Menopause affects every woman who lives long enough and has no dedicated code in Medicare’s 716-page 2027 payment rule.

Buried in the 716 pages of Medicare's proposed 2027 physician payment rule is something the agency almost never does . The Centers for Medicare & Medicaid Services (CMS) proposed paying the new labor-and-delivery codes 15% more than the American Medical Association committee that advises it recommended, reallocating 11,810 work relative value units (RVU)— the currency Medicare uses to price physician labor — to delivery itself.

It moved that value because someone documented the assumption underneath it was wrong. The committee priced the new maternity codes on twelve prenatal visits . American College of Obstetricians and Gynecologists’ (ACOG 2025 guidance replaced that fixed schedule with a targeted one of eight to nine visits for average-risk patients . CMS removed four from the utilization estimate and reallocated them within the maternity code family .

The same 716 pages never once say menopause. They also never say hormone, osteoporosis, contraception, postpartum, perinatal, or migraine. Midwife appears once, in a list of rural clinic practitioners.

CMS moves a number when the evidence is on the record. For most of women's health, no one has put it there. Comments on docket CMS-2026-2377 close September 14.

Why One Number In This Rule Is Almost Unheard Of

The maternity increase matters beyond obstetrics because CMS rarely overrules its own advisers. The definitive analysis of that relationship examined 2,768 work-value decisions between 1994 and 2010 and found the agency accepted 2,419 (87.4%) outright, cut 298, and raised only 51. That is fewer than two increases per hundred decisions across sixteen years.

Jodi Neuhauser, co-founder and CEO of the women’s health network 51&, spent the summer reading the rule looking for what it leaves out. “It’s easy to analyze what’s in a rule; the discipline comes in finding what isn’t,” she told me.

She expects the maternity provision to hold, because of where CMS has already planted itself. “The provisions that move between proposed and final are the ones where the agency has admitted the why and is still debating the how or the how much,” Neuhauser said. Her broader point is about direction of travel: “When the agency corrects the RUC [AMA/Specialty Society Relative Value Scale Update Committee] committee, it corrects toward exactly the kind of care women’s health is made of.”

What Is The Calendar Year (CY) 2027 Medicare Physician Fee Schedule

The CY 2027 Medicare Physician Fee Schedule is the annual rule setting what Medicare pays physicians for roughly 12,600 services, built on relative value units recommended largely by an AMA committee and accepted by CMS about 90% of the time. Its reach extends past Medicare patients. Lisa Satterfield, ACOG’s vice president of practice sustainability, confirmed the mechanism: “commercial contracts often utilize Medicare rates to benchmark their payments, and Medicaid payers use Medicare rates to set their payment rates, which significantly impacts ob-gyns.”

Menopause As The Test Case

Nothing else in the fee schedule has a prevalence of 100% among women who live long enough. The clinical picture has also changed considerably while the coding has not moved at all.

Guidance long held that symptoms run six months to two years. The Study of Women’s Health Across the Nation , which followed more than 3,000 women through the transition, found a median duration of frequent vasomotor symptoms of 7.4 years, rising to 10.1 years for Black women and 11.8 years for women whose symptoms began in early perimenopause. A Mayo Clinic study of 4,440 employed women put menopause-related lost work time at $1.8 billion a year, or $26.6 billion once medical costs are counted.

The severity spread is what breaks the coding. If menopause were uniformly mild, a generic office visit would be adequate payment. It is the range from negligible to disabling that evaluation-and-management codes cannot represent, a gap CMS concedes elsewhere in this same rule when it asks for data on longitudinal care its codes undervalue.

Does Medicare Cover Menopause Treatment

Partially. Satterfield explained the split: “hormone therapy, a common treatment, is typically covered under the Medicare Part D program for prescription drugs. Since the office visits for prescribing hormone therapy are in the Part B rule, as well as care coordination and care management codes, ACOG is looking closely into this coverage for all relevant treatments.”

Is There A Current Procedural Terminology (CPT) Code For Menopause Management

No. There is no dedicated code family for managing the transition, so clinically complex midlife care gets billed as a generic office visit. Menopause has a marketing budget, a venture category, and no billing code.

Two Groups Of Doctors, One Set Of Codes, Opposite Answers

Ask a gynecologic surgeon what a low number does to a practice and the answer arrives in specifics. Jocelyn Fitzgerald, a urogynecologist at UPMC and assistant professor at the University of Pittsburgh School of Medicine, pointed to “endometriosis excision, which, regardless of how complex it is, only reimburses about 12 RVUs (vs. something like a knee replacement which is 19).” A sacrocolpopexy without hysterectomy, she added, runs about 16.

Research has documented the pattern since 1997 , when one study asked whether Adam was still worth more than Eve, and again in 2021 . The most recent entry analyzed 55 sex-specific procedure pairs and found male-coded procedures assigned roughly 30% higher relative value units, with no meaningful narrowing between 2003 and 2023 .

