Who can perform an annual wellness visit?
More people can perform it than most practices think, and fewer can bill it than most vendors imply. Those are two different questions.
The short answer: more people than most practices think can perform it, and fewer than most vendors imply can bill it. Those are two different questions and conflating them is how a wellness visit program becomes a repayment.
Who may perform the visit
Medicare covers the annual wellness visit when it is furnished by a physician, by a qualified non-physician practitioner such as a physician assistant, nurse practitioner, or clinical nurse specialist, or by a medical professional or a team of medical professionals working under the direct supervision of a physician.
That third route is the one that matters operationally. It is why a registered nurse, a health educator, or a licensed practical nurse can deliver the visit itself. Most of an annual wellness visit is a health risk assessment, history, a medication and provider list, screenings, and a written screening schedule. It is structured questioning rather than examination, which is exactly the work a nurse does well.
What direct supervision means
Direct supervision means the physician is immediately available to furnish assistance and direction throughout the performance of the service. Historically that meant present in the office suite, and not merely reachable by telephone.
Since 1 January 2026 the presence it requires may be a virtual one, through real-time audio and video interactive telecommunications. Audio-only does not satisfy it, and it does not extend to services carrying a 010 or 090 global surgery indicator, which the wellness visit does not. CMS adopted this permanently in the CY2026 Physician Fee Schedule final rule rather than extending it as a dated flexibility, and it is the single change that makes a standing telephone wellness visit programme practical to run. We have written the whole chain out in plain English.
It remains a stricter standard than care management, which runs under general supervision, where the billing practitioner directs the service without needing to be present at all. The two are frequently sold together and they do not share a supervision rule. If a vendor's pitch glosses that, press on it.
Who bills it
The billing practitioner, and the supervision obligation, sit with the practice. An outsourced nurse can perform the visit and produce the documentation. An outsourced nurse cannot make your practice's supervision requirement disappear, and no vendor can bill a Medicare annual wellness visit on your behalf as though it were theirs.
Any vendor implying otherwise is describing something other than the benefit. We say this on our own service page rather than in a contract appendix, because it is the thing most likely to cause a practice trouble later.
Can it be done by telephone
For established patients, yes. The annual wellness visit sits on the Medicare telehealth list and audio-only delivery is permitted under the telehealth flexibilities, which the Consolidated Appropriations Act of 2026 extended through 31 December 2027. New patients generally still need to be seen in person. Because these flexibilities have been extended repeatedly rather than made permanent, check the current CMS telehealth list rather than assuming the position holds.
Health centres
Federally qualified health centres and rural health clinics bill the bundled per-diem G0468 under their prospective payment system, with the standard G-codes reported on the claim for tracking. The clinical work is identical; the revenue arithmetic is not, and usually turns on visit volume rather than the per-visit rate.
Questions people ask
Can a registered nurse perform a Medicare annual wellness visit?
Yes, as part of a medical professional or team working under the direct supervision of a physician. The visit is largely history, structured screening, and a written prevention schedule rather than examination, which is why it is well suited to a nurse. The billing practitioner and the supervision obligation remain with the practice.
What exactly is direct supervision?
The physician must be immediately available to furnish assistance and direction throughout the performance of the service. Since 1 January 2026 that presence may be virtual, through real-time audio and video, rather than in the office suite; audio-only does not satisfy it. It remains a stricter standard than the general supervision that applies to care management, where the billing practitioner directs the service without needing to be present at all.
Can an outsourced company bill the AWV for us?
No. Your practice bills it, because the billing practitioner and the supervision requirement sit with you. A vendor can perform the visit and hand you finished documentation. If a vendor tells you it will bill Medicare for your patients' wellness visits, ask exactly what it means, because that is not how the benefit works.
Is an AWV the same as a physical?
No, and patients are often surprised. The annual wellness visit does not include a head-to-toe examination. It is a health risk assessment, medical and family history, a current provider and medication list, height, weight and blood pressure, cognitive impairment detection, depression screening, functional ability and safety review, a written screening schedule for the next five to ten years, and personalised advice with referrals.
What does it pay?
As 2026 national averages, roughly $174 for an initial visit (G0438) and roughly $138 for each subsequent one (G0439), both covered at 100 percent with no patient cost sharing. Amounts are adjusted by locality, so check the fee schedule lookup. You can model your own gap with our AWV revenue calculator.
Sources
- 42 CFR 410.15, annual wellness visit.
- 42 CFR 410.32(b)(3)(ii), levels of supervision.
- CMS, CY2026 Physician Fee Schedule final rule fact sheet, CMS-1832-F.
- CMS, Medicare Wellness Visits, MLN6775421.
- Medicare.gov, yearly wellness visits.
- CMS, Medicare telehealth.
- CMS, Physician Fee Schedule lookup.
Reviewed August 2026. The virtual direct supervision definition was adopted permanently in the CY2026 Physician Fee Schedule final rule, but the patient-facing audio-only telehealth allowance carries a date; confirm the current position with CMS and your MAC. This is not billing or compliance advice.
Nurses who do the visit properly.
TULQ supplies compact-licensed registered nurses who complete the visit by telephone and hand back finished documentation. Your practice supervises and bills, which is how the benefit is designed.