Summary of Application Changes

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-10631 Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

2016 PACE
Application
Section

1. PACE application will be submitted In the application process, technology is used in
through CMS’ Health Plan
the collection, processing, and storage of the
Management System.
data. Applicants must submit the entire PACE
application and supporting documentation
through the CMS HPMS. The substantial
technical change is that the application
submission is 100% web based and attestation
driven. When compared to the paper application,
there are fewer required documents.

N/A

2. Adding section 3.29 “State
Attestations” to the electronic
PACE application. An upload
is required.

3.29

The purpose of this section is to ensure that the state
is willing to enter into a PACE program agreement
with the applying entity, and that it has processes in
place to ensure compliance with its obligations under
the program (42 CFR §460.12 (b)).

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
D

D –Although this
section was added to
the application, a
decrease in burden is
being identified
because the
application is 100%
electronic
1

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

2016 PACE
Application
Section

3. Adding section 3.31 “Application
Applicants are required to submit an attestation
Attestation” to the electronic PACE about the information and statements in their
application. An upload is required. application.

3.31

4. Added section 3.32 “State
Applicants are required to submit a State Readiness
Readiness Review” to the electronic Review of their PACE center.
PACE application.

3.32

5. Addressed typographical issues

Certain
miscellaneous
sections

To maintain a consistent, proper format and
provide clarity

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
D – Although this
section was added to
the application, a
decrease in burden is
being identified
because the
application is 100%
electronic
D – Although this
section was added to
the application, a
decrease in burden is
being identified
because the
application is 100%
electronic
N

2

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

6. Added the State Assurance
Signature Pages to the Table of
Contents.

The State Assurance Signature Pages were
inadvertently not included in the Table of Contents
(Section 4.3).

Table of Contents

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

7. Deleted addresses and phone
numbers for the CMS Regional
Office contacts.

This information can change over time. The more
timely information is included at the website link,
which is provided.

Section 1.2

N

Revision/Clarification

Purpose of the
Revision/Clarification

2016 PACE
Application
Section

3

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

8. Deleted attestation No. 3, which
stated:
“Applicant is licensed under state
law as a risk-bearing entity eligible
to offer health insurance or health
benefits in at least one state in the
RPPO region, and if not licensed in
all states, the applicant has applied
for additional state licenses for the
remaining states in the RPPO
regions. In addition, the scope of
the license or authority allows the
applicant to offer the type of MA
plan that it intends to offer in the
state or states.

The original language was erroneously included. The
revised language corresponds to the regulatory
requirement and represents the correct language
included in the current electronic application.

Section 3.3.A.3.

N

Replaced this attestation with the
following:
“Applicant agrees to appoint a
participant representative to act as a
liaison between the governing body
and Participant Advisory
Committee, to present participant
issues to the governing body and to
ensure community representation
(42 CFR §460.62(b)(1)).

4

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification
9. Changed the regulatory citation
from 42 CFR 460.6(b) to 42 CFR
460.60(b).

Purpose of the
Revision/Clarification
Revised to include correct regulatory citation.

10. Clarify why the applicant is asked to Due to a formatting issue, this prohibited marketing
attest that its employees or agents practice did not appear in the attestation, as was
will not use various prohibited
intended. This prohibited practice is explicitly cited in
marketing practices, including
the regulation; therefore, it is appropriate to include as
“unsolicited door-to-door
part of the attestation. In addition, the applicable
marketing,” which was not included regulatory citation for the 5 identified prohibited
in the current version of the
marketing practices was added (42 CFR 460.82 (e)(1application.
5).

Section 3.3.B

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

Section 3.5.A.6

N

2016 PACE
Application
Section

5

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification
11. Numbering of identified
requirements is off.

Purpose of the
Revision/Clarification
Separated out existing attestation language by adding
No. 4 to properly reflect the regulatory requirements.
No change otherwise to existing language.

12. Changed the attestation to say:
Revised to align with the regulatory language at 42
“Applicant ensures that staff knows CFR 460.72 (c)(4).
how to use the emergency
equipment” instead of “Applicant
ensures that all staff knows how to
use the emergency equipment.”

