CMS Holds COVID-19 Call for PACE Organizations

Regulation | March 25, 2020 | by

Following the March 17 guidance issued for PACE organizations, the Centers for Medicare and Medicaid Services held a teleconference for PACE organizations and state agencies on COVID-19. This article provides a summary of key points CMS made on the call and answers to questions submitted by call attendees.

Following the March 17 guidance issued for PACE organizations, the Centers for Medicare and Medicaid Services held a teleconference for PACE organizations and state agencies on COVID-19. This article provides a summary of key points CMS made on the call and answers to questions submitted by call attendees.

CMS recorded the call and while it is not online as of March 25, recordings from similar calls are posted on CMS’s website and those interested in listening to the recording should monitor the webpage to see if this call is posted.

Flexibility with PACE Requirements

CMS acknowledged, similar to what is written in the March 17 guidance, that during the COVID-19 public health emergency PACE organizations may need to “implement strategies that do not fully comply with PACE requirements” but will help ensure staff and participant safety. This phrasing was used repeatedly during the call and CMS encouraged PACE organizations to use their best judgement in executing such strategies. This is in line with similar messaging from CMS to other providers, including nursing homes.

At the end of the call, CMS said the March 17 guidance is meant to “equip you all”, as in PACE organizations, to make the best decisions possible in a rapidly shifting environment.

PACE organizations will have this flexibility until the public health emergency is over, as indicated by the March 17 guidance. CMS will notify PACE organizations of this via the Health Plan Management System.

Potential Further Guidance

Participants on the call asked CMS about aspects of face-to-face requirements and flexibilities specific to those, and the agency mentioned potential future guidance on this specifically.

CMS also seems to be considering additional guidance on flexibility with respect to employee and/or contractor background checks.

Presence of COVID-19 in PACE Organizations

CMS mentioned that as of March 24, there are four cases of COVID-19 nationwide among people receiving services through PACE. The location(s) of these cases was not disclosed.

Working with CMS PACE Account Managers

CMS outlined the process by which PACE organizations and state agencies can ask questions of CMS during the pandemic. CMS’s team of PACE Account Managers are available in their regular capacity to PACE organizations and CMS encouraged PACE organizations to reach out to their respective Account Manager with questions or needs for guidance. The Account Managers are answering questions and escalating needs for guidance and additional insight back to CMS. In addition, back up Account Managers will be available if a PACE organization’s assigned person is not available.

In addition, CMS mentioned they are holding calls with state agencies with PACE organizations. While a specific schedule wasn’t given, the agency indicated these calls were ongoing.

PACE Organization and State Agency Practices

CMS and state agency staff from two states (Pennsylvania and Massachusetts) indicated that PACE organizations across the country are closing their day centers to minimize the spread of COVID-19.

Many are keeping their facilities and medical clinics open to provide needed services and therapies. In cases where people do come to PACE facilities (e.g., clinics), organizations are implementing social distancing.

The state agencies indicated the use of multiple strategies in their states to reduce person-to-person contact, including virtual tours of PACE centers, increasing home delivered meals for those who typically eat at PACE centers, conducting interdisciplinary team (IDT) meetings virtually and working toward policies that allow remote signatures and/or signing documents by mail. In addition, there were policy-level strategies to reduce burden on PACE organizations, including streamlining how they should report COVID-19 instances to the state (e.g., directly to public health versus a critical incident report) and suspending Medicaid eligibility redeterminations.

Both states indicated that they are allowing PACE organizations to use telephone calls as a means of service delivery but prefer that organizations use video chat/videoconferencing where possible. CMS indicated that it is not requiring written consent for the use of telehealth.

It is important to note that these are state-specific strategies and each state will have a different approach to working with PACE organizations and other providers during the pandemic.

Ongoing Challenges

The call addressed challenges facing PACE organizations that mirror those faced by other providers, namely workforce and access to personnel protective equipment (PPE).

With respect to workforce, personal attendant services workers and similar roles were highlighted as most difficult to fill at this point. While there were not many specific solutions mentioned, there was some discussion of reassigning staff in other roles to these in cases where they are qualified to do so.

For PPE, CMS acknowledged access to PPE as a national challenge, and encouraged PACE organizations to take steps to reduce their burn rate of these supplies. The agency also mentioned steps it was taking to reduce PPE use nationwide, including guidance on elective procedures.

One challenge specific to PACE organizations that came up was accessing PACE participants living in nursing homes. While CMS mentioned the restricted visitor guidance for nursing homes, the agency said IDT team members should be allowed access to these participants as long as those team members do not present symptoms. CMS told the PACE organizations on the call that if facilities are not allowing them to access such individuals, the PACE organization should notify CMS via their Account Manager and CMS can help clarify.


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