PACE CFCO Workgroup Meets
On March 16th, the Department of Health (DOH) convened the fourth Community First Choice Option (CFCO) workgroup focused on Programs of All-Inclusive Care for the Elderly (PACE) issues. As in other workgroup discussions, participants expressed concerns regarding social transportation and suggested that DOH guidance should set criteria tied to ADL and IADL needs of participants. DOH stressed that any CFCO service need must be tied directly to the goals of the individual’s service plan and said it was working on clear guidelines with limitations. Because PACE plans are required to track and document service request denials in a specified way, it is especially important for PACE that the guidelines be clear and well-defined.
Some participants expressed concern about the need to ensure that there is an end value to the requested service. For example, an individual requesting vehicle modification may be able to drive somewhere independently but would still need the assistance of an aide to be safe once they reach their destination. While DOH reiterated that the goal of CFCO is community integration, meeting participants pointed out that for many individuals, the PACE center is the heart of their community, and certain benefits of CFCO may actually result in more isolation.
Workgroup participants noted that federal PACE regulations prohibit programs from paying for rent, while security deposit and first month’s rent is a CFCO benefit. DOH will determine if this is a conflict. DOH clarified that in cases where multiple program benefits may apply, Money Follows the Person benefits would be used first, then CFCO.
Given the size and demographics of most PACE programs, there was concern about the amount of effort needed for network development and provider credentialing to prepare for services that may not be used. While the state would prefer a single set of guidelines for all plans regarding CFCO benefits, staff did express a willingness to discuss whether there were cases that warranted PACE-specific rules. DOH has not yet discussed how CFCO services would be incorporated into the rate. Participants stressed that reimbursement rates needed to be made available early enough to allow contracting with providers, and that the reimbursement should be made at the time the benefit is rolled out, not retroactively.
DOH is seeking specific feedback (via CFCO@health.ny.gov) from PACE plans on the following issues:
- Unique challenges CFCO poses specifically to PACE
- Recommendations on how the CFCO roll out may be customized for PACE
Contact: Darius Kirstein, dkirstein@leadingageny.org, 518-867-8841