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PACE Marketing
A Field-Ready Guide by PACE Operators, for PACE Operators
www.scolariconsulting.com
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Intro
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Purpose of the Course
Welcome to the PACE Marketing Training: A Field-Ready Guide by PACE Operators, for PACE Operators.
This course isn’t just about learning policies or passing a test — it’s about preparing you to represent one of the most important healthcare programs for seniors.
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Module 1
PACE Marketing & Enrollment Training
LEarning Objectives
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By the end of this module, you will be able to:
Understand the regulatory purpose of this training, including why DHCS requires it and how it aligns with participant protections.
Describe the structure and time commitment required by DHCS, including the 12-hour minimum and documentation expectations.
Recognize what certification authorizes you to do — and why no marketing, outreach, or enrollment activity can begin until training is complete.
MODULE 1
Training Overview & Compliance Foundations
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why this training exists
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PACE is a unique, fully capitated care model — and with that comes a strict set of rules about how the program can be presented to the public. The California Department of Health Care Services (DHCS) requires that every person involved in marketing, outreach, or enrollment complete formal training before speaking on behalf of the program.
Training Requirements: What DHCS Expects
The organization must keep logs of your completed training hours, a signed Memorandum of Understanding (MOU), and evidence of competency sign-off.
The content must align with DHCS PL 00-03, including participant rights, program structure, and prohibited practices.
According to the DHCS:
You must complete a minimum of 12 hours of documented marketing training.
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Subtitle
This training is not optional.
This isn’t just about passing a test. It’s about protecting the integrity of the program — and the trust of the participants we serve.
Without completing these steps, you are not authorized to represent the PACE program in any setting.
MODULE 1
Training Overview & Compliance Foundations
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Tips from seasoned coaches
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Hear directly from experienced PACE marketers who’ve lived through compliance audits and know what works in the field:
“We always keep our completion logs in our compliance binder—updated monthly.”
Why it matters: Auditors expect documentation to be current and easily accessible.
“No one goes out until the MOU is signed. No exceptions.”
Why it matters: Even experienced hires must complete training before speaking for the program.
MODULE 1
Training Overview & Compliance Foundations
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Instruction:True or False
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MODULE 1
Training Overview & Compliance Foundations
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Training Overview & Compliance Foundations
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MODULE 1
Training Overview & Compliance Foundations
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Module 1Completed!
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Key Takeaways:
Let’s review what you’ve learned in this first module. You’ve learned that PACE marketing isn’t about persuasion or pressure. It’s about participant-centered communication, grounded in compliance and truth.You also reviewed the three essential components of training readiness:
- 12 hours of documented training
- A signed Memorandum of Understanding (MOU)
- Supervisor sign-off and official clearance before conducting any outreach
Each of these is non-negotiable. You’re not just representing your organization — you’re representing a regulated, trust-based program designed to serve vulnerable older adults.
Module 2
PACE Marketing & Enrollment Training
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LEarning Objectives
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By the end of this module, you will be able to:
Define fee-for-service (FFS) vs. managed care.
Explain how PACE receives payments through capitation.
Identify the basics of dual eligibility (Medi-Cal + Medicare).
MODULE 2
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Understanding Medi-Cal, Medicare, and the PACE Model
key concepts
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Fee-for-Service (FFS) vs. Managed Care
Capitation: One Monthly Payment, Full Responsibility
Dual Eligibility: The Core PACE Population
MODULE 2
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Understanding Medi-Cal, Medicare, and the PACE Model
why this matters to you
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Misrepresenting how PACE is funded or what it covers is a compliance violation.
You must be able to explain:
That PACE is not a fee-for-service program.
That participants don’t “pay per visit” — their care is covered through the capitated model.
That enrollment into PACE replaces their existing Medicare or Medi-Cal coverage.
MODULE 2
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Understanding Medi-Cal, Medicare, and the PACE Model
case example
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Mr. Lee Transitions from FFS to PACE After a Stroke
TheTurningPoint
Background
Discovering PACE
Why This Matters
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MODULE 2
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Understanding Medi-Cal, Medicare, and the PACE Model
best practices
Compare the itemsin this table
MODULE 2
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Understanding Medi-Cal, Medicare, and the PACE Model
Common Pitfalls &How to Overcome Them
Compare the itemsin this table
MODULE 2
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Understanding Medi-Cal, Medicare, and the PACE Model
Instruction:True or False
question 1
MODULE 2
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Understanding Medi-Cal, Medicare, and the PACE Model
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Understanding Medi-Cal, Medicare, and the PACE Model
Instruction:Multiple Choice
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MODULE 2
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Understanding Medi-Cal, Medicare, and the PACE Model
Module 2Completed!
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Key Takeaways:
You’ve just completed Module 2 — and now you understand one of the most important building blocks of PACE: how the program is funded and who it serves.
Unlike traditional health plans, PACE doesn’t get paid per visit. It operates on a capitated model, receiving a fixed monthly payment to cover all medically necessary care for each participant. This structure is what allows PACE to focus on prevention, coordination, and quality of life, instead of reacting to illness after the fact.
You also learned about dual eligibility — when someone qualifies for both Medicare and Medi-Cal — which is how most participants enter the program.
Module 3
PACE Operations & Service Delivery
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overview
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Understanding how PACE operates is key to representing the program accurately and compliantly. As a certified marketing or enrollment representative, you’ll need to clearly explain:
What services are offered (and what aren’t)
Who qualifies for enrollment
How the PACE provider network functions
What happens during the enrollment process
This module will help you communicate those details with clarity and confidence — while staying within regulatory limits.
MODULE 3
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PACE Operations & Service Delivery
LEarning Objectives
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By the end of this module, you will be able to:
List core services provided through PACE as well as excluded services.
Explain what “nursing home level of care” means and why it matters.
Describe the basic eligibility requirements for PACE enrollment.
MODULE 3
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PACE Operations & Service Delivery
key concepts
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Excluded or Limited Services
Core Services Provided by PACE
What Is “Nursing Home Level of Care”?
Enrollment Eligibility Requirements
MODULE 3
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PACE Operations & Service Delivery
case example
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Mrs. Alvarez Wants to Enroll for Day Center and Dental
Assessment Findings
Background
Common Pitfall
Best Practice Response:
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Info
MODULE 3
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PACE Operations & Service Delivery
Field work: workflow
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From family, physician, housing, or self
REFERRAL
Age, location, nursing home level of care, and safe living assessment
Eligibility Review
Review rights, responsibilities, and program details before signature
eNROLLMENT CONFERENCE
This workflow ensures that participants and caregivers fully understand the commitment involved in enrolling in PACE.
MODULE 3
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PACE Operations & Service Delivery
red flags to avoid
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MODULE 2
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Understanding Medi-Cal, Medicare, and the PACE Model
BEST PRACTICESFOR FIELD COMMUNICATION
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MODULE 3
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PACE Operations & Service Delivery
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MODULE 3
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PACE Operations & Service Delivery
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PACE Operations & Service Delivery
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PACE Operations & Service Delivery
Module 3Completed!
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Key Takeaways:
In this module, you learned what makes PACE different — not just how it’s funded, but how it operates. PACE is a network-based, team-managed model. That means all care — from medical visits to therapy to home services — is coordinated through the Interdisciplinary Team, or IDT. You reviewed:
- The core services PACE must provide
- The excluded services and gray areas, like dental or home modifications
- What it means to meet nursing home level of care
- And the enrollment requirements — age, location, and clinical eligibility
This matters because what you say to a prospective participant sets the tone for how they understand the program.
Module 4
Accessing Routine & Emergency Care
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overview
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PACE participants receive all of their medical care through the PACE provider network — but what happens when they’re traveling, or when something urgent comes up?
This module explains how to communicate the difference between routine and emergency care, what to do when participants are out of the service area, and how to set clear expectations about what PACE covers — and when.
This is one of the most critical compliance topics in the training, as miscommunication here can result in:
Participants getting billed unexpectedly
Delayed or inappropriate care
Reportable compliance violations
MODULE 4
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Accessing Routine & Emergency Care
LEarning Objectives
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By the end of this module, you will be able to:
Explain participant responsibilities for using the PACE provider network.
Define emergency care using DHCS-compliant language.
Describe the rules for accessing care out-of-state or out-of-network.
MODULE 4
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Accessing Routine & Emergency Care
key concepts
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What Counts as Emergency Care?
What Is Routine Care?
Care While Traveling or Out of Area
MODULE 4
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Accessing Routine & Emergency Care
Real-Life Scenario
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Ms. Johnson Needs Urgent Care While Visiting Family
Why This Is a Red Flag
Background
How to Respond
What This Teaches
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MODULE 4
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Accessing Routine & Emergency Care
Common Pitfalls &How to Overcome Them
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MODULE 4
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Accessing Routine & Emergency Care
BEST PRACTICESFOR FIELD COMMUNICATION
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MODULE 4
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Accessing Routine & Emergency Care
Instruction:True or False
question 1
MODULE 4
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Accessing Routine & Emergency Care
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Accessing Routine & Emergency Care
Instruction:Multiple Choice
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Accessing Routine & Emergency Care
Module 4Completed!
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Key Takeaways:
You’ve now learned the difference between routine and emergency care — and why it matters so much in PACE.In this model, care must be coordinated. That means participants can’t simply walk into urgent care, refill prescriptions while out of town, or see any provider they choose — unless it’s a true emergency. Here’s the key distinction:
- Emergency care can be accessed anywhere, anytime, without approval.
