MAFP continues to engage with Blue Cross Blue Shield of Michigan (BCBSM) on its revised incident-to billing policy change. As family physicians, we understand the importance of appropriate oversight, accountability, and accurate billing. However, this policy change creates significant administrative and operational challenges for physician practices without demonstrating a corresponding benefit to patients, physicians, or the health care system.

There have been several updates on BCBSM’s incident-to policy including upcoming deadlines. Michigan State Medical Society provided us with the following update to share with members.

With the first phase of BCBSM and Blue Care Network's (BCN) revised incident-to billing policy now in effect, physician practices should ensure they understand the new billing requirements and upcoming credentialing deadlines. Practices should take particular note of the new requirement to use modifier SA on applicable incident-to claims. For practices that participate in the Physician Group Incentive Plan (PGIP) and planning to transition eligible practitioners from incident-to billing to direct billing should make sure these practitioners are credentialed by September 23, 2026, to be eligible to earn Value Based Reimbursement (VBR) beginning in early 2027.

For dates of service on or after September 1, 2026, practitioners who are eligible to enroll directly with BCBSM or BCN but continue to provide services under an incident-to arrangement must have modifier SA appended to each applicable procedure code. Modifier SA identifies that the service was performed incident-to a supervising practitioner rather than personally furnished by the practitioner under whose billing information the claim is submitted. Practices should review their EHR, practice management and clearinghouse workflows to ensure modifier SA is being applied and transmitted correctly on applicable claims in accordance with BCBSM/BCN requirements.

During this transition period, applicable services billed incident-to with modifier SA will continue to be reimbursed based on the submitting practitioner's applicable payment rate. However, practices should be aware of an important distinction: claims submitted with modifier SA are not eligible for value-based reimbursement (VBR), including PGIP incentives. This means that while the underlying service may continue to be paid at the submitting practitioner's rate, the claim will not generate additional VBR that may otherwise be associated with eligible services.

The use of modifier SA also gives BCBSM and BCN the ability to distinguish services personally performed by the billing practitioner from those furnished incident-to by another eligible practitioner. Practices that rely heavily on incident-to billing should consider the potential impact that exclusion from VBR may have on overall reimbursement, particularly when a significant volume of services is provided by advanced practice or other practitioners who are eligible to enroll and bill independently. As practices prepare for the next phase of the policy, they should evaluate whether continuing to bill eligible practitioners incident-to until the March 1, 2027, deadline, or transitioning those practitioners to direct billing sooner is the most appropriate approach for their organization.

With the first phase of the policy now in effect, below is a recap of the steps practices should take:

• Review their billing, credentialing and enrollment processes to ensure they are prepared for both the current requirements and the next phase of implementation.

• Identify all practitioners whose services are currently billed incident-to and determine which practitioners are eligible for direct BCBSM/BCN enrollment;

• Verify that modifier SA is being appropriately reported on applicable claims; and

• Submit any necessary credentialing applications as soon as possible if they want those practitioners to be included in the PGIP snapshot by the September 23, 2026, deadline;

• Consider the potential reimbursement implications of continuing to bill eligible practitioners incident-to, including the loss of VBR on claims submitted with modifier SA versus direct billing.