Part of: 2022 Policy Platform


  • Ensure that older adults are able to receive health care and long-term services and supports in their homes and communities if they prefer to do so.
  • Support increased availability of PACE organization services to older adults through regulatory and statutory flexibility and investment at the federal and state levels.
  • Promote PACE across the country via new and expanded service areas and increased enrollment.
  • Advance policy that promotes the availability of PACE across funding streams.
  • Ensure that any LTSS models from the Center for Medicare and Medicaid Innovation is inclusive of all settings in the home and community (e.g., home health and personal care, adult day other day-based services, PACE services) and provide the supports (e.g., transportation) needed to facilitate these.
  • Promote federal rulemaking that ensures access and quality home and community services for beneficiaries while minimizing provider burden.
  • Oppose block grant and per capita cap policies.


PACE organizations have risen to the challenge COVID-19 has presented. Since March, many PACE organizations transitioned away from in-person services and instead delivered care via home visits and through telehealth. The combination of nimble service delivery, stable reimbursement, and the ability of PACE to keep older adults in their homes and communities make the model attractive to participants, payers (e.g., Medicare and Medicaid), and PACE organizations both during and beyond the pandemic.

PACE organizations have innovated amidst the pandemic, particularly with respect to the use of telehealth and developing new ways to use their PACE centers. Most PACE organizations have also ramped up their in-home services capacity, versus the traditional center-based model many have historically used. Regulatory change is needed to fully realize the use of telehealth in these centers, and states and the federal government must maintain their investment in this model.

In addition, federal barriers exist that limit the growth and availability of PACE, including the optional status of all home and community-based services (waiver, state plan, PACE) as Medicaid benefit categories, limits to emergency relief provisions (e.g., retainer payments), and the lack of an HCBS-centered model from the CMS Innovation Center.

All the while, workers and participants of these providers have not been prioritized for COVID-19 PPE, testing, or vaccination distribution. Ensuring that PACE is included in these critical allocations is fundamental to making sure they are available for older people over the next decade and beyond.


117th Congress

Click here to see the full list of PACE legislation LeadingAge is following in the 117th Congress.
  • COVID-19 Relief: We will continue to advocate for the inclusion of PACE providers in COVID-19 relief provisions, including HCBS grant making, provider relief funding or other dollars and/or equipment allocated to health and long-term care providers (e.g., testing, PPE).
  • Medicaid FMAP: We support an increase in the Federal Medical Assistance Percentage (FMAP) for Medicaid HCBS, which includes state plan/waiver services and the Medicaid share of PACE.
  • Benefit categories: We ask Congress to revise Medicaid and put HCBS (including waiver and state plan services and PACE) on equal footing with nursing homes and make HCBS a mandatory Medicaid benefit.
  • Appropriations: We support increasing funding for key provisions that support HCBS, including Older Americans Act services.

Executive Branch

  • COVID-19: We support high prioritization of workers and participants of HCBS of all types in federal allocations of COVID-19 vaccination, testing, and PPE. Federal agencies should recommend that state-level decision-makers place a high priority on this group.
  • Telehealth: We continue to advocate for revisions to CMS guidance documents to broaden access to telehealth services for PACE participants and Medicare Advantage enrollees. If the Executive Branch does not act, Congress should.
  • Provider Relief Fund: We will advocate that any additional allocations made from the Provider Relief Fund (or similarly situated future funding streams) be inclusive of PACE providers.
  • Protect Medicaid financing: We oppose any Medicaid waiver or rulemaking that reduces federal funding to the program, as these could ultimately jeopardize PACE access. To that end, CMS should not approve and/or rescind waivers that allow per capita caps/block grant financing, work requirements, and unnecessary coverage/enrollment barriers. CMS should not propose rulemaking similar to the 2019 Medicaid Fiscal Accountability Regulation (MFAR).
  • Innovation Center models: We will closely monitor CMMI action to ensure that home and community-based services of all types are included as part of the proposed LTSS Innovation Fund and in other models.


  • Visit the Advocacy Action Center and help your members of Congress understand how policies they make impact PACE organizations.
  • Host a Coffee Chat with Congress in your community to help your members of Congress understand how policies impact PACE organizations and participants.
  • Mobilize with the Advocacy Champions toolkit and let your representatives and senators know you support more opportunities to create and sustain home and community-based services.