CMS Asks If AI Belongs in Wellness Visits. The Answer Is Complicated. Obviously.

CMS is soliciting public input on whether AI should collect patient data before Medicare Annual Wellness Visits, identify beneficiaries needing additional assessment, and generate suggested follow-up steps for clinicians to review. Current policy requires the AWV to be performed by a physician or health professional, or a team directly supervised by a physician enrolled as a Medicare provider. CMS specifically asked what barriers these requirements create for AI technology companies developing or operating clinical AI tools for the AWV.

The mechanism at play is regulatory friction against workflow automation. CMS cannot simply let an AI tool perform a clinical function because Medicare law requires physician supervision. The interesting question is whether AI can reduce the administrative burden enough to matter while staying inside the guardrails. The mental model: regulation constrains deployment speed, but well-designed AI can still compress the non-clinical portions of a visit without crossing the line into practicing medicine.

CMS, the Centers for Medicare and Medicaid Services, issued the inquiry into AI use during Annual Wellness Visits. The agency named three specific AI functions: pre-visit health risk assessment collection, flagging beneficiaries for additional assessment, and generating follow-up suggestions for clinician review.