Academy Remedies CMS' Lack of Guidance on Health Risk Assessment Requirement

In January, family physician Edwin Scott, M.D., of Augusta, Ga., was determined to begin providing his Medicare patients with a health risk assessment as part of their Medicare annual wellness visit benefit. But he couldn't find an example of an existing health risk assessment that that wasn't "ridiculous in its complexity," he told AAFP News Now.

Physicians may remember that the Patient Protection and Affordable Care Act directed CMS to require that a health risk assessment be completed as part of the Medicare annual wellness visit. Despite the Academy's efforts to persuade CMS to provide a health risk assessment model and to delay implementation until that work was completed, CMS made the health risk assessment requirement effective on Jan. 1 -- with no such model in place.

To fill the void left by the government's failure to provide adequate guidance to physicians, the AAFP has facilitated member access to two interactive questionnaires -- one short version and a second longer version -- that meet the requirements for the health risk assessment portion of the annual wellness visit.

The short questionnaire also is available for physicians to download (2-page PDF; About PDFs) and hand to patients who are not comfortable with, or who do not have access to, a computer.

As required by the government, the questionnaires are written at a sixth-grade reading level and should take no more than 20 minutes for a patient to complete. Questions include inquiries about the patient's

All of the materials are made available through HowsYourHealth.org, a not-for-profit service of the Dartmouth Co-Op Project.

According to a Feb. 14 article (Members/Paid Subscribers Only) in Family Practice Management, (FPM) the questionnaires include all of the 34 health risk assessment elements required by CMS. "While a number of health risk assessments for the Medicare annual wellness visit may be in development, FPM is aware of only (this) one source so far," said the author of "Medicare Annual Wellness Visits: Don't Forget the Health Risk Assessment."

CMS is requiring the health risk assessment "to help systematize the identification of health behaviors and risk factors, such as tobacco use and nutrition, that the physician can discuss with the patient in an effort to reduce risk factors and related diseases," according to the FPM article.

Presumably, physicians will use information gathered from the health risk assessment to develop a personalized prevention plan for the patient.

"The health risk assessment is considered an essential element of Medicare's annual wellness visit," said Kent Moore, the AAFP's manager of health care financing and delivery systems. "If physicians do an annual wellness visit in 2012, it must include the health risk assessment with the required components."

However, Moore stressed that physicians have choices when they participate in Medicare. "Physicians can choose the patients they want to see, and they can adjust the scope of their practice as it relates to those patients," he said. "Physicians have the freedom to pick the services they want to provide to patients, and that includes the annual wellness visit."

Scott, who is part of a large family medicine practice with 26 family physicians, said his group collaborated to create their own health risk assessment a few weeks ago. "We did our best, and got a form we feel comfortable with and started using it, even though we're not certain it meets all of CMS' requirements," he said.

Scott said he would compare the health risk assessment the practice had been using to the questionnaires available online and add any components that are missing so that he is in full compliance with all CMS requirements.