What the credential decides about who pays a midwifery practice

Can a certified professional midwife bill insurance?

Not under Medicare, and not under the federal Medicaid provision that names midwifery, because both define who may be paid by reference to a nursing license. Medicare's condition for paying a certified nurse-midwife begins with being a registered nurse who is legally authorized to practice as a nurse-midwife in the State 1Ref 1Centers for Medicare & Medicaid Services (2026).§ 410.77 Certified nurse-midwives' services: Qualifications and conditions..Medicare's qualification condition for a certified nurse-midwife, that the practitioner be a registered nurse legally authorized by the State to practice as a nurse-midwife, which is the structural bar a non-nurse midwifery credential cannot clear.. A midwife who never held a nursing license cannot satisfy that sentence.

Everything else in the question is decided outside federal law. A state legislature decides whether the practice is licensed at all and under what title, a state Medicaid agency decides which license types it enrolls, and each commercial plan sets its own credentialing criteria. Those three answer separately, and a yes from one is not a yes from the others.

Certified Professional Midwife is the industry shorthand for a midwife credentialed outside nursing, and a state statute does not necessarily use the phrase. California and Washington, the two worked examples below, each license the same practitioner under a title of their own. That is why a search for what a CPM may bill in a given state tends to return nothing until it uses the state's own word for the license.

What the nursing credential is worth to a payer

Full parity with a physician on the Medicare fee schedule, since a rule change dated more than a decade ago. Medicare's allowed amounts for a certified nurse-midwife's services may not exceed 100 percent of the physician fee schedule amount for services furnished on or after January 1, 2011 2Ref 2Centers for Medicare & Medicaid Services (2026).§ 414.54 Payment for certified nurse-midwives' services..The Medicare allowed-amount ceiling for certified nurse-midwife services: 65 percent of the physician fee schedule amount before January 1, 2011, and 100 percent of that amount for services furnished on or after that date.. Before that date the same regulation held those amounts to 65 percent of the physician figure for the identical service.

Medicaid's side is written as a mandate rather than an option. The statutory definition of medical assistance includes nurse-midwife services, and it carries two clauses a practice can plan around: the coverage applies whether or not the nurse-midwife is under the supervision of, or associated with, a physician, and without regard to whether or not the services are performed in the area of management of the care of mothers and babies 3Ref 3Office of the Law Revision Counsel, U.S. House of Representatives (2026).42 U.S.C. § 1396d. Definitions.Medicaid's statutory inclusion of nurse-midwife services in medical assistance, applying whether or not the nurse-midwife is supervised by or associated with a physician and without regard to whether the services fall in the management of the care of mothers and babies.. Revenue does not hang on a supervising physician's signature, and the credential is not confined to the maternity cycle.

But a mandate to cover a service is no promise to enroll a particular applicant, set a rate that works, or pay the claim on first submission.

Licensure and payer enrollment are different documents

Two documents decide the state half of the answer, and different agencies write them for different purposes. A midwifery practice act says who may practice and under what title. A Medicaid provider manual says which license types the program enrolls and what it pays them. A state can license a non-nurse midwife and still run no enrollment pathway for that license, so reading the first document tells you nothing about the second.

California and Washington are worth reading as two worked examples, because they reach the same practitioner by different routes. California put its non-nurse pathway in a statute of its own, the Licensed Midwifery Practice Act of 1993, and calls the holder a licensed midwife 4Ref 4California State Legislature (2026).Business and Professions Code § 2505..California's separate statutory pathway for non-nurse midwives, the Licensed Midwifery Practice Act of 1993, and the distinct licensed midwife title it creates alongside nurse-midwife licensure.. Washington licenses through an accredited midwifery program, and its chapter also lets experienced lay midwives sit for the licensing examination without completing the required coursework 5Ref 5Washington State Legislature (2026).RCW 18.50.040 — Qualifications for licensure..Washington's licensure qualifications for direct-entry midwives, including the accredited-program route and the provision letting experienced lay midwives sit for the licensing examination without completing the required coursework, neither of which runs through a national certification.. Neither route runs through the national credential the question started with.

But past those two the picture varies by state, and this page will not guess at it. Whether a state licenses a non-nurse midwife at all can change with a legislative session, so the lookup is worth more than any summary of it.

Commercial coverage is the least predictable of the four. Carriers set it contract by contract and it turns on the credential, so a practice planning around that revenue is better off holding each plan's answer in writing before the first prenatal visit is scheduled.

