A ten-minute sheet
Where do I stand on March 1, 2027?
A ten-minute sheet for Michigan clinicians with a limited license who see Blue Cross Blue Shield of Michigan patients. Free. No sign-up. It is drawn from the Center’s guide on the 2027 Blue Cross change, which cites every source.
This sheet is about Blue Cross commercial office claims. BCN office rules are different. Medicare Plus Blue and BCN Advantage need their own check.
Incident-to means you give the care and another provider’s NPI goes on the claim.
Step 1. Find your license (one minute)
LLPC, LLMSW, LLMFT, TLLP (master’s)
Ends March 1
LLP (master’s or doctoral)
Not affected
Not affected
Not named
Not named
Step 2. Pick the path that fits you (three minutes)
Answer all three. More than one path may fit.
If yes, Path 1, the facility route
Work through that facility. The facility must confirm how it will roster, bill, and supervise your work. The name of the place alone does not make it qualify.
If yes, Path 2, the license route
Finish the license step, then apply for enrollment the day your full license posts. Review can take up to 90 days.
If yes, Path 3, the team route
Ask about a care manager role. Blue Cross supports collaborative care through its physician incentive program in primary care and OB/GYN practices. Its general behavioral health integration support is the Primary Care Behavioral Health model, billed with code 99484. Blue Cross works through physician organizations, so ask the practice whether it belongs to a physician organization in the program. In August 2026 Blue Cross told us in writing that its limited-license restriction does not apply to the collaborative care and behavioral health integration codes, and that a limited-license provider can serve as the care manager. Michigan’s training institute for these programs says the same: “Any licensed (including limited licensed) professional with specialized mental health training can act as the BHCM.” Blue Cross says it follows the collaborative care model as the Medicare booklet describes it (CMS MLN909432). The practice must confirm your license, duties, training, and supervision. It is a defined team role, not therapy under another name, and it does not by itself decide which hours count toward your license.
No to all three? Then your next step is a conversation, not a form. Ask your employer, in writing, which of your patients use Blue Cross products. Ask what happens to your role after February.
Step 3. Do these four things this month (five minutes to start)
Count your Blue Cross patients by product (commercial PPO, BCN, Medicare Plus Blue, BCN Advantage).
Ask your billing lead to check the first September payment notice for the modifiers and the amount paid. It shows how a claim was paid, not your wage.
Ask your employer five questions, in writing.
Which patients are affected? What happens to my role and supervision after February 28? How does each patient continue care? Does my supervisor meet the state rule for counseling supervisors, and may I have the written statement of qualifications the rule requires before supervision starts (R 338.1781(3))? Will you keep the ongoing supervision records the rule requires for me (R 338.1781(4))?
03
Before you take a care-manager job, get your supervisor’s written agreement about which of your duties will count toward your hours.
We asked the state licensing bureau in writing whether care-manager hours count. They replied that they cannot give legal advice and pointed us to the Public Health Code and the counseling rules. The rule (R 338.1774(1)(c)) says what counts is the practice of counseling, in a listed setting, under a licensed professional counselor: for a master’s degree, 3,000 hours over at least two years with 100 hours of scheduled supervision. Your supervisor verifies the hours. The full guide has the rule in plain words.
04
Read the full guide before you decide.
It names what Blue Cross has said, what it has not said, and the questions still open.
What this sheet does not do
It does not tell you what is legal, covered, or payable in your case. It does not replace your employer, your board, or Blue Cross. It is a map of the dates and the paths, in plain words, so you know what to ask.
One open item: in August 2026 a professional association reported a possible accreditation accommodation for qualifying offices. The payer’s eligibility, approval, and billing terms have not been verified. This sheet does not rely on it.
Current through September 14, 2026. Full guide and updates: integrative-neuroscience.com/guides/where-do-i-stand-march-2027. Corrections: integrative-neuroscience.com/updates-and-corrections. Source: Center for Integrative Neuroscience, Limited-License Survival Guide, release candidate v1.8, sections 1, 2, 4, 7, and 8.