Who can perform an Annual Wellness Visit?

When the Centers for Medicare and Medicaid (CMS) designed the Medicare Annual Wellness Visit program, they kept in mind potential challenges that practices could face. On one hand, they knew that asking practices to consider a new program may be overwhelming. Limited staff and time could pose potential barriers to entry for the program. On the other hand, CMS realized the potential impact that the Annual Wellness Visit (AWV) program could have on patient outcomes and overall healthcare spending in the future. That’s why, to meet their audiences’ needs and offer the program as widely as possible, they made the requirements for performing an AWV flexible and simple. 

Staff Requirements

The first area where CMS provided flexibility for AWVs is in regards to the staff requirements. Practices do not need to hire additional staff to have an AWV program. They can choose from a variety of their existing staff members to assist with the program, and not just their physicians. CMS did not want to create restrictions and tasks for specific team members. Rather, Medicare Part B will cover the AWV as long as it is performed by*:

  • A Physician (doctor of medicine (MD) or osteopathy (DO))
  • A Physician Assistant
  • A Nurse Practitioner
  • A Certified clinical nurse specialist or
  • A medical professional or team of professionals under direct supervision of a physician (This includes health educators, nutrition professionals, registered dietitian or other licensed practitioners)

The initial AWV, also known as the Initial Preventive Physical Examination (IPPE), has a few more staff restrictions than the Annual Wellness Visit, but still has some flexibility. The IPPE is covered by Medicare Part B if it is conducted by: 

  • A Physician (doctor of medicine (MD) or osteopathy (DO)) or
  • A Physician Assistant
  • A Nurse Practitioner
  • A Certified clinical nurse specialist

This flexibility prevents practices from having to rely on their physician’s time, which is often stretched thin. Instead, it allows physicians to focus their attention on more urgent physical exams and diagnosing, rather than preventive care.

Practice Requirements

Primary care providers are not the only type of provider who can bill for this preventative service. Certain speciality practices, such as cardiology and neurology, can also bill for AWVs. One important factor to keep in mind is that only one provider can bill for a patient’s AWV each year. So, if a primary care provider bills for an AWV, and then a specialist tries to bill an AWV for the same patient one week later, the specialist’s reimbursement will be denied. That’s why it is crucial to have a real-time system in place to check patient eligibility.  

The Health Risk Assessment

When it comes to the bulk of the work completed during an Annual Wellness Visit, the majority is completed by the actual Medicare patient during the health risk assessment (HRA). Completely on their own, the patient can fill out answers to questions that assess things like their medical history, functional ability, cognitive impairment, and overall health status. The responses to the questionnaire will identify risk factors and help generate a personalized prevention plan that the patient can review and share with their current providers. 

The COVID-19 pandemic has added additional flexibility for AWVs. During the public health emergency, AWVs are permitted to be conducted via telehealth. This approach does require the health care provider to assist with the HRA, but does not require an in-person visit. To bill for a remote AWV, it must be accompanied by modifier -95. Note that only the subsequent AWV has been approved for telehealth, not the IPPE. 

CMS has tried to remove potential barriers to the AWV program so that more practices are willing to offer it. Loose staff requirements, practice requirements, and flexibility with the health risk assessment make the program attainable. So why aren’t more practices utilizing this preventive program? The problem lies with the way individual practices choose to conduct the workflow of their program. Not every workflow is efficient or effective, and CMS does not define a specific way to run the program, which leads to a variety of failed attempts. Thankfully, ChartSpan has built a workflow with proven success. For more information on how to optimize an Annual Wellness Visit program, visit https://www.chartspan.com/solution/annual-wellness-visits/.

*https://www.cms.gov/outreach-and-education/outreach/npc/downloads/ippe-awv-faqs.pdf

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