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CMS has asked whether clinical AI tools could make Medicare annual wellness visits more continuous and tailored to beneficiaries. The agency has not proposed replacing clinicians: current rules require a physician or other qualified health professional, or a supervised medical team, to perform the visit. The final payment rule is expected around Nov. 1.
The Centers for Medicare & Medicaid Services is asking whether artificial intelligence could help reshape Medicare’s annual wellness visit, a preventive-care appointment used by about half of seniors, according to CMS deputy administrator Stephanie Carlton. The agency is seeking feedback through its proposed physician payment rule on whether AI could make the visit more continuous and tailored to beneficiaries; current policy still requires a clinician or supervised medical team to perform it.
CMS says evidence on the impact of the annual wellness visit, or AWV, is mixed. In the proposed rule, the agency wrote that some studies associate AWV receipt with greater use of preventive services, but suggest the visits may not close preventive-care gaps. Other studies, CMS said, found no substantive association with improvements in evidence-based screening, acute-care use or spending, and some suggest a potential increase in downstream low-value services.
Against that backdrop, CMS wants to know whether clinical AI could move the AWV beyond a single point-in-time assessment toward what it described as 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.
CMS also asked whether current requirements create barriers to new delivery models in which an AI technology company develops or operates clinical tools and affiliates with a Medicare-enrolled provider or supplier. The agency emphasized that under current policy, the visit 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.
Keeping AI Within Primary Care
The discussion could affect how preventive care is organized for Medicare beneficiaries, including how practices gather health information, identify care gaps and manage follow-up. If used as support for clinicians, AI tools could help care teams handle administrative work and spot needs that merit attention. CMS has not established that these tools improve health outcomes, however, and its questions in the proposed rule do not amount to a decision to authorize a particular model.
The American Academy of Family Physicians supports thoughtful AI use for tasks such as identifying eligible patients, summarizing health information, supporting documentation and facilitating follow-up. It cautions that an AWV involves more than completing screening checklists: clinicians consider a patient’s medical history, chronic conditions, behavioral health needs, circumstances and long-term goals.
The policy question is therefore not only whether AI can assist with parts of the visit, but how responsibility and continuity would work. The AAFP says separating preventive-care activities from a patient’s primary-care team could lead to fragmented records, duplicate services, inconsistent recommendations and uncertainty about follow-up. Those concerns matter to patients and clinicians if CMS considers models involving outside technology companies.
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How CMS Framed the Proposal
The AWV is a Medicare preventive service, and CMS says existing policy assigns its performance to a physician or other health professional, or a medical team under direct physician supervision. The proposed rule asks for input on whether those requirements impede innovative delivery arrangements involving AI tools developed or operated by companies affiliated with Medicare-enrolled providers or suppliers.
At the Health Datapalooza conference in Washington, D.C., Carlton restated the agency’s interest in the visit’s reach and results. She said about half of seniors use the AWV and that CMS does not have good evidence it is resulting in better outcomes. Her remarks describe the agency’s rationale for exploring AI; they do not establish that AI would increase participation or improve outcomes.
The AAFP’s comments reflect a conditional position: it supports tools that strengthen physician-led care teams, while opposing models that would let vendors or other third parties independently furnish significant portions of preventive care outside a patient’s established primary-care relationship.
“Evidence regarding the impact of the AWV on outcomes is mixed.”
— CMS proposed physician payment rule
Outcomes and Oversight Questions
CMS has not said whether it will change AWV requirements, approve a specific AI-supported delivery model or permit technology companies to furnish parts of preventive care independently. The proposed rule asks about potential barriers and approaches; the agency’s final policy remains pending.
It is also unclear whether AI-supported workflows would increase AWV use, close preventive-care gaps, improve health outcomes or affect spending. CMS cited mixed evidence on the visit itself, and the source material provides no outcome data showing that AI tools resolve those limitations. The safeguards, clinical accountability and follow-up arrangements for any future model have yet to be set out.
Final Rule Expected in November
CMS is expected to release the final physician payment regulation around Nov. 1. That rule will show how the agency responds to feedback on AI-supported AWVs, including questions about clinician oversight and affiliations between technology companies and Medicare-enrolled providers. Until then, the proposal remains a request for input, and current clinician performance and supervision requirements remain in effect.
Key Questions
Has CMS approved AI-run Medicare wellness visits?
No. CMS is asking for feedback on AI tools and possible delivery models in a proposed rule. Current policy requires a physician or other health professional, or a directly 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 the visit, identifying people who may need additional assessment and suggesting follow-up steps for clinicians to review.
Does CMS say AI will improve outcomes?
No. CMS said evidence on AWV outcomes is mixed. The source material does not establish that AI tools improve outcomes, increase participation or close preventive-care gaps.
What concerns has the AAFP raised?
The American Academy of Family Physicians supports AI that assists physician-led teams but warns that care outside an established primary-care relationship could fragment records, duplicate services and make follow-up responsibility unclear.
When will CMS make its next decision?
CMS is expected to issue the final physician payment regulation around Nov. 1. The final rule will clarify how the agency addresses the questions raised in its proposal.
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