CMS PACE Audit Resources
The Centers for Medicare & Medicaid Services (CMS) develops resources to increase transparency related to PACE audits to help drive the industry towards improvements in the delivery of health care services in the PACE program.
CMS PACE Audit Protocol
CMS Requests Comments on 2026 PACE Audit Protocol
The Centers for Medicare & Medicaid Services (CMS) issued an announcement in the Federal Register soliciting feedback on the 2026 Programs of All-Inclusive Care for the Elderly (PACE) Audit Protocol. In conjunction with this notice, CMS posted a series of supporting documents and related data collection materials on its website (see zipped file).
CMS notes that the 2026 PACE Audit Protocol was modified with two goals: to implement the new regulatory provisions that were effective in June 2024 and to incorporate the lessons learned from CMS audit experiences in 2023 and 2024. While the NPA staff is thoroughly reviewing the 2026 PACE Audit Protocol and supporting documents, we call your attention to some of the key changes in the 2026 PACE Audit Protocol:
- modifications to element data requests and compliance standards to align with new federal regulatory requirements;
- introduction of case file cover sheets and seven new impact analysis templates;
- provision of new templates with instructions for responding to requests for additional information and for submitting corrective action plans (CAPs); and
- removing burdensome collections.
NPA will undertake a detailed review of these materials and develop a draft response to the CMS request for comment, incorporating feedback from the NPA Compliance Committee, its PACE Audit and Compliance Subcommittee, and other key stakeholders. We look forward to receiving feedback on the draft comment letter once it is developed in anticipation of submitting the final comment letter to CMS by the Feb. 21, 2025, deadline. To assist members in preparing their own organization comment letters to submit to CMS, NPA will provide a comment letter template by Feb. 14, 2025, for members’ consideration and use.
Please note that this information does not impact audits undertaken in 2025. Current materials continue to apply.
If you have questions or comments regarding the 2026 PACE Audit Protocol, contact NPA Quality and Compliance.
Final PACE 2023 Audit Protocol
On Nov. 10, 2022, CMS announced the release of the final audit protocol for the Programs of All-Inclusive Care for the Elderly (PACE). The protocol and supporting data collection instruments (CMS-10630) will be used for PACE audits beginning in 2023 and are available for download on the CMS website. See “PACE Audit Protocol Package” in the Downloads section.
CMS 2023 PACE Audit Protocol Comment Materials
On May 10, 2022, the Centers for Medicare & Medicaid Services (CMS) released a second notice of opportunity to comment (PDF) (see item #2 on p. 28015) on CMS’ proposed updates to the PACE audit protocol and data collection instruments for audits beginning in 2023.
With input from PACE organization members, the National PACE Association (NPA) has developed a comment (PDF) that both expresses appreciation for CMS’ favorable consideration of numerous NPA recommendations offered in response to the initial notice of opportunity to comment (PDF) and offers several additional recommendations intended to address further the burden imposed on PACE organizations by the audit process.
Note: Beginning Jan. 1, 2022, PACE organizations are accountable for the new requirements included in the Jan. 19, 2021, final rule (CMS-4190-F2) (PDF).
Other Audit Resources
The 2017 Programs of All-Inclusive Care for the Elderly (PACE) Audit and Enforcement Report (PDF) summarizes the experience of PACE organizations
audited in CY 2017.
Archived Audit Protocol Materials
The resources in this section are no longer current, but some resources may continue to be valuable to programs.
Summary of Final PACE 2020 Audit Protocol Released by CMS on Feb. 7, 2020 (PDF)
2018 PACE Audit Updates (PDF) includes updates for the 2018 PACE audit year.
2019 PACE Audit Process Improvements (PDF) outlines PACE audit process improvements and reminders for 2019.
Review of Audit Redesign (PDF) provides an overview of the CMS audit process and the results of PACE audits through mid-July 2017.
For More Information
Contact Mia Phifer