Blue Cross Blue Shield of Michigan and Blue Care Network are updating their professional “incident-to” services and billing reimbursement policy for eligible providers serving commercial members, according to a June provider newsletter.
The incident-to billing practice permits services performed by one provider to be billed under a supervising clinician’s national provider identifier and reimbursed at the supervisor’s rate, which could be higher. The rendering provider may have a lower level of licensure or lack enrollment with the insurer.
Beginning Sept. 1, rendering providers who continue to bill this way must use the incident-to modifier with these claims, receiving reimbursement at the submitting provider’s rate. Claims with the modifier will not be eligible for value-based reimbursement.
The insurer is giving providers six months to join their network, if needed. Starting March 1, 2027, eligible providers must submit their claims directly. Some providers transitioning between states or participating practices will be allowed incident-to billing for a limited time.
If providers still bill incident-to with the modifier after the March deadline, they will receive 80% reimbursement and no value-based reimbursement.
The policy will affect most providers working with commercial members who practice incident-to billing in a professional environment, the memo said. The update carved out providers affiliated with Medicare Advantage offerings, as well as some specific services, including anesthesia, pharmacy, urgent care, team-based care and services by emergency medical technicians.
In March, providers considered to be “in training,” such as students and others with provisional licensure, cannot receive incident-to reimbursement in professional settings. However, facility-based professional services by trainees or students are exempt from the policy. Students and trainees have until the March deadline to associate with a facility. In a June 11 statement, the Michigan State Medical Society described this as “one of the most significant changes,” affecting those in graduate programs, limited-licensed social workers, limited-licensed professional counselors, and limited-licensed marriage and family therapists, among others. These providers need to complete licensure requirements, such as clinical hours, under supervision, MSMS said.
“Practitioners worry that limiting reimbursement opportunities in professional office settings could reduce employment opportunities, training capacity and future workforce development,” the statement said.
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