SPECIAL BULLETIN COVID-19 #27: Update for PACE Organizations

Monday, March 30, 2020

PACE organizations should follow the guidance of the local, state and federal officials and thoroughly document reasoning for making decisions which may fall outside of the PACE program model. NC Medicaid will provide flexibilities in the following areas:

  • Enrollments – Effective April 1, 2020, PACE organizations have the option to temporarily suspend new enrollments. The PACE organization’s decision to temporarily suspend new enrollments should be communicated to NC Medicaid via memorandum. The communication should include the new enrollment suspension effective date as well as the timeframe for the suspension. 
  • Initial Health and Safety Assessments – The Health and Safety assessment is conducted as a means of ensuring that the applicant’s health, safety or welfare will not be jeopardized by living in the community. The assessment requires an on-site evaluation. Due to COVID-19, effective March 1, 2020, the PACE organization has the option of delaying enrollment in the event the PACE organization cannot complete a Health and Safety assessment which considers all the following: 
    • An evaluation of the applicant’s residence either onsite or via remote technology;
    • An evaluation of the applicant’s social support system, including the willingness and capabilities of all informal caregivers; and
    • An evaluation of whether the applicant can be safely transported to the PACE Center.

          The reason for the delay should be clearly documented and the local DSS notified about the delay by checking the revision box in section
          2, page 2 of the 5106 form. The PACE organization should note the enrollment has been delayed and the proposed date of enrollment.

  • Annual Health and Safety Assessments – Effective March 1, 2020 – Dec. 31, 2020, annual Health and Safety assessments for currently enrolled participants may be completed either at the participant’s residence or via remote technology. 
  • PACE Center Closures – PACE organizations have the option to close the Adult Day Health portion of its PACE Center to assist with promoting social distancing and preventing the spread of COVID-19 while maintaining the operation of the clinics and delivery of therapy services. The PACE organization should ensure the needs of participants normally addressed at the Adult Day Health portion of its PACE Center are able to be met in the participants’ homes.
  • PACE Center Attendance – As communicated by CMS, NC Medicaid supports limiting PACE participants from attending the PACE Center as a means of minimizing the potential for exposure to COVID-19. The attendance limit of a participant as a result of COVID-19 precautions will not be viewed by NC Medicaid as a service reduction and therefore will not be appealable by the participant. Participants should, however, be informed of their right to file a grievance. The PACE organization must discuss with and provide to the participant in writing the specific steps, including timeframes for response, that will be taken to resolve the participant’s grievance.
  • Annual FL2s – Clinical Policy 3B, Section 5.5.2 requires the PACE organization to submit an FL2 each calendar year to verify the enrollee continues to meet nursing facility level of care requirements. The submission of annual FL2s, for current participants will be waived beginning March 1, 2020 – Dec. 31, 2020. PACE participants will be deemed to meet nursing home level of care and deemed eligible for the PACE program until their next scheduled annual level of care review due in 2021 (e.g. if an annual FL2 is due in March 2020, the submission requirement of the March 2020 annual FL2 will be waived and the next annual FL2 will be due March 2021).   
  • Prior Approvals – Clinical Policy 3B, Section 5.1 requires prior approval for PACE enrollment. The submission of annual prior approvals will be waived between March 1, 2020 – Dec. 31, 2020.  Prior approvals in place during March 1, 2020 – Dec. 31, 2020, will remain in effect until the next scheduled due date in 2021 (e.g. if an updated prior approval is due March 2020, the submission requirement of the March 2020 prior approval will be waived and the next prior approval will be due March 2021).  
  • Assessments/Reassessments – As communicated by CMS, NC Medicaid supports the use of remote technology as appropriate to complete scheduled and unscheduled participant assessments, care planning monitoring, communication and other related activities that would normally occur on an in-person basis. All assessment and reassessment timelines should be followed.

Reminders

  • Participants living in Skilled Nursing Facilities (SNFs) - PACE organizations are responsible for monitoring the care of participants currently living in nursing homes (NHs). Per CMS, staff from the PACE organizations are considered healthcare providers and therefore should be allowed entrance to NHs to monitor the care of PACE participants if the staff is not ill or showing symptoms. PACE organizations have the option of monitoring participants residing in NHs via remote technology if needed.
  • Timelines associated with service delivery requests, appeals and grievances – At this time NC Medicaid has not relaxed timeframes associated with service delivery requests, appeals and grievances. PACE organizations are expected to follow the timelines related to service delivery requests, appeals and grievances noted in federal and state regulations. 
  • OAH Hearings – The office of administrative hearings (OAH) has implemented new procedures in response to COVID-19. Information about the new procedures can be accessed at  https://files.nc.gov/ncoah/documents/files/OAH-Response-to-COVID-19.pdf
  • Emergency preparedness plans – The PACE organization must comply with all applicable federal, state and local emergency preparedness requirements. The PACE organization must establish and maintain an emergency preparedness program and is expected to update its emergency preparedness plan to include its response to COVID-19.
  • Infection Control plans – A PACE organization is required to update its infection control plans to include its response to COVID-19. The PACE organization must continue to follow accepted policies and standard procedures with respect to infection control, including at least the standard precautions developed by the Centers for Disease Control and Prevention.

PACE Organizations must establish, implement and maintain a documented infection control plan that includes procedures to identify, investigate, control and prevent infections in every PACE center and in each participant’s place of residence, as well as procedures to record and develop corrective actions related to any incidents of infection.

Author: 
GDIT, (800) 688-6696