- But routine or urgent care must go through the PACE care team, even when the participant is traveling.
Why? Because PACE is responsible for all care and all costs — and that only works when services are approved and tracked.
Module 5
Enrollment Process & Participant Rights
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overview
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Enrolling in PACE is not just a matter of filling out forms — it’s a legal, clinical, and participant-centered process. It involves multiple steps to ensure that participants understand what they are agreeing to, what their rights are, and how to exit the program if necessary.
In this module, we walk through:
The four stages of enrollment
The rights of prospective participants
The rules around rescission and disenrollment
MODULE 5
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Enrollment Process & Participant Rights
LEarning Objectives
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By the end of this module, you will be able to:
Describe the four stages of enrollment
Explain participant rights during and after enrollment
Identify valid disenrollment scenarios, both voluntary and involuntary
MODULE 5
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Enrollment Process & Participant Rights
key concepts
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Participant Rights at Enrollment
The Four Stages of PACE Enrollment
Rescission: Backing Out Within 72 Hours
Disenrollment: Voluntary or Involuntary
MODULE 5
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Enrollment Process & Participant Rights
Real-Life Scenario
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“I Guess I Have To...”
Why This Is a Red Flag
Background
Best Practice Response:
What Could Happen:
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MODULE 5
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Enrollment Process & Participant Rights
Best Practices forEnrollment Conversations
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MODULE 5
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Enrollment Process & Participant Rights
Common Pitfalls &How to Overcome Them
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MODULE 5
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Enrollment Process & Participant Rights
Instruction:True or False
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Enrollment Process & Participant Rights
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Instruction:Multiple Choice
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MODULE 5
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Enrollment Process & Participant Rights
Module 5Completed!
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Key Takeaways:
By now, you understand that enrolling someone into PACE isn’t about signing them up — it’s about guiding them through a legal, clinical, and participant-centered process.In this module, you walked through the four stages of enrollment:
- Outreach and education
- Eligibility screening
- Enrollment conference
- Participant signature and activation
Each of these steps must be handled with clarity, documentation, and respect for participant rights. You also learned that enrollment is voluntary. Participants have the right to:
- Ask questions
- Decline enrollment
- Rescind within 72 hours of signing
- Disenroll at any time — voluntarily or under certain conditions
Module 6
Confidentiality & Communication
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overview
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When you represent a PACE organization in the community, you're not just sharing information — you're trusted with personal health details, sensitive family dynamics, and conversations that shape how people view the program.
That’s why this module focuses on two critical responsibilities:
Confidentiality:What you can and cannot say — and to whom.
Communication: How to speak clearly, respectfully, and across cultures, languages, and literacy levels.
Together, these skills help you build trust, stay in compliance, and connect meaningfully with prospective participants and families.
MODULE 6
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Confidentiality & Communication
LEarning Objectives
Click on each item to learn why it matters
By the end of this module, you will be able to:
Apply privacy rules to all verbal and written communication
Use plain, non-technical language and teach-back techniques
Respect cultural and linguistic preferences during outreach and enrollment
MODULE 6
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Confidentiality & Communication
key concepts
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Who Can You Speak To?
HIPAA & Medi-Cal Confidentiality Rules
Language & Cultural Competence
Teach-Back Technique: Do They Really Understand?
MODULE 6
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Confidentiality & Communication
Real-Life Scenario
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“I’m Her Daughter. Just Tell Me.”
Why This Is a Red Flag
Background
How ToRespond:
What This Teaches
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MODULE 6
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Confidentiality & Communication
Best Practicesin the field
Compare the itemsin this table
MODULE 6
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Confidentiality & Communication
Common Pitfalls &How to Overcome Them
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MODULE 6
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Confidentiality & Communication
Instruction:True or False
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Confidentiality & Communication
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Confidentiality & Communication
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Confidentiality & Communication
Module 6Completed!
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Key Takeaways:
This module focused on how we communicate — and just as importantly, who we communicate with. You learned that in PACE, even the most casual conversation must follow HIPAA and Medi-Cal privacy rules. That means:
- You can’t assume a family member has access to information
- You must confirm consent before sharing any participant details
- You must offer interpreter services and use plain language — especially during enrollment or care conversations
Module 7
Grievance and Appeals
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overview
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As a PACE outreach, marketing, or enrollment team member, you're not just a source of information — you're also a first point of contact when something goes wrong.
Whether it's a missed ride, a delayed service, or a concern about care, families and participants often turn to the person they trust — and that might be you.
This module prepares you:
To respond appropriately, document correctly, and stay within your role when participants express frustration or dissatisfaction.
MODULE 7
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Grievance and Appeals
LEarning Objectives
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By the end of this module, you will be able to:
Differentiate between a grievance and an appeal
Explain how and when participants can file each
Recognize that your role is to listen and report — not to resolve
MODULE 7
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Grievance and Appeals
key concepts
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What Is a Grievance?
What Is an Appeal?
The Role of the Outreach, Enrollment, or Marketing Staff
MODULE 7
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Grievance and Appeals
Real-Life Scenario
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“Transportation Was Missed Again”
Why This Is a Red Flag
Background
How ToRespond:
What This Teaches
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MODULE 7
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Grievance and Appeals
Best Practicesin the field
Compare the itemsin this table
MODULE 7
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Grievance and Appeals
Common Pitfalls &How to AVOID Them
Compare the itemsin this table
MODULE 7
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Grievance and Appeals
Instruction:True or False
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Grievance and Appeals
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Grievance and Appeals
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Grievance and Appeals
Module 7Completed!
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Key Takeaways:
In this module, you learned how to support participants and caregivers when something doesn’t go as planned — because even in a well-run program, things will go wrong.Your role isn’t to defend the program or fix the issue on the spot. Your role is to be the first listener, the one who says:“Thank you for telling me. Let’s make sure this gets documented.”You now know the difference between a:
- Grievance – a complaint about service quality or experience
- Appeal – a formal request to reconsider a denied or reduced service
Both must be documented, routed, and tracked according to strict timelines and procedures.
Module 8
Marketing Conduct & Legal Boundaries
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overview
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In PACE, marketing is not traditional sales. You’re not closing deals — you’re providing regulated education about a healthcare program that serves some of the most vulnerable people in our communities.
That’s why marketing in PACE is governed by strict rules from both CMS and the California Department of Health Care Services (DHCS). One misstep — even an innocent one — can lead to audit findings, penalties, or worse: loss of trust from the public.
This module helps you recognize the difference between:
Supportive, compliant outreach and high-risk marketing behavior. It gives you the tools to stay on message, stay in bounds, and protect both your participants and your program.
MODULE 8
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Marketing Conduct & Legal Boundaries
LEarning Objectives
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By the end of this module, you will be able to:
List prohibited marketing practices under DHCS and CMS guidelines
Identify which actions and materials require compliance approval
Describe how violations are reported and what penalties may apply
MODULE 8
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Marketing Conduct & Legal Boundaries
key concepts
Click on each item to learn why it matters
Prohibited Marketing Practices
What Requires Compliance Approval?
Violations: What Happens and Why It Matters
MODULE 8
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Marketing Conduct & Legal Boundaries
Real-Life Scenario
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“They Just Needed a Ride”
What Went Wrong
Background
What the Rep Should Have Said
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MODULE 8
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Marketing Conduct & Legal Boundaries
Instruction:True or False
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Marketing Conduct & Legal Boundaries
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Marketing Conduct & Legal Boundaries
Instruction:Multiple Choice
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MODULE 8
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Marketing Conduct & Legal Boundaries
Module 8Completed!
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Key Takeaways:
In this module, you learned that PACE marketing is not sales. It’s regulated education — and every conversation you have reflects on the credibility of the program. You reviewed which actions are prohibited under DHCS PL 00-03, including:
- Cold calls
- Door-to-door outreach
- Incentives tied to enrollment
- Using materials that haven’t been pre-approved by compliance
Your job is not to convince someone to enroll — it’s to ensure they have accurate information to make an informed choice.
Evaluation
Instruction:True or False
question 1
Final Competency Quiz
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PACE Marketing & Enrollment Training
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Final Competency Quiz
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PACE Marketing & Enrollment Training
Instruction:Multiple Choice
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Final Competency Quiz
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PACE Marketing & Enrollment Training
Instruction:Arrange the Sequence
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Final Competency Quiz
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PACE Marketing & Enrollment Training
Instruction:True or False
question 5
Final Competency Quiz
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PACE Marketing & Enrollment Training
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question 6
Final Competency Quiz
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PACE Marketing & Enrollment Training
Instruction:Multiple Choice
question 7
Final Competency Quiz
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PACE Marketing & Enrollment Training
Instruction:Multiple Choice
question 8
Final Competency Quiz
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PACE Marketing & Enrollment Training
Instruction:Arrange the Sequence
question 9
Final Competency Quiz
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PACE Marketing & Enrollment Training
Instruction:Multiple Choice
question 10
Final Competency Quiz
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PACE Marketing & Enrollment Training
Congratulations!
You’ve successfully completed your course—well done! Your commitment to learning, growing, and improving your skills has truly paid off. By finishing this course, you’ve taken an important step in building new knowledge and strengthening your professional development. Keep up the great work, and remember that every skill you gain is an investment in your future.
Any questions?
👏
rosana.scolari@scolariconsulting.com www.scolariconsulting.com
Disenrollment: Voluntary or Involuntary
All disenrollment actions must:
- Be documented
- Provide written notice to the participant
- Offer alternative resources where applicable
- Be reported to DHCS and CMS when required
Red Flag: Never suggest that a participant can “just leave at any time” without explaining the implications and process.
