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

Now Available: Free Online Options for Annual Wellness Visit Component

February 15, 2012 04:55 pm Sheri Porter

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.

story highlights

  • Jan. 1 marked the effective date for implementation of CMS' requirement that the Medicare annual wellness visit benefit include a health risk assessment component.
  • Thus far, CMS has failed to provide a health risk assessment model to guide physicians, so the AAFP is facilitating use of questionnaires that contain all of the required elements of the health risk assessment.
  • Physicians can use information gathered from the assessment to develop a personalized prevention plan for patients.
  • emotional state;
  • pain level;
  • physical activity;
  • recent history related to falling, sexual problems, eating patterns, dental problems and fatigue;
  • ability to shop, prepare meals and do housework without assistance;
  • alcohol and tobacco use; and
  • ability to take medications as directed.

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

Getting Paid for Providing the Health Risk Assessment

To compensate practices for any additional staff time involved with the addition of the health risk assessment to the Medicare annual wellness visit benefit, CMS increased the allowed amount for the annual wellness visit to $166.44 for the initial visit and $110.96 for a subsequent annual wellness visit when done in the office in 2012.

According to Kent Moore, the AAFP's director of health care financing and delivery systems, the increase comes to about $5.39 for the initial and $3.59 for a subsequent annual wellness visit, on average, compared with 2011 allowances. He noted that the actual Medicare allowance will vary geographically.

The author of an article recently posted in Family Practice Management calls CMS' payment adjustments "underwhelming."

The Academy made a case for properly adjusting payment for provision of the new requirement in an Aug. 29 letter to CMS. The AAFP noted that the addition of the health risk assessment to the annual wellness visit would "add a significant burden of time and expense for the practice."

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.