Blue Cross Blue Shield of Michigan (BCBSM) has announced additional accommodations related to its upcoming changes to incident-to billing requirements following continued engagement with the medical and behavioral health provider communities.
The Michigan State Medical Society (MSMS) has been actively engaged with BCBSM regarding the impact of these changes on physician practices, including concerns related to reimbursement, implementation timelines, administrative burden, and the ability of practices to transition to the new requirements. Based on feedback from MSMS and other interested organizations, BCBSM has outlined several updates intended to provide additional payment opportunities and flexibility for affected practices.
The implementation timeline remains the same with Phase 1 beginning September 1, 2026, with additional requirements taking effect March 1, 2027. This timeframe makes credentialing an important part of practice preparation. Practices should review which clinicians currently provide services under incident-to-billing arrangements and determine whether those practitioners will need to be individually credentialed and enrolled with BCBSM/BCN. Because credentialing can take time, practices are encouraged to begin evaluating their staffing and billing arrangements well in advance of the 2027 implementation date.
For primary care practices, BCBSM has announced additional value-based reimbursement opportunities for advanced practice providers (APPs). Beginning with Phase 1 in September, primary care APPs participating in the Physician Group Incentive Program (PGIP) may earn up to 120 percent of the physician fee schedule through increased value-based reimbursement. Beginning in January, BCBSM will also offer an off-cycle value-based reimbursement opportunity for primary care APPs who were not previously participating in PGIP.
BCBSM has also made accommodations for behavioral health providers. A defined exception process will allow eligible behavioral health offices additional time to complete accreditation while continuing to bill incident-to for limited-license providers through September 2027. Additionally, BCBSM has added flexibility to its Outpatient Psychiatric Center policy. The change allows professional offices, including smaller and rural practices, to engage multidisciplinary teams of psychiatrists and psychologists through consultative arrangements designed to better accommodate different practice structures and needs.
BCBSM recently released a new Frequently Asked Questions (FAQ) document addressing many of the questions raised by practices about the incident-to policy changes. The FAQ provides additional clarification on implementation, credentialing, billing requirements, reimbursement, and other operational considerations to help practices prepare for the transition.
BCBSM also clarified that residents and fellows participating in approved Graduate Medical Education (GME) programs are excluded from the new incident-to-billing guidelines. Services provided as part of an accredited GME training program may continue to be billed incident-to under existing requirements. The policy also does not change current teaching physician billing requirements or the appropriate use of GC and GE modifiers. However, moonlighting services provided by residents or fellows are not eligible for incident-to billing and must be billed according to the applicable billing requirements.
These changes follow months of discussions regarding the potential effects of the incident-to policy on physician practices and access to care. While the additional flexibility and reimbursement opportunities address some of the concerns raised by the physician community,
MSMS continues to engage with BCBSM on implementation of the policy and its impact on practices. MSMS will continue advocating for approaches that provide adequate reimbursement, minimize unnecessary administrative burden, and protect patients' access to physician-led care.
MSMS will share additional information and implementation guidance as it becomes available. For more information, contact Dara Barrera, Director, Health Quality, Equity and Technology at (517) 336-5766 or djbarrera@msms.org.