Policy and primary care
AI and the Medicare Annual Wellness Visit: Caesar Health’s Recommendations to CMS
Caesar Health · September 11, 2026
By Shoukri Kattan, Chief Executive Officer, Caesar Health, Inc.
An Annual Wellness Visit can identify a concern. The next question is whether that concern leads to appropriate care.
That is the central argument in the comment Caesar Health submitted to the Centers for Medicare & Medicaid Services on September 11, 2026. We recommend testing clinician-supervised AI that prepares the visit, makes findings easier to review, and tracks the work that follows. More completed visits or more detailed notes should not, by themselves, count as evidence of better health outcomes.
Read our submitted comment — PDF, 5 pages.
What CMS asked
The CY 2027 Physician Fee Schedule proposed rule, CMS-1848-P, includes a Request for Information on technology and AI augmentation in primary care through the Medicare Annual Wellness Visit. Its eight questions cover current and potential uses of AI, activities requiring clinician involvement, barriers to adoption, payment policy, evaluation and information sharing. Our submitted letter addresses each question. View the proposed rule and docket.
An AWV includes a Health Risk Assessment and a personalized prevention plan. It is distinct from a routine physical examination. That distinction matters: the purpose is to identify risks and plan prevention, and the work around that plan deserves attention. CMS Medicare Wellness Visits guidance.
Our recommendation: connect findings to follow-through
We propose a workflow in which AI prepares information and tracks assigned work, while the responsible health professional makes clinical decisions.
| Stage | What we recommend testing | What remains with the care team |
|---|---|---|
| Before the visit | Collect the Health Risk Assessment through accessible channels and organize findings for review. | Verify information and preserve telephone, staff-assisted and caregiver-supported options. |
| During the visit | Present positive findings alongside relevant chart evidence. | Interpret findings, decide on assessments or referrals, and validate the prevention plan. |
| After the visit | Track clinician-approved orders and referrals and surface unresolved items at later touchpoints. | Decide what care is appropriate and document completion, patient declination or a clinically justified disposition. |
Consider a patient who reports a new memory concern. A completed questionnaire records that concern. A useful workflow also makes it visible to the clinician, records the clinician’s decision, and tracks any agreed next step. Marking the task “closed” is not the same as the patient receiving the recommended care.
This is a policy and workflow proposal. Our submission does not establish that AI-enabled AWVs improve outcomes, and we do not present it as evidence of a proven Caesar product outcome. The hypothesis needs prospective evaluation.
Preserve clinical responsibility and test payment changes first
We support preserving Medicare’s furnishing, enrollment and supervision requirements. Software should not take over clinical accountability or create a route for technology companies to bill AWV-related services directly.
Our comment asks CMS to examine the incremental resources required for pre-visit preparation and post-visit follow-through. We propose testing a bounded payment pathway through a demonstration or Innovation Center model, with billing by the enrolled provider and safeguards against paying twice for work already included in another service.
This proposed payment pathway is a recommendation to CMS, not an available new billing code or an adopted Medicare policy. Broader changes should follow evidence of benefit, resource needs and program integrity.
Measure what happens after the assessment
AWV access, completion and documentation quality remain useful measures. Our recommendation is to evaluate them alongside what happens after a positive finding:
- Was there an appropriate clinician-reviewed assessment, order, referral or documented disposition within a risk-appropriate period?
- Were recommended orders and referrals actually completed?
- Did patient-reported outcomes improve in the relevant area?
- Were there errors, unnecessary tests, duplicate visits, unsupported diagnoses or unequal access?
Patient declinations and clinically justified closure should be reported separately from delivered care. Urgent findings also need faster action than nonurgent concerns; one universal follow-up deadline would miss that distinction.
Make eligibility and unresolved findings easier to use
Our letter recommends authorized eligibility verification through CMS’s HIPAA Eligibility Transaction System, or HETS, with the relevant access and permitted-use safeguards. Missing eligibility information should trigger further verification, rather than an assumption that a beneficiary is due for a visit.
We also recommend keeping findings as structured information with a visible status: recommended, approved, ordered, scheduled, completed, declined or clinically closed. This would let the practice see what remains unresolved across the year, instead of searching through a past visit note.
For practices evaluating technology, the operational question is concrete: can the care team see the finding, its owner, the agreed action and what happened next? Our perspective on a clinic operating system describes the broader coordination problem; the CMS comment applies that perspective to preventive care.
How this relates to our joint work with PCP1st
The letter explicitly references AI-Enabled Annual Wellness Visits: Closing the Loop from Risk Detection to Delivered Care, the white paper PCP1st and Caesar Health jointly submitted to the CMS CCSQ QualTech 2026 showcase on September 3, 2026.
The joint paper describes the workflow. The September 11 comment sets out Caesar Health’s policy recommendations. This comment was submitted by Caesar Health, Inc.; it was not filed on PCP1st’s behalf.
Read the filing
- Submitted letter: Download the exact five-page PDF, including the research references and responses to all eight questions.
- Submitted: September 11, 2026.
- Docket: CMS-2026-2377; rule document CMS-2026-2377-0002.
- Regulations.gov tracking number: mtx-hkf6-xjls.
Regulations.gov confirmed successful submission. Public posting is subject to agency processing. Submission does not imply CMS endorsement or adoption of our recommendations.
To discuss how your practice handles preparation and follow-through, contact Caesar Health.