Opportunities
Contextualize your topic
- Plan the structure of your communication.
- Give it a hierarchy and give visual weight to the main point.
- Add secondary messages with interactivity.
- Establish a flow through the content.
- Measure results.
Prohibited Marketing Practices
PACE programs are required to follow strict outreach and marketing regulations. The following actions are prohibited unless explicitly approved by DHCS:
Always use DHCS-approved collateral and follow your organization’s internal marketing policies. 60.3 – Nominal Gifts 42 CFR 460.82(e) POs may offer gifts to prospective participants, provided they: • Have only Nominal Value (be worth $15 or less) based on the retail value of the item, with a maximum aggregate of $75 per person, per year;
How to Respond
The correct coaching message in the field is:
“PACE covers emergency care anywhere, but for anything else — even urgent care — always call us first so we can coordinate it for you.” And when educating participants or families ahead of time:
“If you're traveling and something comes up, call the PACE center first. We’ll help you figure out the best next step — even after hours.”
How To Respond:
Here’s how a trained, compliance-aware rep might handle it:“Thanks for being involved in your mom’s care — it makes such a difference. Because of privacy laws, we’ll need your mom’s permission or legal documentation before we can go over her specific information. But I can absolutely walk you through the program and what the next steps would be for your family.” Then you can offer to:
- Set up a home visit with the participant present
- Provide general program info in plain language
- Help her understand what documentation would be needed to act on her mother’s behalf
Opportunities
Contextualize your topic
- Plan the structure of your communication.
- Give it a hierarchy and give visual weight to the main point.
- Add secondary messages with interactivity.
- Establish a flow through the content.
- Measure results.
Background
Ms. Johnson is an 81-year-old PACE participant who lives independently and regularly visits the center. Over the weekend, she travels to a nearby county to stay with her son. One evening, she develops sharp abdominal pain — uncomfortable but not life-threatening.
Worried, her son drives her to a local urgent care clinic without calling PACE first. She receives treatment and is discharged with medication.
The next day, her son calls the PACE center to inform the team. The nurse listens carefully… then explains that because the visit wasn’t coordinated through the PACE care team, the clinic may not be reimbursed — and the family might receive a bill.
The son is surprised.
“She’s in the program. Isn’t everything covered?”
Who Can You Speak To?
Teach-Back Technique: Do They Really Understand?
Don’t ask:
“Do you understand?”
Instead, try:
“Can you tell me, in your own words, how this program works?”
Or:
“If your sister asked you what this paper means, what would you tell her?”
This technique ensures the participant truly grasps what you’ve explained — and gives you a chance to clarify before moving on.
PACE organizations receive fixed monthly payments from both Medicare and Medi-Cal for each enrolled participant. This is called capitation.With capitation, the organization assumes full risk for providing all needed care. If the participant’s needs are high, the program still only receives that one monthly amount.
This is why care coordination and proactive planning are central to PACE.
The Four Stages of PACE Enrollment
PACE enrollment is a structured process that typically follows these steps:
All steps must be thoroughly documented and include signed disclosures and consents.
Why This Matters
This scenario shows how PACE simplifies and integrates care — especially for participants with complex needs. Unlike the fragmented, service-by-service structure of FFS, PACE offers one coordinated solution through capitated funding.As a marketing or outreach professional, you’ll use stories like Mr. Lee’s to help families understand:
- What makes PACE different
- Why capitation matters
- How care coordination improves quality of life
Just remember — always stay within compliance and never overpromise.
What This Teaches
- Any complaint about service quality, such as transportation issues, is a grievance
- Staff should listen, validate, and route — not resolve
- Even small complaints help the team track trends and ensure accountability
- Promising a fix in the moment can lead to unmet expectations and audit risk
- The goal is not to defend the program, but to give the participant or caregiver a path to be heard
Background
You’re facilitating an enrollment conference for Mr. Ramirez, a 78-year-old with multiple chronic conditions who lives with his daughter, Elena. They’ve completed the eligibility screening, the home visit, and the Level of Care assessment. Today is the final enrollment conference — and the decision point.
You’ve reviewed the program description, the list of covered services, and the agreement terms. Mr. Ramirez hasn’t asked many questions. Elena has done most of the talking.
As you prepare to move into the signature section of the agreement, you pause and ask:
“Do you have any questions before we go on?”
Mr. Ramirez looks at Elena, shrugs slightly, and says:
“Well… I guess I have to, right?”
Best Practice Response
“Those are great questions. What we do is evaluate all of your aunt’s needs through a full care assessment with our team. If day center attendance or dental care is determined to be medically necessary by our interdisciplinary team, those can absolutely become part of her care plan. We’ll walk through all of that together.”✅ This answer:
- Manages expectations
- Explains how care is determined
- Avoids overcommitting to services not yet approved
- Stays compliant with PACE enrollment rules
What Requires Compliance Approval?
You must not create or distribute materials or messaging on your own. The following always require prior compliance review:
- Flyers or handouts
- Digital ads or emails
- Social media posts
- Video scripts or live presentations
- Internal referral program materials
Even small edits — like changing the word “covers” to “provides” — can shift the meaning and create risk.
This requirement comes directly from DHCS Policy Letter 00-03, which outlines the minimum standards, compliance protections, and documentation expectations for PACE marketing representatives.
What Could Happen If You Don't Intervene?
- Mr. Ramirez signs the agreement out of pressure or confusion
- Two days later, Elena calls to cancel the enrollment
- She says, “He didn’t even know what he was signing — we just felt like we didn’t have a choice.”
- Now the program must reverse the enrollment, file documentation with DHCS, and record it as a rescission
HIPAA & Medi-Cal Confidentiality Rules
As a PACE representative, you must follow both federal Health Insurance Portability and Accountability Act (HIPAA) and state (Medi-Cal) privacy regulations. These rules apply to everything you say, write, or share — whether in the field, on the phone, or through written materials. You must only discuss information the participant has explicitly consented to share. This includes:
- Health conditions
- Medications or diagnoses
- Participation status in PACE
- Any personal or identifying information
Even close family members — including adult children — may not be authorized to receive information unless they're the legal representative on file.
Care While Traveling or Out of Area
PACE participants must notify the care team before leaving the area. If they require medical attention while traveling:
Participants should always carry their PACE membership card, which includes emergency contact numbers and coverage instructions.
The Role of the Outreach, Enrollment, or Marketing Staff
Your role is not to explain, justify, or fix the situation.Your role is to:
- Listen carefully
- Acknowledge the concern
- Document it properly
- Report it to the appropriate team or compliance lead
🛑 Trying to “make it right” on your own can lead to missteps, unmet expectations, and compliance violations.
🧠 What This Example Shows:
This scenario illustrates:
- The importance of IDT-driven decision-making
- Why not all services are guaranteed
- How even well-meaning language can result in compliance violations or enrollment rescission
- The power of transparent, participant-centered communication
Background
You’re working a community resource fair in partnership with a local senior center. A woman approaches your table and asks about enrolling her mother in PACE. She explains:
“My mom’s 86. She lives with me now. She has diabetes and early dementia. We really need help.”
You offer a warm response and begin explaining how PACE works. As you talk, she starts filling out the referral form for her mother — but stops when you ask about a signed release or power of attorney.
“I don’t have any legal paperwork,” she says.
“But I’m her daughter. Just tell me what I need to know.”
Background
You’re visiting a senior apartment complex for a scheduled outreach event. A resident approaches you quietly and says:
“I haven’t seen my doctor in months. I can’t get a ride anywhere. I just need help getting to the pharmacy.”
You see an opportunity to connect. You want to offer hope — and you want her to feel supported.
So, you respond:
“If you enroll in PACE, we can send a van to take you wherever you need — no problem.”
She lights up. Finally, a solution. Or so she thinks.
Violations: What Happens and Why It Matters
If a marketing violation occurs — whether intentional or not — it can trigger:
- A DHCS audit
- Required corrective action plans
- Public complaints
- Risk to your organization’s PACE contract
And yes — violations must be reported. PACE is held to high transparency standards. Trying to hide or "fix" a mistake quietly only increases the risk.
Background
Mrs. Alvarez is 83 years old and lives with her niece in a duplex within your PACE organization’s service area. She’s been feeling isolated and says she “just wants to get out of the house and see people.”
Her niece reaches out after hearing that PACE offers a day center and dental care. During the initial call, she says:
“We’re interested in the day center and getting her some dental work done. We heard you take care of everything.”
What Counts as Emergency Care?
Emergency care is any situation where a person could reasonably expect serious harm without immediate treatment.According to DHCS and CMS guidelines, this includes:
- Severe chest pain or heart attack symptoms
- Difficulty breathing
- Loss of consciousness
- Severe bleeding or trauma
- Psychiatric emergencies (harm to self or others)
📌 Participants do not need prior authorization to access emergency services.They can call 911 or go directly to the emergency room — even outside of the PACE service area.
Why This Is a Red Flag
In many families, adult children are deeply involved in care decisions. But being a family member doesn’t automatically grant legal authority to access health or enrollment information.If you proceed and share private details about the participant — even basic medical eligibility info — you could violate HIPAA and Medi-Cal privacy rules. This includes:
- Whether the participant qualifies for enrollment
- Any information from past referrals or screenings
- Any protected health information, unless a consent form or legal rep status is documented
What Is Routine Care?
