On March 17, 2020, the Center for Medicare & Medicaid Services (CMS) issued guidance specifically related to PACE organizations regarding infection control and prevention of the coronavirus (COVID-19). The guidance emphasized the potential need to implement new strategies for handling PACE clients and added the possibility that CMS would find acceptable certain strategies and protocols that do not fully comply with the CMS PACE requirements.

A few key highlights of the guidance include:

• Additional Strategies – CMS is recognizing that there may be circumstances where PACE organizations may need to implement strategies that do not fully comply with CMS PACE requirements in order to provide benefits to clients while ensuring clients and staff are also protected from the spread of COVID-19. An example given was that PACE organizations may use remote technology for items such as scheduled and unscheduled client assessments, care planning, monitoring and other related activities that would normally occur on an in-person basis. CMS will take into account the need to implement such remote-assistance strategies when conducting monitoring or oversight of PACE organizations. PACE organizations should clearly document why such alternative strategies may be necessary in a given circumstance.
• Medications – PACE organizations can relax “refill-too-soon” edits and provide maximum extended day supply, home or mail delivery of Part D drugs, and waive prior authorization requirements.
• Caring for COVID-19 Clients – PACE organizations are reminded that they are responsible for providing any diagnostic laboratory tests to identify COVID-19, and any other services necessary to improve and maintain a client’s overall health. This responsibility extends to the home setting, including clients who should not attend PACE centers because they have symptoms that may be attributable to COVID-19.
• Restricting Access – PACE clients may be restricted from attending the PACE center if doing so would best meet the clients’ needs in light of the pandemic threats, including the prevalence of COVID-19 in their community. It may be advisable to limit PACE center attendance even for clients that do not display symptoms of COVID-19, in order to minimize the potential for exposure.
• General Guidance – As expected, CMS continues to stress that strategies for preventing the spread of COVID-19, such as reviewing infection control practices with all personnel; implementing proper hand and respiratory hygiene; monitoring clients, personnel and visitors for fever and respiratory symptoms; using alcohol-based hand sanitizers; and implementing instruction that all individuals, including visitors, staff and residents, should stay at home when they are ill.

To read the full guidance, click here.

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