2016 PACE
Application
Section
Sections
3.16.A.3 and
3.16.A.4

Section 3.22.A.2

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

N

6

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

13. Changed the regulatory citation
from 42 CFR 460.50(1)(2) to 42
CFR 460.50(d)(1)(2).

Revised to include correct regulatory citation.

Section 3.25.A.1

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

14. Changed the regulatory citation
from 42 CFR 460.52(1) to 42 CFR
460.52(a)(1).

Revised to include correct regulatory citation

Section 3.25.A.2

N

Revision/Clarification

Purpose of the
Revision/Clarification

2016 PACE
Application
Section

7

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification
15. Changed the regulatory citation
from 42 CFR 460.52(2-4)) to 42
CFR 460.52(a)(2-4).

Purpose of the
Revision/Clarification
Revised to include correct regulatory citation

16. Slightly modified and combined the Revised to more accurately reflect the regulatory
last 2 bulleted requirements and
requirements and proper regulatory citation.
changed the identified regulatory
citation from 42 CFR 460,200(f)(iiii) to 42 CFR 460.200(f)(1-2).

Section 3.25.A.3

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

Section 3.26.A.5

N

2016 PACE
Application
Section

8

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification
17. Modified the introductory statement
of the Quality Assessment and
Performance Improvement Program
(QAPI) section.

Purpose of the
Revision/Clarification
Revised to accurately represent the purpose of the
QAPI section and provide the correct regulatory
citation. The introductory statement inadvertently
referenced the purpose of the “Maintenance of
Records & Reporting Data” and not the QAPI, as
was intended.

2016 PACE
Application
Section
Section 3.28

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

9

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification
18. Added the following attestation:
“A. In HPMS, complete the table
below:
1. Applicant has assurance from
the SAA of the State in which
the program is located indicating
that the State considers the
entity to be qualified to be a
PACE organization and is
willing to enter into a PACE
program agreement with the
entity.”

Purpose of the
Revision/Clarification
This attestation was inadvertently excluded. The
attestation language corresponds to the regulatory
requirement.

2016 PACE
Application
Section
Section 3.29.A.

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
D – Although this
section was added to
the application, a
decrease in burden is
being identified
because the
application is 100%
electronic

10

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

19. Deleted attestation No. 1, which
stated:
“Applicant agrees to do the
following as specified in 42 CFR
§460.130(a-c):
• Develop, implement, maintain and
evaluate a QAPI program;
• Reflect the full range of services
furnished by the PACE
organization; and
• Take action resulting in
improvements in its performance in
all types of care.”

The original language was erroneously included. The
revised language corresponds to the regulatory
requirement and reflects the correct language
included in the current electronic application.

Section 3.30.A.1

N

Replaced this attestation with the
following:
“Applicant is requesting specific
modifications or waivers of certain
regulatory provisions as part of this
application as permitted under
Section 903 of the Benefits
Improvement and Protection Act
(BIPA) of 2000.”

11

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

2016 PACE
Application
Section

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
D – Although this
section was added to
the application, a
decrease in burden is
being identified
because the
application is 100%
electronic

20. Added a new attestation as follows: This attestation was inadvertently excluded. The
attestation language corresponds to the regulatory
“Applicant ensures that specific
requirement.
modifications or waivers of certain
regulatory provisions as part of this
application have been submitted to
the SAA for review and approval, as
specified in 42 CFR 460.(a)(2).”

Section 3.30.A.2

21. Deleted the words “Misc.
Comments.”

N
Immediately
preceding Section
4.3: “State
Assurance Signature
Pages”

These words were erroneously included.

12

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

22. Deleted reference PACE in relation The word “other” Medicare Advantage plans, in this
to other Medicare Advantage plans context, implies that PACE is a form of MA plan, and
in the introductory paragraph and it is not.
the “County Rates” discussion.
Specifically, the word “other” was
deleted.

2016 PACE
Application
Section
Section 4.4

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

The following are revisions made to the application subsequent to the
publication of the initial 30-day Federal Register notice on May 2, 2016 (81 FR 26234)

13

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

2016 PACE
Application
Section

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

23. Updated the Table of Contents

Modified to reflect revision to the title of Section 4.4,
which is now “Medicare and State Medicaid
Capitation Payment” (added the word “Medicare” to
reflect the description of the Medicare aspect of the
capitation payment discussion)

Table of Contents
(Section 4.4)

24. Revised the overview section.

Modified to provide greater clarity by including only
most pertinent background information.

