BCBSM & BCN Announce Changes to Incident-To Billing Policy

Blue Cross Blue Shield of Michigan (BCBSM) and Blue Care Network (BCN) are implementing changes to their incident-to billing policy beginning September 1, 2026.

Key Dates to Know

September 1, 2026 – February 28, 2027

• Claims billed incident-to a physician or non-physician must include the SA modifier and will be reimbursed based on the submitting provider’s applicable payment rate.
• Incident-to claims will no longer qualify for value-based reimbursement (VBR), including those associated with the Physician Group Incentive Program (PGIP).
• To receive VBR, services performed by PGIP-participating physicians and non-physicians must be billed directly under the rendering provider.

Beginning March 1, 2027

• Physicians and non-physicians eligible to participate directly with BCBSM or BCN will be required to bill under their own National Provider Identifier (NPI).
• Eligible providers who continue billing incident-to using the SA modifier will be reimbursed at 80% of the applicable rate and will not qualify for VBR.
• Only claims billed directly for services provided by PGIP-participating physicians and non-physicians will be eligible for VBR.
• Students, trainees, and providers with provisional licensure will no longer be eligible for reimbursement through incident-to billing in professional settings.

Who Is Not Impacted?

These changes do not apply to:

• Medicare Plus Blue℠ and BCN Advantage℠ providers
• Certain provider types and services, including anesthesia, dental, laboratory, pharmacy, urgent care, Provider-Delivered Care Management (PDCM), and select support staff who are not eligible for direct participation

What Should Providers Do Now?

Review your current billing practices and determine whether any providers currently billing incident-to will need to enroll directly with BCBSM or BCN before March 1, 2027.

For full policy details, refer to BCBSM’s June 2026 The Record newsletter.

Contact your Yeo & Yeo advisor with questions or for help navigating these changes.