Annual Wellness Visits

AWV Workflow and Component Checklist

Separate required AWV elements from conditional reviews, optional services, and practical operating controls.

Classification rule

The AWV is a prevention planning service, not a routine physical. Do not mistakenly group all wrappers and add-ons as "15 CMS-required components." Instead, carefully separate first/subsequent elements, conditional reviews, optional separately reportable services, and recommended operational controls.

How to select the code path

Code Service Operational control
G0402 IPPE First 12 months of Part B; follow current IPPE rules.
G0438 Initial AWV First AWV in a patient's lifetime; verify Part B and IPPE history.
G0439 Subsequent AWV Requires a prior AWV and must satisfy current frequency rules.
Code correction: G0406 is an inpatient telehealth consult, not an AWV or IPPE.

Required elements (Initial vs. Subsequent)

Item Initial (G0438) Subsequent (G0439) Required evidence
HRA Perform Review and update Dated responses, documented source, and reviewer name.
Medical and family history Establish Update Conditions, treatments, medications, and family history.
Providers and suppliers Establish Update Current list of providers and their roles.
Measurements Current CMS initial elements Current CMS subsequent elements Value, source, date, device/method, and practitioner review.
Cognition Detect impairment Detect impairment Clinical input and disposition.
Prevention plan Establish Update Written schedule, risks/interventions, personalized advice/referrals, and delivery method.

Conditional reviews

You must apply current CMS descriptions for functional/safety, depression, opioid, and substance-use risk according to the specific visit type and circumstances.

Required documentation: Record the trigger, finding, action taken, referral, owner, and any supported exceptions.

Optional separately reportable services

Do not treat these as mandatory AWV elements.

  • ACP (99497/99498): This is voluntary. Independently verify time, documentation, telehealth, modifier 33, and patient cost-sharing.
  • G0136: This is not HRA administration. Verify current physical activity and nutrition assessment meaning, tool/domains, frequency/time, and payer rules.
  • Same-day E/M: Only report a significant, separately identifiable, medically necessary E/M. Append modifier 25 and maintain a separate record when supported.

How to track ownership, status, and evidence

Note: Status and state models are implementation recommendations—not CMS mandates or claims of a shipped FairPath workflow engine.

Data field Tracking examples
Owner Scheduler, support staff, pharmacy, practitioner, biller, care coordinator.
Status Not started, submitted, review needed, accepted, returned, exception, complete.
Evidence Source, collector, date, device/document, discrepancy, reviewer.
Control Due date, escalation pathway, authentication, correction reason.

Phase 1: Pre-visit preparation

  • [ ] Verify Part B effective date and paid G0402/G0438/G0439 history.
  • [ ] Prepare an accessible HRA, histories, provider list, prevention history, measurements, and necessary patient supports.
  • [ ] Identify missing evidence, clinical flags, visit modality, practice scope, and task owners.

Phase 2: Visit and clinician review

  • [ ] Confirm patient identity, participants, visit modality, and history changes.
  • [ ] Review imported patient, pharmacy, device, payer, and program evidence.
  • [ ] Complete all applicable elements; actively accept, correct, reject, or replace evidence.
  • [ ] Authenticate the record and route unresolved follow-up tasks.

Phase 3: Prevention-plan output

The practitioner must generate a compliant prevention plan.

Note: Do not claim a deterministic engine generated, locked, or auto-routed the plan unless explicitly verified.

  • [ ] Patient-specific written screening schedule.
  • [ ] Identified risks/interventions and personalized advice/referrals.
  • [ ] Task owner, due date, patient instructions, delivery method/date, and a retained version of the plan.

Phase 4: Billing handoff and exceptions

  • Send to billing: Route eligibility, selected code, completed elements, authentication, diagnosis, provider info, add-on/modifier/time data, and telehealth evidence.
  • Stop conditions: Pause on unknown history. Return incomplete evidence. Record declined optional services. Clinically escalate urgent findings.
  • Manage denials: Preserve the original claim, classify the root cause, correct only supported data, and retain the resubmission trail.

How to conduct an audit sample

  1. Select cases: Sample initial, subsequent, telehealth, pharmacy-supported, add-on, and denied records.
  2. Trace the lifecycle: Trace eligibility, evidence, clinician acceptance, plan generation/delivery, claim submission, and follow-up.
  3. Check major boundaries: Check G0402 vs G0406, G0438 vs G0439, G0136 restrictions, ACP voluntariness, proper use of modifiers 25/33, and time overlaps.
  4. Log findings: Record the deficiency, owner, correction made, required training, and the scheduled re-audit date.

Sources (public)

Disclaimer: Operational education only. Verify current CMS, MAC, payer, code-year, scope, supervision, setting, and telehealth rules. No coverage or payment is guaranteed.

FairPath is designed to handle this complexity for you.

While most platforms simply record what happened, FairPath actively runs the program. It continuously monitors every patient, staff action, and billing rule across CCM, RPM, RTM, and APCM, intervening immediately when a requirement is missed.

This allows you to scale your own program without losing quality, breaking trust with physicians, or losing control of your revenue. We provide the precision of an automated medical director without the chaos.