ACOG disputes that finding, on the record. Satterfield wrote that her committee, ACOG staff and counterparts at the American Urological Association studied the code pairs and “ did not find a statistically significant difference in the comparable code pairs,” a conclusion published in 2024. She did not dismiss what members experience, writing that ACOG “recognizes and validates the experiences of our members in being undervalued for the incredibly important work that they do” while maintaining that “the RUC is not the source of that.”

She also disclosed something not previously reported. In 2025, ACOG’s Committee on Health Economics and Coding (CHEC) met in Denver with liaisons from the subspecialty societies to begin evaluating gynecologic surgery codes. “We are continuing that work; there are over 200 codes for the volunteer workgroups to study.”

Researchers on the other side find that the 2024 analysis is too narrow to carry the weight placed on it. Christopher Robertson, a law professor at Boston University, noted that it “only looked at nine code pairs (about 3% of the procedural volume), and excluded many other comparable codes, using criteria that are themselves a result of discriminatory valuations.” His summary was blunter: “Hathaway’s study is like a small bird flying into a hurricane of evidence.”

Louise King, director of reproductive bioethics at Harvard Medical School Center for Bioethics, has served on CHEC, the committee in question. She states her loyalties first. “I’m a strong supporter of ACOG. I donate a great deal of my time to working with them and believe their leadership is invaluable. But we are all human and even exceptional organizations can make mistakes.”

Her objection goes to who wrote the rules of comparison. The reason only some codes get compared, she argues, “is a result of the taxonomy established by ACOG and by the RUC over time,” and “this taxonomy is their product as well — they can change it.” This produces the sharpest line in the dispute: “It’s nonsensical to create a system that doesn’t allow comparisons and call it a system of ‘relative value.’”

Fitzgerald offers a structural explanation that indicts no one. Gynecologic surgery hasn’t been revalued, she suggested, because “we do not have a big voice advocating for Gynecologic surgeons in the way that ACOG (almost entirely comprised of general Ob/Gyns that primarily do Obstetrics) is motivated to focus their energies on maternity care,” adding that she completely understands why. Satterfield’s answer: ACOG “prioritizes the needs of our members both in obstetrics AND gynecology, including our many members who practice only gynecologic care.”

Where The Bias Enters Before The Committee Votes

There is a way both sides can be describing something true. The committee’s valuations rest heavily on surveys in which surgeons estimate their own operating time. A review of 901,917 surgeries compared those estimates against operative records and found urology overreported by a median of 20 minutes and gynecology by 5, the lowest of any specialty , with overreporting closely tracking higher relative value units per hour. A 2026 commentary puts the gap at “four times higher than gynecologists compared with objective measures of surgical times.”*

If the inputs skew before the committee ever votes, ACOG can be technically right that the committee did not create the disparity while the disparity stays real and travels through it anyway.

What The Comment Period Can And Cannot Do

Miriam Laugesen, a Columbia health policy professor who has studied the committee for two decades, finds the pattern familiar. “I was told informally at a RUC meeting by an AMA staff person that the problem of undervaluing female-specific services had been ‘addressed’ after studies came out in the 1990s,” she recalled.

She also thinks the agency has more room than it uses. “CMS has more latitude than people realize,” she observed, noting that no statute requires deference to the committee. On whether comments matter, she is unequivocal: “when there is strong consensus around an issue among commenters, agencies are more likely to respond to those comments.”

What counts as a comment is where most people go wrong. “The biggest misconception is that volume moves an agency, when a thousand identical form letters legally count as one comment,” Neuhauser said. “What actually moves a final rule is a handful of distinct, evidence-heavy filings from different corners of the field, each proposing language CMS could lift word for word.”

Satterfield described the same bar from inside the process. CMS, she wrote, “would need compelling information from interested parties, such as EHR-derived data, peer-reviewed articles that demonstrate a change in technology, or evidence that the physician work or practice expense has changed since the last time the code was valued.”

Why Investors Read The Fee Schedule First

Mark Gannott, CFO at Suncoast Ventures and a partner at Thalassea Partners, argues that codes govern capital before science does. “Payment visibility, not disease burden alone, governs investability,” he said, citing evidence that only 17% of medtech developers pursued technologies without an established reimbursement pathway. The disparity, in his reading, penalizes unit economics directly, because it “compresses provider ROI and device pricing at adoption.”

Fitzgerald’s forecast for a rule finalized without changes to gynecologic valuation is undramatic, which is what makes it credible. “Gynecologic surgery will be performed in fewer places, and wait times will increase for complex surgeries like endometriosis, prolapse, fibroids,” she said, with more surgeons moving to models where patients pay directly.

King, who has worked on this for close to a decade, frames the goal differently. “We are not looking for better salaries - we are looking for better access to care and resources for our patients.”

A comment doesn’t create a code. It creates the record CMS needs to make one, in this rule and the ones that follow. File your comments by September 14.

*Uppal S, Rice LW, Spencer RJ, "Discrepancies Created by Surgeon Self-Reported Operative Time and the Effects on Procedural Relative Value Units and Reimbursement," Obstetrics & Gynecology 2021;138(2):182–188. DOI: 10.1097/AOG.0000000000004467.