Today, Community Catalyst’s Center for Consumer Engagement in Health Innovation submitted comments on the proposed regulations updating the Program of All-inclusive Care for the Elderly (PACE) model. The regulations proposed by the Centers for Medicare and Medicaid Services (CMS) represent the first major update to the PACE program in a decade. PACE is a team-based program available to nursing-home eligible people over age 55 with Medicare or Medicaid, or both (in some states, only Medicaid beneficiaries are eligible). The program’s goal is to keep participants in the community in which they live rather than a nursing home or other care facility. PACE does this by coordinating care and connecting members to many specialists and other providers, as well as to a range of services and supports in the community to provide a well-integrated care experience. Despite evidence showing PACE participants have significantly lower rates of hospital, nursing home, and emergency department utilization and lower overall rates of inpatient days, both the numbers of PACE programs and the level of enrollment has remained relatively small.

To address some of these challenges, CMS is proposing a number of improvements including operational flexibilities, particularly around the Interdisciplinary Team (IDT) that is so central to the benefits of the PACE model. For example, the integration of community-based providers as primary care providers (PCPs) and expansion of the professions which would qualify as PCPs to include nurse practitioners and physician assistants are both steps in the right direction. The ACA has enabled CMS to explore and promote new models of care via demonstrations to integrate care for some of the most high-need, high-cost consumers. Our comment letter urges that some of this work, including the PACE program, be integrated into the work of the Medicare-Medicaid Coordination Office within CMS.

In general, the Center is supportive of the proposed regulations and believes it is important to build upon the lessons learned from PACE’s successes over the past four decades and expand these to other integrated models of care. In our comments, we urge CMS to make building awareness of this model more of a priority and in the final regulations, to encourage provisions that will allow for greater expansion of the number of PACE programs across the nation.