TL;DR
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 policy requires a physician or other qualified professional to perform the visit, and the American Academy of Family Physicians says AI should support physician-led care.
The Centers for Medicare & Medicaid Services is asking whether clinical AI tools could make Medicare Annual Wellness Visits more continuous and tailored to beneficiaries, opening a policy discussion about how preventive care is delivered. CMS has not announced a new AI-based visit model: under current policy, a physician or other qualified health professional must perform the visit.
In its proposed physician payment rule, CMS said research on the effect of the Annual Wellness Visit (AWV) is mixed. Some studies associate AWV receipt with greater use of preventive services, but find that visits may not close care gaps. Other studies, the agency wrote, found no substantive association with improvements in evidence-based screening, acute care use or spending, and raised the possibility of more low-value services.
CMS asked whether AI could help shift the AWV from a single point-in-time assessment to a more continuous, data-driven and beneficiary-specific preventive care function. Possible uses named in the proposal include collecting beneficiary-reported information before a visit, identifying people who may need additional assessment, and generating follow-up suggestions for clinicians to review.
At the Health Datapalooza conference in Washington, D.C., the agency’s deputy administrator and chief clinical AI officer, Stephanie Carlton, also pointed to limited use and uncertain outcomes. She said about half of seniors use the AWV and that CMS lacks good evidence that the visits improve outcomes. Carlton called that gap an opportunity for AI. Her remarks describe the agency’s interest; they do not establish that AI improves health outcomes.
AI Could Change How Prevention Is Delivered
The proposal could affect how Medicare beneficiaries prepare for wellness visits and how clinicians identify preventive care needs. If AI tools gather information in advance or flag gaps for review, they may help care teams organize visits and follow-up. CMS is asking whether such tools could make prevention more tailored over time, but it has not established that they would improve outcomes or lower spending.
The policy question also reaches beyond software. CMS asked whether current requirements create barriers to models in which an AI company develops or operates tools and affiliates with a Medicare-enrolled provider or supplier. Any change in delivery arrangements could affect who handles information, makes recommendations and remains responsible for follow-up. The proposal asks for input on those barriers; it does not itself authorize vendors to provide AWVs independently.
For beneficiaries, the distinction matters because a wellness visit can address a person’s medical history, ongoing conditions, behavioral health and personal goals, not only a list of screenings. The American Academy of Family Physicians (AAFP) supports appropriate AI assistance, while warning that a model that separates preventive care from a patient’s established primary care team could create gaps in coordination and accountability.
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Current Rules Keep Clinicians in the Visit
Medicare’s AWV is a preventive service, and current CMS 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 framed its question around whether that requirement constrains innovative delivery models that use AI tools developed or operated by a technology company working with an enrolled provider or supplier.
The agency’s review comes amid disagreement about what the AWV has achieved. CMS cited studies pointing both to increased use of preventive services and to limited or absent improvements in screening, acute care use or spending. That mixed record is the stated reason for seeking input; it does not show that AI would resolve the shortcomings.
The AAFP said AI could help identify eligible patients, summarize health information, find preventive care gaps, support documentation and facilitate follow-up. The academy also argued that decisions about prevention need the context and trust built through an ongoing relationship with a physician-led care team. Its position supports assistance that strengthens that relationship and raises concerns about third parties independently furnishing significant portions of care.
“Evidence regarding the impact of the AWV on outcomes is mixed.”
— CMS proposed physician payment rule
Outcomes and Oversight Remain Open
No AI model has been adopted through the proposal, and the source material does not identify a specific system, vendor, pilot or implementation schedule. It is also unclear whether CMS will revise the existing clinician requirements or how any permitted arrangement would assign responsibility for clinical decisions, documentation and follow-up.
The effectiveness question remains unresolved. CMS described mixed evidence on AWVs, but the cited material does not provide evidence that AI use would improve preventive care, close gaps, reduce spending or avoid low-value services. The agency’s questions are requests for comment, not findings that AI can deliver those results.
It is also unclear how CMS would address risks identified by the AAFP, including fragmented records, duplicate services, inconsistent recommendations and uncertainty over who follows up. The academy’s statements are its policy concerns, not findings that a proposed CMS model has already caused those problems.
CMS Rule Will Set the Next Step
CMS was expected to issue the final physician payment regulation around Nov. 1, according to the report. The final rule will show how the agency responds to feedback about AI tools, provider affiliations and existing requirements for who performs an AWV. Until that regulation is available, the agency’s questions should be treated as a proposal-stage discussion.
For now, Medicare beneficiaries remain subject to the current AWV policy, and the source material does not announce any change to how they schedule or receive a visit. Further details about any AI-enabled model—including oversight, clinical accountability and safeguards for continuity—would depend on what CMS includes in the final rule or subsequent guidance.
Key Questions
Has CMS approved AI to conduct Medicare Annual Wellness Visits?
No. CMS is seeking feedback in a proposed payment rule. Current policy requires a physician or other qualified health professional to perform the visit.
What AI uses is CMS considering?
The proposal describes collecting beneficiary-reported information before a visit, identifying people who may need further assessment and generating follow-up suggestions for clinicians to review.
Does CMS say AI improves AWV outcomes?
No. CMS says the evidence on AWV outcomes is mixed and is asking whether AI could change how preventive care is delivered. The source material does not establish that AI improves outcomes.
What concerns has the AAFP raised?
The AAFP supports appropriate tools that assist care teams, but warns that separating preventive care from a patient’s primary care relationship could fragment records, duplicate services and leave follow-up responsibility unclear.
When could CMS clarify its approach?
The report said CMS was expected to release the final physician payment rule around Nov. 1. The final rule would clarify how the agency responds to comments; the material does not confirm its eventual contents.
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