Medicare wellness visit documentation guide
December 9, 2025 | Laureen Jandroep, QMC, QMPM, QMCI
Medicare annual wellness visits (AWVs) are essential preventive services covered under Medicare Part B. This guide breaks down the three visit types—IPPE, initial AWV, and subsequent AWV—along with their documentation and billing requirements. Learn how to avoid common errors, ensure compliance and receive accurate reimbursement.
Documentation requirements for Medicare wellness visits
| Code | Timing | Specific requirements |
|---|---|---|
G0402 Initial Preventive Physical Examination (IPPE) "Welcome to Medicare" visit | Must occur within 12 months of Medicare enrollment | Unique to G0401
Required for all AWVs
|
G0438 Initial Annual Wellness Visit (AWV) First AWV after IPPE | After 12 months of Medicare enrollment Can only be billed once in a lifetime | Unique to G0438
Required for all AWVs
|
| G0439 Subsequent annual wellness visit | Covered annually, but not until 12 months after the Initial AWV | Unique to G0439
Required for all AWVs
|
Medicare wellness visit coding and billing guidelines
- Use the appropriate HCPCS code (G0402, G0438, or G0439) based on the visit type
- Report a diagnosis code when submitting claims:
- Z00.00 (encounter for general adult medical examination without abnormal findings)
- Z00.01 (encounter for general adult medical examination with abnormal findings)
- Ensure at least 11 full months have passed since the previous wellness visit before billing G0438 or G0439
- Do not bill G0438 or G0439 within 12 months of a previous G0402 (IPPE) billing for the same patient
- AWVs are covered for Medicare Part B patients without a copay
Key considerations for Medicare annual wellness visits
- AWVs are not typical physical exams but focus on preventive care and health promotion
- Additional services ordered during an AWV may be subject to deductibles or coinsurance
- Non-physicians must be legally authorized and qualified to provide AWVs in their state
- Misuse of codes (e.g., billing G0438 more than once) will result in claim denials
- Some patients over 65 have private/commercial insurance and would then need CPT 99397 “Periodic comprehensive preventive medicine reevaluation and management of an individual including an age and gender appropriate history, examination, counseling/anticipatory guidance/risk factor reduction interventions, and the ordering of laboratory/diagnostic procedures, established patient; 65 years and older” to be reported instead of AWS codes.
- Use modifier -25 when the patient comes for AWVs but also has problems that require a significant and separate EM service. It is highly recommended to document each service separately so there is no confusion.
- Do not count elements like ROS, PFSH and PE on both services (no “double dipping”)
- Must meet all elements of an AWVs and problem-focused EM visit
- Clearly document that patient was “here today for AWVs or annual exam but also wanted to address problem…”
- Use diagnosis codes for illnesses to support EM visits (i.e., HTN, diabetes, etc.)
- Use Z codes to support AWVs codes (i.e., Z00.0X, “encounter for general adult exam”)
Medicare wellness visit errors and compliance risks
Recent findings have highlighted several issues with accurate reporting and billing of Medicare wellness visits. Depending on the severity and intent behind errors, providers may face fines and penalties from Medicare.
- AWVs are a compliance risk area because reimbursement for the entire visit may be at risk if physicians fail to document all the required components.
- Penn State Health agreed to pay over $11 million to resolve allegations of improper billings related to Medicare AWV services.
- Common billing errors include:
- Failing to document all mandated services
- Miscoding claims
- Overbilling by submitting claims more frequently than allowed
- Confusion between IPPE and AWV codes
- Elements often missing or improperly documented:
- Comprehensive health risk assessment
- Personalized prevention plan
- Cognitive impairment screening
- Review of functional ability and safety
- Some providers mistakenly bill AWVs using CPT codes for comprehensive preventive medicine evaluations (99381-99397)
- Traditional Medicare will not cover standard preventive codes.
- Preventive codes may be reported when a patient still has private insurance in addition to Medicare.
- Some Medicare advantage plans allow use the preventive codes as well as AWVs.
Providers and their billing teams must understand that these are comprehensive wellness services and not just a typical annual physical. ALL the required elements must be documented to bill the Medicare wellness codes.
Laureen Jandroep, clinical development specialist at Solventum.
