New this year, the Centers for Medicare & Medicaid Services (CMS) will support clinicians conducting the Physical Activity and Nutrition Risk Assessment for Medicare patients. This is good news for older adults because when physicians are incentivized to evaluate eating habits, nutrition status, and related health risks as a part of routine care, nutrition moves from being a “nice to have” aspect of care to a core component of a wellness or other office visit.
The change supports a clinician’s ability to provide meaningful assessment, discussion, and management of a patient’s overall health. This is especially true for older adults, for whom the risk of being malnourished is high (up to 1 in 2) and the risk of dying from malnutrition has increased in recent decades—with deaths attributed to malnutrition rising significantly from 2000–2019 in individuals ages 65 years and older. Thus, this policy change, published in November 2025 and officially outlined in the final rule of CMS on the 2026 physician fee schedule and Medicare Part B payment policies, is significant in its recognition of nutrition as an essential piece of preventive care, one that aligns well with the CMS vision of “[s]hifting the paradigm for health care from a system that focuses on sick care to one that fosters prevention, wellness, and chronic disease management.”
In line with this change, when clinicians complete a Physical Activity and Nutrition Risk Assessment it is not intended as a routine screen conducted before patient visits. Instead, it is a risk assessment conducted during a visit for patients with a known or suspected physical activity and/or nutrition need. Once completed, the results of the risk assessment can help clinicians make better-informed diagnoses, more appropriate treatment plans, and clearly supported patient referrals. Additional specifications for the Physical Activity and Nutrition Risk Assessment are provided in Table 1, below.
Table 1: Administration of Physical Activity and Nutrition Risk Assessment
| Definition and coding | Defined as administration of a standardized, evidence-based assessment of physical activity and nutrition, 5–15 minutes, not more often than every 6 monthsMay include both a physical activity and nutrition risk assessment or either a physical activity or a nutrition risk assessment Coded as HCPCS code G0136* |
| When administered | Optional addition (without patient cost sharing) to Medicare Annual Wellness Visit Optional addition (with patient cost sharing) to Evaluation and Management (E/M) visit, behavioral health visit, psychiatric diagnostic evaluation, or Health Behavioral Assessment Intervention (HBAI) services |
| Designated providers | PhysicianPhysician associateNurse practitionerClinical nurse specialistMedical professional working under direct supervision of a billing practitioner and incident to the practitioner’s professional services such as Registered Dietitian Nutritionists, medical assistants, nurses, and technicians |
*HCPCS is the Healthcare Common Procedure Coding System. Code G0136 was previously used for administering a social determinants of health risk assessment. With publication of the 2026 physician fee schedule and Medicare Part B payment policies, CMS delineated a new definition for HCPCS code G0136 and identified that all billing rules for the code remain the same.
Nutrition Risk Assessment in the Medicare Annual Wellness Visit
Clinicians who work with older adults on Medicare may find the Nutrition Risk Assessment integrates well into their current practice, specifically during the Medicare Annual Wellness Visit. This visit is designed to develop or update a comprehensive, personalized plan to prevent disease or disability. That plan is based on a person’s current health and risk factors, as identified through a health risk assessment (HRA). Because so many aspects of a person’s health are discussed during these Annual Wellness Visits, clinicians are likely already addressing aspects of nutrition-related concerns that fit with a Nutrition Risk Assessment (see Table 2, below).
Table 2: Medicare Annual Wellness Visit Components and Potential Nutrition-related Health Problems and/or Measures
| Annual Wellness Visit component | Potential nutrition-related health problem and/or measure |
| Psychosocial risks (cognitive impairment, depression, loneliness, social isolation) | Reduced appetite and food consumption, unintended weight loss, poor quality diet, food security* |
| Behavioral risks (diet and nutrition, oral health, alcohol consumption, substance use disorders) | Reduced appetite and food consumption, unintended weight loss, poor quality diet, food security* |
| Activities of daily living (ADLs) (feeding and physical ambulation—including balance or fall risks) | Reduced ability to safely ambulate and shop for/prepare food, to sit up, or to feed self |
| Instrumental activities of daily living (IADLs) | Reduced ability to shop for/prepare food |
| Measures (height, weight, body mass index or BMI) | Unintended weight changes, BMI outside recommended range |
*Food security can be related to financial constraints, transportation access, physical mobility, and bodily functioning.
Tools for Nutrition Risk Assessment
With so many factors contributing to nutrition risks, including diseases, medical treatments (such as GLP-1 use), functional health, social/mental health, and quality of diet/food access, agreed-upon tools for reliably assessing such risks are helpful. CMS has identified several such examples of standardized, evidence-based tools for nutrition and diet assessment:
Separate from general nutrition risks is the medical condition that occurs when those risks go unnoticed or untreated: malnutrition—a lack of the adequate amount or quality of calories needed for tissue maintenance and repair. This could be caused by lack of access to a healthy and varied diet, not eating enough food, or not being able to meet nutrition needs because of an existing health condition, medication, and/or past surgery. Malnutrition is associated with poor health outcomes, frailty and disability, and increased healthcare costs. Validated nutrition assessment tools to identify malnutrition specifically are:
- Subjective Global Assessment (SGA)
- Mini Nutrition Assessment (MNA)
- Consensus Statement: Academy of Nutrition and Dietetics and American Society for Parenteral and Enteral Nutrition, characteristics recommended for the identification and documentation of adult malnutrition)
- Global Leadership Initiative on Malnutrition (GLIM) Consensus Framework
Notably, health and diet are dynamic; a person’s nutrition status may change over time. Thus, it is appropriate to repeat Nutrition Risk Assessments regularly to reassess a person’s nutrition needs, determine the impact of nutrition interventions, and make changes to treatment plans as appropriate.
Nutrition Interventions
Administering a Nutrition Risk Assessment can also help identify specific nutrition needs, providing insight into which intervention(s) might best meet a person’s particular nutrition risk(s). Possible nutrition interventions and resources, including some community-based examples, are described in Table 3, below.
Table 3: Nutrition Interventions and Resources for Nutrition-related Health Problems
| Treat medical issues impacting dietary intake/nutrient utilization |
| Review medications for possible impact on dietary intake |
| Refer to registered dietitian nutritionist (RDN) for person-centered counseling and/or medical nutrition therapy* |
| Refer to medically tailored meal program |
| Recommend oral nutrition supplements |
| Refer to community-based congregate or home delivered meals program, including those provided by Area Agency on Aging programs |
| Refer to Supplemental Nutrition Assistance Program (SNAP), local food bank |
| Provide patient educational materials and resources |
*Medical nutrition therapy is a Medicare covered benefit for individuals with diabetes or kidney disease; it is provided by an RDN and can include an initial nutrition and lifestyle assessment, individual and/or group nutrition therapy services, help managing lifestyle factors, and follow-up visits.
Conclusion
Anyone can be impacted by poor nutrition, and it may not be immediately obvious to older adults or those who care for them. Identifying risks of poor nutrition is integral to preventive care and to limiting the development or progression of conditions that impact health and quality and length of life. Medicare Annual Wellness visits, other office visits, and behavioral healthcare visits are powerful opportunities to administer a Nutrition Risk Assessment, evaluate needs, and provide nutrition education and referrals that empower older Americans and caregivers to take steps toward good nutrition and healthy aging.
Alissa M. Deal is an MD candidate with the Class of 2026 at The Ohio State University College of Medicine in Columbus, Ohio. Dominique R. Williams, MD, MPH, is the adult nutrition medical director for the Nutrition Division of Abbott in Columbus, Ohio.
Photo credit: Shutterstock/sasirin pamai
