BCBS MI discontinues incident to billing for mental health providers in private practice

Effective March 1, 2027, BCBSM will restrict incident-to billing to facility-based settings only, including psychiatric hospitals, community mental health agencies, and similar institutional environments.2 Private practice offices, regardless of size, will no longer qualify. To help providers adjust, a transition period runs from September 1, 2026, through February 28, 2027. During this window, services rendered by limited license clinicians under supervision can still be billed with the "SA" modifier, but reimbursement will be paid at the submitting provider's applicable rate and they will not be eligible for value-based incentive programs.3 After the transition, any limited licensee attempting to bill incident-to from a private practice will face a penalty: only 80% of the allowed amount will be paid, and the claim remains ineligible for value-based reimbursement. https://www.counselingpsychology.org/articles/bcbsm-billing-change-mental-health-2026-06-14/