Intersecting Challenges in Maternity Care: Proposed CMS RPM Changes, OB Code Unbundling, RHTP & TMaH

Maternity care in the United States is standing at an unprecedented operational crossroads. Over the next two years, healthcare executives and clinical leaders face a regulatory shift that could dismantle how high-risk obstetric care is delivered outside clinic walls:

1. CMS’s Proposed CY 2027 Physician Fee Schedule (PFS) rules for Remote Patient Monitoring (RPM) and Remote Therapeutic Monitoring (RTM).
2. ACOG and the AMA’s overhaul of CPT coding for obstetric services, effectively unbundling traditional global OB billing starting January 1, 2027.
3. Federal policies from CMS’s Transforming Maternal Health Model (TMaH) and the Rural Health Transformation Program (RHTP) assume that providers can leverage vendors to launch and scale programs quickly.

Individually, each policy aims to modernize care delivery and eliminate waste. Combined, however, they threaten to create a massive administrative and operational bottleneck at a time when maternal mortality rates and maternity care deserts demand more remote touchpoints, not fewer.

Here is what practice leaders and health system executives need to know about these proposals, their specific impact on maternal health, and what steps administrators should take today.

What CMS Is Proposing for Remote Patient Monitoring

In the CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P), the Centers for Medicare & Medicaid Services (CMS) signals a shift toward stricter guardrails and tightened accountability for remote care technologies. Two OIG reports found that roughly 43% of Medicare RPM enrollees in 2022 didn't receive all three components of the service they were billed for, and flagged cold-calling enrollment tactics from monitoring vendors. Those are legitimate program-integrity findings, and CMS's response is direct: starting in 2027, RPM and RTM services would have to be furnished exclusively by clinical staff directly employed by the billing practice. The outsourced, vendor-supported monitoring model that most OB practices currently lean on would no longer be billable.

While CMS’s overarching intent, to eliminate low-value, transactional RPM programs, is understandable, the specific proposals create severe operational friction:

• Elimination of Contracted Third-Party Clinical Staff: CMS proposes requiring all RPM and RTM clinical staff services to be performed exclusively by direct employees of the billing practice or hospital, effectively banning contracted vendor-provided clinical care management. In resource-stretched practices, clinical staff often do not have additional bandwidth to manage RPM programs, so these programs may disappear altogether.
• Mandatory Initiating Visits: A separately billable initiating visit (in-person or via telehealth) would be required to obtain explicit patient consent and discuss RPM services prior to enrollment.
• RTM Alignment with RPM: RTM services would be restricted strictly to established patients.
• Code Consolidation & Valuation Drops: CMS proposes to lower RPM device and treatment-management valuations and is seeking feedback on collapsing the current 17 RPM/RTM CPT codes into four new bundled G-codes, each requiring device supply, data transmission, and 20+ minutes of monitoring to qualify for payment.

Most state Medicaid programs adopt Medicare's CPT and HCPCS codes and valuations by default. Medicaid finances roughly 41% of U.S. births, and a considerably higher share in the Southern and rural states that have invested the most in maternal RPM. With no maternal-specific carve-out, many pregnant patients will not receive the care they need.

The Maternal Health Impact: Why Third-Party RPM Is Critical to OB/GYN

In obstetrics, remote patient monitoring is not a convenience, it is a life-saving tool.

Conditions like chronic hypertension, preeclampsia, and gestational diabetes require daily surveillance. Through RPM, clinicians monitor blood pressure trends and blood glucose levels continuously between visits, allowing for rapid medication titrations and early hospital admission before a hypertensive crisis or eclamptic event occurs.

However, running an effective maternal RPM program is operationally complex. Most OB/GYN practices and hospital maternity units face severe staffing shortages. To maintain 24/7 or extended-hours coverage for urgent physiological alerts, practices have long relied on specialized third-party clinical teams to triage routine vitals, contact patients, and escalate critical readings directly to the on-call OB/GYN.

The Immediate Risks to Maternal Care:

• Forced Program Shut Downs: Demanding that OB/GYN practices transition all remote monitoring workflows to internal, direct-employee staff within a few months is operationally impossible for many practices. Hospitals will be forced to shut down remote blood pressure and glucose monitoring programs, pushing care back into overburdened emergency departments and clinics.
• Widening Health Disparities: Rural practices and community health centers serving maternity care deserts rely heavily on external clinical infrastructure to manage geographically dispersed patients. Direct-employee requirements will leave vulnerable pregnant and postpartum populations without access to care.

