BCBSM Is Changing Incident-to Billing. What Michigan Therapy Groups Need to Know.

Last updated: June 2, 2026.

Blue Cross Blue Shield of Michigan and Blue Care Network are changing how they handle incident-to billing for commercial members. For therapy practices, this is not just a modifier update. It is a credentialing, roster, rendering-provider, and revenue-operations update.

Practice takeaway: do not wait until March 2027. Start mapping every clinician, NPI, license, payer enrollment status, group affiliation, and claim setup now.

TL;DR

• Starting with dates of service on September 1, 2026, eligible providers who deliver services to BCBSM or BCN commercial members incident-to another provider should begin filing claims under their own NPI.

• During the transition period, incident-to claims must use the SA modifier, and those claims will not be eligible for value-based reimbursement.

• Starting March 1, 2027, eligible providers will be required to bill directly under their own NPI. Eligible providers who keep billing incident-to with SA will receive 80% reimbursement and no value-based reimbursement.

• This applies to BCBSM and BCN commercial members. The BCBSM update says it does not apply to Medicare Plus Blue or BCN Advantage.

• For group therapy practices, the high-risk workflows are where the clinician seeing the client is not the provider whose NPI is attached to the claim.

Source: BCBSM The Record, June 2026 incident-to billing update.

What Changed?

BCBSM and BCN announced a phased change to their professional incident-to services and billing reimbursement policy. Incident-to billing is when one provider performs a service, but the claim is billed under another supervising provider's NPI and reimbursed at the supervising provider's rate.

BCBSM says this can happen when the rendering provider has a lower level of licensure or is not directly enrolled with BCBSM or BCN. That is exactly why this matters for group practices.

A solo therapist billing only under their own enrolled NPI may not feel much day-to-day impact. But a growing group practice may have multiple clinicians, multiple license levels, new hires, interns, provisionally licensed clinicians, part-time clinicians, contractors, and supervisors. That is where incident-to billing can sneak into the workflow.

BCBSM and BCN are moving toward clearer rendering-provider attribution. In plain English: they want claims to show who actually performed the service.

The Timeline

September 1, 2026: Transition Period Begins

For dates of service from September 1, 2026 through February 28, 2027, claims submitted incident-to must use the SA modifier. BCBSM also says additional value-based reimbursement will not apply to incident-to claims during this phase.

This is the warning period. Practices still have time to fix enrollment, credentialing, and billing workflows, but incident-to billing becomes more visible and less favorable.

March 1, 2027: Direct Billing Becomes Required

For dates of service starting March 1, 2027, physicians and non-physicians who are eligible for direct participation with BCBSM or BCN must submit claims directly.

Providers who are eligible to bill directly but keep billing incident-to with the SA modifier will receive 80% reimbursement and will not be eligible for value-based reimbursement.

That is the revenue risk. If a practice does not clean this up before the deadline, the issue may show up as reduced reimbursement, claim confusion, denied claims, or messy follow-up work.

Who Is Affected?

BCBSM says the change affects most providers who deliver services to BCBSM or BCN commercial members incident-to a physician or non-physician in a professional setting. The update does not apply to Medicare Plus Blue or BCN Advantage.

For therapy practices, the highest-risk scenarios are group-practice workflows where the person seeing the client is not the person whose NPI is being used to bill the claim.

That may include:

• a newly hired clinician not yet fully enrolled

• a clinician waiting on payer credentialing or group affiliation

• a supervised clinician being billed under a supervisor

• a clinician who changed locations or groups

• a group practice that has not updated payer rosters

• a practice where EHR billing settings default to the owner's NPI

• a practice using different workflows for BCBSM, BCN, and other payers

The danger is not always intentional. A lot of incident-to problems are workflow drift. A clinician joins. The practice wants to keep care moving. Credentialing takes time. The EHR setup gets copied from another provider. A payer roster update lags. Claims go out under the wrong rendering or billing relationship.

Then the payer policy changes, and suddenly the quiet workflow becomes a revenue problem.

What Is Staying the Same?

Not every provider type is being pushed into direct billing. BCBSM says provider types that are not eligible for direct participation can continue delivering services incident-to a directly participating provider.

The examples listed include registered nurses, dieticians, physical therapy assistants, occupational therapy assistants, behavioral health technologists, community health workers, and peer support specialists.

The key phrase is eligible for direct participation. For therapy groups, the first operational question is not just, "who is seeing BCBSM clients?" It is:

Is this clinician eligible to participate directly with BCBSM or BCN, and if so, are they actually enrolled, affiliated, active, and set up correctly for claims?

That is a credentialing question. That is a roster question. That is a billing-system question. And for groups, it needs to be answered clinician by clinician.

Why BCBSM Says It Is Making the Change

BCBSM says the policy change is meant to clarify billing practices, strengthen identification of rendering providers, improve quality-of-care oversight, and align reimbursement with provider licensure and participation status.

