PACE is a provider-led model that offers fully integrated care to frail adults ages 55 and older with nursing-facility level of care needs while allowing them to remain in the community. The June 2025 Report to Congress included a chapter presenting findings on the statutory and regulatory framework governing the program, as well as key elements of the PACE model. During development of the chapter, Commissioners and interviewees, including federal and state officials, PACE organizations, and consumer advocates, raised questions about the transparency of the PACE model, particularly how states and the federal government evaluate compliance and monitor quality.
In this session, staff introduced new work examining how state Medicaid agencies oversee PACE organizations and carry out their oversight responsibilities. The presentation highlighted findings from a review of three core oversight documents: required three-way program agreements among the Centers for Medicare & Medicaid Services (CMS), states, and PACE organizations; optional two-way agreements between states and PACE organizations; and waiver requests submitted under Section 903 of the Medicare, Medicaid, and the SCHIP Benefits Improvement and Protection Act of 2000 (BIPA, P.L. 106-554), known as BIPA 903 waivers.