Here's how to comply with all the Annual Wellness Visit requirements from CMS and avoid an audit disaster at your medical practice.
Medicare's Annual Wellness Visit (AWV) is not just about reviewing patient health risks, but must include actions to address those risks in a written format for the patient. So don't forget to give your patients all the required information before they leave the visit.
Here is a summary of some CMS requirements as stated and interpreted per their bulletin #7079:
1. Provide a Health Risk Assessment (HRA) before the AWV (or during if you want to provide it in the office).
2. Establish a written list of risk factors and conditions from the HRA with recommended interventions for the patient to take with them following the visit.
3. Review health conditions, home safety, medications, care providers, cognitive and functional ability, complete family and care history, plus risk factors for depression.
4. Provide a written five-year to 10-year Personal Prevention Plan Services (PPPS) for the patient detailing all their scheduled preventive services provided by CMS (most at no copay).
5. Furnish personalized health advice and referrals to national and local community health education services and centers.
Here are the key interpretations and comments from CMS (per their website) that most practices are ignoring:
“It is thought that the beneficiary would leave the visit with personalized health advice, appropriate referrals, and a written screening schedule, such as a checklist.
“CMS does not expect that the health professional would provide only general recommendations during wellness visit encounters and then mail a personalized prevention plan that incorporates an HRA to the beneficiary outside of the annual wellness visit encounter.”
The result is that each topic in the HRA should be “actionable” in that if the responses identify a risk, the clinician should be able to treat, counsel, or refer the patient, through shared decision making, to an appropriate treatment or risk mitigation program.
The non-compliance that I see in every practice so far is that they are not providing an actionable schedule of risk advice and referrals.
Every practice must create a template that details a specific local or national solution to every risk that is identified. The HRA Action Plan should start by listing all your current referrals for the specialists to whom you normally refer. Then, list your local community referrals for senior citizen programs, centers, and services, etc. Plus, any national programs or links for seniors should be included.
CMS requires 100 percent compliance on the AWV for reimbursement. Data "collection" on the HRA is only 50 percent of the requirement of the AWV. "Action" on the data is the other 50 percent.
"Collection without Action" does not result in reimbursement compliance.
So don't fall into the trap of just collecting data that is listed on the CMS directive. The patient must leave with a PPPS for the next 5 years to 10 years of all CMS-provided benefits and an actionable care plan for all health risks at the time of the visit (not mailed or provided later) to fulfill 100 percent of CMS compliance requirements.
Ideally, you could create an electronic data capture template on your patient portal or use a commercial Internet site that populates all the health risks and their solutions and is completed before the visit.
If you are not fully complying with all these requirements, you could be in for a big nasty surprise on an audit and give back all the money you have collected, which could be $165 per AWV or more.
Jeff Gatewood is a principal in BeneMedical, LLC, which creates digital solutions to assist doctors and patients in the quest for healthy lives and profitable medical practices. He is also the co-creator of AWVSolution.com, a website providing electronic data capture and care plan creation for Medicare Annual Wellness Visits. E-mail him here.