Crosswalk

PACE Quality Data Monitoring and Reporting

PRA Supporting Statement

PRA Supporting Statement

The title of the current COI is “PACE
Quality Data Entry in CMS Health Plan
Management System.”

The title was revised to “PACE Quality Data
Monitoring and Reporting.”

PRA Supporting Statement

PRA Supporting Statement

Frequency for Reporting PACE Quality
Data with Root Cause Analysis

Under the current PRA, PACE organizations
(POs) report PACE Quality data with root
cause analysis (RCA) on a quarterly basis, in
addition to a 45-day grace period at the end
of every quarter.

CMS is changing the frequency of reporting
PACE Quality Data with Root Cause
Analysis to occur within three working
days of identifying the incident.

For example, quarter 1 ends on March 31st.
therefore, all PACE quality data must be
reported by May 15th.

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Burden Change

REV

CMS revised the title of the supporting
statement to align with the current CMS
terminology and polices for reporting and
monitoring PACE Quality Data.

REV

No impact.
CMS revised the supporting statement to
streamline the language, eliminate outdated
and/or extraneous text, and align the
terminology with the current polices for
reporting and monitoring PACE Quality Data.

REV

Under the currently approved PRA, CMS has
identified that reporting this type of data on a
quarterly basis, rather than on a more
expeditious basis, has resulted in missed
opportunities for technical assistance, and
delays in implementing quality improvement
efforts. CMS believes that reporting this data
in a more expeditious manner will promote
better collaboration, and improve the health
and safety of PACE participants.

Language in the current PRA is outdated and CMS made overall revisions to the
does not align with current polices for
supporting statement.
reporting and monitoring PACE Quality
Data.
Frequency for Reporting PACE Quality
Data with Root Cause Analysis

Reason for Change

Type of Change

2020 (new version)

2017 (Current
version)

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No impact.

Burden increase from 2
to 4 hours to account for
submitting this data in a
more expeditious
manner.

PACE Quality Data Monitoring and Reporting

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Frequency for Reporting Root Cause
Analyses

Frequency for Reporting Root Cause
Analyses

Under the current PRA, POs are required to CMS is changing the frequency for reporting
report RCAs on a quarterly basis, in addition RCAs to within 45 days of the incident
to a 45-day grace period at the end of every date.
quarter.
For example, quarter 1 ends on March 31st.
therefore, all RCAs must be reported by May
15th.

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REV

Under the currently approved PRA, CMS has
identified that reporting RCAs on a quarterly
basis, rather than on a more expeditious basis,
has resulted in missed opportunities for
technical assistance, and delays in
implementing quality improvement efforts.
CMS believes that reporting this data in a
more expeditious manner will promote better
collaboration, and improve the health and
safety of PACE participants.

Burden increase from 2
to 4 hours to account for
submitting this data in a
more expeditious
manner.

PACE Quality Data Monitoring and Reporting

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PACE Quality Measures
PACE quality measures included in the
current PRA package are: Falls, Falls with
Injury and Pressure Ulcer Prevalence.

PACE Quality Data Types

PACE Quality Measures
CMS removed the PACE quality measures
and the associated burden.

DEL

CMS removed the PACE quality measures as Reduction in the burden
estimate.
we currently collect similar data under the
PACE Quality Data reporting requirements,
and, these measures were never formally
implemented under the current PRA.

Types of PACE Quality Data

REV

CMS made this clarification to align the
No impact
terminology with current polices for reporting
and monitoring PACE Quality Data, and to
distinguish between the 2 types of data.

REV

CMS made these changes to ensure accuracy No impact
and align with current polices for reporting
and monitoring PACE Quality Data.

In the current PRA, PACE Quality Data is CMS clarified that there are two types of
referred to as “quality data” and in some
PACE Quality Data, 1). Does not require an
instances, the former terms Level I and Level RCA, for example appeals, grievances,
II are used throughout.
enrollment data, etc., and 2). Requires an
RCA, such as unexpected deaths, falls with
injury, etc., and added “PACE” to precede all
references to Quality Data.

PACE Quality Data, Appendix A
Appendix A identifies all incident types
under the term PACE Quality Data. Under
the current PRA, some of the incident types
are outdated, do not mirror industry
terminology, and are not part of the current
PACE Quality Data reporting thresholds.

We also removed all outdated references to
“Level I and Level II” data.
PACE Quality Data, Appendix A
CMS made minor updates to Appendix A to
reflect current industry terminology, provide
clarification, and align with CMS policies.
The list was also revised to reflect
alphabetical order.

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PACE Quality Data Monitoring and Reporting

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Burden Estimate to PACE Organizations Burden Estimate to PACE Organizations REV
The current PRA calculates the burden
CMS changed the estimated burden for POs
estimate for PACE organizations by using using the “average number of data entries per
the “number of possible data entries/PO,”
PO annually,” instead of the “number of
and the “estimated number of data categories possible data entries/PO.”
per data entry.”
In addition, we removed the “estimated
number of data categories per data entry.”

CMS decreased the burden estimate as the
Overall decrease in the
process for submitting PACE Quality Data is annual burden hours for
PACE organizations.
now less burdensome than previous data
collection efforts as all data is now collected
by one system and largely through drop down
menus VS narrative text.
Based on recent HPMS data, CMS changed
the estimated burden for POs using the
“average number of data entries per PO
annually,” instead of the “number of possible
data entries/PO.” We believe this is a more
accurate way to estimate the overall burden.
Also, we removed the “estimated number of
data categories per data entry as we
determined that it was not relevant to the
burden estimate and that most data categories
were reported across all PACE organizations,
especially entries regarding PACE Quality
Data without RCA.

PACE Organization Wage Estimates

PACE Organization Wage Estimates

REV

The current PRA estimates the wages for PO CMS changed the hourly wage to
staff to report PACE Quality Data at
$69.72/hour based on the U.S. Bureau of
$36.00/hour.
Labor Statistics’ May 2018 National
Occupational Employment and Wage
Estimates for industry personnel, and
adjusted for fringe and overhead.

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The wage estimate for PACE staff in the
current PRA did not account for fringe and
overhead.

Increased cost to POs.

PACE Quality Data Monitoring and Reporting

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Burden Estimate to the Federal
Government

Burden Estimate to the Federal
Government

The current PRA estimated the cost for the
Federal Government to review and analyze
PACE Quality Data at $19,205.

CMS increased the cost incurred by the
Federal Government.

REV

For accuracy and transparency, CMS
Increased cost to the
increased the burden estimate for the cost
Federal Government.
incurred by the Federal Government as it was
significantly underestimated in the current
PRA and didn’t take into account the number
of POs submitting data to CMS annually,
Also, it seemed to be based on one PACE
organization, and not the 120 POs in operation
at the time.
We increased the cost estimate to CMS from
$19,205 to $896,439.

Number of PACE Organizations in
Operation

Number of PACE Organizations in
Operation

REV

CMS made this change for accuracy purposes. Increased cost to POs.

REV

CMS made these revisions to clearly articulate No impact
the changes to the frequencies for reporting
PACE Quality Data and to update
corresponding resources.

The current PRA estimated the burden based CMS adjusted the number of POs from 120
on 120 operational PACE organizations.
to 134.

PACE Quality Monitoring & Reporting
Guidance

PACE Quality Monitoring & Reporting
Guidance

Outlines the PACE Quality Data reporting
requirements and provides relevant
resources.

CMS revised the PACE Quality Monitoring
& Reporting Guidance Document to
streamline the language, reflect changes to
the reporting frequencies, and update expired
web links.

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