Health First Colorado Maternity Billing Changes for 2026 and 2027

Prenatal billing changes are effective September 1, 2026,  in preparation for the AMA maternity CPT restructuring effective January 1, 2027. Under HCPF Operational Memo OM 26-056, the guidance applies to enrolled providers caring for Medicaid-eligible pregnant members.

Health First Colorado Prenatal Billing Update

Providers seeing newly pregnant members for prenatal visits must use an appropriate Evaluation & Management (E&M) code with modifier TH rather than CPT 59425, 59426, 59400, 59510, 59610, or 59618.

The selected E/M code must remain appropriate to the services rendered. This change does not mean that all Health First Colorado maternity services will become unbundled on September 1, 2026.

CPT Codes Covered by the Prenatal Change

For the prenatal circumstances addressed by OM 26-056, the specified CPT codes are:

• 59425
• 59426
• 59400
• 59510
• 59610
• 59618

The instruction does not remove these codes from every maternity billing circumstance; it applies to the prenatal situations covered by OM 26-056.

Prenatal Care Already Underway

Providers who have already billed a bundled payment code or have begun providing prenatal visits before September 1, 2026 should continue following the billing procedures in the Obstetrical Care Provider Billing Manual.

HCPF also states that providers may not use unbundled codes to supplement a bundled payment that includes antepartum care.

Separately Billable Prenatal Services

For other prenatal services billed separately, providers should continue using appropriate standalone codes currently effective and covered by the Health First Colorado Fee Schedule until new codes become available.

Labor and Delivery Billing

The September 2026 prenatal billing change does not alter the current labor and delivery payment structures.

HCPF states that labor and delivery payment structures remain unchanged for now. The Department will provide further guidance once it determines new payment structures.

Preparing for the January 1, 2027 CPT Transition

The AMA maternity coding structure changes for antepartum, postpartum, labor, & delivery services take effect on January 1, 2027. HCPF also notes that its billing policy may change because of pending federal guidance and related developments.

Providers and billing representatives should sign up for the Provider News Mailing List and confirm they receive emails so they get forthcoming guidance.

What OB/GYN Practices Should Review Now

OB/GYN practices can review the following as part of transition preparation:

• identify prenatal episodes that began before September 1, 2026;
• identify newly pregnant members who fall under the E/M + TH billing requirement;
• proactively review how E/M codes are selected for prenatal visits;
• make sure modifier TH is set up correctly in the billing system;
• attentively check CPT 59425, 59426, 59400, 59510, 59610, & 59618 within prenatal claim workflows;
• do not add unbundled prenatal codes to bundled antepartum payments;
• actively review separately billable prenatal services against the Health First Colorado Fee Schedule;
• continue following the Obstetrical Care Provider Billing Manual for applicable existing episodes;
• monitor HCPF guidance on future labor, delivery, and postpartum payment changes.

These are practical workflow steps and should not be treated as additional HCPF requirements.

BillingFreedom Support

BillingFreedom helps OB/GYN practices review Health First Colorado prenatal billing requirements, update maternity coding workflows, and prepare for the 2027 CPT transition. Our team can support prenatal claim review, E&M + TH workflows, and payer-rule monitoring as additional Colorado guidance is released. Contact BillingFreedom to review your OB/GYN maternity billing workflow.

Resources

HCPF.Colorado.gov - Colorado Department of Health Care Policy & Financing

2027 OB billing: Colorado OM 26-056: E&M + TH for antepartum on new pregnancies from Sep 1, 2026