Routine care refers to:
- Primary and specialty care
- Medication refills
- Ongoing therapy
- Non-urgent lab work or imaging
- Preventive care (e.g., checkups, vaccinations)
This care must be coordinated through the PACE organization — and must be approved in advance.PACE staff are responsible for scheduling, referring, and authorizing all non-emergency services. Unauthorized use of routine care outside the network may not be covered, and participants could be billed.
Participant Rights at Enrollment
Participants and their legal representatives have the right to:
- Receive a full explanation of the program before signing
- Ask questions and review all documents in plain language
- Be informed of their right to rescind enrollment within 72 hours
- Understand what happens if they choose to disenroll voluntarily or are disenrolled involuntarily
- Be provided with translations or interpreter services as needed
Enrollment is not just a formality. It’s a decision with legal and clinical implications, and participants must feel confident in their understanding.
What Is an Appeal?
An appeal is a formal request to reconsider a denied, delayed, or reduced service.Examples include:
- “My home care hours were cut.”
- “The doctor won’t approve my therapy.”
- “PACE won’t pay for the equipment I need.”
📄 Appeals typically involve clinical or coverage decisions and must follow specific timelines.
Opportunities
Contextualize your topic
- Plan the structure of your communication.
- Give it a hierarchy and give visual weight to the main point.
- Add secondary messages with interactivity.
- Establish a flow through the content.
- Measure results.
Not all services are guaranteed under PACE. Some are excluded by regulation, while others are provided only when deemed medically necessary.
Key Compliance Risk: Overpromising excluded or conditional services is a red flag.
How To Respond:
The correct response in this moment is calm, validating, and compliant:
- “Thank you for telling me. That does sound frustrating. I want to make sure it gets documented so the right team can follow up. I’m going to report this as a grievance.”
Then, follow your organization’s grievance reporting workflow.Don’t:
- Try to fix the problem yourself
- Offer guarantees
- Downplay the concern
Background
You’re doing follow-up calls at the PACE center when a caregiver stops you in the hallway.
She looks tired and frustrated.
“My mom’s van was late again. She missed her physical therapy. That’s twice this month. What’s the point if she can’t get there on time?”
She’s clearly upset. And she’s looking at you for answers.
You want to help. It’s tempting to apologize, explain the situation, or even try to fix it directly.
Background
Mr. Lee is a 76-year-old retired carpenter with diabetes and high blood pressure. He lives alone and has been using fee-for-service Medicare and Medi-Cal, which means each medical service is billed separately.
His daughter, Grace, helps manage his care but lives an hour away. Coordinating appointments, transportation, and follow-ups has become overwhelming.
Dicovering PACE
At a local community event, Grace hears about PACE. Mr. Lee is screened, found eligible, and enrolls the following month.Now he receives:
- Coordinated care through a full interdisciplinary team
- Transportation to the PACE center
- On-site physical therapy
- All medications through the PACE pharmacy
- A single point of contact for his care plan
Grace no longer has to act as his care manager. The PACE team handles it all.
Opportunities
Contextualize your topic
- Plan the structure of your communication.
- Give it a hierarchy and give visual weight to the main point.
- Add secondary messages with interactivity.
- Establish a flow through the content.
- Measure results.
Best Practice Response:
Here’s how a seasoned rep might respond:
“Actually, this is your decision — and it’s completely voluntary. Let’s pause for a minute. Is there anything you’re unsure about, or anything you want me to go over again?”
Then, turn to the participant directly:
“Mr. Ramirez, do you feel comfortable with everything we’ve reviewed so far? Would it help if we went back to any part of the agreement or your care plan?”
This gives the participant space to speak, invites clarification, and demonstrates that your role is supportive, not persuasive.
Assessment Findings:
- Mrs. Alvarez does meet the nursing home level of care — she needs assistance with bathing, managing medications, and has a history of falls.
- She’s in the service area and over age 55, making her technically eligible for enrollment.
- However, she is not currently homebound, and her dental needs, while important, are not medically urgent.
What is a Grievance?
A grievance is any complaint or expression of dissatisfaction about the quality of care or services.Examples include:
- “They forgot to pick me up again.”
- “The nurse was rude on the phone.”
- “I didn’t get my medication on time.”
Grievances can come from:
- Participants
- Family members or caregivers
- Staff acting on the participant’s behalf
✅ Grievances do not have to be written and can be reported verbally.
Most PACE participants are dually eligible, meaning they qualify for both Medi-Cal (California’s Medicaid) and Medicare.- Medi-Cal covers low-income Californians.
- Medicare provides federal health coverage for those over 65 or with disabilities.
PACE integrates both, so participants don’t need separate plans or pay multiple premiums. PACE becomes their sole provider and payer.
- In FFS, the government pays for each service individually — every doctor visit, procedure, or hospital stay is billed separately.
- In Managed Care, providers receive a set monthly amount to manage a participant’s care — regardless of how many services are used.
PACE is a managed care model. This means it focuses on prevention, coordination, and cost control — rather than volume of services.
Language & Cultural Competence
PACE serves diverse populations — often across languages, generations, and cultural beliefs about aging, illness, and independence. Your communication must be:
- Respectful
- Culturally aware
- Linguistically appropriate
Do not assume understanding based on head nods, smiles, or silence. Always offer:
- Interpreter services
- Translated materials
- Extra time for explanation
🎯 Key Point: Don’t rely on family members to translate — especially when discussing legal documents or health information.
PACE is designed to provide comprehensive, coordinated care. All medically necessary services are delivered through the PACE provider network, including:
- Primary and specialty care
- Prescription drugs
- Adult day center services
- Physical, occupational, and speech therapy
- Social work services
- Meals and nutritional counseling
- Home care
- Transportation
- Hospital and nursing home care (when needed)
These services are coordinated by the Interdisciplinary Team (IDT) and based on what is medically necessary — not on participant requests alone.
What This Teaches
- Emergency care (e.g., chest pain, severe bleeding, loss of consciousness) can be accessed immediately, anywhere.
- Routine and urgent care must go through the PACE team — even when the participant is out of the service area.
- Uncoordinated care may not be covered — leading to confusion, dissatisfaction, and compliance issues.
- Clear education during enrollment and ongoing reminders are essential.
What Went Wrong
While the rep meant well, this is a classic case of overpromising services.By suggesting that PACE will provide unlimited transportation “wherever you need”, the rep failed to clarify that:
- All services must be medically necessary
- All transportation must be approved by the care team
- PACE is not a taxi service — rides are based on the participant’s care plan and health needs
This kind of statement sets unrealistic expectations. Later, when the participant is told she can’t get a ride to her cousin’s house or to run errands, she may feel misled — which can lead to grievances, rescission, or even audit findings.
Opportunities
Contextualize your topic
- Plan the structure of your communication.
- Give it a hierarchy and give visual weight to the main point.
- Add secondary messages with interactivity.
- Establish a flow through the content.
- Measure results.
Why This Is a Red Flag
That statement — “I guess I have to” — may seem small, but it’s a signal. It tells you the participant may not:
- Fully understand the program
- Feel empowered to make the decision
- Realize that enrollment is voluntary
If you ignore it and proceed with the signature, you risk:
- Enrollment rescission within the 72-hour window
- Future grievances from the family
- A compliance violation for not ensuring informed consent
What This Teaches
This scenario reinforces that:
- Family involvement is important, but doesn’t replace legal consent
- Boundaries must be maintained, even in casual or “informal” settings like outreach events
- You can still be respectful, supportive, and informative without crossing compliance lines
Why This Is a Red Flag
This situation is a common compliance risk. The family:
- Assumed PACE would cover any medical care, regardless of coordination
- Sought non-emergency care without calling first
- May now face out-of-network charges and confusion about coverage
PACE is a managed care model, meaning all non-emergency services must be authorized in advance by the care team — even more so when participants are traveling. This scenario could lead to:
- Grievances or appeals
- Family frustration and loss of trust
- Audit issues if the care is improperly coded or reimbursed
Why This Is a Red Flag
This is a classic example of a participant grievance — and a common situation where well-meaning staff may overstep their role.Here’s what makes it risky:
- Staff might try to justify or explain the delay
- Others might say, “I’ll make sure it never happens again” — which is a promise you can’t keep
- Some might think it’s too small to report
But every participant complaint — even verbal — must be documented and routed to the compliance team.Failing to do so can result in:
- Missed deadlines for grievance resolution
- Lack of tracking patterns (e.g., repeated missed rides)
- Non-compliance with CMS and DHCS grievance regulations
Common Pitfall:
A newer outreach staff member is excited to help and responds:“Yes, we definitely take care of all that. She’ll be able to come to the day center whenever she wants, and we can take care of her dental work too.”🚫 This is a compliance red flag:
- It overpromises services that may not be approved by the IDT.
- It implies participant choice determines services like day center attendance or dental — rather than medical necessity and care planning.
To enroll in PACE, participants must meet the state-defined criteria for nursing home level of care. This does not mean they must live in a nursing home — rather, they need the level of care that would qualify them for nursing home placement. It is important to note that the state agency and not the PACE program determines if a person meets nursing home level of care. This includes:
- Help with multiple Activities of Daily Living (ADLs) (e.g., bathing, dressing, toileting)
- Cognitive or behavioral impairments
- Complex chronic medical conditions
PACE enables these individuals to live safely at home while receiving the care they need.
“PACE provides transportation to medically necessary appointments — and your care team works with you to schedule those rides.”
This answer keeps things accurate, compliant, and grounded in the PACE care model.