How one birth becomes two bills

A birth in a freestanding birth center typically generates two claims, not one, and the credential question lands on only one of them. South Dakota Medicaid's birth center manual is a clean worked example of the structure: the facility side is an all-inclusive flat rate per episode of care, billed on HCPCS code S9083 and paid at the lesser of the billed charge or the fee schedule amount 6Ref 6South Dakota Department of Social Services, Division of Medical Services (2025).South Dakota Medicaid Billing and Policy Manual: Freestanding Birth Center.One state's worked example of the two-line birth center billing structure: the all-inclusive facility fee on HCPCS S9083 paid at the lesser of billed charge or fee schedule amount, the separate professional and delivery billing by physician, certified nurse-midwife, nurse practitioner or physician assistant, and HCPCS S4005 for labor not resulting in delivery..

The professional side is separate by that manual's own terms. Delivery and professional services are not considered facility services, and the manual names the physician, certified nurse-midwife, nurse practitioner and physician assistant as the ones who bill them 6Ref 6South Dakota Department of Social Services, Division of Medical Services (2025).South Dakota Medicaid Billing and Policy Manual: Freestanding Birth Center.One state's worked example of the two-line birth center billing structure: the all-inclusive facility fee on HCPCS S9083 paid at the lesser of billed charge or fee schedule amount, the separate professional and delivery billing by physician, certified nurse-midwife, nurse practitioner or physician assistant, and HCPCS S4005 for labor not resulting in delivery.. That list is the credential economics compressed into one line of a state manual. It is also one state's list, in one program's manual, so the version that governs a practice is that practice's own state.

The same manual prices the case that does not end in a delivery, under HCPCS code S4005 for labor not resulting in delivery 6Ref 6South Dakota Department of Social Services, Division of Medical Services (2025).South Dakota Medicaid Billing and Policy Manual: Freestanding Birth Center.One state's worked example of the two-line birth center billing structure: the all-inclusive facility fee on HCPCS S9083 paid at the lesser of billed charge or fee schedule amount, the separate professional and delivery billing by physician, certified nurse-midwife, nurse practitioner or physician assistant, and HCPCS S4005 for labor not resulting in delivery.. A practice that has priced the birth and never priced the transfer is carrying the difference itself.

What a self-pay practice puts in writing

A written estimate, in advance, and a fee schedule the practice can defend line by line. Self-pay comes with its own set of rules. New York's insurance regulator, restating the federal right for readers in its state, describes an uninsured or self-pay patient's entitlement to a good faith estimate and a dispute route when the final bill runs at least $400 above it 7Ref 7New York State Department of Financial Services (2026).Surprise Medical Bills.A representative state insurance-department guide, used to mark the boundary of surprise-billing protection, which reaches a patient who did not choose the out-of-network provider or who needed emergency care, and to state the uninsured or self-pay good faith estimate and its $400 dispute threshold..

That guide also marks a boundary in the other direction. Its surprise-billing protections cover a patient who did not choose the out-of-network provider, or who needed emergency care, and leave that patient owing only in-network cost sharing 7Ref 7New York State Department of Financial Services (2026).Surprise Medical Bills.A representative state insurance-department guide, used to mark the boundary of surprise-billing protection, which reaches a patient who did not choose the out-of-network provider or who needed emergency care, and to state the uninsured or self-pay good faith estimate and its $400 dispute threshold.. A family that chooses a self-pay midwife for a planned birth sits in neither category, so those protections are not what makes the arrangement work or fail. New York is one state's guide; the one to read is the department of insurance in the state where the practice sits.

The exception arrives at a transfer. Care that begins as a planned out-of-hospital birth and ends in a hospital emergency crosses into the territory those rules were written for, which is a reason to know the state version well in advance of a transfer.

A practice that never sends a claim should still run the covered-entity test rather than assume the answer follows from the billing model.

Choosing the model before the entity

Sequence matters, because the billing decision constrains the entity, the staffing and the insurance, and reversing it later is expensive. Settle which payers the practice will bill before anything is filed. A nurse-midwife practice that intends to enroll with Medicaid and commercial plans is building a credentialing function; a self-pay practice is building an estimate and collections function. Those are different jobs carrying different overhead.

• Read the scope-of-practice section of the state's act before the licensure section, since scope decides what there is to bill for.
• Ask each carrier in writing whether it credentials that license type at all, and keep the reply.
• Price the transfer case as carefully as the birth, and know which codes travel with the patient.

Two midwives who split a call schedule usually end up splitting an entity as well, and equal owners, no tiebreaker is a problem worth solving on paper before it arrives in the middle of a delivery month. Whichever license the state issues, its renewal cycle and any payer enrollment attached to it belong on the expirables calendar.

A practice holding both documents, its own state's practice act and its own state's Medicaid provider manual, can answer this question for itself in an afternoon and answer it again after the next legislative session.