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CMS has asked whether clinical AI tools could make Medicare Annual Wellness Visits more continuous and tailored to beneficiaries, as part of its proposed physician payment rule. The agency has not proposed replacing clinicians: current policy requires a physician or other qualified health professional, or a supervised team, to perform the visit. Physician and geriatrics groups support some administrative uses but warn against separating preventive care from an ongoing care relationship.
Federal health officials are weighing whether clinical AI tools could help reshape Medicare’s Annual Wellness Visit from a one-time assessment into more continuous, tailored preventive care. The Centers for Medicare & Medicaid Services raised the question in its proposed physician payment rule, while leaving the visit’s current clinician requirements in place and seeking input on possible delivery models.
CMS said the evidence on whether the AWV improves health outcomes is mixed. In the proposed rule, the agency wrote that some studies associate the visit with greater use of preventive services, but find that it may not close care gaps. Other studies, CMS said, found no substantive link with improvements in evidence-based screening, acute care use or spending, and suggested the visit could be associated with more low-value services.
The agency asked whether AI could help make preventive care more continuous, data-driven and specific to each beneficiary. Potential uses include collecting patient-reported information before an appointment, identifying people who might need additional assessment, and generating follow-up suggestions for clinicians to review. CMS Deputy Administrator and Chief Clinical AI Officer Stephanie Carlton also pointed to low use and uncertain outcomes as reasons to explore the technology.
CMS emphasized that existing policy requires an AWV to be performed by a physician or other health professional, or by a team of medical professionals directly supervised by a physician enrolled as a Medicare provider. The agency is asking whether those rules create barriers to models in which an AI company develops or operates tools in affiliation with a Medicare-enrolled provider or supplier. The proposal does not establish that such a model will be adopted.
AI Could Change How Prevention Is Delivered
The debate concerns how Medicare beneficiaries receive preventive care and who remains accountable for it. AI-assisted intake or documentation could give clinical teams more time to identify care needs and coordinate follow-up, if the tools fit into existing care. That could matter for older adults who do not currently use the AWV or whose preventive care needs are not addressed during a single appointment.
But the same design choices raise questions about continuity and responsibility. If a vendor-run process operates apart from a patient’s usual primary care team, clinicians may have difficulty seeing which screenings were completed, reconciling recommendations or ensuring follow-up. The groups commenting to CMS argue that technology should support a trusted care relationship rather than fragment it.
The practical effects will depend on what CMS ultimately permits, how any AI tools are evaluated, and whether providers can integrate their outputs into care. The source material does not establish that AI would improve outcomes, increase AWV use or reduce clinician workload.
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Why CMS Is Reviewing the Visit
The AWV is a Medicare preventive service, and CMS’s proposed physician payment rule is the venue for considering changes to policies that govern physician services and payment. The agency’s stated interest follows uncertainty about whether the visit, as delivered, translates into better outcomes. It is exploring whether AI could help connect information gathering and follow-up more effectively.
The American Academy of Family Physicians (AAFP) said it supports thoughtful AI use for tasks such as identifying eligible patients, summarizing health information, finding preventive care gaps, supporting documentation and facilitating follow-up. It also said an AWV involves a patient’s medical history, chronic conditions, behavioral health, circumstances and long-term goals, and that decisions in that context depend on an ongoing relationship with a physician-led team.
The American Geriatrics Society likewise said technology could simplify data collection and support shared goal-setting, while describing the relationship with a practitioner’s care team as the visit’s central value. It recommended linking any such services to continuity-of-care practices. The society said it was not aware of technology-driven “AWV mills” and did not recommend new requirements for these services at this time.
“The agency wants to know whether AI could change the AWV into “a more continuous, data-driven, and beneficiary-specific preventive care function.””
— CMS proposed physician payment rule
How Any AI Model Would Be Governed
No final policy has been announced. CMS has asked whether current provider and supervision requirements create barriers to models involving AI companies, but the supplied material does not specify what regulatory changes, if any, the agency may make. It is also unclear what safeguards or oversight would apply to AI-generated assessments and suggested follow-up.
The evidence CMS cited is mixed, and the source material does not identify a particular AI tool or report clinical results from an AI-enabled AWV program. It remains uncertain whether these tools would increase participation or improve preventive care outcomes. The AAFP and geriatrics society describe potential benefits and risks, not measured results from an implemented model.
Final Medicare Rule Expected in November
CMS is expected to issue the final physician payment regulation around Nov. 1, according to the source report. The final rule will show how the agency responds to comments on AI-supported wellness visits and whether it changes or clarifies the existing delivery requirements. Until then, the proposal remains a request for input, and AWVs continue to be subject to current policy.
Key Questions
Has Medicare approved AI-run wellness visits?
No. CMS raised questions in a proposed rule, but has not announced a new AI-run visit model. Current policy requires a physician or other health professional, or a supervised medical team, to perform the AWV.
What might AI do during an Annual Wellness Visit?
CMS listed possible uses such as collecting beneficiary-reported information before a visit, identifying people who may need more assessment and generating follow-up suggestions for clinicians to review.
Why are physician groups cautious?
The AAFP and American Geriatrics Society support some technology uses but stress that preventive care should remain connected to an ongoing relationship with a patient’s care team. They raise concerns about fragmented records, duplicate services and unclear follow-up responsibility.
When will CMS make its decision?
The final physician payment regulation is expected around Nov. 1. The source material does not say what decision CMS will make on AI-enabled AWV models.
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