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CMS has proposed exploring whether clinical AI tools could make Medicare Annual Wellness Visits more continuous and tailored to beneficiaries. The agency has not proposed removing the requirement for a Medicare-enrolled clinician, and the final payment rule is expected around Nov. 1.
The Centers for Medicare & Medicaid Services is asking whether clinical AI tools could make Medicare Annual Wellness Visits more continuous and tailored to beneficiaries, as the agency weighs changes in its proposed physician payment rule. The proposal opens discussion about how AI might support prevention, while current policy still requires the visit to be performed by a Medicare-enrolled clinician or a supervised medical team.
CMS cited mixed evidence on whether the Annual Wellness Visit (AWV) improves health outcomes. The agency said some studies link AWV receipt with greater use of preventive services, but those visits may not close gaps in care. Other studies found no substantive association with improved evidence-based screening, acute care use or spending, and suggested a possible increase in downstream low-value services.
In response, CMS asked whether AI could help shift the AWV from a single, point-in-time assessment to what it described as a more continuous, data-driven and beneficiary-specific preventive care function. Potential uses include gathering patient-reported information before a visit, flagging people who may need further assessment, and preparing suggested follow-up steps for a clinician to review. These are areas CMS is considering; the proposal does not establish that such tools are already part of routine Medicare visits.
CMS Deputy Administrator and Chief Clinical AI Officer Stephanie Carlton said at the Health Datapalooza conference in Washington, D.C., last Friday that about half of seniors use the AWV and that evidence of better outcomes is limited. She described the situation as an opportunity for AI. The agency also asked whether current rules create barriers to models in which an AI company develops or operates tools and affiliates with a Medicare-enrolled provider or supplier.
AI Could Change Preventive Care Follow-Up
The discussion could affect how clinicians identify preventive care needs and organize follow-up for people with Medicare. If AI tools help collect information before appointments or flag gaps for review, care teams may have more time to discuss a patient’s needs. That possibility matters because CMS says AWV use is limited and the evidence linking the visits to better outcomes remains mixed.
The delivery model will also shape who is responsible for interpreting information and acting on it. The American Academy of Family Physicians (AAFP) supports appropriate AI assistance with tasks such as summarizing health information and supporting documentation, but says an AWV must account for a patient’s medical history, behavioral health, circumstances and goals. The academy argues that decisions require an ongoing relationship with a physician-led care team. The policy question is therefore not only whether AI can assist with tasks, but how its use fits into accountable, coordinated care.
Current Rules Keep Clinicians Involved
Medicare’s AWV is a preventive visit, and current policy requires it to be performed by a physician or another health professional, or by a team of medical professionals directly supervised by a physician enrolled as a Medicare provider. CMS’s proposal asks whether those requirements create barriers to new delivery models, including arrangements in which technology firms supply or operate clinical AI tools in partnership with enrolled providers.
The agency’s request follows uncertainty about what AWVs achieve in practice. CMS acknowledged that some research finds greater use of preventive services after a visit, while other findings do not show substantive improvements in screening, acute care use or spending. The proposed rule asks for input on whether AI could address limitations in the current approach; it does not establish that AI will improve outcomes or specify a new model for delivering the visits.
“Evidence regarding the impact of the AWV on outcomes is mixed.”
— CMS proposed physician payment rule
How AI Would Fit Into Visits
CMS has not specified which AI tools, if any, it will support in a final rule, or how a tool’s suggestions would be reviewed and acted on. It is also unclear whether the agency will change any requirements governing clinician supervision or third-party involvement. The proposal does not establish that AI improves AWV outcomes, resolves preventive care gaps or reduces spending.
The AAFP has warned that separating preventive care from a patient’s established primary care team could lead to fragmented records, duplicate services, inconsistent recommendations and unclear follow-up responsibility. How CMS would address those concerns in any technology-enabled model remains unsettled.
Final Payment Rule Due Around November
CMS is expected to issue the final physician payment regulation around Nov. 1. That rule will show how the agency responds to comments on AI-supported AWVs, including questions about provider affiliations and the role of Medicare-enrolled clinicians. Until it is released, the scope of any policy change remains unknown.
For clinicians and beneficiaries, the practical details to watch are whether CMS authorizes new delivery arrangements, what responsibilities stay with the care team, and how suggested follow-up would be coordinated with a patient’s existing records and care. The source material does not say when any approved model would begin or whether CMS will set specific safeguards for AI use.
Key Questions
Has CMS approved AI for Medicare Annual Wellness Visits?
No. CMS has asked for input in a proposed physician payment rule. The source material does not report a final approval or a required AI tool.
What could AI do during an Annual Wellness Visit?
CMS identified possible uses such as collecting beneficiary-reported information before a visit, flagging people who may need further assessment, and suggesting follow-up steps for clinicians to review.
Would a clinician still have to be involved?
Under current policy, an AWV must be performed by a physician or other health professional, or a medical team directly supervised by a physician enrolled as a Medicare provider. CMS is asking whether those rules create barriers to new models.
Why is CMS considering changes?
The agency says AWV use among seniors is limited and research on the visits’ effects is mixed. Some studies find increased use of preventive services, while others do not find substantive improvements in several measured outcomes.
When will CMS make its decision?
The final physician payment regulation is expected around Nov. 1. The source material does not specify when any new approach might take effect.
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