Effective January 1, 2011, all Medicare beneficiaries will be entitled to an annual wellness visit with a physician and Personalized Prevention Plan. Although the prevention plan is free, with no cost-sharing, providers are awaiting CMS guidelines, due to be released in March 2011, on whether the annual visit itself must also be free. The Personalized Prevention Plan shall include a health risk assessment, a list of the patient’s current health care providers and prescription medications, an updated medical history, height, weight and blood pressure measurements, a screening schedule over the next 5-10 years for appropriate preventive services and a list of health factors the patient may face, along with appropriate treatment options. The annual wellness visit is not available in the first twelve (12) months of a beneficiary’s enrollment, during which time new enrollees are already entitled to a covered “Welcome to Medicare” exam. Specific requirements related to the two potentially different services will hopefully be clarified in the CMS guidelines.

For concierge physicians, this new coverage will have a significant impact. Similar to the way in which many concierge practices carve out the “Welcome to Medicare” exam from the annual retainer amount paid by patients, the newly-covered wellness visits and personalized prevention plans will also need to be excluded from the benefits included in the annual retainer fee. It remains essential for concierge practices that participate in the Medicare program to avoid charging Medicare beneficiaries separately for services that are already reimbursed/covered by the Medicare program. Concierge practices will need to examine their form of patient agreement and the description of their concierge program and make the necessary revisions prior to January 1.