The maternity bundle is going away. Employers need to ask what replaces it?

The January 2027 coding change is not just an operational issue. Employers must understand how carriers intend to reimburse maternity care under the new structure

For years, employers have been told that fee-for-service can reward more activity, while bundled payment creates better incentives around cost and care. Now, one of the most predictable episodes in healthcare is moving toward a more fragmented billing structure. That deserves attention.

The traditional global maternity package is being “retired.” Prenatal care, labor management, delivery, and postpartum care will be reported in separate phases, with many services billed individually. There are good clinical reasons for this change. Pregnancy care today may involve multiple physicians, health systems, telehealth, home monitoring, and specialists. A single global code doesn’t always show who provided the care, when it happened, or how complex it became.

As a physician, I understand the rationale, but employers have a different responsibility. They need to know what happens to the economics when the bundle goes away. And here’s the important part—they need to ask that question now.
 

The hard part: we don’t yet know what this will cost

Without final fee schedules, provider contracts, or carrier reimbursement policies, I don’t think anyone can responsibly tell employers that maternity costs will rise by a certain percentage in 2027. But nor should employers assume the change will be cost neutral.

Under the current global structure, many services have been contained within a single episode of care. Starting next year, more of that activity will become visible and separately reportable. That may be useful. Better data typically provides employers and health plans with a clearer picture of utilization, high-risk pregnancies, postpartum care, and where maternity dollars are going. But it also creates more opportunities for variation in reimbursement, coding intensity, duplicate billing, and payment integrity problems.

There’s no need to panic, but there are plenty of reasons to get more specific.
 

Processing the codes is not the same as managing the economics

One distinction matters here: coding and contracting aren’t the same thing. The new CPT structure changes how services can be reported. It doesn’t necessarily require every health plan to abandon episode-based economics. Depending on the market, funding arrangements, and provider contracts, carriers may have options for preserving or recreating some form of maternity bundle, even when the services are coded separately.

So, if a carrier or TPA tells me, “Our systems are ready for the new maternity codes,” my response would be, “How are you going to pay for them?” That is the strategic question, and there are others that are critical to understanding what will happen: 

  • Will the carrier reimburse the new services individually under existing fee schedules? 
  • Will it preserve some form of episode-based reimbursement? 
  • Does it expect maternity episode costs to change? 
  • How will it monitor utilization, coding intensity, and payment integrity?

The answers to these questions matter, especially for self-funded employers, because changes can show up directly in paid claims.
 

Your own population matters more than the national average

There will not be one answer for every employer. A younger workforce with more women of childbearing age may have very different exposure from an employer with relatively little maternity utilization. High-risk pregnancies matter. Fertility-supported pregnancies matter. Provider concentration matters. Geography matters. Funding arrangements matter. That is why I would spend less time looking for a national prediction and more time understanding what maternity already looks like inside your own plan.

Start with a 2026 baseline

This year’s baseline may be the most practical step employers can take right now. If maternity economics change in 2027, you need something meaningful to compare them against.

At a minimum, you need visibility into allowed cost per maternity episode, prenatal visits, diagnostic testing, C-section rates, postpartum utilization, and employee cost-sharing, as well as duplicate, incorrectly unbundled, or upcoded claims. Then, as 2027 experience develops, you’re well positioned to ask why the numbers are moving. Is the population clinically more complex? Are employees receiving more appropriate care? Are more services being delivered? Are visits being coded differently? Or—and this is important—is the reimbursement structure simply paying more for essentially the same episode?

These are very different explanations. They require different responses.
 

These questions belong in the 2027 benefits conversation now

Employers are already making decisions that will shape 2027 carrier relationships, plan administration, and cost. Before these decisions are final, I would want the employer, advisor, carrier, and TPA aligned around four issues:

  • How will our maternity claims be reimbursed under the new structure?
  • What will we measure so we know whether our experience is changing?
  • What protections are in place against duplicate billing, inappropriate unbundling, or coding intensity?
  • Do we have a 2026 baseline strong enough to recognize a change when it happens?
     

The maternity coding change may turn out to be less disruptive than some expect. I truly hope it does. But, taking a “we will see what happens” approach is not a benefits strategy. Employers have time to understand the change, establish their baseline, and ensure their advisor and carrier are treating this as more than a systems update.

While there’s not a lot of time, there’s enough time to act strategically.

Speak to our Health & Benefits team today