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CMS is asking whether clinical AI tools could help make Medicare Annual Wellness Visits more continuous and tailored to beneficiaries. The agency has not proposed replacing clinicians: current policy requires a physician or other qualified health professional, or a supervised medical team, to perform the visit. The final physician payment rule is expected around Nov. 1.
The Centers for Medicare & Medicaid Services is asking whether clinical AI could help reshape Medicare Annual Wellness Visits, which CMS says are used by only about half of seniors. The agency is seeking input through its proposed physician payment rule on whether AI could make preventive care more continuous and tailored, while current policy still requires a physician or other medical professional, or a team directly supervised by a physician, to perform the visit.
CMS raised the question because evidence on the visit’s effects is mixed, according to the proposed rule. The agency said some studies associate receiving an AWV with greater use of preventive services, but suggest the visits may not close preventive care gaps. Other studies found no substantive association with improved evidence-based screening, acute care use or spending, and some suggested visits could increase downstream low-value services.
CMS said it wants to know whether clinical AI could move the AWV from a single point-in-time assessment toward a “more continuous, data-driven, and beneficiary-specific preventive care function.” Possible uses include collecting beneficiary-reported information before a visit, identifying people who may need further assessment and generating suggested follow-up steps for clinicians to review. These are examples for consideration, not announced features of a new Medicare service.
At the Health Datapalooza conference in Washington, D.C., CMS Deputy Administrator and Chief Clinical AI Officer Stephanie Carlton made a similar case. She said about half of seniors use the visit and that evidence it improves outcomes is limited. CMS also asked whether existing provider requirements create barriers to models in which an AI company develops or operates tools and affiliates with a Medicare-enrolled provider or supplier. The agency has not said it will change those requirements.
Keeping Prevention Connected to Primary Care
The policy question could affect how preventive care is organized for Medicare beneficiaries. If AI helps collect information, flag possible care gaps or support documentation, clinicians may have more capacity for follow-up and coordination. CMS has framed these tools as a possible way to make prevention more continuous, rather than an encounter limited to one annual appointment.
The American Academy of Family Physicians supports careful use of AI for tasks such as identifying eligible patients, summarizing health information, documenting care gaps and facilitating follow-up. It says those uses could reduce administrative work and give physician-led teams more time for coordinated care. The academy also cautions that an AWV involves a patient’s medical history, chronic conditions, behavioral health, personal circumstances and health goals—not just a checklist.
That distinction matters because a tool’s usefulness depends on who reviews its output and who is responsible for acting on it. AAFP says preventive decisions belong within an ongoing relationship with a physician-led team. If technology improves access while weakening continuity or leaving follow-up responsibility unclear, the model could create new gaps even as it addresses existing ones.
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The Current Rules for AWVs
Medicare’s Annual Wellness Visit is a preventive care service. Current CMS policy requires it to be performed by a physician or other health professional, or by a team of medical professionals directly supervised by a physician who is enrolled as a Medicare provider. CMS’s request for input concerns whether that framework presents barriers to technology-enabled delivery models, including arrangements involving AI companies and enrolled providers or suppliers.
The question appears in a proposed physician payment rule issued this summer. CMS cited uncertainty about whether AWVs improve outcomes as a reason to seek views on possible AI uses. Its examples focus on gathering information before the visit, identifying beneficiaries who may need additional assessment and offering suggested steps for a clinician to consider.
AAFP’s comment letter argues that an AWV should remain integrated with a patient’s established primary care relationship. The academy warned that separating preventive services from a patient’s primary care physician could lead to fragmented records, duplicated services, inconsistent recommendations and uncertainty about follow-up. These are concerns raised by the academy, not findings CMS has adopted as conclusions about any proposed model.
“Evidence regarding the impact of the AWV on outcomes is mixed.”
— CMS proposed physician payment rule
Who Would Perform and Own Follow-Up
CMS has not announced a final policy or described a specific AI-enabled AWV model it intends to approve. It remains unclear whether the agency will revise provider requirements, how any affiliation between an AI company and a Medicare-enrolled provider would work, or what clinical tasks such a company could perform.
The source material also does not identify particular AI products, explain how their suggestions would be evaluated, or say how responsibility for reviewing recommendations and arranging follow-up would be assigned. CMS has asked whether current rules create barriers; that question does not itself establish that the agency plans to remove clinician oversight.
Evidence about AWV outcomes remains contested in the rule’s description. The cited studies point to differing results, and CMS has not provided a settled conclusion that AI would improve outcomes. AAFP’s concerns about fragmented care are the academy’s position in its comment letter.
Final Rule Expected Around Nov. 1
CMS is expected to release the final physician payment regulation around Nov. 1. That rule will show how the agency responds to comments on AI-supported AWVs and whether it changes, clarifies or leaves current provider requirements in place. Until then, the possible uses outlined by CMS remain questions for consideration rather than adopted policy.
For beneficiaries and clinicians, the key details to watch are whether any final approach keeps visits under qualified clinical responsibility, how AI-generated suggestions would be reviewed, and who would be accountable for follow-up. The available source material does not specify when any new model could begin or whether CMS will authorize a separate delivery pathway.
Key Questions
Has Medicare approved AI-run Annual Wellness Visits?
No approval is described. CMS is seeking input on possible AI uses in a proposed rule. Current policy requires a physician or other health professional, or a directly supervised medical team, to perform the visit.
What AI tasks is CMS considering?
CMS cited collecting beneficiary-reported information before a visit, identifying people who may need further assessment and generating suggested follow-up steps for clinicians to review.
Why is CMS asking about AI?
CMS says evidence on AWV outcomes is mixed and that about half of seniors use the visit. It is asking whether AI could support more continuous and beneficiary-specific preventive care.
What concerns has the AAFP raised?
The AAFP supports some AI assistance but says preventive care should remain connected to a patient’s physician-led team. It warns that separating care from that relationship could fragment records and make follow-up responsibility unclear.
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