Blue Cross Blue Shield of Michigan (BCBSM) and Blue Care Network (BCN) Billing Changes
Blue Cross Blue Shield of Michigan (BCBSM) and Blue Care Network (BCN) have officially announced a strict multi-phase elimination of incident-to billing which will have direct impacts on Advanced Practice Providers like Physician Assistants (PAs). [1]
The policy shift rolls out in two major phases over the next several months, fundamentally altering how PA services are compensated in Michigan.
Timeline of BCBSM Billing Restrictions
The transition moves from mandatory tracking to a complete financial penalty and direct billing requirement:
| Phase | Effective Date | Policy Enforcement | Impact on PA Billing |
| Phase 1 | September 1, 2026 | • Mandatory SA modifier on all incident-to claims. • Exclusion from Value-Based Reimbursement (VBR). |
Claims are paid at the PA's basic rate; the practice loses all PGIP/VBR bonuses for these visits. |
| Phase 2 | March 1, 2027 | • Mandatory Direct NPI Billing for fully credentialed PAs. • 80% payment penalty for non-compliance. |
Credentialed PAs must bill independently. Failing to do so triggers a 20% cut and zero VBR eligibility. |
Core Operational Impacts for Michigan PAs
- Loss of Value-Based Incentives: To receive VBR or qualify for the Physician Group Incentive Program (PGIP), the PA must be enrolled directly with BCBSM/BCN and bill under their own NPI. Incident-to claims are permanently barred from these incentive pools. [1]
- The 80% Reimbursement Ceiling: If a practice continues to bill incident to-using the SA modifier past March 1, 2027, BCBSM will automatically reduce the payout to 80% of the applicable physician fee schedule. [1]
- Complete Ban on Provisionally Licensed PAs: If your practice employs PA students, trainees, or PAs working under a temporary/provisional license, they are entirely ineligible to use incident-to billing in professional settings. Their services will not be reimbursed by BCBSM under a supervisor. [1]
Immediate Action Plan for Your Practice
To protect your practice's revenue from steep cuts, your billing and administrative teams should begin executing these steps immediately:
- Verify BCBSM Credentialing: Ensure all PAs in your group are fully credentialed and individually enrolled with BCBSM and BCN. Delays in credentialing will prevent you from transitioning to direct billing smoothly. [1, 2]
- Update the EMR and Billing Software: Configure your billing systems to automatically attach the SA modifier to any remaining incident-to claims starting September 1, 2026. [1]
- Map Out Financial Impacts: Separate your PA-rendered claims from physician claims to calculate the anticipated loss of PGIP/VBR bonuses, and prepare to transition those PAs to 100% direct-NPI billing well before the March 2027 hard deadline
