BCBS Policy Changes for Limited-Licensed Therapists at IEG

Access to affordable mental health care can be challenging. To find a therapist who is affordable, available, and a good fit takes time.  To build a safe therapeutic relationship requires effort, vulnerability, and trust. To lose that relationship due to insurance policy changes is unacceptable.

Next spring, BCBS intends to discontinue incident-to billing for limited-licensed therapists in non-facility private practices in Michigan. This change will impact some clients' access care and therapists' ability to build sustainable careers.

At IEG, we believe high-quality, consistent care and fair compensation for our therapists are inextricably intertwined. We cannot address access to care without considering the people who provide it.

What is changing?

Beginning March 1, 2027, Blue Cross, Blue Shield (BCBS) will no longer cover services provided by limited-licensed therapists in non-facility private practices in Michigan. Simply put, this targets most outpatient therapy offices and private practices, versus places like psychiatric facilities and hospitals.

The change applies to therapists with limited licenses (LLMSWs, TLLPs, LLMFTs, and LLPCs/LLCs). It does not affect fully licensed therapists (LMSWs, LLPs, LPs, LMFTs, and LPCs).

Client and Community Impact

Losing insurance coverage for a therapist could leave clients with the difficult choice between private pay, finding a new therapist, or reducing/pausing treatment. For people who have spent months or years building trust with their therapist, this can be devastating. Those who cannot afford additional costs or find another compatible provider may lose access entirely.

At IEG, we consider access to mental health care to be an issue of equity and social justice. Income, disability, location, and access to culturally responsive care all influence whether someone can find and afford a therapist. The BCBS incident-to policy shift and others like it reduce the number of accessible providers and risk making an already difficult situation worse, particularly in historically marginalized populations and communities.

Therapists, Licensure, and Compensation

We also consider what this means for therapists. Providing therapy is skilled, demanding work that requires years of education, ongoing training, supervision, and constant professional development. Therapists deserve to be paid fairly not only for their time and training, but also for the great responsibility to client and community that they carry. Insurance reimbursement is a major factor in gaining compensation, maintaining a practice, supporting a family, and continuing to serve the community.

Limited-licensed therapists are master's-level mental health professionals who are completing supervised hours required for full licensure. They provide meaningful care that meets the requirements of their profession. They have completed placements and internships prior to graduation to hone their skills and work under an approved supervisor who provides guidance and consultation. 

Restricting reimbursement for limited-licensed therapists will make it harder for these clinicians to maintain sustainable caseloads, complete their supervised hours, and remain in the profession. It could also reduce the number of providers available to people seeking care. At a time when so many already struggle to find mental health providers, we should be looking for ways to support growth of qualified clinicians, not create additional barriers.

We should not have to choose between affordable care for clients and fair compensation for therapists. Clients deserve access to care they can afford, and therapists deserve to make a living doing work that is valuable and necessary. These goals should support one another.

Who determines standards of care?

We also believe it is important to consider who should be making decisions about a therapist's professional qualifications. State licensing boards like NASW, APA, and ACA establish licensure requirements, set professional standards, and guide the profession. Insurance companies can determine what services they will reimburse, but they are not qualified to evaluate a therapist's competence to practice.  

We believe decisions that affect access to care should recognize the training, supervision, and professional oversight already in place. Insurance coverage decisions have real consequences for both the people receiving care and the professionals providing it.

What can you do?

Check your therapist's licensure status. If you're unsure whether your therapist is limited-licensed or fully licensed, ask them directly.  If you have BCBS and your therapist has an impacted license…

Contact BCBS. Ask how the policy change will affect your specific benefits.

Discuss alternatives. Work with your therapist to determine what next steps look like for you. This could include negotiating an affordable out-of-pocket fee with your current therapist, being referred to a fully licensed therapist within IEG, or us providing referrals for a fully licensed provider outside of IEG.

Not seeing someone at IEG yet? If you are considering therapy at IEG and use BCBS insurance, please be aware of this upcoming change. If you choose to work with a limited-licensed provider, an out-of-pocket fee will be discussed and agreed upon before services begin.

Raise your voice!

You can contact BCBS and ask that the decision be reconsidered. Hearing directly from people matters. Your experiences can help show how a change in coverage affects real people and their communities.

Call the customer service number on the back of your BCBS insurance card. Ask to have your concerns documented and forwarded to the appropriate department.

Go online to the BCBS Customer Action Center.

Send a letter to:

Blue Cross Blue Shield of Michigan 600 E. Lafayette Blvd. Detroit, MI 48226

Explain why your current therapist is important to you, what losing insurance coverage would mean for your ability to continue treatment, and how this policy affects others in your community. Request that they reconsider and reverse their decision to end incident-to reimbursement for limited-licensed therapists.

Our Commitment

At IEG, we believe everyone deserves access to quality mental health care, regardless of their financial circumstances. We also believe the people providing that care deserve to be respected, supported, and fairly compensated. We remain committed to investing in the professional growth of our limited-licensed clinicians through referrals, consultation, and ongoing support. We believe this investment benefits everyone, from the clinicians themselves to our practice and the broader community. Supporting their development brings diverse perspectives into our practice, strengthens our field, and ultimately helps build a healthier community.

There has been significant opposition to this policy from across the state, including legal challenges and coordination with state officials. We are following these developments and will share updates as we learn more.  

We hope BCBS will reconsider this decision and recognize the impact it could have on the people who rely on mental health services and the professionals who provide them.

If you have questions about how this change may affect your care, please contact your therapist.

Note: Thank you to all of the leaders and providers on the Advocating for Therapists in Michigan Facebook group.  You have all provided much more clarity around these issues than BCBS ever could, thank you for the transparency and advocacy!