PACE State Plan Amendment Preprint
CMS-10227, OMB 0938-1027
Background
The Balanced Budget Act (BBA) of 1997 created section 1934 of the Social Security Act that established the Program for the All- Inclusive Care for the Elderly (PACE). PACE programs coordinate and provide all needed preventive, primary, acute and long-term care services so that older individuals can continue living in the community. PACE is an innovative model designed to enable individuals age 55 and older who are certified to need nursing home care to live as independently as possible. The legislation authorized the PACE program as a Medicaid State plan option serving the frail and elderly in the home and community. The BBA incorporates the PACE model of care as a benefit of the Medicare program and enables States to provide PACE services to Medicaid beneficiaries as a State option. To provide this Medicaid benefit, States must elect to cover PACE services as a State Plan option and collaborate with potential PACE organizations to submit the PACE provider application. Upon completion and approval of these documents, a three party program agreement is executed. As of December 2016, there are approximately 120 PACE organizations operating in over 30 States.
A. Justification
1. Need and Legal Basis
Pursuant to notice given in the Federal Register, 64 FR 66271 (November 24, 1999), if a State elects to offer PACE as an optional Medicaid benefit, it must complete a State Plan Amendment preprint packet described as “Enclosures #3, 4, 5, 6 and 7”. The information, collected by CMS from the State on a one-time basis is needed in order to determine if the State has properly elected to cover PACE services as a State Plan option. Outside of the one-time requirement, States would need to update their SPA whenever they make changes to their eligibility section or rate setting methodology.
2. Information Users
CMS will review the information provided in order to determine if the State has properly elected to cover PACE services as a State Plan option.
Eligibility is reviewed to ensure it matches with what is done in the particular state while the methodology is reviewed to ensure it meets regulatory requirements.
3. Use of Information Technology
The application process is facilitated through the use of emails, faxes and phone calls between the Regional Offices and the States. Once the preprint forms are completed, every effort is made to communicate via the use of information technology to complete the process.
4. Duplication of Efforts
There is no duplication of effort on how information is associated with this collection. The State is required to complete the preprint only once.
5. Small Businesses
The collection of this information is not applicable to small businesses.
6. Less Frequent Collection
Interested States are required to complete a preprint packet (Enclosures #3-7) only once. In the event that the state changes something in the state plan, only the affected page must be updated.
7. Special Circumstances
There are no special circumstances that would require an information collection to be conducted in a manner that requires respondents to:
Report information to the agency more often than quarterly;
Prepare a written response to a collection of information in fewer than 30 days after receipt of it;
Submit more than an original and two copies of any document;
Retain records, other than health, medical, government contract, grant-in-aid, or tax records for more than three years;
Collect data in connection with a statistical survey that is not designed to produce valid and reliable results that can be generalized to the universe of study,
Use a statistical data classification that has not been reviewed and approved by OMB;
Include a pledge of confidentiality that is not supported by authority established in statute or regulation that is not supported by disclosure and data security policies that are consistent with the pledge, or which unnecessarily impedes sharing of data with other agencies for compatible confidential use; or
Submit proprietary trade secret, or other confidential information unless the agency can demonstrate that it has instituted procedures to protect the information's confidentiality to the extent permitted by law.
8. Federal Register/Outside Consultation
The 60-day notice published in the Federal Register on December 16, 2016 (81 FR 91175). No comments were received.
The 30-day notice published in the Federal Register on February 17, 2017 (82 FR 11037). No comments were received.
9. Payments/Gifts to Respondents
There are no payments of gifts associated with this collection.
10. Confidentiality
There is no personal identifying information collected.
11. Sensitive Questions
There are no sensitive questions associated with this collection. Specifically, the collection does not solicit questions of a sensitive nature, such as sexual behavior and attitudes, religious beliefs, and other matters that are commonly considered private.
12. Burden Estimates (Hours & Wages)
Wages
To derive average costs, we used data from the U.S. Bureau of Labor Statistics’ May 2015 National Occupational Employment and Wage Estimates for all salary estimates (http://www.bls.gov/oes/current/oes_nat.htm). In this regard, the following table presents the mean hourly wage, the cost of fringe benefits (calculated at 100 percent of salary), and the adjusted hourly wage.
Occupation Title |
Occupation Code |
Mean Hourly Wage ($/hr) |
Fringe Benefit ($/hr) |
Adjusted Hourly Wage ($/hr) |
Medical and Health Services Manager |
11-9111 |
50.99 |
50.99 |
101.98 |
As indicated, we are adjusting our employee hourly wage estimates by a factor of 100 percent. This is necessarily a rough adjustment, both because fringe benefits and overhead costs vary significantly from employer to employer, and because methods of estimating these costs vary widely from study to study. Nonetheless, there is no practical alternative and we believe that doubling the hourly wage to estimate total cost is a reasonably accurate estimation method.
