PACE application readiness is the work of preparing an organization to file the CMS Programs of All-Inclusive Care for the Elderly (PACE) initial application, or a service area expansion application, under 42 CFR Part 460. It is for health systems and elder services organizations developing a PACE organization or adding service areas or PACE centers. Integral Healthcare Solutions (IHS) drafts your PACE governance documents and operating policies and organizes the application; your clinicians and actuaries own care design and financials, and your organization files.

Last reviewed: October 2026.

What is PACE?

PACE is a Medicare and Medicaid program governed by 42 CFR Part 460, "Programs of All-Inclusive Care for the Elderly (PACE)" (eCFR, current as of 30 September 2026). Subpart B, §§ 460.10 to 460.28, sets out the PACE organization application and waiver process (42 CFR Part 460, Subpart B). The application itself is the CMS "Programs of All-Inclusive Care for the Elderly" Initial and Service Area Expansion (SAE) Application, OMB Control Number 0938-1326, which expires 31 January 2028 (the 2025 update) (CMS PACE application). Each state's administering agency has its own requirements on top of these, including a State Readiness Review.

The CMS application describes the model in two parts. The center: "The PACE center is the focal point for the delivery of PACE services; the center is where the interdisciplinary team (IDT) is located, services are provided, and socialization occurs with staff that is consistent and familiar to participants." The money: "financing of this model is accomplished through prospective capitation of both Medicare and Medicaid payments" (CMS PACE application).

Who needs it and what triggers it

The buyers are health systems and elder services organizations. Three events start the work.

• Becoming a new PACE organization. CMS states: "Organizations interested in becoming a new PO must complete a nonbinding NOIA in order to submit an initial PACE application to be approved as a PACE organization" (CMS PACE application). The application must also carry the state's assurance that it "considers the entity to be qualified to be a PACE organization and is willing to enter into a PACE program agreement with the entity" (42 CFR 460.12(b)(1)).
• Expanding a service area. The same CMS application covers "all new applicants and existing PACE Organizations seeking to expand a service area" (CMS PACE application).
• Adding a PACE center. 42 CFR 460.10(a)(2) covers "A PACE organization that seeks to expand its service area or to add a new PACE center" (42 CFR Part 460, Subpart B).

Expansions have a precondition. "CMS and the State administering agency will only approve a service area expansion or PACE center site expansion after the PACE organization has successfully completed its first trial period audit and, if applicable, has implemented an acceptable corrective action plan" (42 CFR 460.12(d)).

Timing is set by CMS's calendar. "Applications are accepted on a quarterly basis, on a designated day, which is generally the last Friday in March, June, September and December, with possible modification to account for a holiday" (CMS PACE application). Once a complete application is in, 42 CFR 460.20(a) gives CMS 90 days to act on an initial application and 45 days on an application under 42 CFR 460.10(a)(2), an existing PACE organization expanding its service area or adding a new PACE center (42 CFR 460.20(a)).

How IHS helps

IHS works the application in this order:

1. Gap assessment. IHS compares your plans and documents with the CMS PACE initial and SAE application and 42 CFR Part 460, using questionnaires on governance, the interdisciplinary team, the PACE center and contracts.
2. Application sequence and agreement register. IHS lays out a sequence that links the state and federal reviews, and keeps a register of the agreements the application relies on.
3. Document and evidence mapping. Each application item is mapped to the document or record that answers it, so gaps are visible before the quarterly date.
4. Drafting. IHS drafts governance documents and operating policies. Care content is drafted for your medical director to review and approve.
5. Mock review. IHS reviews the assembled package against the application as a reviewer would read it and lists what is missing or unclear.
6. Readiness support. IHS drafts application text and responses for your team to finalize and file.

What you supply: governance records, PACE center plans, contracts, actuarial work and clinical approval of care content.

The limit: financial feasibility and actuarial work belong to your organization and its actuaries. IHS does not prepare them. Your organization files the application and works with its state administering agency; IHS drafts and does not file or correspond with CMS or the state.

What to have ready

Each item below ties to 42 CFR Part 460 (eCFR, current as of 30 September 2026) or the CMS PACE Initial and SAE Application (OMB 0938-1326, 2025 update).