That framing matters. This is not only about one modifier. The payer wants cleaner data about who performed the service.

For group practices, that means more scrutiny around rendering-provider identity, enrollment status, licensure, participation, and claim attribution.

Why This Matters for Therapists

Therapy practices often think about billing in CPT-code terms: 90834, 90837, family therapy, diagnostic evaluations, add-on codes, and modifiers.

But payer operations are not only about CPT codes. A perfectly valid therapy code can still create a problem if the wrong provider is attached to the claim.

This BCBSM update is a reminder that claims have multiple layers:

• client coverage

• payer network

• group contract

• individual clinician enrollment

• supervising provider relationship

• rendering provider NPI

• billing provider NPI

• service location

• license level

• modifier use

• effective dates

• taxonomy

• CAQH and roster status

That is why group billing gets complicated fast. The clinical session may be straightforward. The claim behind it may not be.

The Group-Practice Impact

1. Credentialing Becomes More Urgent

BCBSM says eligible providers will have six months starting September 1, 2026 to enroll before they are required to bill directly on March 1, 2027.

That sounds like plenty of time until you remember how credentialing actually works.

BCBSM's provider enrollment page says applications may take 30 days or more to process, professional providers need to keep CAQH current and authorize BCBSM to pull the application, and providers can only be reimbursed for networks where they are listed as Active. Read BCBSM's provider enrollment guidance.

For a group practice, "we submitted the application" is not the same as "this clinician is ready to bill." The operational status that matters is closer to:

• enrolled

• credentialed when required

• affiliated with the group

• active in the right network

• effective for the right dates

• loaded correctly in the EHR

• loaded correctly with the clearinghouse

• showing correctly on claims

2. Rendering-Provider Attribution Needs to Be Clean

The central issue is whether the claim accurately reflects who performed the service. If your EHR or billing workflow defaults claims to the owner, supervisor, or clinical director, this is the time to audit that setup.

Group owners should review:

• who appears as rendering provider

• who appears as billing provider

• which NPI is used

• whether group and individual NPIs are mapped correctly

• whether the service location is correct

• whether the supervising-provider relationship is being used

• whether the payer expects direct billing for that clinician

• whether the SA modifier is being applied only when appropriate

This is especially important for practices with multiple payers. A workflow that works for one payer can be wrong for another.

Insurance is local. Payer rules are specific. Copy-paste billing workflows are dangerous.

3. New Hires Need a More Disciplined Start-Date Workflow

Many group practices hire first and clean up payer enrollment later. That can work for some cash-pay or out-of-network workflows. It gets harder inside commercial insurance.

With this BCBSM change, groups should be more careful about when a new clinician begins seeing BCBSM or BCN commercial clients.

Before assigning those clients, the practice should know:

• Is the clinician eligible for direct participation?

• Has the enrollment application been submitted?

• Is CAQH complete and current?

• Has BCBSM or BCN pulled the CAQH profile?

• Is the clinician active in the right network?

• Is the clinician affiliated with the group?

• What is the effective date?

• Is the EHR billing setup complete?

• Are claims going out under the correct NPI?

A clinician can be clinically ready before they are billing-ready. That gap is where revenue gets messy.

4. Provisionally Licensed Clinicians, Trainees, and Students Need Special Attention

BCBSM says that for dates of service starting March 1, 2027, providers considered by BCBSM to be in training, such as students and providers with provisional licensure, will no longer be eligible for reimbursement for incident-to billing in a professional setting.

BCBSM also notes that students and trainees have until February 28, 2027 to associate with a facility to continue providing professional services to BCBSM or BCN commercial members.

This is one of the most important parts for therapy groups. A lot of mental health practices rely on supervised or early-career clinicians. The exact impact depends on the clinician's license, payer participation rules, facility status, contract structure, and whether the provider is eligible for direct enrollment.

Do not assume supervised billing can continue the same way after March 1, 2027.

Review every clinician who is not fully independently enrolled and billing directly.

What This Is Not

This is not a new therapy CPT-code update.

This is not specific to 90837.

This is not a universal BCBS policy across every state.

This is not about Medicare Plus Blue or BCN Advantage.

This is not automatically a problem for every solo therapist.

This is not a reason to stop seeing BCBSM or BCN commercial clients.

It is a payer-specific incident-to billing change for BCBSM and BCN commercial claims. But for group practices, payer-specific billing rules are exactly where the operational mess usually lives.

What Therapy Practices Should Do Now

1. Pull a list of all BCBSM and BCN commercial clients. Start with the active client population. Identify every client with BCBSM or BCN commercial coverage, then map those clients to the clinician actually performing the service.

2. Identify every claim where rendering and billing may not match. Look for claims where the service is performed by one clinician but billed under another provider's NPI. That is the core incident-to risk.

3. Classify every clinician. Document license type, license status, individual NPI, taxonomy, CAQH status, malpractice information, BCBSM enrollment, BCN enrollment, group affiliation, effective dates, direct-participation eligibility, and current billing setup.

