PACE Innovation Act Request for Information Data Supplement

Members | August 11, 2017 | by

LeadingAge submitted comments on the supplement to the PACE Innovation Act Request for Information (RFI) released on December 23, 2016. 

This RFI (including the RFI Data Supplement that is part of the RFI) is issued solely for information and planning purposes.

The documents contain data and analysis on potential adjustments to capitation rates for Medicare Parts A and B services (“acuity adjustment”) referred to in a description of a potential payment methodology for the potential Person Centered Community Care (P3C) model discussed in the RFI. The data and analysis in this RFI Data Supplement are based on the P3C eligibility criteria as described in the RFI, including the diagnostic criteria in Appendix A, and the Medicare payment methodology described as Option 1 in the RFI. LeadingAge submitted comments on the original PIA RFI

CMS seeks comment on:
•    The data and analysis in this RFI Data Supplement from all interested parties
•    Input on alternate approaches for determining the acuity adjustment and in particular the relative merits of a potential state-wide acuity adjustment or a potential county-based adjustment described in the memorandum and illustrated in the data sets. 
•    Data showing whether or not the adjustment to Medicare rates under the alternative acuity adjustments, would be viable for potential P3C organizations seeking to serve the P3C-eligible population. 

Commenters should provide the name of their organization and a contact person, mailing address, email address, and phone number, and indicate whether the commenter is a current PACE organization, other provider type, state Medicaid agency, other state agency, advocacy organization, or other entity.
Comments must be received by 5 p.m. EST on August 15, 2017. Comments should be submitted electronically in pdf form to Please identify the organization or individual submitting comments in the title of the document and put “RFI Data Supplement” in the subject line.

CMS has made no decision on the testing of the P3C model described in the RFI, or on limiting the potential eligibility criteria or using the payment methodologies described in the RFI. The parameters of the P3C model may change, or CMS may ultimately decline to conduct the model test. The data presented do not represent final rates for a potential P3C model, which, if implemented under either of the acuity adjustment methodologies described, or an alternative methodology, would be based on more current data and could include additional refinements to improve accuracy.

LeadingAge submitted comments on the supplement to the PACE Innovation Act Request for Information (RFI) released on December 23, 2016. Our main focus is to see the eligibility criteria for P3C model be appropriate in order to maximize the participation of individuals that would benefit from the services of the P3C model. Also, we have a strong belief that PACE-like models of care would be effective in improving quality care outcomes and reduce costs of care for multiple populations. We concur with the comments submitted by the National PACE Association (NPA).