The Annual Wellness Visit is one of the highest-margin Medicare services and remains one of the most under-billed. CMS data indicates roughly half of eligible Medicare beneficiaries received an AWV in recent reporting periods, and many practices that bill AWVs do so without the documentation that supports the codes. G0438 (initial AWV) reimburses around $174 in 2026 depending on locality. G0439 (subsequent AWV, billed annually after the initial) reimburses around $117. For a panel of 1,000 Medicare patients, capturing AWVs at the recommended cadence is meaningful annual revenue, and the work is mostly already happening in the room. The gap between the work performed and the work billed is documentation, not effort.
Eligibility and frequency
The initial AWV (G0438) is billable once per Medicare beneficiary, after the first 12 months of Part B coverage and at least 12 months after the Initial Preventive Physical Examination (IPPE, code G0402) if one was performed. Subsequent AWVs (G0439) are billable annually thereafter, with at least 11 full months between visits. The AWV cannot be performed during the same calendar month as the IPPE, and beneficiaries newly enrolled in Medicare are eligible for the IPPE in the first 12 months and the AWV after that 12-month window closes. Practices that schedule AWVs without verifying frequency eligibility see denials when patients are inside the 11-month window or have a recent IPPE.
The Health Risk Assessment requirement
The AWV requires a Health Risk Assessment (HRA) as a discrete component. The HRA covers demographic data, self-assessed health status, psychosocial risks (depression screening, life satisfaction, stress, anger, loneliness), behavioral risks (tobacco, alcohol, physical activity, nutrition), activities of daily living, and instrumental activities of daily living. Practices can have the patient complete the HRA before the visit (paper or portal) or during the visit. The HRA must be documented in the medical record. Practices that bill AWVs without an HRA in the chart fail the most basic audit element of the code.
The personalized prevention plan
Beyond the HRA, the AWV requires several specific elements to be documented: review of the patient’s medical and family history, list of current providers and suppliers, vital signs (height, weight, BMI, blood pressure), detection of cognitive impairment, review of risk factors and conditions for which primary, secondary, or tertiary prevention interventions are recommended, list of risk factors and conditions, list of treatment options, advance care planning if elected by the patient, and a written screening schedule (the personalized prevention plan) for the next 5 to 10 years based on USPSTF and CDC recommendations. The personalized prevention plan is the deliverable that ties the AWV together, and it must be documented in the chart.
AWV versus IPPE
The Initial Preventive Physical Examination (IPPE, code G0402) is the “Welcome to Medicare” visit, billable once per beneficiary in the first 12 months of Part B enrollment. It is a different code from the AWV with overlapping but distinct content requirements. Practices that confuse the two end up billing G0402 when G0438 was appropriate (or vice versa), with denials and re-billing delays. The simple rule: G0402 in the first 12 months only, G0438 once after that, G0439 annually thereafter.
Same-day E/M with AWV
When a patient presents for an AWV and a problem-oriented service is provided at the same visit (a new symptom, a chronic condition requiring management beyond the AWV’s preventive scope), modifier 25 applies on the problem-oriented E/M code, and the practice can bill both. Documentation must establish a separately identifiable E/M service distinct from the AWV’s preventive content. The audit-defensible note has two parts: the AWV elements documented in the AWV section, and the problem-oriented evaluation in a separate problem section with its own assessment and plan. Practices that bundle the work in one combined note may face denials on the modifier 25 claim.
Common documentation gaps
The most common documentation gaps that fail AWV audits include:
- HRA absent or incomplete (the most common single failure).
- Cognitive impairment screening not documented.
- Personalized prevention plan absent or generic (the same plan attached to every patient).
- List of risk factors or conditions missing.
- Same-day E/M billed with AWV but the documentation does not support a separately identifiable problem-oriented service.
How MHB helps practices capture AWV revenue
For primary care and internal medicine practices that want AWV billing reviewed for documentation completeness with HRA verification, personalized prevention plan tracking, and same-day E/M discipline, our team supports specialty medical coding for primary care including AWV billing.
The bottom line
The AWV is one of the most under-billed Medicare services, and the work is mostly already happening in the room. The barrier is documentation discipline: the HRA, the cognitive screening, the personalized prevention plan, the same-day E/M when applicable. Practices that build templates aligned to the code requirements capture meaningful revenue. Practices that bill AWV without the elements either get denials or absorb audit risk.
Authoritative sources
This article cites the following primary sources for billing-code and regulatory guidance. Always confirm current rules and codes with the publishing authority before applying to a specific claim.
