In Michigan, limited-license behavioral health providers practice under supervision while working toward full licensure. Provisional licensure is a temporary or limited license that allows a healthcare professional to practice while they complete additional requirements needed for full, independent licensure.
Limited license providers are clinicians who have finished their education but are still completing the supervised work experience needed for full licensure, similar to how medical residents practice under supervision before becoming fully licensed physicians.
What is incident-to billing and why is it used?
“Incident-to” billing is a healthcare payment practice that allows services provided by non-physician providers to be billed under the National Provider Identification (NPI) of a supervising provider. This occurs when the provider has a lower level of licensure than their supervising provider, or when the provider is not directly enrolled with Blue Cross.
Part of delivering quality, affordable healthcare involves making every step of the care delivery process as transparent as possible. With that in mind, Blue Cross Blue Shield of Michigan is updating our “incident-to” services and billing reimbursement policy for our commercial health insurance plans.
Why the policy is changing and how it will improve care
We are giving affected providers nearly a year to adjust. Under the change – which will go into effect on March 1, 2027 – students, trainees and other limited license behavioral health providers will no longer be able to bill “incident-to” a supervising provider in office-based practices. Instead, to receive payment, they must submit claims in facility-based settings such as hospitals, outpatient psychiatric centers and community health centers.
Our commercial PPO plans cover nearly 200 outpatient psychiatric centers across six regions in Michigan in addition to hundreds of additional Blue Cross-approved facilities across the state.
This change is designed to ensure members receive the best possible care from fully licensed providers while allowing students, trainees and other limited-licensed professionals to be paid for services authorized and overseen by fully licensed providers in facility-based settings.
This change will align our policy with the one we have in place for medical trainees – such as interns and residents – as they are both post-graduate clinicians that require extra training and tests to become fully licensed. It also aligns the Blue Cross policy with Blue Care Network and Medicare Advantage policies; neither of which allowed students, trainees or limited license providers to bill “incident-to.”
Ultimately, we believe this change will help create a consistent approach to payment for all provider trainees who are not yet fully licensed.
Blue Cross is helping prepare providers and members for this change
Blue Cross is committed to making this payment policy transition as seamless as possible for our members and providers, which is why we announced this change nine months in advance.
Providers not impacted by this change can continue billing services “incident-to” with Blue Cross. These providers include:
- Registered Nurses
- Dieticians
- Physical Therapy Assistants
- Occupational Therapy Assistants
- Behavioral Health Technologists
- Community Health Workers
- Peer Support Specialists
Private practice owners can apply for their practice to be qualified as an outpatient psychiatric center, which would allow limited license professionals to continue billing “incident-to.” To read more about enrolling a practice as an outpatient psychiatric center, review the qualification requirements at this link.
Members currently receiving services from this group of providers should look to transition their care to a fully licensed provider or a limited license provider at a facility-based location by March 1, 2027. Providers who have additional questions about this policy can access the provider FAQ at Availity.com:
- Within our payer space, click on the Resources tab and then click on Secure Provider Resources (Blue Cross and BCN).
- Under the Billing and Claims tab, click on Medical and Reimbursement Policies from the drop-down menu, and then choose Blue Cross and BCN Reimbursement Policies.
After signing in with their member ID, Blue Cross members can click here to scroll our directory of behavioral health providers. The directory includes only fully licensed providers.
Incident-to FAQs
| Which specific limited licenses (LLMSW, LLPC, LLMFT, TLLP) are affected by the BCBSM incident-to policy? | This change is inclusive of provider types such as physicians in graduate medical education (GME) programs, limited licensed social workers, limited licensed professional counselors, limited licensed marriage and family therapists, temporary limited licensed psychologists and equivalent provider types. |
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| What changes take effect on September 1, 2026, versus March 1, 2027, for limited license therapists? | Beginning Sept. 1, 2026, claims submitted incident-to a physician or non-physician must use the incident-to modifier (SA) and will be reimbursed at the submitting provider’s applicable payment rate. Beginning March 1, 2027, students, trainees and other limited license behavioral health providers will no longer be able to bill incident-to a supervising provider in office-based settings. Instead, to receive payment they must submit claims in accredited facility-based settings such as hospitals, community health centers or Blue Cross-designated outpatient psychiatric centers. Michigan is home to nearly 200 outpatient psychiatric centers as well as hundreds of additional hospitals and community health centers in the Blue Cross network. This will align our payment policies with Blue Care Network and Medicare, which have never allowed students, trainees or limited license providers to bill incident-to in professional settings. |
| How can a private practice qualify as a BCBSM Outpatient Psychiatric Center (OPC)? | There are two main components to be an OPC. A multidisciplinary staff for the provision of services which must include: A board-certified or board-eligible psychiatrist A fully licensed psychologist or master’s level limited licensed psychologist, or LLP, or PhD LLP with a supervisory or consulting licensed psychologist, or LP contractual relationship A licensed master’s social worker, or LMSW General requirements include: Organization as a legal entity Full accreditation, either three or four years, for each facility site, by address, by one of the following: The Joint Commission, or TJC American Osteopathic Association, or AOA Council on Accreditation of Services for Families and Children, or COA Commission on Accreditation of Rehabilitation Facilities, or CARF National Council on Accreditation, or NCQA MDHHS Certification Letter for Community Mental Health Services. |
| What are options for limited license therapists after BCBSM billing changes? | Limited licensed providers that wish to continue billing BCBSM for services after March 1, 2027, must work in a facility-based setting like a hospital, community mental health facility or Blue Cross-designated OPC. |
Providers with additional questions about this policy may share feedback by emailing BlueCrossBlueShieldofMichiganandBlueCareNetwork@bcbsm.com.
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