Medicare and Medicaid Programs; CY 2025 Payment Policies Under the Physician Fee Schedule and Other Changes to Part B Payment and Coverage Policies; Medicare Shared Savings Program Requirements; Medicare Prescription Drug Inflation Rebate Program; and Medicare Overpayments
The CY 2025 Physician Fee Schedule final rule includes changes to Medicare Part B payment policies, supervision requirements, and overpayment rules that affect medical spas and aesthetics clinics billing Medicare. Key changes: expanded scope of supervision for certain services, new coding for telehealth, and stricter overpayment identification and repayment timelines.
Aforeworn detected this change in the Med-Spa & Aesthetics Clinics space on July 6, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated High urgency. Medical spas and aesthetics clinics that bill Medicare for Part B services (e.g., physician-administered injections, laser procedures) or participate in Medicare Shared Savings Programs. should confirm how it applies to their specific situation before acting. There is a time constraint attached: Effective January 1, 2025. Overpayment rule changes effective immediately upon publication (December 9, 2024).. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Med-Spa & Aesthetics Clinics continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.
What changed
1) Supervision requirements for certain therapeutic services (e.g., incident-to billing) now require direct supervision by a physician or NPP. 2) New HCPCS codes for telehealth services (e.g., G0316-G0318) with specific billing rules. 3) Overpayment identification and repayment period reduced to 60 days from date of identification, with expanded definition of 'identified' overpayment.
Who it affects
Medical spas and aesthetics clinics that bill Medicare for Part B services (e.g., physician-administered injections, laser procedures) or participate in Medicare Shared Savings Programs.
What you must do
Review and update supervision policies for Medicare services; ensure compliance with new telehealth coding; implement processes to identify and repay overpayments within 60 days.
Deadline
Effective January 1, 2025. Overpayment rule changes effective immediately upon publication (December 9, 2024).
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