Blue Cross Blue Shield of Michigan (BCBSM) and Blue Care Network (BCN) have announced significant changes to their professional incident-to billing reimbursement policy that will take effect beginning September 1, 2026, with additional requirements taking effect March 1, 2027. According to BCBSM, the changes are intended to improve transparency, strengthen identification of rendering practitioners, and better align reimbursement with practitioner licensure and participation status. However, healthcare organizations, physicians, and non-physicians practitioners across Michigan have raised concerns about the potential impact on workforce development, practice operations, and patient access to care, particularly in behavioral health and primary care settings.
Incident-to billing allows services performed by one healthcare professional to be billed under the National Provider Identifier (NPI) of a supervising physician or non-physician practitioner and reimbursed at the supervising practitioner's rate. Traditionally, this approach has been used when a rendering practitioner has a lower level of licensure or is not directly enrolled with BCBSM or BCN. Many physician practices, behavioral health organizations, and multidisciplinary care teams have relied on incident-to billing as part of collaborative care models that integrate supervised clinicians into patient care while they work toward full licensure or enrollment.
Under the new policy, practitioners who are eligible to enroll directly with BCBSM or BCN and continue to bill incident-to beginning September 1, 2026, must use modifier SA on claims. These claims will no longer be eligible for value-based reimbursement (VBR), including Physician Group Incentive Program (PGIP) incentives, although they will continue to be reimbursed at the submitting practitioner's applicable payment rate during the transition period. Beginning March 1, 2027, practitioners who are eligible for direct participation with BCBSM or BCN will be required to submit claims under their own NPI. Practitioners who continue to bill incident-to under limited transition circumstances will be reimbursed at 80% of the professional fee schedule and will not be eligible for VBR.
One of the most significant changes affects practitioners who are considered to be in training. After March 1, 2027, students, trainees, physicians in graduate medical education programs, limited licensed social workers, limited licensed professional counselors, limited licensed marriage and family therapists, temporary limited licensed psychologists, and similar provider types will no longer be eligible for reimbursement through incident-to billing in professional office settings. These providers may continue delivering services incident-to only in facility-based settings.
BCBSM says the policy changes support broader efforts to improve quality measurement, care coordination, and accountability while creating additional opportunities for eligible practitioners to participate directly in quality incentive programs. They also cite potential benefits for advanced practice providers, including nurse practitioners and physician assistants, who may qualify for value-based reimbursement opportunities when they enroll directly and participate in PGIP.
At the same time, physician and non-physician practitioner groups have raised concerns about the practical implications of the policy. Behavioral health organizations, in particular, have expressed concern that the changes could disrupt a workforce pipeline that depends heavily on limited-license professionals practicing under supervision while completing licensure requirements. Many counseling, psychology, marriage and family therapy, and social work professionals must accumulate supervised clinical hours before obtaining full licensure, and practitioners worry that limiting reimbursement opportunities in professional office settings could reduce employment opportunities, training capacity, and future workforce development.
Those concerns were highlighted in a recent media report featuring behavioral health providers who warned that the policy could create financial challenges for practices that rely on supervised clinicians as part of their care delivery model. Some organizations fear the changes could lead to reduced appointment availability, longer wait times, and diminished access to behavioral health services in communities already experiencing provider shortages. Others have expressed concern that the policy may make it more difficult for future clinicians to obtain the supervised experience necessary to advance toward full licensure.
Independent physician practices may also face unique challenges as they prepare for the transition. Many practices operate with limited administrative resources and may need significant time to evaluate the financial impact, redesign care delivery and billing processes, enroll practitioners, update compliance procedures, and adjust budgets. At the same time, practices are continuing to navigate workforce shortages, rising operating costs, and ongoing reimbursement pressures. The loss of value-based reimbursement on incident-to claims and the requirement for more practitioners to bill directly could affect both revenue and operational efficiency.
In primary care, where care is increasingly delivered through multidisciplinary teams that include physicians, nurse practitioners, physician assistants, behavioral health professionals, care managers, and other support staff, the changes may require practices to reevaluate how services are delivered and billed. While BCBSM notes that direct enrollment may create new opportunities for advanced practice providers to participate in quality incentive programs, some physician leaders have expressed concern that the implementation timeline may not provide sufficient opportunity to fully assess the downstream effects on practice sustainability, workforce planning, integrated care delivery, and patient access before the policy takes effect.
Not all providers and services will be affected equally. BCBSM has indicated that several provider types that are not eligible for direct participation may continue billing incident-to indefinitely, including registered nurses, dietitians, physical therapy assistants, occupational therapy assistants, behavioral health technologists providing Applied Behavior Analysis services, community health workers, and peer support specialists. In addition, several services and settings are excluded from the policy changes, including anesthesia, dental services, laboratory services, pharmacy services, urgent care, Provider Delivered Care Management (PDCM), team-based care programs, facility-based professional services, including outpatient psychiatric centers, and ambulance and emergency medical technician services performed under supervision.
BCBSM and BCN have established a phased implementation approach. From September 1, 2026, through February 28, 2027, practitioners eligible for direct enrollment may continue billing incident-to using modifier SA while preparing for direct billing requirements. Eligible practitioners who are not currently enrolled are encouraged to complete enrollment before March 1, 2027. Limited exceptions will remain available for practitioners transitioning from another state to Michigan licensure or changing participating practices, allowing them to bill incident-to for up to 90 days while completing transition activities. They have published additional guidance, including a detailed Frequently Asked Questions (FAQ) document, to help practitioners understand the policy changes, implementation timeline, billing requirements, and available exceptions.
As practices evaluate the potential implications of these changes, questions remain about how the policy will affect workforce development, care delivery models, reimbursement, and patient access across Michigan. MSMS is interested in hearing from physicians and practice leaders about any operational, financial, or patient care concerns they anticipate as a result of the new policy. Contact Dara Barrera, Director, Health Quality, Equity and Technology at djbarrera@msms.org for more information and/or to share concerns regarding the policy update.
BCBSM The Record - Changes are coming to incident-to billing policy for Blue Cross, BCN commercial
BCBSM Incident-to Services and Billing Frequently Asked Questions for Providers