 4 p.m. Any comments received after 4 p.m. will be posted on the following business day.
Comments
Michael:
Because the bundled obstetric code is scheduled to end January 1, 2027, and OHCA is moving to service-level billing, we respectfully recommend that the transition be accompanied by a small monitoring set using aggregate, de-identified information.
If operationally feasible, please retain or publish, by month and by rural/non-rural geography or comparable region:
- obstetric claim denial and rejection rates before and after the transition;
- the share of denials attributable to coding, modifier, or claim-configuration issues versus coverage or medical-necessity reasons;
- resubmission rates and median time from initial claim to successful payment;
- changes in payment lag for rural hospitals, obstetric practices, birthing providers, and other maternal-care providers;
- prenatal and postpartum visit utilization where already maintained in aggregate;
- provider participation or network-access indicators that can be compared across the transition; and
- dates of coding guidance, edits, or system changes that could affect observed trends.
These measures would help distinguish temporary coding disruption from an actual decline in access to care, while also making it easier to identify a true access problem if one develops. We do not suggest that a change in claims volume by itself demonstrates a change in maternal health outcomes.
We also recommend preserving denominator definitions and version history for any transition reports so rural, tribal, and statewide comparisons remain reproducible.
Thank you for considering this recommendation and for providing a public comment opportunity before the September 16 Board date.
OHCA Response:
Thank you for the comment. OHCA appreciates the recommendation to monitor claims processing and access indicators during the transition from bundled obstetric billing to service-level billing. OHCA will consider available claims data, system capabilities, provider impacts, and existing monitoring processes as implementation proceeds.
Consistent with OHCA’s public comment posting practices, the comment above was lightly edited to remove identifying information. These edits did not change the substance of the comment.
