TEMPLATE COMMENT LETTER ON PROPOSED PACE RULE

FOR NPA MEMBERS

October XX, 2016

Please choose one of the following options for submitting your comment:

  1. Electronically – send to
  1. By express or overnight mail –

Centers for Medicare & Medicaid Services

Department of Health and Human Services

Attention: CMS—4168—P

Mail Stop C4-26-05

7500 Security Boulevard

Baltimore, MD 21244-1850

RE: CMS-4168-P—Medicare and Medicaid Programs; Programs of All-Inclusive Care for the Elderly (PACE)

NAME OF ORGANIZATION is pleased to submit comments on the Centers for Medicare and Medicaid Services’ (CMS) proposed rule for Programs of All-Inclusive Care for the Elderly (PACE) published in the Federal Register on August 16, 2016.

DESCRIPTION OF YOUR ORGANIZATION: Include a brief description of your organization and its relationship to PACE. For example:

  • If your organization is a PACE organization, provide information on when it initiated operations, number of participants you serve, the role you play in your state’s long-term services and supports system, your experience caring for a PACE-eligible population, etc.
  • If your organization is a prospective PACE organization, your plans for PACE development.
  • If your organization is a PACE technical assistance center, speak to your experience in terms of when you initiated operations, the number and type of organizations with which you have worked, etc.

NAME OF ORGANIZATION is a member of the National PACE Association (NPA) and, like NPA, commends CMS for the thorough and thoughtful consideration that has gone into the development of the proposed rule. We support in full the comments submitted by NPA and, in particular,want to emphasize our support for NPA’s recommendationsrelated to the following (PLEASE INCLUDE THOSE ISSUES OF GREATEST IMPORTANCE TO YOU AND/OR INCLUDE OTHER ISSUES IDENTIFIED IN NPA’S COMMENT):

  • An expanded definition of primary care provider on the PACE interdisciplinary team to include nurse practitioners, physician assistants and community-based physicians in addition to PACE physicians: this allows participants in the PACE program more options for how and from whom they can receive their primary care services while maintaining the integrity of the PACE program’s interdisciplinary team which is central to its effectiveness.
  • Greater flexibility in PACE organizations' use of the PACE center and alternative care settings in response to participants' needs and preferences: this supports choice by PACE participants regarding how and where they would like to participate in activities and access PACE program services while allowing the PACE program to grow more efficiently and more nimbly.
  • Greater flexibility with regard to how individual IDT members participate in assessments and care planning with the objective of varying the composition of the IDT for individual participants based on their care needs: this makes the most effective use of the IDT members’ time, balancing the needs of assessing and care planning with the direct delivery of services to PACE participants.
  • Allowing for one IDT member to perform up to two roles on the IDT and eliminating the requirement that IDT members must “primarily serve” PACE participants: these changes will support PACE organizations’ flexible staffing and improve the operational efficiency of their teams.
  • Allowing PACE organizations to open new PACE centers in approved service areas without having to submit expansion applications: this facilitates PACE programs’ growth in response to increased enrollment and ability to offer additional settings of care within their service areas.
  • Supporting participant-directed home and community based settings options within the requirements of the PACE regulation, rather than the Home and Community Based Settings rule: this recognizes the PACE program’s current home and community-based focus and assures participants’ access to the PACE center as an option for primary care, rehabilitative care and activities.
  • Retaining the current option for PACE organizations to use contracted entities to assist them with marketing activities: this option supports seniors’ awareness of PACE as an option that might best meet their needs.

If finalized, we believe that, collectively, these changes will provide PACE organizations with much needed operational flexibilities resulting in more efficient operations, and new opportunities to expand seniors’ access to the PACE program’s high quality services.

IF YOU’D LIKE, INCLUDE A PARAGRAPH EMPHASIZING ONE OR MORE ISSUES OF MOST IMPORTANCE TO YOU OR EXPLAINING HOW ONE OR MORE OF NPA’S RECOMMENDATIONS WILL IMPACT YOUR PROGRAM’S FUTURE.

Again, thank you for the opportunity to comment. If you have any questions, please do not hesitate to contact NAME and TITLE, at EMAIL ADDRESS or PHONE NUMBER.

Sincerely,

NAME

TITLE