CMS Updates PACE Audit Process

Last week, the Centers for Medicare and Medicaid Services (CMS) announced that it would be implementing several Program of All-Inclusive Care for the Elderly (PACE) audit process improvements for 2019. The changes include improved in-depth auditor training and a modification of condition classification definitions to better reflect how CMS determines the impact to participants and whether a condition of non-compliance warrants immediate correction. The agency is providing an additional day for certain sample case file submissions but abbreviating the timeline for corrective action plans related to corrections identified in the final audit report. PACE Organizations will be limited to three universe submission attempts. If the third attempt does not produce a usable universe, CMS will consider the impact of the universe submission inaccuracies during the condition classification and will note the failure in audit reports.

CMS will continue to perform audits over two consecutive weeks: week one as an off-site desk-review, week two as an in-person review of the onsite element and any elements not reviewed during week one. CMS expects to publish a revised audit protocol for 2020 PACE audits within the next few months. The text of the letter is available here. Feedback and questions should be addressed to PACEAuditsQs@cms.hhs.gov.

LeadingAge NY Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841