New LOI allows groups, practices to bill incident-to until Sept. 1, 2027, while completing OPC enrollment

REQUIREMENTS: - Effective immediately: All groups and practices with currently contracted Blue Cross or Blue Care Network coverage must begin using modifier SA on all professional incident-to claims for limited-licensed providers for dates of service starting September 1, 2026. Verify that billing software is configured to append modifier SA to all applicable behavioral health incident-to claims. - Immediately: Identify all limited-licensed providers in behavioral health (excluding limited-licensed psychologists) currently billing incident-to. Confirm they are eligible for the extended period and communicate enrollment requirements to practice leadership. - As soon as possible: Billing and operations teams must work with clinical leadership to begin OPC enrollment process requirements, including recruiting the OPC core team and identifying accreditation pathways (national accrediting organization). - By March 1, 2027 DEADLINE: Obtain and sign the Letter of Intent to become an Outpatient Psychiatric Care (OPC) facility from Blue Cross provider resources. Submit signed LOI to Blue Cross per instructions on the form. Failure to submit LOI by this date will terminate the extended incident-to billing period after September 1, 2026. - By September 1, 2027 DEADLINE: Complete full OPC enrollment and credentialing with Blue Cross. Practices not achieving OPC status by this date will no longer be able to bill incident-to for limited-licensed providers. All claims submitted after this date without OPC status will be denied. - Ongoing: Maintain awareness of incident-to billing policy requirements and related FAQs available in the Secure Provider Resources section of the Blue Cross provider portal under Billing and Claims > Medical and Reimbursement Policies.