PACE—Programs of All-Inclusive Care for the Elderly—is a Medicare/Medicaid program that helps people who need nursing home-level care meet their needs in the community, instead of an institution. NCQA strongly supports care that works for patients and aligns with their personal goals. We know that the provision of comprehensive, coordinated benefits through models like PACE accelerates the transition to paying for the value of care for those who need it most.
Following the success of PACE, CMS is now proposing to expand the model of care to new populations. NCQA had the chance to read the proposal and comment. We back many of the same goals as PACE; for example, the social and employment support services and access to adaptive home equipment in the Person-Centered Community Care (P3C) model. P3C will be a fully integrated care model and share the same goals as PACE, many of which NCQA implemented in our programs.
Improving on PACE
As we read through the proposed structure of the P3C model, we noticed a few opportunities for further change, which we included in a letter to CMS. We suggest the P3C model should:
- Share savings. In traditional PACE programs, the largest share of savings goes to the federal government, which has resulted in limited enrollment. More people could access new PACE-like models—such as P3C—if more savings were shared with state Medicaid programs and organizations that deliver services.
- Align PACE and P3C with HCBS. We support reconfiguring PACE requirements to support the principles of the Medicaid Home & Community Based Services (HCBS) rule. HCBS and PACE share the goal of person-centered care planning that emphasizes keeping people in their homes. Aligning PACE, P3C and HCBS will improve access to care, especially in rural areas.
- Include NCQA Accreditation. Aligning PACE and P3C with HCBS will put administrative burden on CMS. But two NCQA programs can be adapted to reduce that burden: Accreditation of Case Management for Long-Term Services and Supports and Long-Term Services and Supports Distinction. These programs address the precise needs of PACE and P3C. Both programs set a high bar in the delivery of long-term care. Auditing organizations with NCQA Accreditation/Distinction could be considered a low priority for CMS.
- Include quality outcomes measures. We encourage evaluation of P3C through our proposed quality outcomes measures*, now in testing for CMS. We are also exploring patient-reported outcome measures (PROM), and we urge CMS to include them as they become available.
Updates to these models are welcome as the health care system continues to elevate the patient in the delivery of care equation.
We strongly support models such as PACE and P3C that focus on the patient and their health goals. Read our full letter to CMS here.
*Falls Risk Assessment; Falls: Plan of Care; Patient-Reported Access to Care; Medication Reconciliation Post-Discharge; Use of High-Risk Medications in the Elderly; Potentially Harmful Drug-Disease Interactions in the Elderly; Depression Remission or Response for Adolescents and Adults.
Amy Maciejowski is a Program Manager for State Affairs at NCQA. She supports NCQA’s work with state legislators and regulators. Amy holds a master’s degree in Political Communications from American University.