CMS Sends Guidance to Programs of All-Inclusive Care for the Elderly (PACE) Organizations

Today, the Centers for Medicare & Medicaid Services (CMS) issued guidance to all Programs of All-Inclusive Care for the Elderly (PACE) Organizations (POs) to protect the health and safety of Americans in response to the 2019 Novel Coronavirus (COVID-19) pandemic. PACE is a Medicare and Medicaid program that helps people meet their healthcare needs in the community instead of going to a nursing home or other care facility. CMS is putting out COVID-19 guidance to all types of healthcare providers and facilities. PACE is the latest area of focus because these organizations serve older adults who often have serious chronic medical conditions and therefore are at higher risk of serious illness from the virus.

The guidance, which is a part of the White House Coronavirus Task Force efforts, offers clear, actionable information to POs on accepted policies and standard procedures with respect to infection control. CMS will use discretion, as detailed in the memo, if PACE centers need to implement strategies to mitigate the spread of the virus that are not in full compliance with the program’s requirements.

“Today we announced guidance to PACE Organizations to keep the beneficiaries who use these services healthy and safe,” said CMS Administrator Seema Verma. “It is critically important to ensure that those most at risk of serious illness from COVID-19 are protected in every care setting, including the seniors who rely on PACE Centers as healthcare providers in their daily lives.”

CMS and states are responsible for protecting beneficiaries who receive healthcare services through POs. Today’s guidance aims to help control and prevent the spread of infection. In particular, the new guidance reminds all POs to establish, implement, and maintain a documented infection control plan and frequently monitor for potential symptoms of respiratory infection. POs experiencing an increased number of respiratory illnesses among participants, caregivers and/or healthcare and PACE personnel should immediately contact their state and local health officials for further guidance. The memo also states that PO personnel should be given and trained on the use of recommended personal protective equipment (PPE).

CMS recognizes that there may be circumstances where a PO needs to implement strategies that do not fully comply with programmatic requirements in order to protect beneficiaries from the spread of the virus. The agency will take those situations into consideration when conducting monitoring or oversight activities of POs. This will allow POs to use strategies including, for example, using telehealth to provide patient assessments that would normally be conducted on an in-person basis or limiting PACE center attendance in order to minimize the potential for exposure.

The guidance also explains that POs can ensure access to Part D drugs by relaxing “refill-too-soon” edits and providing maximum extended day supply, providing home or mail delivery of Part D drugs, and waiving prior authorization requirements at any time that they otherwise would apply to Part D drugs used to treat or prevent COVID-19, if or when such drugs are identified. These flexibilities help break down barriers to PACE participants accessing medications during this pandemic.

This guidance, and earlier CMS actions in response to the COVID-19 virus, are part of the ongoing White House Task Force efforts. To keep up with the important work the Task Force is doing in response to COVID-19 click here www.coronavirus.gov. For a complete and updated list of CMS actions, and other information specific to CMS, please visit the Current Emergencies Website.

Update, March 24th: In a call with PACE programs, CMS offered further clarification that with the rapidly changing environment, PACE programs are better equipped as providers on the ground to make decisions about staff and participant care than timely additional guidance can be developed by CMS, and that this guidance equips PACE programs to focus on participant needs first and foremost. CMS will exercise enforcement discretion as a result. To the greatest extent possible, PACE programs will document rationale for strategies implemented.