IMPORTANT PRACTICE ALERT: BCBSM & BCN Announce Changes to Incident-To Billing Policy

✯ BCBSM & BCN Announce Changes to Incident-To Billing Policy ✯

This announcement was sent today (June 10) to all licensed mental health professionals in Michigan. We know that many of you are deeply concerned about the recent Blue Cross Blue Shield of Michigan (BCBSM) policy announcements regarding mental health provider reimbursement and "incident-to" billing guidelines (see link below).

Please rest assured: your professional associations are actively, aggressively, and strategically on top of this issue.

The Michigan Mental Health Counselors Association (MMHCA) and the National Association of Social Workers - Michigan Chapter (NASW-MI) have formed a united front. We are working directly in tandem, alongside our respective legislative lobbyists, to advocate on behalf of all mental health professionals across the state including Counselors, Social Workers, Psychologists, and Marriage & Family Therapists.

Our joint legal, legislative, and clinical advocacy teams are currently finalizing a comprehensive strategy to challenge these policy interpretations and protect the integrity of our licenses, our practices, and the clients we serve.

What you can expect next:

𝗜𝗻 𝘁𝗵𝗲 𝗰𝗼𝗺𝗶𝗻𝗴 𝗱𝗮𝘆𝘀, 𝘄𝗲 𝘄𝗶𝗹𝗹 𝗯𝗲 𝗿𝗲𝗮𝗰𝗵𝗶𝗻𝗴 𝗼𝘂𝘁 𝘁𝗼 𝘆𝗼𝘂 with an urgent request for help. We will be launching a state-wide impact survey to gather unquestionable, hard metrics regarding caseloads, service availability, and the financial impact this policy will have on Michigan communities. We will need your immediate participation to provide the unassailable data our lobbyists and legal teams require for upcoming meetings with decision-makers.

Thank you for your dedication to the profession and to the behavioral health of Michigan residents. We are stronger together, and we will continue to keep you updated every step of the way.

Sincerely,

The Leadership Teams of

The Michigan Mental Health Counselors Association (MMHCA) &

The National Association of Social Workers - Michigan Chapter (NASW-MI)

https://www.mmhcanow.org/

https://www.nasw-michigan.org/        

https://www.bcbsm.com/.../the.../2026/jun/Record_0626a.html 

Email sent to NASW members on June 3, 2026.

IMPORTANT PRACTICE ALERT:
BCBSM & BCN Announce Changes to Incident-To Billing Policy

Blue Cross Blue Shield of Michigan (BCBSM) recently announced an upcoming policy change that may significantly impact behavioral health providers across Michigan.

Based on information currently available, services provided by limited licensed clinicians—including Limited Licensed Social Workers (LLMSWs), Limited Licensed Professional Counselors (LLPCs), and Limited Licensed Marriage and Family Therapists (LLMFTs)—as well as students of any discipline, may no longer be eligible for reimbursement through incident-to billing under BCBSM commercial plans after March 1, 2027. BCBSM will begin implementing changes to its incident-to billing policy starting this fall.

Providers are encouraged to review the full policy announcement in BCBSM's June 2026 The Record newsletter .

NASW-Michigan is actively working with coalition partners, including the Michigan Mental Health Counselors Association (MMHCA), to obtain additional clarification regarding implementation, operational impacts, and the broader implications for Michigan's behavioral health workforce and access to care.

To help inform these discussions, coalition partners are developing a survey to gather information on how these proposed changes could affect provider capacity, supervision models, workforce development, practice operations, and client access to services. We strongly encourage affected providers to participate once the survey becomes available.

Providers with specific questions, concerns, or examples of how these changes may impact their practice are encouraged to email Policy and Advocacy Manager Jess Riley at jriley.naswmi@socialworkers.org. This feedback will help inform ongoing coalition discussions and requests for clarification from BCBSM.

NASW-Michigan will continue to share updates as additional information becomes available.

If you'd like to be part of a live open discussion on this issue, please join us for the next Private Practice Workgroup meeting this Friday, June 5th, 2026