The Turning Point
Mr. Lee suffers a mild stroke and is hospitalized. After discharge, Grace struggles to arrange the services he needs:
- Home health
- Physical therapy
- Medications
- Transportation
Three weeks later, he still hasn’t started rehab.
Opportunities
Contextualize your topic
- Plan the structure of your communication.
- Give it a hierarchy and give visual weight to the main point.
- Add secondary messages with interactivity.
- Establish a flow through the content.
- Measure results.
Rescission:Backing out Within 72 hrs
California regulations give participants 72 hours after signing the enrollment agreement to rescind their decision — for any reason.If this happens:
- Enrollment is voided with no penalty
- The participant remains with their previous coverage (Medi-Cal, Medicare, etc.)
Revision - PACE Marketing
Scolari Consulting
Created on October 24, 2025
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Transcript
👋
PACE Marketing
A Field-Ready Guide by PACE Operators, for PACE Operators
www.scolariconsulting.com
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Intro
How to Navigate our Course
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Welcome to Your Course!We’re excited to have you here. This course is designed to be interactive and engaging, so you’ll get the most out of your learning experience. To ensure your success, please keep the following in mind:
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Enjoy your learning journey—we’re here to support you every step of the way!
Purpose of the Course
Welcome to the PACE Marketing Training: A Field-Ready Guide by PACE Operators, for PACE Operators. This course isn’t just about learning policies or passing a test — it’s about preparing you to represent one of the most important healthcare programs for seniors.
Having Technical Issues?Click me
Module 1
PACE Marketing & Enrollment Training
LEarning Objectives
Click on each item to learn why it matters
By the end of this module, you will be able to:
Understand the regulatory purpose of this training, including why DHCS requires it and how it aligns with participant protections.
Describe the structure and time commitment required by DHCS, including the 12-hour minimum and documentation expectations.
Recognize what certification authorizes you to do — and why no marketing, outreach, or enrollment activity can begin until training is complete.
MODULE 1
Training Overview & Compliance Foundations
Having Technical Issues?Click me
why this training exists
Click on each item to learn why it matters
PACE is a unique, fully capitated care model — and with that comes a strict set of rules about how the program can be presented to the public. The California Department of Health Care Services (DHCS) requires that every person involved in marketing, outreach, or enrollment complete formal training before speaking on behalf of the program.
Training Requirements: What DHCS Expects
The organization must keep logs of your completed training hours, a signed Memorandum of Understanding (MOU), and evidence of competency sign-off.
The content must align with DHCS PL 00-03, including participant rights, program structure, and prohibited practices.
According to the DHCS:
You must complete a minimum of 12 hours of documented marketing training.
Title
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Subtitle
This training is not optional.
This isn’t just about passing a test. It’s about protecting the integrity of the program — and the trust of the participants we serve.
Without completing these steps, you are not authorized to represent the PACE program in any setting.
MODULE 1
Training Overview & Compliance Foundations
Having Technical Issues?Click me
Tips from seasoned coaches
Click on each item to learn why it matters
Hear directly from experienced PACE marketers who’ve lived through compliance audits and know what works in the field:
“We always keep our completion logs in our compliance binder—updated monthly.”
Why it matters: Auditors expect documentation to be current and easily accessible.
“No one goes out until the MOU is signed. No exceptions.”
Why it matters: Even experienced hires must complete training before speaking for the program.
MODULE 1
Training Overview & Compliance Foundations
Having Technical Issues?Click me
Instruction:True or False
question 1
MODULE 1
Training Overview & Compliance Foundations
Having Technical Issues?Click me
Instruction:Drag the Word
question 2
MODULE 1
Training Overview & Compliance Foundations
Having Technical Issues?Click me
Instruction:Multiple Choice
question 3
MODULE 1
Training Overview & Compliance Foundations
Having Technical Issues?Click me
Module 1Completed!
Click to Start Audio
Key Takeaways:
Let’s review what you’ve learned in this first module. You’ve learned that PACE marketing isn’t about persuasion or pressure. It’s about participant-centered communication, grounded in compliance and truth.You also reviewed the three essential components of training readiness:
- 12 hours of documented training
- A signed Memorandum of Understanding (MOU)
- Supervisor sign-off and official clearance before conducting any outreach
Each of these is non-negotiable. You’re not just representing your organization — you’re representing a regulated, trust-based program designed to serve vulnerable older adults.Module 2
PACE Marketing & Enrollment Training
Click to Play Audio
LEarning Objectives
Click on each item to learn why it matters
By the end of this module, you will be able to:
Define fee-for-service (FFS) vs. managed care.
Explain how PACE receives payments through capitation.
Identify the basics of dual eligibility (Medi-Cal + Medicare).
MODULE 2
Having Technical Issues?Click me
Understanding Medi-Cal, Medicare, and the PACE Model
key concepts
Click on each item to learn why it matters
Fee-for-Service (FFS) vs. Managed Care
Capitation: One Monthly Payment, Full Responsibility
Dual Eligibility: The Core PACE Population
MODULE 2
Having Technical Issues?Click me
Understanding Medi-Cal, Medicare, and the PACE Model
why this matters to you
Click on each item to learn why it matters
Misrepresenting how PACE is funded or what it covers is a compliance violation.
You must be able to explain:
That PACE is not a fee-for-service program.
That participants don’t “pay per visit” — their care is covered through the capitated model.
That enrollment into PACE replaces their existing Medicare or Medi-Cal coverage.
MODULE 2
Having Technical Issues?Click me
Understanding Medi-Cal, Medicare, and the PACE Model
case example
Click on each item to learn why it matters
Mr. Lee Transitions from FFS to PACE After a Stroke
TheTurningPoint
Background
Discovering PACE
Why This Matters
Click to Start Audio
MODULE 2
Having Technical Issues?Click me
Understanding Medi-Cal, Medicare, and the PACE Model
best practices
Compare the itemsin this table
MODULE 2
Having Technical Issues?Click me
Understanding Medi-Cal, Medicare, and the PACE Model
Common Pitfalls &How to Overcome Them
Compare the itemsin this table
MODULE 2
Having Technical Issues?Click me
Understanding Medi-Cal, Medicare, and the PACE Model
Instruction:True or False
question 1
MODULE 2
Having Technical Issues?Click me
Understanding Medi-Cal, Medicare, and the PACE Model
Instruction:Drag the Word
question 2
MODULE 2
Having Technical Issues?Click me
Understanding Medi-Cal, Medicare, and the PACE Model
Instruction:Multiple Choice
question 3
MODULE 2
Having Technical Issues?Click me
Understanding Medi-Cal, Medicare, and the PACE Model
Module 2Completed!
Click to Start Audio
Key Takeaways:
You’ve just completed Module 2 — and now you understand one of the most important building blocks of PACE: how the program is funded and who it serves. Unlike traditional health plans, PACE doesn’t get paid per visit. It operates on a capitated model, receiving a fixed monthly payment to cover all medically necessary care for each participant. This structure is what allows PACE to focus on prevention, coordination, and quality of life, instead of reacting to illness after the fact. You also learned about dual eligibility — when someone qualifies for both Medicare and Medi-Cal — which is how most participants enter the program.
Module 3
PACE Operations & Service Delivery
Click to Play Audio
overview
Click on each item to learn why it matters
Understanding how PACE operates is key to representing the program accurately and compliantly. As a certified marketing or enrollment representative, you’ll need to clearly explain:
What services are offered (and what aren’t)
Who qualifies for enrollment
How the PACE provider network functions
What happens during the enrollment process
This module will help you communicate those details with clarity and confidence — while staying within regulatory limits.
MODULE 3
Having Technical Issues?Click me
PACE Operations & Service Delivery
LEarning Objectives
Click on each item to learn why it matters
By the end of this module, you will be able to:
List core services provided through PACE as well as excluded services.
Explain what “nursing home level of care” means and why it matters.
Describe the basic eligibility requirements for PACE enrollment.
MODULE 3
Having Technical Issues?Click me
PACE Operations & Service Delivery
key concepts
Click on each item to learn why it matters
Excluded or Limited Services
Core Services Provided by PACE
What Is “Nursing Home Level of Care”?
Enrollment Eligibility Requirements
MODULE 3
Having Technical Issues?Click me
PACE Operations & Service Delivery
case example
Click on each item to learn why it matters
Mrs. Alvarez Wants to Enroll for Day Center and Dental
Assessment Findings
Background
Common Pitfall
Best Practice Response:
Click to Start Audio
Info
MODULE 3
Having Technical Issues?Click me
PACE Operations & Service Delivery
Field work: workflow
Click on each item to learn why it matters
From family, physician, housing, or self
REFERRAL
Age, location, nursing home level of care, and safe living assessment
Eligibility Review
Review rights, responsibilities, and program details before signature
eNROLLMENT CONFERENCE
This workflow ensures that participants and caregivers fully understand the commitment involved in enrolling in PACE.
MODULE 3
Having Technical Issues?Click me
PACE Operations & Service Delivery
red flags to avoid
Compare the itemsin this table
MODULE 2
Having Technical Issues?Click me
Understanding Medi-Cal, Medicare, and the PACE Model
BEST PRACTICESFOR FIELD COMMUNICATION
Compare the itemsin this table
MODULE 3
Having Technical Issues?Click me
PACE Operations & Service Delivery
Instruction:True or False
question 1
MODULE 3
Having Technical Issues?Click me
PACE Operations & Service Delivery
Instruction:Drag the Word
question 2
MODULE 3
Having Technical Issues?Click me
PACE Operations & Service Delivery
Instruction:Multiple Choice
question 3
MODULE 3
Having Technical Issues?Click me
PACE Operations & Service Delivery
Module 3Completed!
