06/17/2026

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June 2026 Frequently Asked Questions

Question:

Is there ever a scenario where unused drug in a MDV can be reimbursed as waste?   Example: BCG J9303 comes in a vial that treats two patients. It has an extremely short shelf life once mixed. If there are an odd number of patients scheduled that day, our pharmacy would like to charge for waste. So, five patients come and the first four get billed 25mg and the 5th one would be billed for the 25mg administered.  Can the remaining 25mg be wasted on that claim?

Answer:

Medication management is a responsibility of the practice.  Payers are expecting practices to purchase smaller dose vials if available. For multi-dose vials, you do not bill the waste separately.  You bill only the portion of the vial that was actually administered to patients, using the HCPCS code and units for the administered amount.  The remaining unused portion is considered part of the vial inventory and is not reimbursable under the discarded drug policy.

Question:

How will the Incident-to policy affect provider reimbursement if the practices send claims with Modifier SA on APP claims billed under the physician's NPI?  Will these claims be excluded from the PGIP program and other PPO bonus payments?   The practices are asking if in addition to the 15% reduction in reimbursement, will they also see a reduction in the PGIP PPO bonus as well?

Answer: 

Changes are coming to incident-to billing policy for Blue Cross, BCN commercial Blue Cross Blue Shield of Michigan and Blue Care Network are changing our professional incident-to services and billing reimbursement policy. For dates of service starting on Sept 1, 2026, eligible providers who deliver services to Blue Cross or BCN commercial members incident-to another provider should file claims under their own National Provider Identifier, or NPI. Providers who continue to bill incident-to will be required to use a designated modifier (SA) on the claim.

These claims won’t be eligible for value-based reimbursement, or VBR. Beginning March 1, 2027, eligible providers will be required to file claims under their own NPI. Blue Cross and BCN are committed to delivering quality, affordable care for our members. Clarifying our policies and billing practices will strengthen our ability to identify rendering providers, improve oversight of quality of care and align reimbursement with provider licensure and participation status. These changes also align with additional opportunities for eligible providers to participate in quality rewards programs, which promote high-quality, patient-centered outcomes and care coordination.

What is incident-to? Incident-to is a billing practice that allows services performed by a provider to be billed under a supervising physician’s or non-physician’s NPI and reimbursed at the supervising provider’s rate. This may occur when the rendering provider has a lower level of licensure than their supervising provider, or when the rendering provider isn’t directly enrolled with Blue Cross or BCN. Which providers will these changes affect? These changes will affect most providers who deliver services to Blue Cross or BCN commercial members incident-to a physician or non-physician in a professional setting. Note: These changes won’t apply to providers affiliated with Medicare Plus Blue℠ and BCN Advantage℠

What’s changing For dates of service starting on Sept. 1, 2026, through Feb. 28, 2027: 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. Additional value-based reimbursement won’t be applied to incident-to claims, including claims associated with providers participating in the Physician Group Incentive Program, or PGIP. Only claims submitted directly for services performed by a PGIP participating physician or PGIP non-physician will be eligible for VBR.

For dates of service starting on March 1, 2027: Physicians and non-physicians eligible for direct participation with Blue Cross or BCN must submit claims directly. Providers who are eligible to bill directly but continue to bill incident-to with the SA modifier will receive 80% reimbursement and won’t be eligible for VBR. Only claims submitted directly for services performed by PGIP participating physicians or non physicians will be eligible for VBR. Providers considered by Blue Cross 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.

The Record. Incident To Billing

Incident To Reimbursemnet Policy Faq