What Are Medicare AWV Requirements?
Quick Answer
Medicare Annual Wellness Visit (AWV) requirements include six mandatory components: (1) a completed Health Risk Assessment (HRA) questionnaire covering demographic data, self-assessed health status, psychosocial risks, behavioral risks, and activities of daily living; (2) a review and update of medical, surgical, and family history; (3) an updated list of current providers and suppliers; (4) a complete medication reconciliation including OTC drugs and supplements; (5) height, weight, BMI, blood pressure, and a cognitive function assessment; and (6) a personalized, written prevention plan with a screening schedule based on age, gender, and risk factors. The AWV is billed as G0438 (initial, ~$175) or G0439 (subsequent annual, ~$119) with zero patient cost-sharing. NPIxray data shows the national AWV completion rate is only 48.2%, meaning over half of eligible Medicare patients miss this free preventive service each year. Source: NPIxray analysis of 1.175M Medicare providers and 8.15M billing records.
Health Risk Assessment (HRA)
The HRA is the foundational document of every AWV. It must be completed by the patient (with staff assistance if needed) and reviewed by the provider. CMS requires the HRA to collect: demographic data (age, gender, race/ethnicity), self-assessment of health status and functional ability (ADLs and IADLs), psychosocial risk factors (depression screening, social isolation, elder abuse risk, home safety), behavioral risk factors (tobacco use, alcohol use, physical activity level, nutrition, seatbelt use, fall risk), and a list of current medications including OTC drugs, supplements, and herbal remedies.
Many practices mail or electronically send the HRA to patients 1-2 weeks before their scheduled AWV. This allows the patient to complete it at home, reduces in-office time, and ensures the provider has the completed questionnaire ready for review during the visit. EHR-integrated HRA templates make scoring and documentation efficient.
Medical and Family History Review
The provider must review and update the patient's medical history, surgical history, and family history at each AWV. For the initial AWV (G0438), this must be a comprehensive review including: past medical history (all diagnoses, hospitalizations, surgeries), family history (first-degree relatives with cancer, heart disease, diabetes, stroke, mental illness), and a complete review of organ systems.
For subsequent AWVs (G0439), this is an update of any changes since the last visit. Document new diagnoses, hospitalizations, procedures, and any changes in family health history. This review often uncovers screening opportunities — a new family history of colon cancer may indicate earlier screening, for example.
Cognitive Function Assessment
CMS requires a cognitive function assessment as part of every AWV. This can be an observation-based assessment (provider documents their observations of the patient's cognitive function during the visit) or a validated screening tool such as the Mini-Cog (3-item recall + clock drawing, takes 3 minutes), Montreal Cognitive Assessment (MoCA), or Saint Louis University Mental Status (SLUMS) exam.
The cognitive assessment serves dual purposes: it fulfills the AWV requirement and identifies patients who may benefit from further evaluation for cognitive impairment or dementia. Early detection of cognitive decline allows for care planning, caregiver support, and advance directive discussions while the patient can still participate in decision-making.
Personalized Prevention Plan
After completing the HRA and clinical assessments, the provider must create a written, personalized prevention plan. This plan must include: a screening schedule for the next 5-10 years based on USPSTF recommendations and the patient's risk profile, an updated list of identified risk factors and conditions, treatment recommendations and health education, referrals to appropriate preventive services (mammography, colonoscopy, lung cancer screening, etc.), and advance care planning discussion (optional but recommended and separately billable under 99497).
The prevention plan must be provided to the patient in writing. Many practices use EHR templates that auto-generate the prevention plan based on HRA responses, patient demographics, and the USPSTF screening recommendations database. This makes the plan creation process fast and consistent while ensuring no recommended screenings are missed.
What the AWV Is NOT
A critical compliance point: the AWV is NOT a comprehensive physical examination. The AWV focuses on risk assessment, screening, and prevention planning — not on diagnosing or treating acute or chronic conditions. Providers should not perform head-to-toe physical exams and bill them as AWVs.
However, if during the AWV the provider identifies or manages a medical problem, a separate E&M visit can be billed on the same day using modifier 25. For example, if the AWV screening reveals uncontrolled blood pressure and you adjust medications, bill G0439 (AWV) + 99214-25 (E&M for the BP management). This same-day combination is common and compliant when properly documented as two distinct services.
Frequently Asked Questions
Who can bill for an AWV?
The AWV can be billed by physicians (MD/DO), nurse practitioners (NP), physician assistants (PA), and clinical nurse specialists (CNS). A licensed clinical staff member can perform portions of the AWV (HRA review, vitals, medication reconciliation) under the supervision of the billing provider.
Can you bill an AWV for a new patient?
Yes. There is no requirement for an existing provider-patient relationship. However, CMS requires the patient to have been enrolled in Medicare Part B for more than 12 months to receive a subsequent AWV (G0439). The initial AWV (G0438) can be performed at any time after the IPPE eligibility period.
Is the cognitive assessment mandatory?
Yes. CMS lists cognitive function assessment as a required component of the AWV. It can be observation-based (provider documents their assessment of the patient's cognitive function) or use a validated tool like the Mini-Cog. Skipping the cognitive assessment puts the AWV claim at risk for denial upon audit.
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