PACE (the Programs of All-Inclusive Care for the Elderly) is back in the news. In late July, the Centers for Medicare & Medicaid Services (CMS) offered updated guidance on the operation of PACE programs (see 2026 Rural PACE Memo). Of note, mobile clinics are now considered an Alternative Care Setting for PACE participants. In addition, with the exception of assessments, telehealth can be used to deliver services.

CMS also clarified that “states may utilize their Rural Healthcare Transformation (RHT) Program funding, before and during application review, as approved by CMS to establish, support, or bolster PACE organizations…” The guidance went on to stipulate specific reimbursement rules around PACE Medicaid capitation rates, but noted that RHT payments for…