Medi-Cal obstetric E/M transition retains CPSP and doula exceptions
Oct 11, 2026 edition · GC-2026-0281 · Published 2026-10-11 · Version 3 · Final
DHCS encourages E/M plus TH obstetric billing from November 1 while preserving mandatory CPSP and doula Z-code exceptions. Its reminder distinguishes that transition from the January AMA framework and from anticipated CMS changes.
What happened
The notice describes an AMA obstetric coding framework beginning January 1, 2027 and anticipates related CMS changes without claiming those are already issued. Medi-Cal encourages prenatal and postpartum E/M claims with modifier TH from November 1, selected according to documented time and complexity. The recommendation to move toward E/M is distinct from the requirement to include TH when using that pathway, and it is not a blanket immediate prohibition on every existing local code.
Prenatal claims require a gestational-age code in Z3A.00 through Z3A.49; postpartum claims need an applicable code within O86–O92, Z39.0–Z39.2, or F53.0–F53.1. Actual billable subcodes must be used where a listed entry is only a category header, and the notice states the member must be female. CPSP providers and doulas must continue Z1032, Z1034, and Z1038 until further notice. Updated manual sections will follow. These explicit program exceptions and diagnosis conditions need to remain in place when other obstetric workflows transition.
Scope and timing
- Authority status
- Final
- Applicability
- Directly applicable
- Audience
- Health systems, Provider networks
- Jurisdiction
- California
- Affected functions
- Coding, Clinical Operations, Revenue Cycle, IT
- Responsible owner
- Coding
- Recorded date
- 2026-11-01
- Date type
- implementation
Why it matters
Select E/M by documented time and complexity. Prenatal and postpartum diagnosis rules apply; CPSP providers and doulas must continue local Z codes until further notice. Encouragement is not a blanket immediate ban on every existing code.
Recommended action
Map affected obstetric workflows, preserve program exceptions and train clinicians on documentation and valid diagnosis subcodes. Playbook dates are recommended internal targets, except any explicitly identified agency date.
Implementation playbook
- Separate ordinary obstetric, CPSP and doula workflows before changing edits. Coding · Due 2026-10-18
- Test TH, valid prenatal/postpartum diagnosis subcodes and E/M documentation. IT · Due 2026-10-25
- Train affected clinicians and monitor November claims while retaining stated exceptions. Clinical Operations · Due 2026-11-01
Sources
- Obstetric E/M and TH reminderOfficial · DHCS Medi-Cal Providers · 2026-10-09 · Source review 2026-10-11
Complete edition and supplemental material
This finding in the complete approved report →Regulatory horizons, CIA trends and implementation trackers remain in the full report.
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