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July 22, 2025


CMS has released proposed updates to the PACE audit protocol and is inviting public comments through August 13, 2025. This is a key opportunity for PACE Organizations to influence future audit processes.


Key Updates Include:

  • Increase in audit documents from 24 to 34, including new templates for impact analyses, corrective actions, and case file organization.
  • Removal of two prior requirements to reduce burden.
  • Clarifications on audit scoring, compliance classifications, and documentation standards.
  • Adjusted burden estimates to better reflect actual audit demands.


It is crucial that your feedback is received by this date, either electronically or by mail, following the instructions provided in the notice. The supporting statement and related forms for the proposed collection are available for review at: CMS Supporting Documents.


To read more, click here for the BluePeak Summary.

BluePeak is here to support your PACE Organization’s compliance and commitment to the CMS audit process. Contact us to learn more about how we can help.

BluePeak Advisors is a division of Gallagher Benefit Services, Inc. 

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