The National PACE Association (NPA) responded to the Centers for Medicare and Medicaid Services’ (CMS) Data Supplement to the Request for Information regarding the Person Centered Community Care (P3C) model acuity adjustment analysis. In the response, NPA cited three areas of concern:

  • Eligibility, criteria, market penetration, and service area;
  • Rate-setting methodology; and,
  • Acuity adjustment.

The CMS acuity adjustment analysis assumes there must be 80 participants enrolled in a P3C organization to be viable, and assumes approximately one-third of all eligible individuals will enroll into the P3C organization. Health Dimensions Group completed a comprehensive study of all PACE programs in 2016 and found the average penetration rate of programs that had been open for at least three years was approximately 10 percent. Health Dimensions Group is pleased that NPA referenced this study in their response, and Health Dimensions Group agrees that a nearly 33 percent penetration and a viable program of 80 participants is overly optimistic.

NPA members may read NPA’s excellent response in its entirety by logging into the NPA website, clicking on the PACE Pilots page, and looking under Policy and Advocacy.