The commenter, an independent Registered Dietitian Nutritionist, opposes the proposal to bundle Medical Nutrition Therapy (MNT) payments into Shared Medical Appointments (SMAs). They argue that this could make nutrition services financially invisible and reduce access to specialized care, requesting that MNT remain separately reimbursable.

A Durable Medical Equipment (DME) supplier argues that CMS should reclassify the nebulizer compressor (HCPCS E0570) from a monthly rental to a one-time purchase. The commenter contends that the current rental model creates excessive administrative burdens, negative cash flow for suppliers, and unnecessary claims volume for Medicare.

The commenter supports the proposed 15% increase in work RVUs for labor management and delivery codes but argues that the overall valuation of maternity care remains undervalued. They also oppose the creation of new HCPCS G-codes, citing concerns over administrative burden and reimbursement fragmentation across different payers.

Alex Eaccarino, representing Roswell OB/GYN, opposes the proposed creation of HCPCS G-codes for maternity care services. The commenter argues that maintaining a parallel coding pathway alongside new CPT codes will create administrative burdens, cause billing confusion, and fragment obstetric data collection.

Remo Medical Group, a virtual dementia specialty practice, strongly supports the creation of HCPCS codes GACP1 and GACP2 and their inclusion on the Medicare Telehealth Services List. They argue that these codes are necessary to compensate clinical staff for advance care planning and advocate for the retention of separate codes to ensure clear tracking of physician versus clinical staff time.

The commenter, an administrator of an OB/GYN practice and certified coder, opposes the adoption of new G codes for maternity care. They argue that adding these codes would cause confusion for providers and patients, increase the burden of training and staffing, and complicate the claims process with payers.

Jessica Miller, representing Women's Healthcare Associates, argues that the proposed maternity care code restructuring results in a significant reduction in work RVUs for typical uncomplicated maternity episodes compared to the current global code. While they support the 15% increase in certain codes, they urge CMS to ensure the cumulative valuation remains equivalent to the current global value and strongly oppose the creation of new HCPCS G-codes due to potential administrative complexity and fragmentation.

A compliance officer for an EHR company and OB/Gyn subject matter expert supports the proposed changes. They argue that the current changes are necessary to resolve issues with Medicaid secondary payments and urge the agency not to introduce additional new codes.

The commenter opposes the proposal to delay the implementation of new maternity care services CPT codes by using temporary G-codes and allowing individual health plans to choose whether to adopt them. They argue that this approach creates administrative fragmentation, undermines standardization, and hinders CMS's goals for accurate quality measurement and value-based care.

The commenter opposes the creation of 15 new HCPCS G-Codes for CY 2027. They argue that a dual coding system will lead to payer exploitation, consumer confusion, and increased billing complexity for providers.