4. Fix CAQH and enrollment gaps. Do not wait until February 2027 to discover that a clinician's CAQH profile is stale, missing malpractice information, missing work history, or not authorized for BCBSM access.

5. Review EHR and clearinghouse settings. Check rendering NPI, billing NPI, group NPI, taxonomy, service facility, supervising provider fields, claim modifier logic, payer-specific templates, ERA/EOB attribution, and clinician-level reporting.

6. Use the SA modifier carefully during the transition. From September 1, 2026 through February 28, 2027, incident-to claims must use SA. That does not mean every claim should suddenly get SA. Identify which claims are actually billed incident-to and apply the rule intentionally.

7. Plan for March 1, 2027 as the real deadline. By then, eligible providers should be billing directly. The deadline should live in the practice's credentialing tracker, billing workflow, and provider onboarding process.

Why This Is Exactly a Bomi Problem

This kind of update is why insurance billing is not just "submit the claim." The claim is the final step. The real work starts earlier:

• Is the clinician enrolled?

• Is the clinician affiliated with the group?

• Is the payer roster updated?

• Is the CAQH profile current?

• Is the effective date known?

• Is the EHR mapped correctly?

• Is the claim being attributed to the right provider?

• Are denials being tracked by clinician and payer?

• Are revenue issues visible before they become a cash-flow problem?

Bomi helps therapy practices handle the insurance work around every session: verification of benefits before sessions, claims and EOBs after sessions, denials and stale-claim follow-up, balances, CAQH, attestations, rosters, credential maintenance, and reporting. See Bomi Billing.

For group practices, Bomi also helps coordinate provider onboarding, payer roster updates, claims by clinician and payer, denial and A/R reporting, revenue attribution, and credentialing maintenance across clinicians. See Bomi Groups.

That is the exact muscle this BCBSM update requires. Not panic. Not guesswork. A clean provider-by-provider operating system.

The Bigger Lesson for Group Practices

Group practices often grow clinically before they grow operationally. The owner hires a second clinician. Then a third. Then someone changes license status. Someone moves locations. Someone starts telehealth in another state. Someone joins a new payer. Someone leaves. Someone is waiting on credentialing. Someone's CAQH expires. Someone is active with one BCBS product but not another.

The practice still thinks of itself as a therapy practice. The payer sees a web of NPIs, licenses, effective dates, locations, contracts, affiliations, tax IDs, modifiers, claims, and rosters.

That is the mismatch.

BCBSM's incident-to update is a reminder that group practices need insurance infrastructure as they grow. Not because the therapy is more complicated. Because the billing identity of each session is more complicated.

Bottom Line

BCBSM and BCN are changing incident-to billing for commercial members. Starting September 1, 2026, incident-to claims must use the SA modifier and will not be eligible for value-based reimbursement. Starting March 1, 2027, eligible providers must bill directly under their own NPI, and eligible providers who continue billing incident-to with SA will receive 80% reimbursement and no value-based reimbursement.

For therapists, the key question is simple:

Am I billing under the NPI of the clinician who actually performed the service?

For group practices, the better question is:

Do we have a clean roster, credentialing, and claims workflow for every clinician before this change takes effect?

If the answer is not clearly yes, now is the time to fix it.

Want Bomi to Help Clean Up the Insurance Backend?

Bomi helps therapy practices with benefit checks, claims, EOBs, denials, stale claims, balances, CAQH, attestations, rosters, credentialing maintenance, and revenue reporting.

For growing groups, Bomi helps keep provider onboarding, payer rosters, clinician-level claims, denial follow-up, and revenue reporting from turning into a second full-time job.

You see clients. Bomi helps keep the insurance side moving. Talk to Bomi.

FAQ

What is BCBSM changing about incident-to billing?

BCBSM and BCN are moving eligible providers toward direct billing under their own NPI for commercial members, with a transition period requiring the SA modifier for incident-to claims.

When does the BCBSM incident-to transition begin?

The transition begins for dates of service on September 1, 2026. From September 1, 2026 through February 28, 2027, incident-to claims must use the SA modifier.

When does direct billing become required?

For dates of service starting March 1, 2027, eligible providers must bill directly under their own NPI. Eligible providers who continue billing incident-to with SA will receive 80% reimbursement and no value-based reimbursement.

Does this apply to Medicare Plus Blue or BCN Advantage?

No. BCBSM's update says the change does not apply to Medicare Plus Blue or BCN Advantage.

What should Michigan therapy groups do first?

Start by mapping every BCBSM and BCN commercial client to the clinician who actually performs the service, then compare that against each clinician's NPI, license, enrollment status, group affiliation, effective dates, and EHR billing setup.

Sources

• BCBSM The Record: Changes are coming to incident-to billing policy for Blue Cross, BCN commercial

• BCBSM provider enrollment and credentialing guidance

• Bomi Billing

• Bomi Groups