PACE organizations should continue to follow the guidance of the local, state and federal officials regarding COVID-19 and thoroughly document reasoning for making decisions which may fall outside of the PACE program model. This guidance supplements the Special Bulletin COVID-19 #27 released on March 30, 2020. The temporary flexibilities noted in Special Bulletin COVID-19 #27 and this Special Bulletin will end the earlier of the cancellation of the North Carolina state of emergency declaration or December 31, 2020.
PACE Program Flexibilities:
- Use of remote technology – PACE organizations may use remote technology as appropriate for initial FL2s, scheduled and unscheduled participant assessments, care planning, monitoring, health and safety assessments (initial, annual and address change), communications and other related activities that would normally occur on an in-person basis.
As noted by CMS in its April 9, 2020 communication to PACE organizations, if remote technology is used, it must be real-time communications and the platform is a type consistent with one described in the HHS Office for Civil Rights. The use of remote technology should be properly documented in the participant’s medical record.
- Semi-annual Reassessments - If there has not been a significant change in an individual’s functioning or status, the PACE organization has the option of not completing a semi-annual assessment and continue with the current level of services until the next annual review. The reason for the decision to defer the semi-annual assessment should be clearly documented in the participant’s record to include notification and agreement from the participant.
- Flexibilities on signature requirements – The DHB-5106 form is used for communication, notification and documentation between the local DSS and the PACE organization. Due to the COVID-19 emergency, a “verbal signature” or “verbal concurrence” from the PACE applicant/participant or the representative may be obtained on the 5106 form.
In addition, the PACE organization can obtain a “verbal signature” or verbal concurrence related to a participant’s enrollment in PACE or continued enrollment in PACE where a signature requirement is noted in the CFR.
The PACE organization should maintain a record of the verbal signature or concurrence that clearly documents who took part in the verbal agreement, both at the PACE organization and the participant side (for example, PACE organization enrollment coordinator, participant, their spouse, daughter, etc.).
- Adult Day Health Operations – PACE organizations have the authority to suspend or reduce its Adult Day Health operations as a means of promoting social distancing and the spread of COVID. The PACE organizations should ensure that all participants not attending the Adult Day Health program have adequate in-home supports to include medication and coordination of necessary meals and any other services normally provided at the Adult Day Health in order to ensure the safety and well-being of the PACE participant.
- PACE Clinic Operations – The PACE organization continues to be responsible for coordinating the medical care of its participants. In doing so, measures should be taken to ensure adequate clinic hours are available to address the needs of the participants. PACE clinic operations should incorporate measures to promote social distancing and to prevent the spread of COVID.
- NC Medicaid Quarterly On-site Monitoring Visits - Onsite visits by NC Medicaid PACE Unit staff are suspended. The PACE Unit will complete quarterly monitoring via desktop reviews and continue to participate on CMS calls.
Additional Guidance:
- Voluntary Disenrollments – PACE participants can continue to exercise their right to voluntarily disenroll from PACE. In the event a participant chooses to voluntarily disenroll, it continues to be the PACE organization’s responsibility to ensure the individual is linked to comparable services the individual is receiving through the PACE organization to include assistance/referral to local DSS as applicable until the effective date of disenrollment.
Medicaid benefits which are different from PACE enrollment will not be reduced or terminated during the COVID-19 emergency, with the exceptions: beneficiaries moving out of state, beneficiaries requesting termination of benefits, and beneficiaries who are deceased. The DSS will follow its policy/procedures after the PACE disenrollment of continuing the Medicaid without PACE enrollment.
- Emergency Preparedness Plans – Per CFR, the PACE organization’s emergency preparedness plans should include information about the use of volunteers and other emergency staffing strategies to address surge needs during the COVID emergency. In addition, the emergency preparedness plans should include arrangements with other PACE organizations, PACE centers, or other providers to receive participants in the event of limitation or cessation of operations in order to maintain the continuity of services to PACE participants.
PACE organizations are requested to review its emergency preparedness plan to ensure it includes the above noted information and update the plan if needed.
- 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 suspension effective date as well as the timeframe for the suspension.
- Participants living in Skilled Nursing Facilities (SNFs) - PACE organizations are responsible for monitoring the care of participants currently living in SNFs. PACE organizations have the option of monitoring participants residing in NHs via remote technology if needed.
- Reporting any positive COVID cases – Immediate notification should be made to the local health department in the event of a positive COVID case. The assigned PACE Unit staff and CMS should also be informed of any positive cases after notification is made to the local health department.
- Weekly PACE organization Operation Updates – Due to the COVID-19 emergency, PACE organizations are requested to provide updates regarding its operations and response to the COVID-19 emergency to the PACE Unit on a weekly basis and when a significant event occurs related to operations or a PACE participant.
Contact NCTracks: (800) 688-6696; NCTracksProvider@nctracks.com