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
NPA Responds to Second CMS Request for Comments on 2026 PACE Audit Protocol
The Centers for Medicare & Medicaid Services (CMS) announced a second opportunity to comment on proposed revisions to the PACE Audit Protocol and data collection instruments in the Federal Register.
In conjunction with this notice, CMS released supporting documents and related data collection materials on its website (see zipped file).
CMS notes that the 2026 PACE Audit Protocol reflects two primary objectives:
- implementation of new regulatory provisions that took effect in June 2024 and
- integration of lessons learned from CMS audit experiences in 2023 and 2024.
Key updates to the protocol include the following:
- revisions to data requests and compliance standards to align with updated federal regulations;
- introduction of case file cover sheets and seven new impact analysis templates;
- new templates and instructions for responding to Requests for Additional Information (RAI) and submitting Corrective Action Plans (CAPs); and
- elimination of burdensome data collection requirements.
NPA conducted a comprehensive review of the proposed materials and submitted a formal response to CMS. The response incorporates input from the NPA Compliance Committee, PACE Audit and Compliance Subcommittee, and other key stakeholders.
Please note that these changes will apply to audits conducted in calendar year 2026 and do not affect audits undertaken in 2025.
If you have any questions 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