What to Know

• The shift from global billing to component pregnancy billing could accelerate adoption of team-based care models by creating greater flexibility to bill for services provided across the care team.
• Organizations should assess care team roles, scheduling protocols, and operational workflows to ensure patients receive care from the right provider at the right time.
• The transition will require significant updates to revenue cycle processes, coding practices, documentation standards, and staff education to support accurate billing and reimbursement.

Note: ECG is closely monitoring emerging information on the OB billing change. As of mid-July, CMS is seeking comments on the most effective implementation process. The draft fee schedule has put forward G-codes in place of the existing global codes. While the final rule will not be available until December, we believe the ACOG-recommended principles related to the change remain valid and will be implemented eventually, though potentially delayed. Either way, organizations should have a proactive transition plan that models potential impacts on compensation or productivity and considers the associated operational implications.

As a cornerstone of OB reimbursement and practice operations, global billing has long influenced how care is structured and delivered. So it’s no surprise that the recently announced changes to OB coding guidelines are causing uncertainty about the potential ripple effects across workforce planning, staffing models, and the broader care delivery ecosystem.

In part one of our series, we discussed how health system leaders can prepare for the potential compensation-related changes stemming from the new billing methodology. Here in part two, we explore three operational considerations that will support a smoother transition for your clinicians and staff.

Consideration One: The Care Team

Part of the rationale for moving from global to component billing is to reflect the modern care team, where every team member works to the top of their license to provide the best patient care. The change in billing structure also allows for more flexibility in billing for the services provided, opening the door to areas such as medical nutrition therapy or genetic counseling, potentially enabling practices to provide more holistic care.

As such, OB program leaders should explore their practice’s current structure and opportunities for improving their care team strategy. Defined roles and responsibilities across the care team, such as those outlined below, lead to efficient and standardized operations that support patient coordination, access to care, quality, and workforce constraints.

Table 1: Example Care Team Roles and Responsibilities

Care Team Member Role	Responsibilities
Physicians	Treat complex patients. Oversee residents and fellows. Partner with advanced practice providers (APPs) in patient care. Depending on the clinical care model, provide call coverage and labor and delivery (L&D) support or partner with hospitalists for L&D services.
APPs and Certified Nurse Midwives	Function as independent providers within their scope of practice for pregnancy care, OB triage, and L&D. As needed, refer to physicians for consult, comanagement, or transfer in alignment with established clinical pathways and protocols. Focus on initial evaluation of patients with gynecological surgical concerns. Cover pre- and postsurgical rounding, admission, and discharge. Assist in the operating room.
Registered Nurses	Triage patient phone calls and portal messages. Coordinate in-between visit care for complex patients. Provide patient education.
Medical Assistants	Conduct previsit planning. Coordinate in-between visit care for patients. Room patients.
Front Desk and Administrative Support	Schedule patients. Check patients in and out (includes eligibility, registration, and copay collection). Coordinate referrals.
Other Qualified Health Professionals	Provide visits for specific services, such as nutrition and genetic counseling, that may fall outside of traditional E&M guidelines.

Regardless of the care model used, be intentional about the delineation of duties and ensure they are aligned with your practice’s patient care philosophy and the state’s regulations related to scope of practice. While many individuals likely can perform a particular task, practice operations are more efficient and effective if each task is specifically assigned to the appropriate role(s).

Consideration Two: Patient Access and Scheduling

As the practice evolves, it is important that the preferred care model is supported by scheduling algorithms embedded in the EHR to ensure patients are seen at the right time, in the right place, and by the right provider. Additionally, scheduling practices should be documented and promote patient choice and timely access to care in alignment with system-wide policies.

With the shift to the new OB payment model, evaluate scheduling governance, rules, and templates to ensure:

• Scheduling guidelines are accurate and embedded in the EHR system.
• Visit types are consistent and reflect the services provided.
• Visit lengths reflect the actual time it takes to provide the service.
• Templates include reserved time for special patient populations (e.g., urgent).
• New visit types are added, as needed, for new and unique providers (e.g., nutrition).

Consideration Three: Revenue Cycle and Billing

Unwinding global billing will ultimately lead to a significant shift toward E&M-based billing. While eliminating the global codes presents an opportunity to more accurately capture patient complexity and ensure care team members receive “credit” or attribution for their contributions, it will also require notable changes in billing and coding documentation.

Prepare your care team by:

• Closely monitoring any billing guidance being published to ensure your practice is up to date with recommendations.
• Updating workflows in IT and billing logic systems to account for the new (as currently available) and eliminated codes.
• Aligning front-office personnel and revenue cycle teams to drive accurate claims and optimize the patient billing experience through shared information, workflows, and communication.
• Providing education for all OB-adjacent providers and billing and coding staff on E&M and other documentation updates (e.g., 98016: brief, real-time audio check-ins initiated by the patient) to ensure appropriate billing based on care rendered. This is essential, as proper documentation of patient risk and complexity will drive the appropriate level of E&M that can be billed.
• Supporting providers in ongoing billing management and monitoring.

What’s Next?

Given that the implementation plan for this OB billing change is evolving in real time, including the number of shifts required at both the national and individual practice level, it is imperative to remain up to date on the latest changes. Continue to plan proactively for the future by working through the considerations above, which will help you capture the best elements of the change to reshape your practice.

In our final post of the OB global billing code series, we will explore the implications of this change from a revenue perspective and consider how organizations will want to evaluate the net impact of the deleted and added codes, as today’s pregnancy global codes and E&M codes might be under different reimbursement rates even for the same payer.

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