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CMS is asking whether artificial intelligence should play a larger role in Medicare’s annual wellness visit, citing mixed evidence on the visit’s outcomes. The AAFP supports AI as a physician-support tool but opposes vendors independently furnishing preventive care. A final rule is expected around Nov. 1.
The Centers for Medicare & Medicaid Services is asking whether Medicare’s annual wellness visit (AWV) should become less physician-driven and more artificial intelligence-driven, according to the agency’s proposed physician payment rule issued this past summer. A final regulation is expected around Nov. 1, and the outcome could reshape how millions of seniors receive preventive care.
In the proposed rule, CMS wrote that although prevention is widely valued, “evidence regarding the impact of the AWV on outcomes is mixed.” The agency noted that some studies found AWV receipt is associated with increased use of preventive services but may not 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 tools that might be used 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 the current requirement that the AWV be performed by a physician or other health professional, or a team supervised by a Medicare-enrolled physician. The agency said it is interested in what barriers, if any, these requirements create for delivery models in which an AI technology company develops or operates the tools and affiliates with a Medicare-enrolled provider.
Stakes for Seniors and Primary Care
Only about half of seniors use the AWV, according to CMS’s Stephanie Carlton, and the agency says there is not good evidence the visit is producing better outcomes. CMS frames this gap as “a huge opportunity for AI” — an argument that could redirect how a core Medicare preventive benefit is delivered. If CMS allows AI companies a larger operational role, it could change who collects health information, who decides on follow-up care, and how accountable any given clinician is for a patient’s preventive needs.
For clinicians, the rule raises questions about administrative burden and care fragmentation. The American Academy of Family Physicians (AAFP), whose members administer many AWVs, warned that models letting technology vendors independently furnish significant portions of preventive care could produce fragmented records, duplicative services, and inconsistent recommendations, with unclear responsibility for follow-up.
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How the AI Question Reached the Rule
The proposal emerged from CMS’s summer physician payment rulemaking, in which the agency routinely solicits comment on payment and delivery questions. The AI language grew out of CMS’s own literature review concluding the evidence on AWV outcomes is mixed. Separately, Stephanie Carlton, CMS’s deputy administrator and chief clinical AI officer, reinforced the agency’s interest at the Health Datapalooza conference in Washington, D.C., saying the low uptake and uncertain outcomes of the AWV represent an opportunity for AI. The chief clinical AI officer role itself reflects CMS’s growing institutional focus on how AI should be deployed in Medicare and Medicaid programs.
“Evidence regarding the impact of the AWV on outcomes is mixed.”
— CMS, in the proposed physician payment rule
What the Final Rule Hasn’t Answered
Several questions remain open. CMS has only asked for input — it has not proposed a specific AI-driven AWV model, so whether the final rule adopts any change, and in what form, is not yet known. It is unclear whether CMS would allow AI companies to affiliate with Medicare-enrolled providers as a workaround to current supervision requirements, or how such arrangements would be regulated. The effectiveness and safety of AI tools in preventive care at scale also remain unproven, since the agency’s own evidence review focused on the traditional AWV. Whether higher AI involvement would actually improve outcomes, or instead add the low-value downstream services some studies have flagged, is unknown.
Watching for the November Final Rule
CMS is expected to release the final physician payment regulation around Nov. 1. Stakeholders will be watching whether the agency preserves the requirement that a physician or supervised team perform the AWV, or opens a pathway for AI-company-affiliated delivery models. AAFP and other physician groups are likely to continue pressing CMS to keep clinical accountability within physician-led care teams. If CMS proceeds with an AI-enabled AWV model, subsequent steps could include pilot programs, new billing rules, or guidance on vendor accountability — none of which has been proposed yet.
Key Questions
Has Medicare already approved AI for annual wellness visits?
No. CMS has only asked for public input on whether AI tools could reshape the AWV. Under current policy, the visit must still be performed by a physician, another health professional, or a physician-supervised team.
Why does CMS want to change the annual wellness visit?
According to the proposed rule, evidence on the AWV’s impact is mixed — some studies link it to more preventive services, others find no improvement in screening, acute care use, or spending. CMS also notes only about half of eligible seniors use the visit.
What AI tools is CMS considering?
CMS cited possibilities including pre-visit collection of patient-reported information for the health risk assessment, flagging beneficiaries who may need additional assessment, and generating suggested follow-up steps for clinicians to review.
What does the AAFP think of the proposal?
The AAFP conditionally supports AI tools that help identify patients, summarize information, and reduce administrative burden, but opposes models in which AI companies or other third parties independently furnish significant portions of preventive care outside a patient’s primary care relationship.
When will Medicare decide?
CMS is expected to issue the final physician payment regulation around Nov. 1. What the final rule says about AI and the AWV remains to be seen.
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