Click to Start Audio
Key Takeaways:
In this module, you learned what makes PACE different — not just how it’s funded, but how it operates. PACE is a network-based, team-managed model. That means all care — from medical visits to therapy to home services — is coordinated through the Interdisciplinary Team, or IDT. You reviewed:
- And the enrollment requirements — age, location, and clinical eligibility
This matters because what you say to a prospective participant sets the tone for how they understand the program.Module 4
Accessing Routine & Emergency Care
Click to Play Audio
overview
Click on each item to learn why it matters
PACE participants receive all of their medical care through the PACE provider network — but what happens when they’re traveling, or when something urgent comes up? This module explains how to communicate the difference between routine and emergency care, what to do when participants are out of the service area, and how to set clear expectations about what PACE covers — and when. This is one of the most critical compliance topics in the training, as miscommunication here can result in:
Participants getting billed unexpectedly
Delayed or inappropriate care
Reportable compliance violations
MODULE 4
Having Technical Issues?Click me
Accessing Routine & Emergency Care
LEarning Objectives
Click on each item to learn why it matters
By the end of this module, you will be able to:
Explain participant responsibilities for using the PACE provider network.
Define emergency care using DHCS-compliant language.
Describe the rules for accessing care out-of-state or out-of-network.
MODULE 4
Having Technical Issues?Click me
Accessing Routine & Emergency Care
key concepts
Click on each item to learn why it matters
What Counts as Emergency Care?
What Is Routine Care?
Care While Traveling or Out of Area
MODULE 4
Having Technical Issues?Click me
Accessing Routine & Emergency Care
Real-Life Scenario
Click on each item to learn why it matters
Ms. Johnson Needs Urgent Care While Visiting Family
Why This Is a Red Flag
Background
How to Respond
What This Teaches
Click to Start Audio
MODULE 4
Having Technical Issues?Click me
Accessing Routine & Emergency Care
Common Pitfalls &How to Overcome Them
Compare the itemsin this table
MODULE 4
Having Technical Issues?Click me
Accessing Routine & Emergency Care
BEST PRACTICESFOR FIELD COMMUNICATION
Compare the itemsin this table
MODULE 4
Having Technical Issues?Click me
Accessing Routine & Emergency Care
Instruction:True or False
question 1
MODULE 4
Having Technical Issues?Click me
Accessing Routine & Emergency Care
Instruction:Drag the Word
question 2
MODULE 4
Having Technical Issues?Click me
Accessing Routine & Emergency Care
Instruction:Multiple Choice
question 3
MODULE 4
Having Technical Issues?Click me
Accessing Routine & Emergency Care
Module 4Completed!
Click to Start Audio
Key Takeaways:
You’ve now learned the difference between routine and emergency care — and why it matters so much in PACE.In this model, care must be coordinated. That means participants can’t simply walk into urgent care, refill prescriptions while out of town, or see any provider they choose — unless it’s a true emergency. Here’s the key distinction:
- Emergency care can be accessed anywhere, anytime, without approval.
- But routine or urgent care must go through the PACE care team, even when the participant is traveling.
Why? Because PACE is responsible for all care and all costs — and that only works when services are approved and tracked.Module 5
Enrollment Process & Participant Rights
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overview
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Enrolling in PACE is not just a matter of filling out forms — it’s a legal, clinical, and participant-centered process. It involves multiple steps to ensure that participants understand what they are agreeing to, what their rights are, and how to exit the program if necessary. In this module, we walk through:
The four stages of enrollment
The rights of prospective participants
The rules around rescission and disenrollment
MODULE 5
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Enrollment Process & Participant Rights
LEarning Objectives
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By the end of this module, you will be able to:
Describe the four stages of enrollment
Explain participant rights during and after enrollment
Identify valid disenrollment scenarios, both voluntary and involuntary
MODULE 5
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Enrollment Process & Participant Rights
key concepts
Click on each item to learn why it matters
Participant Rights at Enrollment
The Four Stages of PACE Enrollment
Rescission: Backing Out Within 72 Hours
Disenrollment: Voluntary or Involuntary
MODULE 5
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Enrollment Process & Participant Rights
Real-Life Scenario
Click on each item to learn why it matters
“I Guess I Have To...”
Why This Is a Red Flag
Background
Best Practice Response:
What Could Happen:
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MODULE 5
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Enrollment Process & Participant Rights
Best Practices forEnrollment Conversations
Compare the itemsin this table
MODULE 5
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Enrollment Process & Participant Rights
Common Pitfalls &How to Overcome Them
Compare the itemsin this table
MODULE 5
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Enrollment Process & Participant Rights
Instruction:True or False
question 1
MODULE 5
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Enrollment Process & Participant Rights
Instruction:Drag the Word
question 2
MODULE 5
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Enrollment Process & Participant Rights
Instruction:Multiple Choice
question 3
MODULE 5
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Enrollment Process & Participant Rights
Module 5Completed!
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Key Takeaways:
By now, you understand that enrolling someone into PACE isn’t about signing them up — it’s about guiding them through a legal, clinical, and participant-centered process.In this module, you walked through the four stages of enrollment:
- Outreach and education
- Eligibility screening
- Enrollment conference
- Participant signature and activation
Each of these steps must be handled with clarity, documentation, and respect for participant rights. You also learned that enrollment is voluntary. Participants have the right to:Module 6
Confidentiality & Communication
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overview
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When you represent a PACE organization in the community, you're not just sharing information — you're trusted with personal health details, sensitive family dynamics, and conversations that shape how people view the program. That’s why this module focuses on two critical responsibilities:
Confidentiality:What you can and cannot say — and to whom.
Communication: How to speak clearly, respectfully, and across cultures, languages, and literacy levels.
Together, these skills help you build trust, stay in compliance, and connect meaningfully with prospective participants and families.
MODULE 6
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Confidentiality & Communication
LEarning Objectives
Click on each item to learn why it matters
By the end of this module, you will be able to:
Apply privacy rules to all verbal and written communication
Use plain, non-technical language and teach-back techniques
Respect cultural and linguistic preferences during outreach and enrollment
MODULE 6
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Confidentiality & Communication
key concepts
Click on each item to learn why it matters
Who Can You Speak To?
HIPAA & Medi-Cal Confidentiality Rules
Language & Cultural Competence
Teach-Back Technique: Do They Really Understand?
MODULE 6
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Confidentiality & Communication
Real-Life Scenario
Click on each item to learn why it matters
“I’m Her Daughter. Just Tell Me.”
Why This Is a Red Flag
Background
How ToRespond:
What This Teaches
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MODULE 6
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Confidentiality & Communication
Best Practicesin the field
Compare the itemsin this table
MODULE 6
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Confidentiality & Communication
Common Pitfalls &How to Overcome Them
Compare the itemsin this table
MODULE 6
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Confidentiality & Communication
Instruction:True or False
question 1
MODULE 6
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Confidentiality & Communication
Instruction:Drag the Word
question 2
MODULE 6
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Confidentiality & Communication
Instruction:Multiple Choice
question 3
MODULE 6
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Confidentiality & Communication
Module 6Completed!
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Key Takeaways:
This module focused on how we communicate — and just as importantly, who we communicate with. You learned that in PACE, even the most casual conversation must follow HIPAA and Medi-Cal privacy rules. That means:
Module 7
Grievance and Appeals
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overview
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As a PACE outreach, marketing, or enrollment team member, you're not just a source of information — you're also a first point of contact when something goes wrong. Whether it's a missed ride, a delayed service, or a concern about care, families and participants often turn to the person they trust — and that might be you. This module prepares you:
To respond appropriately, document correctly, and stay within your role when participants express frustration or dissatisfaction.
MODULE 7
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Grievance and Appeals
LEarning Objectives
Click on each item to learn why it matters
By the end of this module, you will be able to:
Differentiate between a grievance and an appeal
Explain how and when participants can file each
Recognize that your role is to listen and report — not to resolve
MODULE 7
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Grievance and Appeals
key concepts
Click on each item to learn why it matters
What Is a Grievance?
What Is an Appeal?
The Role of the Outreach, Enrollment, or Marketing Staff
MODULE 7
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Grievance and Appeals
Real-Life Scenario
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“Transportation Was Missed Again”
Why This Is a Red Flag
Background
How ToRespond:
What This Teaches
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MODULE 7
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Grievance and Appeals
Best Practicesin the field
Compare the itemsin this table
MODULE 7
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Grievance and Appeals
Common Pitfalls &How to AVOID Them
Compare the itemsin this table
MODULE 7
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Grievance and Appeals
Instruction:True or False
question 1
MODULE 7
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Grievance and Appeals
Instruction:Drag the Word
question 2
MODULE 7
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Grievance and Appeals
Instruction:Multiple Choice
question 3
MODULE 7
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Grievance and Appeals
Module 7Completed!
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Key Takeaways:
In this module, you learned how to support participants and caregivers when something doesn’t go as planned — because even in a well-run program, things will go wrong.Your role isn’t to defend the program or fix the issue on the spot. Your role is to be the first listener, the one who says:“Thank you for telling me. Let’s make sure this gets documented.”You now know the difference between a:
- Grievance – a complaint about service quality or experience
- Appeal – a formal request to reconsider a denied or reduced service
Both must be documented, routed, and tracked according to strict timelines and procedures.Module 8
Marketing Conduct & Legal Boundaries
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overview
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In PACE, marketing is not traditional sales. You’re not closing deals — you’re providing regulated education about a healthcare program that serves some of the most vulnerable people in our communities. That’s why marketing in PACE is governed by strict rules from both CMS and the California Department of Health Care Services (DHCS). One misstep — even an innocent one — can lead to audit findings, penalties, or worse: loss of trust from the public. This module helps you recognize the difference between:
Supportive, compliant outreach and high-risk marketing behavior. It gives you the tools to stay on message, stay in bounds, and protect both your participants and your program.