• A completed nonbinding Notice of Intent to Apply (NOIA), which CMS requires before an initial application (CMS PACE application).
• The state administering agency's assurance that it considers your organization qualified and is willing to enter into a PACE program agreement (42 CFR 460.12(b)(1)).
• A plan for the State Readiness Review. CMS notes it "is required but may or may not be uploaded as part of the initial submission of the application" (CMS PACE application).
• The physical street address of each PACE center. "Placeholder addresses will not be accepted" in HPMS (CMS PACE application).
• A target quarterly submission date, generally the last Friday in March, June, September or December (CMS PACE application).
• A description of the PACE center as the place "where the interdisciplinary team (IDT) is located, services are provided, and socialization occurs" (CMS PACE application).
• Financial and actuarial work from your actuaries reflecting "prospective capitation of both Medicare and Medicaid payments" (CMS PACE application).
• For an expansion or new center: evidence that your first trial period audit is complete and any corrective action plan is in place (42 CFR 460.12(d)).
• Staff time on the calendar. CMS estimates the application takes "81 hours and 51 hours per initial and service area expansion response, respectively" (CMS PACE application).

If you would like to go through this list against your own plans, start with an introductory call.

How it compares

The same CMS application serves new organizations and existing ones that are growing. The sources we reviewed draw these differences:

An existing organization may also consider an alternative care setting (ACS) inside its current service area. The CMS application states: "An ACS can be any physical location in the PACE organization's CMS approved existing service area other than the participant's home, an inpatient facility, or PACE center" (CMS PACE application).

What it costs

CMS does not publish a fee schedule on the pages we reviewed; fees depend on scope. We did not review state fees. The main cost is staff and expert time, including the work of your actuaries and the hours CMS estimates for the application itself. IHS scopes each engagement after a free introductory call.

What this is not

• IHS does not guarantee or predict a decision by CMS or the state administering agency.
• IHS does not file the application or communicate with CMS or the state for you. Your organization files and corresponds.
• This page is not legal, actuarial or financial-feasibility advice.

Frequently asked questions

What is PACE (Program of All-Inclusive Care for the Elderly)?

PACE is a care model governed by 42 CFR Part 460 in which a PACE center is the focal point for services. CMS describes the center as where the interdisciplinary team is located, services are provided and socialization occurs. CMS states that the model is financed through prospective capitation of both Medicare and Medicaid payments.

Who can become a PACE organization?

An organization that completes a nonbinding Notice of Intent to Apply can submit an initial PACE application. Under 42 CFR 460.12(b)(1), the application must include an assurance from the state administering agency that it considers the entity qualified and is willing to enter into a PACE program agreement with it.

What are the steps to apply for a new PACE program, starting with the Notice of Intent to Apply?

CMS requires a nonbinding Notice of Intent to Apply before an initial application. The applicant then completes the CMS PACE Initial and Service Area Expansion Application, obtains the state assurance and plans the State Readiness Review, and files on one of CMS's quarterly dates. CMS acts within 90 days of receiving a complete initial application.

When does CMS accept PACE applications?

CMS accepts applications quarterly on a designated day. The CMS application says this is generally the last Friday in March, June, September and December, with possible changes around a holiday.

How long does CMS take to decide on a PACE application?

Under 42 CFR 460.20(a), CMS takes action within 90 days after an entity submits a complete application. For an application under 42 CFR 460.10(a)(2) (an existing PACE organization expanding its service area or adding a new PACE center), 460.20(a) sets 45 days.

What is the State Readiness Review and when is it done?

The State Readiness Review is a state requirement that sits alongside the CMS application. CMS notes that it is required but may or may not be uploaded as part of the initial submission. Its content varies by state, so the state administering agency's requirements govern it.

What does the state have to provide before CMS will accept a PACE application?

The application must include an assurance from the state administering agency of the state where the program is located. Under 42 CFR 460.12(b)(1), that assurance states that the state considers the entity qualified to be a PACE organization and is willing to enter into a PACE program agreement with it.

How do we apply for a PACE service area expansion or a new PACE center?

Existing PACE organizations use the same CMS Initial and Service Area Expansion Application. 42 CFR 460.10(a)(2) covers an organization that seeks to expand its service area or add a new PACE center, and 42 CFR 460.20(a) sets 45 days for a complete application of that kind. Section 460.10(a)(3) separately lists an organization that seeks to expand its service area and add a new center; 460.20(a) names only (a)(2). IHS's reading (October 2026) is that the 45-day window may not reach a combined application, so plan on 90 days until your organization has CMS's written answer.

Can an existing PACE organization expand before its trial period audit?

No. Under 42 CFR 460.12(d), CMS and the state administering agency approve a service area or PACE center site expansion only after the organization has completed its first trial period audit and, if applicable, implemented an acceptable corrective action plan.

What documents must a PACE applicant upload in HPMS?

The full upload list is in the CMS PACE application itself, and IHS maps each item to your documents during the gap assessment. Two points from the application: the PACE center address entered in HPMS must be the physical address, with no placeholder addresses, and the State Readiness Review may or may not be uploaded with the initial submission.