Burden Estimates
The burden associated with this requirement is the time and effort put forth by a State to develop its State plan amendment to elect PACE as an optional Medicaid benefit. CMS estimates that it would take one State approximately 20 hours to complete the requirement including time to review instructions, search existing data resources, gather the data needed, and complete and review the information collection.
At 20 hours x $101.98 per hour, the cost for one state would be $2,039.60. Since over 30 States have already elected PACE as an optional benefit, the burden estimate provided here only includes the remaining States/Territories. We are unable to determine how many of the remaining States will elect this option in any given year; therefore, we have divided the burden by 3 (OMB approval period in years) to obtain the estimated annual burden.
Time: 140 annual hours = 7 States x 20 hours
(21 States \ 3 = 7 States)
Cost: $14,277.20 annual cost = 7 States x $2,039.60 per State
This is likely far above the realistic cost since we estimate only 2-5 states at most will be submitting a package within the next 3-5 years, however we are estimating on the high end since we have no way of knowing in advance the actual number.
Information Collection Instruments/Instruction/Guidance Documents
To provide PACE as a Medicaid benefit, the state must elect to cover PACE services as a State plan option.
Current Enclosures
Enclosure 3: Permits state to elect PACE for Categorically Needy
Enclosure 4: Permits state to elect PACE for Medically Needy
Enclosure 5: Addresses amount, duration and scope of medical and remedial care services provided to categorically needy
Enclosure 6: Addresses amount, duration and scope of medical and remedial care services provided to medically needy
Enclosure 7:
identifies how eligibility is determined under rules applying to community groups, as well as post eligibility, and spousal post eligibility
State assurance that rates will be equal or less than cost to comparable population and narrative description of rate methodology.
State assurance of process to provide for dissemination of enrollment and disenrollment data to adjust for the difference between the estimated number of participant on which the prospective monthly payment was based and the actual number of participants in that month.
Enclosure History
In March 1998 HCFA issued an SMD and provided Enclosures 2 and 3 for interim preprint text pages, and Enclosures 4, 5 and 6 for interim preprint attachments and supplements for states to use pending the publication of the interim final regulation implementing PACE.
In September 2001 revised pre-print pages were released. Previous Enclosure 1 (which was a summary description of the program history as a demonstration, the BBA authority, and plans for transition from demonstration to permanent program) was eliminated. Enclosures 2 and 3 became Enclosures 3 and 4. Enclosures 4 and 5 became enclosures 5 and 6. Enclosure 6 (which required the state to identify any established enrollment limits) was eliminated. Enclosure 7 was created to describe how the state would determine eligibility and post eligibility for PACE under rules applying to community groups (due to the use of community based services as an alternative to institutional care).
13. Capital Costs
There are no capital costs.
14. Cost to Federal Government
The cost to the Federal government would be the time and effort put forth by a Health Insurance Specialist to review the State Plan Amendment. It is estimated that it would take one analyst 5 hours to review the State Plan Amendment. Using the average grade and step of a GS-13, step 2, at an average hourly salary of $46.94/hr x 5 hours, it would cost $234.70 for each State Plan Amendment review. To complete the review for all 56 states, it would cost the Federal government a total of $13,143.2. If we use our estimate of 7 States annually, the cost to the Federal Government would be $1,642.90.
Note: $46.94/hr @ GS-13 step 2 for the Washington-Baltimore-Arlington locality (effective January 2017). See https://www.opm.gov/policy-data-oversight/pay-leave/salaries-wages/salary-tables/pdf/2017/DCB_h.pdf.
15. Changes to Burden
This ICR does not propose any program changes or burden adjustments. Since this is a one-time collection, estimated annual burden will decrease as States/Territories elect the option.
16. Publication/Tabulation Dates
Approved Medicaid State Plan Amendments are posted on our Medicaid.gov website.
There are no plans to publish the information for statistical use.
17. Expiration Date
CMS does not oppose the display of the expiration date.
18. Certification Statement
There are no exceptions to the certification statement.
Collections of Information Employing Statistical Methods
The use of statistical methods does not apply to this form.
| File Type | application/vnd.openxmlformats-officedocument.wordprocessingml.document |
| File Title | Supporting Statement for Paperwork Burden Reduction Act |
| Author | CMS |
| File Modified | 0000-00-00 |
| File Created | 2021-01-22 |