MODULE 8
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Marketing Conduct & Legal Boundaries
LEarning Objectives
Click on each item to learn why it matters
By the end of this module, you will be able to:
List prohibited marketing practices under DHCS and CMS guidelines
Identify which actions and materials require compliance approval
Describe how violations are reported and what penalties may apply
MODULE 8
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Marketing Conduct & Legal Boundaries
key concepts
Click on each item to learn why it matters
Prohibited Marketing Practices
What Requires Compliance Approval?
Violations: What Happens and Why It Matters
MODULE 8
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Marketing Conduct & Legal Boundaries
Real-Life Scenario
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“They Just Needed a Ride”
What Went Wrong
Background
What the Rep Should Have Said
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MODULE 8
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Marketing Conduct & Legal Boundaries
Instruction:True or False
question 1
MODULE 8
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Marketing Conduct & Legal Boundaries
Instruction:Drag the Word
question 2
MODULE 8
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Marketing Conduct & Legal Boundaries
Instruction:Multiple Choice
question 3
MODULE 8
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Marketing Conduct & Legal Boundaries
Module 8Completed!
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Key Takeaways:
In this module, you learned that PACE marketing is not sales. It’s regulated education — and every conversation you have reflects on the credibility of the program. You reviewed which actions are prohibited under DHCS PL 00-03, including:
- Cold calls
- Door-to-door outreach
- Incentives tied to enrollment
- Using materials that haven’t been pre-approved by compliance
Your job is not to convince someone to enroll — it’s to ensure they have accurate information to make an informed choice.Evaluation
Instruction:True or False
question 1
Final Competency Quiz
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PACE Marketing & Enrollment Training
Instruction:Drag the Word
question 2
Final Competency Quiz
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PACE Marketing & Enrollment Training
Instruction:Multiple Choice
question 3
Final Competency Quiz
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PACE Marketing & Enrollment Training
Instruction:Arrange the Sequence
question 4
Final Competency Quiz
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PACE Marketing & Enrollment Training
Instruction:True or False
question 5
Final Competency Quiz
Having Technical Issues?Click me
PACE Marketing & Enrollment Training
Instruction:Drag the Word
question 6
Final Competency Quiz
Having Technical Issues?Click me
PACE Marketing & Enrollment Training
Instruction:Multiple Choice
question 7
Final Competency Quiz
Having Technical Issues?Click me
PACE Marketing & Enrollment Training
Instruction:Multiple Choice
question 8
Final Competency Quiz
Having Technical Issues?Click me
PACE Marketing & Enrollment Training
Instruction:Arrange the Sequence
question 9
Final Competency Quiz
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PACE Marketing & Enrollment Training
Instruction:Multiple Choice
question 10
Final Competency Quiz
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PACE Marketing & Enrollment Training
Congratulations!
You’ve successfully completed your course—well done! Your commitment to learning, growing, and improving your skills has truly paid off. By finishing this course, you’ve taken an important step in building new knowledge and strengthening your professional development. Keep up the great work, and remember that every skill you gain is an investment in your future.
Any questions?
👏
rosana.scolari@scolariconsulting.com www.scolariconsulting.com
Disenrollment: Voluntary or Involuntary
All disenrollment actions must:
Red Flag: Never suggest that a participant can “just leave at any time” without explaining the implications and process.
Opportunities
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Prohibited Marketing Practices
PACE programs are required to follow strict outreach and marketing regulations. The following actions are prohibited unless explicitly approved by DHCS:
Always use DHCS-approved collateral and follow your organization’s internal marketing policies. 60.3 – Nominal Gifts 42 CFR 460.82(e) POs may offer gifts to prospective participants, provided they: • Have only Nominal Value (be worth $15 or less) based on the retail value of the item, with a maximum aggregate of $75 per person, per year;
How to Respond
The correct coaching message in the field is: “PACE covers emergency care anywhere, but for anything else — even urgent care — always call us first so we can coordinate it for you.” And when educating participants or families ahead of time: “If you're traveling and something comes up, call the PACE center first. We’ll help you figure out the best next step — even after hours.”
How To Respond:
Here’s how a trained, compliance-aware rep might handle it:“Thanks for being involved in your mom’s care — it makes such a difference. Because of privacy laws, we’ll need your mom’s permission or legal documentation before we can go over her specific information. But I can absolutely walk you through the program and what the next steps would be for your family.” Then you can offer to:
Opportunities
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Background
Ms. Johnson is an 81-year-old PACE participant who lives independently and regularly visits the center. Over the weekend, she travels to a nearby county to stay with her son. One evening, she develops sharp abdominal pain — uncomfortable but not life-threatening. Worried, her son drives her to a local urgent care clinic without calling PACE first. She receives treatment and is discharged with medication. The next day, her son calls the PACE center to inform the team. The nurse listens carefully… then explains that because the visit wasn’t coordinated through the PACE care team, the clinic may not be reimbursed — and the family might receive a bill. The son is surprised. “She’s in the program. Isn’t everything covered?”
Who Can You Speak To?
Teach-Back Technique: Do They Really Understand?
Don’t ask: “Do you understand?” Instead, try: “Can you tell me, in your own words, how this program works?” Or: “If your sister asked you what this paper means, what would you tell her?” This technique ensures the participant truly grasps what you’ve explained — and gives you a chance to clarify before moving on.
PACE organizations receive fixed monthly payments from both Medicare and Medi-Cal for each enrolled participant. This is called capitation.With capitation, the organization assumes full risk for providing all needed care. If the participant’s needs are high, the program still only receives that one monthly amount. This is why care coordination and proactive planning are central to PACE.
The Four Stages of PACE Enrollment
PACE enrollment is a structured process that typically follows these steps:
All steps must be thoroughly documented and include signed disclosures and consents.
Why This Matters
This scenario shows how PACE simplifies and integrates care — especially for participants with complex needs. Unlike the fragmented, service-by-service structure of FFS, PACE offers one coordinated solution through capitated funding.As a marketing or outreach professional, you’ll use stories like Mr. Lee’s to help families understand:
- What makes PACE different
- Why capitation matters
- How care coordination improves quality of life
Just remember — always stay within compliance and never overpromise.What This Teaches
Background
You’re facilitating an enrollment conference for Mr. Ramirez, a 78-year-old with multiple chronic conditions who lives with his daughter, Elena. They’ve completed the eligibility screening, the home visit, and the Level of Care assessment. Today is the final enrollment conference — and the decision point. You’ve reviewed the program description, the list of covered services, and the agreement terms. Mr. Ramirez hasn’t asked many questions. Elena has done most of the talking. As you prepare to move into the signature section of the agreement, you pause and ask: “Do you have any questions before we go on?” Mr. Ramirez looks at Elena, shrugs slightly, and says: “Well… I guess I have to, right?”
Best Practice Response
“Those are great questions. What we do is evaluate all of your aunt’s needs through a full care assessment with our team. If day center attendance or dental care is determined to be medically necessary by our interdisciplinary team, those can absolutely become part of her care plan. We’ll walk through all of that together.”✅ This answer:
What Requires Compliance Approval?
You must not create or distribute materials or messaging on your own. The following always require prior compliance review:
- Flyers or handouts
- Digital ads or emails
- Social media posts
- Video scripts or live presentations
- Internal referral program materials
Even small edits — like changing the word “covers” to “provides” — can shift the meaning and create risk.This requirement comes directly from DHCS Policy Letter 00-03, which outlines the minimum standards, compliance protections, and documentation expectations for PACE marketing representatives.
What Could Happen If You Don't Intervene?
HIPAA & Medi-Cal Confidentiality Rules
As a PACE representative, you must follow both federal Health Insurance Portability and Accountability Act (HIPAA) and state (Medi-Cal) privacy regulations. These rules apply to everything you say, write, or share — whether in the field, on the phone, or through written materials. You must only discuss information the participant has explicitly consented to share. This includes:
Even close family members — including adult children — may not be authorized to receive information unless they're the legal representative on file.
Care While Traveling or Out of Area
PACE participants must notify the care team before leaving the area. If they require medical attention while traveling:
Participants should always carry their PACE membership card, which includes emergency contact numbers and coverage instructions.
The Role of the Outreach, Enrollment, or Marketing Staff
Your role is not to explain, justify, or fix the situation.Your role is to:
- Listen carefully
- Acknowledge the concern
- Document it properly
- Report it to the appropriate team or compliance lead
🛑 Trying to “make it right” on your own can lead to missteps, unmet expectations, and compliance violations.🧠 What This Example Shows:
This scenario illustrates:
Background
You’re working a community resource fair in partnership with a local senior center. A woman approaches your table and asks about enrolling her mother in PACE. She explains: “My mom’s 86. She lives with me now. She has diabetes and early dementia. We really need help.” You offer a warm response and begin explaining how PACE works. As you talk, she starts filling out the referral form for her mother — but stops when you ask about a signed release or power of attorney. “I don’t have any legal paperwork,” she says. “But I’m her daughter. Just tell me what I need to know.”