Section 1.1
(overview)

25. Deleted information related to
regional office contacts.

Revision made because CMS Central Office staff
provides technical support and responds to questions
during the application process.

N
Section 1.2
(Technical Support)

26. Minor revisions to the discussion
about HPMS.

To more accurately describe the role of HPMS
specific to PACE and included appropriate reference
the program agreement.

Section 1.3 (A) and
(B)

D (less information to
review)

N

14

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

2016 PACE
Application
Section

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
D (less information to
review at time of
application)

27. Deleted information regarding the
listserv.

Not necessary to include for a user accessing HPMS
for purposes of application.

Section 1.3 (D)

28. Deleted all but first paragraph
regarding appeal information.

Redundant information, as information regarding
appeal rights and process is provided as part of direct
communications to applicants in the event the
application is denied.

Section 1.5

D (less information to
review at time of
application)

29. Deleted reference to 2016 for
purposes of the application.

To avoid confusion, particularly in the event the
application is not revised annually.

Cover Sheet and
Section 2.1

N

30. Deleted the sentence: “CMS will
only accept submissions using this
current 2016 version of the MA
application.”

This is no longer needed with the transition to an
automated process. (We note that the reference to MA
was incorrect; this should have referred to the PACE
application).

Section 2.1
(“Instructions”
overview)

N

15

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

31. Added “N/A” as an option for
To inform the applicant that “N/A” is another option
responding to certain attestations, as for responding to certain attestations.
follows:

2016 PACE
Application
Section
Section 2.1
(“Instructions”
overview)

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

“In preparing a response to the
prompts throughout this
application, the applicant must
mark “Yes” or “No” or “N/A” in
sections organized with that format.

16

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification
32. Deleted the following language:

Purpose of the
Revision/Clarification

Deleted because the language does not relate to an
application but, rather, is specific to an operational
“Failure to meet the requirements PACE program.
represented in this application
and to operate a PACE plan
consistent with the applicable
statutes, regulations, and the
PACE program agreement, and
other CMS guidance could result
in the suspension of plan
marketing and enrollment. If
these issues are not corrected in a
timely manner, the applicant will
be disqualified from participation
in the PACE program, as
applicable.”

2016 PACE
Application
Section
Section 2.1
(“Instructions”
overview)

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
D (less information to
review)

17

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

33. Added 2 columns to the chart to
To provide greater clarity regarding upload
reflect required uploads specific to requirements specific to each type of application.
both initial applications and SAE
applications (and correctly
identified attestations required of
SAE applicants).

Level of
Applicant
Burden I =
Increases burden
D – Decreases
2016 PACE
burden
Application
N – No
Section
Change
Section 2.3 (Chart 1) N

34. In conjunction with No. 27 above, To appropriately reflect the additional information
changed title to reflect the additionalnow included.
information (now “Chart of
Required Attestations and
Uploads”)

Section 2.3 (Chart 1) N

35. Added “x (as applicable)” to the
Added to reflect that initial applicants may or may not
Column titled “Upload Required
upload waiver information. (This only applies to
(Initial)” to denote that a waiver
applications that are requesting a waiver(s).)
upload applies, as applicable, to an
initial application.

Section 2.3 (Chart 1) N

18

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

2016 PACE
Application
Section

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

36. Modifications to the description of Revisions made to provide greater clarity in terms of
the Part D Prescription drug Benefit the Part D application vis-à-vis this PACE
Instructions.
application.

Section 2.5

37. Deleted attestation No. 3 as follows: This is not an appropriate attestation for a PACE
applicant. The SAA determines whether an entity
“Applicant's defined geographic may apply to be a PO in a geographic area that is
service area does not duplicate a covered by another PO; the applicant would not
service area covered by another
necessarily be in a position to attest to this or have
PACE program agreement (42 CFRdirect knowledge of duplicate geographic service
§460.22(a)(b)).”
areas. (Note: see language that was added to the State
Assurances Signature Pages to address the issue of
Similarly, the following
geographic service area.
language was deleted as part of
the upload discussion: “If the
geographic service area includes
an area covered by another PO,
identify the duplicate area.”

