SPECIAL BULLETIN COVID-19 #145: Updated Guidance for PACE Organizations

Monday, December 21, 2020

Program of All-inclusive Care for the Elderly (PACE) organizations should continue to follow the guidance of 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 Special Bulletin COVID-19 #27 released on March 30, 2020 and Special Bulletin COVID-19 #47 released on April 17, 2020. Unless a specific date to end the flexibility is indicated below, the temporary flexibilities noted in this Special Bulletin will end the latter of the cancellation of the North Carolina state of emergency declaration OR March 31, 2021.

  • Use of remote technology. PACE organizations may continue to use remote technology as appropriate for initial FL2s, scheduled and unscheduled participant assessments to include semi-annual reassessments, 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 communication and the platform must be a type that is 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.
  • 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 representative may continue to be obtained on the 5106 form. In addition, the PACE organization may continue to 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 (e.g., PACE organization enrollment coordinator, participant, their spouse, daughter, etc.).
  • Adult Day Health Operations. PACE organizations continue to have the authority to suspend or reduce Adult Day Health operations as a means of promoting social distancing and the spread of COVID-19. 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 center in order to ensure the safety and well-being of the PACE participant. 
  • 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 continue to be waived through March 31, 2021.  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 date.
  • Prior Approvals. Clinical Policy 3B, Section 5.1 requires prior approval for PACE enrollment. The submission of annual prior approvals will continue to be waived through March 31, 2021.  Prior approvals in place remain in effect until the next scheduled prior approval due date.


  • PACE Participants living in Skilled Nursing Facilities (SNFs). PACE organizations are responsible for monitoring the care of participants currently living in SNFs. PACE organizations continue to have the option of monitoring participants residing in SNFs through remote technology if needed.
  • Semi-annual Reassessments. The completion of semi-annual reassessments should be reinstated effective Jan. 1, 2021. PACE organizations have the option of completing semi-annual reassessments through remote technology if needed.
  • Reporting positive COVID-19 Cases. Immediate notification should continue to be made to the local health department in the event of a positive COVID-19 case. The NC Medicaid PACE Unit  and CMS should also be informed of any positive cases after notification is made to the local health department.
  • 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 continue to incorporate measures to promote social distancing and to prevent the spread of COVID-19.   
  • Weekly PACE Organization Operation Updates. Due to the COVID-19 state of emergency, PACE organizations will continue to provide updates regarding operations on a weekly basis.
  • 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.
  • Involuntary Disenrollments. Involuntary disenrollments from the PACE program continue to be suspended. The PACE organization should notify NC Medicaid in the event there is a need to involuntarily disenroll a participant due to a health or safety reason.

CONTACT: GDIT (800) 688-6696