Background
You’re visiting a senior apartment complex for a scheduled outreach event. A resident approaches you quietly and says: “I haven’t seen my doctor in months. I can’t get a ride anywhere. I just need help getting to the pharmacy.” You see an opportunity to connect. You want to offer hope — and you want her to feel supported. So, you respond: “If you enroll in PACE, we can send a van to take you wherever you need — no problem.” She lights up. Finally, a solution. Or so she thinks.
Violations: What Happens and Why It Matters
If a marketing violation occurs — whether intentional or not — it can trigger:
- A DHCS audit
- Required corrective action plans
- Public complaints
- Risk to your organization’s PACE contract
And yes — violations must be reported. PACE is held to high transparency standards. Trying to hide or "fix" a mistake quietly only increases the risk.Background
Mrs. Alvarez is 83 years old and lives with her niece in a duplex within your PACE organization’s service area. She’s been feeling isolated and says she “just wants to get out of the house and see people.” Her niece reaches out after hearing that PACE offers a day center and dental care. During the initial call, she says: “We’re interested in the day center and getting her some dental work done. We heard you take care of everything.”
What Counts as Emergency Care?
Emergency care is any situation where a person could reasonably expect serious harm without immediate treatment.According to DHCS and CMS guidelines, this includes:
- Severe chest pain or heart attack symptoms
- Difficulty breathing
- Loss of consciousness
- Severe bleeding or trauma
- Psychiatric emergencies (harm to self or others)
📌 Participants do not need prior authorization to access emergency services.They can call 911 or go directly to the emergency room — even outside of the PACE service area.Why This Is a Red Flag
In many families, adult children are deeply involved in care decisions. But being a family member doesn’t automatically grant legal authority to access health or enrollment information.If you proceed and share private details about the participant — even basic medical eligibility info — you could violate HIPAA and Medi-Cal privacy rules. This includes:
What Is Routine Care?
Routine care refers to:
- Primary and specialty care
- Medication refills
- Ongoing therapy
- Non-urgent lab work or imaging
- Preventive care (e.g., checkups, vaccinations)
This care must be coordinated through the PACE organization — and must be approved in advance.PACE staff are responsible for scheduling, referring, and authorizing all non-emergency services. Unauthorized use of routine care outside the network may not be covered, and participants could be billed.Participant Rights at Enrollment
Participants and their legal representatives have the right to:
- Receive a full explanation of the program before signing
- Ask questions and review all documents in plain language
- Be informed of their right to rescind enrollment within 72 hours
- Understand what happens if they choose to disenroll voluntarily or are disenrolled involuntarily
- Be provided with translations or interpreter services as needed
Enrollment is not just a formality. It’s a decision with legal and clinical implications, and participants must feel confident in their understanding.What Is an Appeal?
An appeal is a formal request to reconsider a denied, delayed, or reduced service.Examples include:
- “My home care hours were cut.”
- “The doctor won’t approve my therapy.”
- “PACE won’t pay for the equipment I need.”
📄 Appeals typically involve clinical or coverage decisions and must follow specific timelines.Opportunities
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Not all services are guaranteed under PACE. Some are excluded by regulation, while others are provided only when deemed medically necessary.
Key Compliance Risk: Overpromising excluded or conditional services is a red flag.
How To Respond:
The correct response in this moment is calm, validating, and compliant:
- “Thank you for telling me. That does sound frustrating. I want to make sure it gets documented so the right team can follow up. I’m going to report this as a grievance.”
Then, follow your organization’s grievance reporting workflow.Don’t:Background
You’re doing follow-up calls at the PACE center when a caregiver stops you in the hallway. She looks tired and frustrated. “My mom’s van was late again. She missed her physical therapy. That’s twice this month. What’s the point if she can’t get there on time?” She’s clearly upset. And she’s looking at you for answers. You want to help. It’s tempting to apologize, explain the situation, or even try to fix it directly.
Background
Mr. Lee is a 76-year-old retired carpenter with diabetes and high blood pressure. He lives alone and has been using fee-for-service Medicare and Medi-Cal, which means each medical service is billed separately. His daughter, Grace, helps manage his care but lives an hour away. Coordinating appointments, transportation, and follow-ups has become overwhelming.
Dicovering PACE
At a local community event, Grace hears about PACE. Mr. Lee is screened, found eligible, and enrolls the following month.Now he receives:
- Coordinated care through a full interdisciplinary team
- Transportation to the PACE center
- On-site physical therapy
- All medications through the PACE pharmacy
- A single point of contact for his care plan
Grace no longer has to act as his care manager. The PACE team handles it all.Opportunities
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Best Practice Response:
Here’s how a seasoned rep might respond: “Actually, this is your decision — and it’s completely voluntary. Let’s pause for a minute. Is there anything you’re unsure about, or anything you want me to go over again?” Then, turn to the participant directly: “Mr. Ramirez, do you feel comfortable with everything we’ve reviewed so far? Would it help if we went back to any part of the agreement or your care plan?” This gives the participant space to speak, invites clarification, and demonstrates that your role is supportive, not persuasive.
Assessment Findings:
What is a Grievance?
A grievance is any complaint or expression of dissatisfaction about the quality of care or services.Examples include:
- “They forgot to pick me up again.”
- “The nurse was rude on the phone.”
- “I didn’t get my medication on time.”
Grievances can come from:- Participants
- Family members or caregivers
- Staff acting on the participant’s behalf
✅ Grievances do not have to be written and can be reported verbally.Most PACE participants are dually eligible, meaning they qualify for both Medi-Cal (California’s Medicaid) and Medicare.
- Medi-Cal covers low-income Californians.
- Medicare provides federal health coverage for those over 65 or with disabilities.
PACE integrates both, so participants don’t need separate plans or pay multiple premiums. PACE becomes their sole provider and payer.- In FFS, the government pays for each service individually — every doctor visit, procedure, or hospital stay is billed separately.
- In Managed Care, providers receive a set monthly amount to manage a participant’s care — regardless of how many services are used.
PACE is a managed care model. This means it focuses on prevention, coordination, and cost control — rather than volume of services.Language & Cultural Competence
PACE serves diverse populations — often across languages, generations, and cultural beliefs about aging, illness, and independence. Your communication must be:
- Respectful
- Culturally aware
- Linguistically appropriate
Do not assume understanding based on head nods, smiles, or silence. Always offer:- Interpreter services
- Translated materials
- Extra time for explanation
🎯 Key Point: Don’t rely on family members to translate — especially when discussing legal documents or health information.PACE is designed to provide comprehensive, coordinated care. All medically necessary services are delivered through the PACE provider network, including:
These services are coordinated by the Interdisciplinary Team (IDT) and based on what is medically necessary — not on participant requests alone.
What This Teaches
What Went Wrong
While the rep meant well, this is a classic case of overpromising services.By suggesting that PACE will provide unlimited transportation “wherever you need”, the rep failed to clarify that:
- All services must be medically necessary
- All transportation must be approved by the care team
- PACE is not a taxi service — rides are based on the participant’s care plan and health needs
This kind of statement sets unrealistic expectations. Later, when the participant is told she can’t get a ride to her cousin’s house or to run errands, she may feel misled — which can lead to grievances, rescission, or even audit findings.Opportunities
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Why This Is a Red Flag
That statement — “I guess I have to” — may seem small, but it’s a signal. It tells you the participant may not:
- Fully understand the program
- Feel empowered to make the decision
- Realize that enrollment is voluntary
If you ignore it and proceed with the signature, you risk:What This Teaches
This scenario reinforces that:
Why This Is a Red Flag
This situation is a common compliance risk. The family:
- Assumed PACE would cover any medical care, regardless of coordination
- Sought non-emergency care without calling first
- May now face out-of-network charges and confusion about coverage
PACE is a managed care model, meaning all non-emergency services must be authorized in advance by the care team — even more so when participants are traveling. This scenario could lead to:Why This Is a Red Flag
This is a classic example of a participant grievance — and a common situation where well-meaning staff may overstep their role.Here’s what makes it risky:
- Staff might try to justify or explain the delay
- Others might say, “I’ll make sure it never happens again” — which is a promise you can’t keep
- Some might think it’s too small to report
But every participant complaint — even verbal — must be documented and routed to the compliance team.Failing to do so can result in:Common Pitfall:
A newer outreach staff member is excited to help and responds:“Yes, we definitely take care of all that. She’ll be able to come to the day center whenever she wants, and we can take care of her dental work too.”🚫 This is a compliance red flag:
To enroll in PACE, participants must meet the state-defined criteria for nursing home level of care. This does not mean they must live in a nursing home — rather, they need the level of care that would qualify them for nursing home placement. It is important to note that the state agency and not the PACE program determines if a person meets nursing home level of care. This includes:
- Help with multiple Activities of Daily Living (ADLs) (e.g., bathing, dressing, toileting)
- Cognitive or behavioral impairments
- Complex chronic medical conditions
PACE enables these individuals to live safely at home while receiving the care they need.“PACE provides transportation to medically necessary appointments — and your care team works with you to schedule those rides.” This answer keeps things accurate, compliant, and grounded in the PACE care model.
The Turning Point
Mr. Lee suffers a mild stroke and is hospitalized. After discharge, Grace struggles to arrange the services he needs:
- Home health
- Physical therapy
- Medications
- Transportation
Three weeks later, he still hasn’t started rehab.Opportunities
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Rescission:Backing out Within 72 hrs
California regulations give participants 72 hours after signing the enrollment agreement to rescind their decision — for any reason.If this happens: