By Daniel R. Walworth, Christopher H. Casey, Frederick R. Ball, Erin M. Duffy and Arti Fotedar
The Centers for Medicare & Medicaid Services (CMS) issued a Final Rule as part of the 2025 Physician Fee Schedule, which revises requirements for reporting and returning overpayments of Medicare and Medicaid funds. The Final Rule, which took effect January 1, 2025, amends CMS’s regulation interpreting the federal overpayment statute in two key ways: It revises the definition of when an overpayment is “identified” to trigger the 60-day return period and establishes a 180-day timeframe for investigating additional related overpayments.