Section 3.1 (Service D
Area)

19

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

2016 PACE
Application
Section

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
D – Although this
section was added to
the application, a
decrease in burden is
being identified
because the
application is 100%
electronic

38. Added the following attestation (No.Necessary as a follow-on to the previous attestation,
7):
which addressed the required time period for
notification of a change in organizational structure.
“For any change in organizational This information was addressed in recent guidance to
structure that includes a Change of PACE organizations.
Ownership, the applicant agrees to
abide by the general provisions
described in the MA regulations at
42 CFR 422.550.”

Section 3.2

39. Deleted reference to the Board of
Directors and replaced “consumer
representatives(s)” with PACE
participant representative(s).

To focus on the requirement for information specific
to governing body members, per regulatory language.

Section 3.3(B)

N

40. Deleted certain references to
“upload” and replaced with
“provide”.

To be clear that certain financial requirements are
ongoing and not necessarily specific to the application
requirement alone.

Section 3.4.A.3 and
Section 3.4.A.5

N

20

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

2016 PACE
Application
Section

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N (net overall effect)

41. Added attestation No. 6 to align
Modifications made to align with the structure of
with the required upload (if
other Attestation sections. Edits made to provide
applicable). And modified
greater clarity regarding current fiscal requirements.
somewhat the sequence of both the
attestations and follow-on upload
information. Also edited some of
the fiscal soundness requirements
and combined certain uploads.

Section 3.4

42. Deleted the previously-referenced The previously-referenced citations were incorrect.
regulatory citations (42 CFR
Revised to correctly identify the applicable regulatory
§460.98 and §460.102) and replaced citations.
them with the following 42 CFR
§460.92 and §460.96).

N
Section 3.14
(purpose statement)

43. Minor edits to introductory
statement.

To reflect the purpose of the section.

Section 3.16

N

44. Minor edits to introductory
statement.

To reflect the purpose of the section.

Section 3.17

N

21

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

45. Modified attestation No. 4 by
To ensure that the most recent edition of the National
replacing the “2000” edition of the Fire Protection Association's Life Safety Code is
National Fire Protection
referenced and applies.
Association's Life Safety Code with
“current” edition, as follows:

2016 PACE
Application
Section
Section 3.21

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

“Applicant ensures the PACE center
meets the occupancy provisions of
the current edition of the National
Fire Protection Association's Life
Safety Code that apply to the type of
setting in which the center is
located.

22

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification
46. Revised original attestation No. 2
which stated: “Applicant ensures
that staff knows how to use the
emergency equipment. Every site
must have available and ready for
immediate use the emergency
equipment.”

Purpose of the
Revision/Clarification
Revision made to provide greater clarity and better
align with the regulatory language.

2016 PACE
Application
Section
Section 3.22.A.2

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

Replaced this attestation with the
following:
“Applicant ensures that staff who
know how to use the emergency
equipment are on the premises of
every center at all times and are
immediately available to use the
emergency equipment.”

23

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

47. Revised original attestation No. 5
which stated:

Revision made to more closely track the regulatory
language and correct the regulatory citation.

Section 3.22.A.5

N

“Applicant agrees to provide for
emergency services, inpatient and
outpatient settings by a qualified
emergency services provider, or
one of its contract providers, either
in or out of the PO's service area in
order to evaluate or stabilize an
emergency medical condition as
specified in 42 CFR §
460.100(a)(1)(2).”
Replaced this attestation with the
following:
“Applicant agrees to provide for
emergency services, both inpatient
and outpatient settings, by a
qualified emergency services
provider other than the PO or one of
its contract providers, either in or
out of the PO's service area, in order
to evaluate or stabilize an
emergency medical condition as
specified in 42 CFR §460.100(b).”

24

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

48. Made minor edits to the following To correct minor typographical issues.
attestation:

2016 PACE
Application
Section
Section 3.23.A.7

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

“Applicant agrees that the
transportation system has been
modified to accommodate the
proposed service area/site
expansion.”

