The US Government is asking for feedback on changes to how Medicare pays for healthcare - and women’s health companies are being urged to take part.

The Centers for Medicare & Medicaid Services (CMS) published its proposed 2027 Medicare Physician Fee Schedule last month, setting out changes to how physicians and other healthcare professionals could be paid from next year.

The consultation is a routine annual process. But this year it contains some potentially important questions for women’s health.

Alongside specific payment proposals, CMS is seeking feedback on the wider system used to code and value medical services - including whether the current process reflects modern clinical practice.

Jodi Neuhauser, who convened the Women’s Health Reimbursement Summit and who founded 51&, says the immediate opportunity is as much about getting the industry involved in the process as securing any one policy change.

Jodi told FutureFemHealth that established organisations including medical societies have traditionally submitted comments on the annual payment rules, but companies actually building and delivering new models of women’s healthcare have had far less of a collective presence.

“My goal with doing all this work around the Medicare Physician Fee Schedule is literally just to raise awareness,” she said.
“This happens every single year. The people who are submitting comments are the AMA, ACOG, all of the different medical societies and all the different organisations in DC. We as an industry need to understand that this is happening and start to have a voice in it.”

Why does this matter?

The US system relies on codes to describe medical services and procedures so they can be billed.

The American Medical Association maintains the CPT coding system, while an AMA-convened committee known as the RUC makes recommendations about the relative value of physician services. CMS then sets Medicare payment policy, with the system also influencing payment more widely across US healthcare.

The problem is that new types of care do not always fit neatly into that infrastructure.

Work led by Jodi Neuhauser and the Women’s Health Reimbursement Summit has identified more than 50 areas of women’s health that are not adequately represented in the existing coding system, including menopause management, PCOS and infertility counselling.

That matters for patients, clinicians and the companies trying to build businesses around new models of women’s healthcare. If a service cannot easily be described and billed within the existing system, then creating a sustainable route to reimbursement can be considerably harder.

Maternity care offers one example

One major change is already due to take effect next year. From January 2027, new obstetric CPT codes are set to replace the traditional system that bundles much of maternity care together into a single payment.

ACOG, which spent years advocating for the change, argues that the bundled system no longer reflects how maternity care is delivered, including telehealth, home monitoring and additional postpartum support. Under the new structure, prenatal visits, labour and delivery and postpartum care can be billed separately.

There is an interesting example here of how evidence can feed into these decisions. As Geri Stengel recently reported in Forbes, CMS has proposed valuing the new labour and delivery codes 15% higher than the AMA committee recommendation, after updated ACOG guidance provided evidence that one of the assumptions used to calculate their value had changed.

The transition is not completely settled. CMS is also considering alternative Medicare codes that would retain elements of the existing bundled approach, which ACOG opposes.

That makes maternity a useful case study in something that can otherwise sound very technical: how healthcare is coded and valued can affect what providers get paid to do - and potentially which new models of care can fit into the system.

An industry starting to organise

Jodi does not expect one comment period to transform women’s health reimbursement.

But she does want more of the people actually delivering and building women’s healthcare to understand that these decisions are being made - and start showing up when they are.

And she stresses that this is not about generating hundreds of identical responses. As she explained to Geri Stengel, a thousand identical form letters effectively count as one comment. Specific submissions backed by evidence and first-hand experience are much more useful.

That could mean evidence from a clinician about care they cannot adequately bill for, or from a company about where an existing code or payment model does not reflect the care it is delivering.

Comments on the proposed 2027 Medicare Physician Fee Schedule are open until September 14. View the CMS proposal and submit comments.

Why is reimbursement getting so much more attention in women’s health now? In this week’s FutureFemHealth Pro, I’ve taken a look at what’s driving the shift - and what it could mean for founders, investors and the companies that can scale. Read it here.

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