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Final PACE Rule Allows Non-Physicians to Fill PCP Shoes for Some Services

Analysis  |  By Steven Porter  
   May 29, 2019

The update is designed to bolster protections and improve care for program participants while easing up on the administrative and regulatory burden shouldered by PACE organizations, CMS said.

Non-physician medical providers, such as nurse practitioners (NP) and physician assistants (PA), will be allowed next year to take the place of primary care physicians (PCP) in providing some services for participants in Programs of All-Inclusive Care for the Elderly (PACE), under a final rule released this week.

The change was rolled out Tuesday by the Centers for Medicare & Medicaid Services in what the agency describes as an effort to improve care and protections for PACE participants while also giving programs greater flexibility. This final rule, which marks the first major update since 2006, comes nearly three years after changes were proposed.

"This rule strengthens the PACE program by offering a more flexible and adaptable approach to the coordinated care that patients receive from PACE organizations, which will allow care teams to provide seamless, better-tailored care to individual patients," said CMS Administrator Seema Verma in a statement.

The non-physicians who will be allowed to serve in some capacities as PCPs must be practicing within the scope of their state licensure and clinical practice guidelines, the rule states. The added flexibility may makes things easier both operationally and financially, especially in rural areas, the rule adds.

The agency says it has historically granted waivers for individual PACE providers that sought permission to have an NP or PA fill a PCP's shoes.

"[W]e have typically granted such waivers, and we have not encountered any issues or concerns with the quality of care provided by non-physician primary care providers or community-based physicians acting in this capacity on behalf of and working collaboratively with the PACE primary care physician or medical director," the final rule states.

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More than 100 organizations across 31 states use PACE to provide medical and social services to more than 45,000 elderly people who qualify for nursing home care but can continue living in the general community safety, according to a CMS fact sheet. Enrollment in PACE has more than doubled in the past eight years, the fact sheet adds.

The updated rule drew praise from the National PACE Association (NPA).

"These updated regulations build on the success of the PACE model and will improve the ability of PACE organizations to keep even more people out of nursing homes and in the community," said NPA CEO and President Shawn Bloom in a statement.

The final rule also includes changes to the way PACE organizations are audited and their compliance programs are overseen.

Steven Porter is an associate content manager and Strategy editor for HealthLeaders, a Simplify Compliance brand.


The agency says it has historically approved waivers to allow NPs and PAs to deliver certain PCP services and experienced no problems.

The final rule, which is PACE's first major update in more than a decade, comes nearly three years after the proposed rule.

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