What CMS Should Do Instead: Outcomes-Based Accountability

CMS’s goal to root out fraud, waste, and abuse is correct. However, rather than enacting blanket staffing prohibitions that disrupt clinical care, CMS should adopt an outcomes-driven policy framework:

1. Implement Diagnostic & Staffing Modifiers: Introduce specific modifier codes to track the type of device used and whether internal or contracted clinical staff supported the encounter. This provides CMS with precise data to investigate true cases of fraud, waste and abuse.
2. Mandate Clinical Outcomes Tracking: Require practices to report baseline and discharge outcome measures, such as proportion of patients achieving blood pressure control, reduction in preeclampsia-related hospital readmissions, or glycemic target achievement, to retain reimbursement.
3. Align with Value-Based Frameworks: Evaluate RPM models based on whether they achieve clinical goals and align with outcome-driven payment frameworks, rather than mandating employment.

The Intersecting Challenges: OB Code Unbundling, RHTP, and TMaH

Proposed CMS RPM changes add complexity to a massive overhaul of obstetric billing. The American College of Obstetricians and Gynecologists (ACOG) Committee on Health Economics and Coding has urged the AMA to dismantle the traditional global OB billing model.

Why Unbundling Is Happening:

Global billing assumed pregnancy was a uniform, predictable process. In reality, modern maternity care is highly individualized. Patients with preeclampsia, gestational diabetes, or perinatal mental health conditions require vastly different visit frequencies and multidisciplinary coordination.

The move toward discrete, service-based coding aims to reflect care intensity accurately. However, it completely changes practice economics:

• Granular Documentation Demands: Every prenatal touchpoint, mental health screening, and remote monitoring interaction may soon need to be separately documented and coded.
• The Double Administrative Squeeze: If global OB billing is unbundled into itemized touchpoints while CMS simultaneously restricts third-party RPM staffing and bundles RPM CPT codes into G-codes, practices will face an exponential increase in administrative paperwork alongside reduced clinical bandwidth.

The Transforming Maternal Health Model

CMS's own ten-year maternal health model selected 15 states (including DC) in January 2025, and built required milestones around telehealth and home monitoring for hypertension and gestational diabetes. States are roughly halfway through the three-year pre-implementation period, which means they've spent the last 18 months lining up the vendor relationships, technology, and clinical workflows the model calls for, largely through the outsourced-staffing arrangement this rule would end. If TMaH states can't bill for the RPM they've built their milestones around, CMS's flagship maternal health model loses one of its core levers right as it's supposed to start proving results.

The Rural Health Transformation Program

RHTP is a $50 billion fund created by the 2025 reconciliation law, and 35 states cited maternal or child health in their applications. States like Oklahoma, Pennsylvania, South Dakota, and Alabama specifically funded RPM, hypertension monitoring, virtual prenatal and postpartum care, as their strategy for keeping high-risk pregnancies safe in places that have lost labor-and-delivery units altogether. Fewer than half of rural hospitals still deliver babies. RHTP dollars are meant to be seed funding: the programs are supposed to become self-sustaining through ordinary clinical reimbursement once the grant runs out. If that reimbursement pathway narrows or disappears, these rural programs lose their bridge to sustainability at exactly the moment they need it.

How Hospital Administrators and OB Leaders Should Prepare Now

Hospital C-suites, MFM department chairs, and practice administrators cannot afford to wait until 2027 to adapt. Preparing requires proactive clinical, financial, and operational realignment today:

1. 1. Submit comments on CMS-1848-P by September 14, 2026 at https://www.regulations.gov/docket/CMS-2026-2377
   2. If you are interested in joint advocacy efforts, or want to talk through what this rule means for your program specifically, schedule a call with our team using the form below:
      

Modernizing healthcare reimbursement should elevate patient outcomes, not dismantle functional care delivery models. For OB/GYNs and hospital administrators, the path forward requires advocating for smart policy - demanding that CMS measure RPM by clinical outcomes, not administrative staffing structure - while building the operational and digital foundation necessary to thrive in an unbundled, data-driven maternity care landscape.