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From Jodi · The Business of Women's Health
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Twenty Years, One Request — And the Clock Is Already Running
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CMS opened the door on how women's health gets paid weeks ago. The comment window closes September 14.
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Here's what stopped me this week: this has been sitting open since mid-July, and the deadline is now six weeks out.
Buried inside the CY2027 Medicare Physician Fee Schedule proposed rule, CMS opened a Request for Information on CPT-4 — the coding system that decides how physicians get paid — and on the AMA RUC process that sits underneath it. MedPAC first flagged problems with this system 20 years ago. Nothing this size has moved since.
An RFI isn't a headline. It's the start of the official record. Whatever CMS proposes next has to point back to what comes in before the comment window closes on September 14, 2026.
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Why This Isn't Just a Policy Story
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If you build products, run clinics, sell into health systems, or work anywhere near reimbursement in this industry, this is your record too. Coding and valuation decide what gets built, what gets funded, and what gets left behind.
We talk constantly about the $1T opportunity in women's health. That number doesn't move until the underlying reimbursement architecture does. This RFI is the first real crack in that architecture in a generation — and it's open for exactly as long as we let it stay open.
And there's an entry point wherever you sit. If you're in fertility, the same-day billing cut is your fight. In menopause or midlife care, it's those zero mentions — and the wellness-visit redesign that's being written right now without you in it. In maternity, it's who gets to bill the new codes before that silence becomes policy. Different door, same room.
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What's Actually Being Asked
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CMS is asking whether the current coding process reflects modern clinical practice, whether AMA's oversight creates barriers to innovation, and what alternatives exist to CPT and RUC.
If that sounds abstract, here's what it looks like in a real exam room. This same rule proposes:
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Cutting the supply overhead for a well-woman pelvic exam from $20.16 to $2.81 — an 86% cut baked into a code used at millions of visits a year. |
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Paying every second service on the same day at 50% — hitting the exact patterns of office gynecology and fertility care: exam plus biopsy, monitoring visit plus IUI. |
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Building all of this while menopause, hormone, and osteoporosis appear zero times in 716 pages. |
That's not an oversight. It's what happens when a field isn't in the room when the prices get set.
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In women's health, the answer has never been in question — we've just needed the government to ask.
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The administration named the "sick care" problem directly and cited a recent NASEM report on RUC alternatives. Senators Warren and Cassidy are both on record in support — that's the kind of bipartisan cover this fight hasn't had in a generation.
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How We Got Here
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None of this happened by accident. Last year, I convened the first-ever Women's Health Reimbursement Summit — 67 C-level women's health executives in one room. That work reached Congress, HHS, and the White House. Sixty-three days ago, we were back in a room in NYC, this time with government leadership sitting across the table.
Jocelyn Fitzgerald, Louise King, and Christopher Robertson built the substantive data behind it. A Congressional briefing helped raise awareness on the Hill. Chris Klomp, Secretary Kennedy, and the HHS team have been working this since taking office.
I didn't know, sitting in either of those rooms, exactly when this moment would come. I just knew we had to be ready when it did. I didn't expect "ready" to mean racing a clock that started weeks before most of us had a chance to look up.
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This record closes September 14. Whatever you build, treat, sell, or fund in this space — this is your shot to put it on the record with CMS directly, not just talk about it on a panel.
One thing to know before you do: a form letter counts as a single comment, but a specific, first-hand one — what you've seen, treated, priced, or built — carries real weight on its own. So write from where you sit. I'll be sharing exactly how — and pulling together what our industry submits — in the coming weeks.
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Jodi Neuhauser · Founder, In Women's Health
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