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CMS has asked, in its proposed physician payment rule, whether clinical AI tools could transform the Medicare annual wellness visit into a more continuous, data-driven preventive care function. The agency cites mixed evidence on the AWV’s outcomes and low uptake — about half of seniors use it. The final rule is expected around Nov. 1.
The Centers for Medicare & Medicaid Services (CMS) is asking whether the Medicare annual wellness visit (AWV) should become less physician-driven and more AI-driven, a question raised in the agency’s proposed physician payment rule issued this past summer and reiterated by a senior CMS official last Friday at the Health Datapalooza conference in Washington, D.C. The agency says evidence on the visit’s impact on health outcomes is mixed and that only about half of eligible seniors use it — and it is soliciting input on how AI tools, including those developed by technology companies, could reshape the visit. A final payment regulation is expected around Nov. 1.
In the proposed rule, CMS wrote that “evidence regarding the impact of the AWV on outcomes is mixed.” The agency noted that some studies have found the AWV is associated with increased use of preventive services but may not sufficiently close gaps in preventive care, while other studies found no substantive association between AWV adoption and improvements in evidence-based screening, acute care utilization, or spending — and possibly an increase in downstream low-value services.
Because of those mixed findings, CMS said it wants to know whether clinical AI tools could change the AWV from a single, point-in-time assessment into “a more continuous, data-driven, and beneficiary-specific preventive care function.” AI uses the agency pointed to include pre-visit collection of beneficiary-reported information such as the health risk assessment, identifying beneficiaries who may warrant additional assessment, and generating suggested follow-up steps for clinicians to review.
CMS also flagged a policy question: under current rules, the AWV must be performed by a physician or other health professional, or a team directly supervised by a Medicare-enrolled physician. The agency said it is “interested in what barriers — if any — these requirements create to innovative AWV delivery models in which an AI technology company develops or operates these clinical AI tools and affiliates with a Medicare-enrolled provider or supplier.” Stephanie Carlton, CMS’s deputy administrator and chief clinical AI officer, reinforced the point at Health Datapalooza: “Only about half the seniors use [the AWV], and we don’t have good evidence that it’s actually resulting in better outcomes,” she said. “That’s a huge opportunity for AI.”
Stakes for Seniors and Primary Care
The AWV is a cornerstone of Medicare’s preventive care benefit, and any change to how it is delivered would affect the roughly half of seniors who currently use it — and potentially the half who do not. If CMS ultimately allows AI-driven or AI-assisted delivery models, technology companies could gain a substantially larger role in Medicare preventive services, a shift with implications for care continuity, clinical accountability, and follow-up responsibility.
The proposal also signals CMS’s broader interest in embedding clinical AI into everyday Medicare services, a priority underscored by Carlton’s dual role as deputy administrator and chief clinical AI officer. Physicians’ groups warn that separating preventive care from a patient’s established primary care relationship could produce fragmented records, duplicative services, and inconsistent recommendations, while proponents argue AI could reduce administrative burden and expand access to underused preventive services.
How the AWV Works Now
The annual wellness visit is a Medicare benefit focused on prevention, including a health risk assessment, review of medical and family history, and screening for cognitive issues and other risks. Under current policy, as CMS stated in the proposed rule, it must be performed by a physician or other health professional, or a team of medical professionals directly supervised by a physician currently enrolled as a Medicare provider.
The current debate emerged from CMS’s annual physician payment rule, issued this past summer, which sets Medicare payment and policy for clinician services. The public comment period drew responses including a comment letter from the American Academy of Family Physicians (AAFP), whose members are among the clinicians who administer AWVs.
“Only about half the seniors use [the AWV], and we don’t have good evidence that it’s actually resulting in better outcomes. That’s a huge opportunity for AI.”
— Stephanie Carlton, CMS deputy administrator and chief clinical AI officer
Unresolved Questions in the Proposal
It is not yet clear whether the final rule, expected around Nov. 1, will adopt any specific AI-related changes to the AWV or simply continue gathering input. CMS framed its AI questions largely as requests for information about barriers and innovative delivery models rather than concrete policy proposals.
Key open questions include whether an AI technology company affiliated with a Medicare-enrolled provider could lawfully furnish parts of the AWV under existing supervision requirements; how clinical accountability and follow-up responsibility would be assigned; and what safeguards would apply to AI-generated assessments and recommendations. CMS has not said which AI tools, if any, it would endorse or how outcomes would be measured if the visit format changes.
Watching the Final Rule
CMS is expected to release the final physician payment regulation around Nov. 1, which should clarify whether the agency pursues AI-enabled AWV delivery models, delays action, or initiates further rulemaking or demonstration projects. Stakeholders including the AAFP, which has urged CMS to ensure any technology-enabled approach strengthens rather than bypasses the patient’s primary care team, will be watching how the agency balances innovation with continuity-of-care concerns.
Further CMS requests for information, pilot programs, or revised supervision rules could follow if the agency decides to move AI-driven wellness visit models forward.
Key Questions
Is Medicare replacing the annual wellness visit with AI?
No decision has been made. CMS raised the question in its proposed physician payment rule and asked for input on whether AI tools could make the AWV more continuous and data-driven. The final rule is expected around Nov. 1.
Who can currently perform a Medicare annual wellness visit?
Under current policy, according to CMS, the AWV must be performed by a physician or other health professional, or a team of medical professionals directly supervised by a physician enrolled as a Medicare provider.
Why does CMS want to change the wellness visit?
CMS says evidence on the AWV’s impact on outcomes is mixed and that only about half of eligible seniors use the benefit. The agency sees AI as a possible way to improve uptake and make preventive care more continuous.
What do doctor groups say about AI in the wellness visit?
The American Academy of Family Physicians supports using AI tools to identify patients, summarize information, and support documentation, but opposes models in which technology vendors or AI companies independently furnish significant portions of preventive care outside a patient’s primary care relationship, citing risks of fragmented and duplicative care.
What AI uses is CMS considering for the AWV?
CMS pointed to pre-visit collection of beneficiary-reported information such as the health risk assessment, identifying beneficiaries who may need additional assessment, and generating suggested follow-up steps for clinicians to review.
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