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PA Bulletin, Doc. No. 14-2644


PACE Expansion of the Living Independence for the Elderly Program for Montgomery County

[44 Pa.B. 7974]
[Saturday, December 20, 2014]

 The Living Independence for the Elderly (LIFE) Program is the Commonwealth's version of the Federal Program of All-inclusive Care for the Elderly (PACE). The Department of Human Services (Department) is planning to expand the LIFE Program in Montgomery County to satisfy participant needs and interest from providers and stakeholders in serving Montgomery County. The Department will solicit information from organizations interested in opening a LIFE center and participating in the LIFE Program in Montgomery County.

 PACE providers will be responsible to deliver specific services to individuals enrolled in the LIFE Program who are eligible for Medical Assistance (MA) and are nursing facility clinically eligible. To become a PACE provider, the organization must be enrolled in the MA Program, comply with Federal PACE regulations and adhere to the related PACE program agreements.

 There are no start-up grant dollars related to the development or operations of a LIFE center. Interested organizations will be responsible for all costs incurred during this and subsequent processes. Participant enrollment will not be authorized until the PACE program agreements between the provider, Centers for Medicare and Medicaid Services (CMS) and the Department have been signed, an executed MA Provider Agreement is in place and the Commonwealth budget allocation is sufficient to support this expansion.

 The organization shall provide an original and three hard copies of the submission to the Department within 90 days of this publication. In addition, the organization may submit a redacted copy of the submission for proprietary purposes.

Submission Requirements

 The following must be included in the submission in the order listed and documents must be clearly labeled:

1. Cover Letter

 An officer of the organization authorized to contractually bind the organization shall submit a signed cover letter which indicates interest in operating and participating as a LIFE provider serving the Montgomery County area.

2. Organizational Background

 The organization shall illustrate its history (and of any parent organization) and experience in serving individuals qualified for the PACE program and in developing long-term services and supports projects. The organization shall also identify the governing board.

3. Feasibility Study

 The organization shall provide the Department with a feasibility study (market and financial assessment) of the project showing the number of PACE-eligible citizens in the service area and the expected growth of enrollment by month for at least the first 2 years of operation. The study must be conducted by an approved PACE Technical Assistance Center which can be found at The organization shall provide a complete copy of the study or the submission will be rejected.

 The feasibility study must evaluate at least the following and provide evidence and examples to support any claims:

 • The realistic demand for the PACE services in the proposed service area. The analysis must cite the sources and years of the data used, the calculations and rationale to estimate the PACE-eligible population and it must provide comparison to successful PACE programs in similar regions, Nationally or in this Commonwealth. The analysis cannot assume that the program will achieve substantial market penetration in the early years or be a market leader, that is reaching 15-16%, without substantial proof.

 • The organization's experience in programs having principles consistent with the PACE model, and that the organization has the depth of leadership and experience required to address the challenges in developing a sustainable PACE program.

 • The organization's experience with primary, acute or long-term care services and demonstrated capability in serving a Medicare and Medicaid-eligible population.

 • The financial capacity to fund program development, assume financial risk and fund risk reserve to and through the sustainability point. This shall include a 2-year start-up budget showing the following:

 a) Monthly enrollment growth projections.

 b) Costs of operations, including marketing and advertising.

 c) Sources of funding, both initial startup and periodic infusions.

 d) The break-even census number and month, plus the desired maximum census.

 • The project design incorporates a LIFE center (licensed as an adult daily living center), transportation for the participants, 24-hour service capability, service plan and staffing ratios—all at or above the Commonwealth and Federal PACE mandates.

 • The accessibility to nursing facilities, home and community-based services, hospitals and other needs of population in this Commonwealth.

4. Service Area

 Organizations shall describe the service area (include zip codes), the estimated number of PACE-eligibles, geography, demographics and the realistic annual enrollment expected over the first 2 years.

5. Marketing Plan

 Organizations shall illustrate the outreach methods, the advertising methods and schedules and follow-up schedules. Organizations shall also illustrate and document any supportive relationships, contracts and commitments that are already in place with aging organizations, medical and service providers, community leaders, and the like (examples, marketing professionals on staff who have successfully started and sustained a PACE-like program; uniqueness in project design or outcomes expected; eliminating or downsizing nursing facility beds; improving the quality of collaborations with hospitals, personal service and medical providers, housing sources, and builders; incorporating innovative referral and marketing methods).

6. Implementation Plan

 Organizations shall show an ability to provide services to potential Montgomery County participants within 18 months of receiving formal notification of selection from the Department. Details of the implementation plan shall include the level of construction needed for site and whether a design firm or contractor has been consulted. Organizations shall also describe the staffing plan and whether a set of professionals and others has been surveyed for interest in serving the program. The implementation plan shall also explain how operational needs will be managed 24 hours a day. Further, the organization selected must adhere to milestones established by the Department. The Department will terminate a project which is not executed in a timely manner.

7. Financial Viability and Commitment

 Organizations shall provide realistic, justified and attainable detailed financial projections (including: resources for consulting, acquisition of space, acquisition of equipment, vans, working capital and solvency reserves) and enrollment census projections for at least 2 years. If applicable, the organization shall provide evidence that the organization has been successful with similar operations. The organization shall provide a letter of commitment from the board of directors, signed by an officer of the organization authorized to contractually bind the organization, to fund the project. In addition, the organization shall provide documentation of a risk reserve that will provide for sustainability. The organization shall provide the last 2 years of audited financial statements. If external financing is needed, provide a letter of intent from the lender.

Evaluation of Submissions

 The responses will be evaluated by a committee of Department administrators and analysts. The Department reserves the right to investigate any claims made or information provided. The Department also reserves the right of final approval or to reject a submission or to modify and reissue this solicitation. If selected, additional steps will be required, such as submission of a formal CMS application.

 Partnering in submissions is allowable; however, each organization must provide a letter of commitment authorized by their board of directors, which is signed by an officer of the organization authorized to contractually bind the organization. Partnering in a submission does not limit an organization's ability to submit independently.

Fiscal Impact

 There is no fiscal impact anticipated for this notice.

Submission of Information

 Submissions must be addressed to the Department of Human Services, Office of Long-Term Living, Office of Chief of Staff, Attention: Jonathan Bowman, P. O. Box 8025, Harrisburg, PA 17105-8025. The Department must receive the submission within 90 days of this publication or the submission will be rejected. Questions regarding this notice should be submitted to the Department at

 Persons with a disability who require an auxiliary aid or service may submit questions using the Pennsylvania AT&T Relay Service at (800) 654-5984 (TDD users) or (800) 654-5988 (voice users).


Fiscal Note: 14-NOT-923. No fiscal impact; (8) recommends adoption.

[Pa.B. Doc. No. 14-2644. Filed for public inspection December 19, 2014, 9:00 a.m.]

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