25

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification
49. Revised original attestation No. 5
which stated:

Purpose of the
Revision/Clarification
Modified to reflect an attestation statement, in line
with other attestations.

2016 PACE
Application
Section
Section 3.24.A.5

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

“Each meal must meet the following
requirements consistent with the
requirements of 42 CFR §460.78
(a): be prepared by methods that
conserve nutritive value, flavor and
appearance; be prepared in a form
designed to meet individual needs;
and be prepared and served at the
proper temperature.”
Replaced this attestation with the
following:
“Applicant agrees to provide meals
that meet the following
requirements consistent with 42
CFR §460.78 (a): be prepared by
methods, . . .”

26

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification
50. Revised original overall purpose
statement:
“The purpose of this section is to
ensure that all PACE applicants take
appropriate actions to improve
performance, including the
establishment and operation of a
QAPI in accordance with 42 CFR
Section 460.130.”

Purpose of the
Revision/Clarification
The previous regulatory citation was not all-inclusive.
Language modified to capture all requirements as part
of Subpart H instead of citing each applicable section
of the subpart.

2016 PACE
Application
Section
Section 3.28

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

Replaced this attestation with the
following:
“The purpose of this section is to
ensure that all PACE applicants take
appropriate actions to improve
performance, including the
establishment and operation of a
QAPI in accordance with 42 CFR
Section 460, Subpart H, 460.200
and 460.202.”

27

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

51. Deleted the word “provide” and
replaced with “upload.”

To reflect that the document is to be uploaded.

Section 3.28(B)

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

52. Deleted reference to SAA
“approval” of applicant waiver
requests.

To be clear that the SAA is not required to approve
waiver requests but, rather, to review such requests
and provide any concerns regarding the requests.

Section 3.30.A.2

N

53. Corrected the regulatory
requirement cited (i.e., 42 CFR
460.26(a)(2).

The regulatory citation was not completely and
accurately cited previously.

Section 3.30.A.2

N

Section 3.30
(attestation table)

N

Revision/Clarification

Purpose of the
Revision/Clarification

54. Slight modification to the
Waivers are not required of applicants in every case.
introductory statement and included
a column to provide the applicant
with the option to respond “N/A” to
the attestations.

2016 PACE
Application
Section

28

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification
55. Minor edits

Purpose of the
Revision/Clarification
To provide better clarity in terms of required
information.

56. Replaced the “Subordinated Debt” To align with updated information. Entails a similar
attestation language previously
attestation (i.e., sign-off on part of a PACE
included with the following:
organization official).

2016 PACE
Application
Section
Section 4.1.2 and
Section 4.1.3

Section 4.2

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

I (only a slight added
burden to capture the
appropriate form from
a separate web link)

“If the applicant has a subordinated debt
arrangement, the applicant must complete
the “PACE Organization Attestation of
Subordinated Debt Arrangement” form
located at
https://www.cms.gov/Medicare/HealthPlans/HealthPlansGenInfo/FSRR.html.
This completed form may be uploaded as
part of the fiscal soundness part of the
application (see section 3.4).

29

2016 High Level Summary of Change or Crosswalk of Changes for
PRA Package (CMS-XXXXX Electronic PACE Application (for Both Initial and Service
Area Expansion Applications)

Revision/Clarification

Purpose of the
Revision/Clarification

57. Added to the statement in the “State Added to denote that the State in which the PACE
Assurances and Signature Pages” applicant intends to operate its program is aware of
Section: “and operate in the
the geographic service area that the applicant
proposed geographic service area” proposes to serve, including any area that may
as follows:
duplicate an area already served by an active PO (it is
up to the State whether to allow multiple POs to serve
“State certifies that the entity
the same geographic area).
described in this application is
qualified to be a PACE provider and
operate in the proposed geographic
service area.”
58. Updated the discussion of the
To provide added clarity and reflect current approach
Medicare capitation payment
and information.
methodology discussion.

Section 4.3

Level of
Applicant
Burden I =
Increases burden
D – Decreases
burden
N – No
Change
N

Section 4.4

N

2016 PACE
Application
Section

30