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The PACE intake checklist: what the IDT needs on file before the initial comprehensive assessment

Every document a PACE organization needs before the initial comprehensive assessment, who holds it, and the federal or state rule that makes it necessary.

things the medical record must contain at a minimum, 42 CFR 460.210
15
domains the initial assessment must evaluate, 42 CFR 460.104
11
items in the enrollment agreement, (a) to (t), 42 CFR 460.154
20
the age limit on Pennsylvania's physician certification, MA 570
1 year

There is no published PACE intake checklist. The regulation lists what the medical record must contain, what the assessment must evaluate and what the enrollment agreement must say; the states each name a form; CMS’s manual adds a few lines of guidance. Nobody has put them in one list with the rule beside each item and a column for who holds the document. This is that list.

The clocks these documents run against are in the PACE intake timeline and are not repeated. One framing point first, because the title of this article can mislead: the initial comprehensive assessment under 42 CFR 460.104 is performed after enrollment. CMS’s PACE Manual says it is done “independent of any pre-enrollment screening by the IDT” and “must be completed promptly following enrollment”, and the plan of care it feeds is due within 30 days of the enrollment date. “Before the initial comprehensive assessment” therefore means: gathered during intake and the pre-enrollment screening, in the file on the day the eight disciplines start.

What the rule says must be in the record

42 CFR 460.210 requires “a single, comprehensive medical record for each participant” that is complete, accurately documented, readily accessible, systematically organized and available to all staff. “At a minimum, the medical record must contain the following”, and the list is fifteen items:

  1. Appropriate identifying information
  2. Documentation of all services furnished, including a summary of emergency care and other inpatient or long-term care services, services furnished by employees of the PACE center, and services furnished by contractors and their reports
  3. Interdisciplinary assessments, reassessments, plans of care, treatment, and progress notes that include the participant’s response to treatment
  4. All recommendations for services made by employees or contractors of the PACE organization, including specialists
  5. If a recommended service is not approved or provided, the reasons
  6. Original documentation of written communications described in 460.200(d)(2)
  7. Laboratory, radiological and other test reports
  8. Medication records
  9. Hospital discharge summaries, if applicable
  10. Reports of contact with informal support (for example, caregiver, legal guardian, or next of kin)
  11. Enrollment Agreement
  12. Physician orders
  13. Discharge summary and disenrollment justification, if applicable
  14. Advance directives, if applicable
  15. A signed release permitting disclosure of personal information

Six of those are generated by the organization itself over time (2, 3, 4, 5, 6, 13). The other nine have to be in hand at or near intake, and five of the nine (7, 8, 9, 12, 14) originate with someone other than the organization or the applicant.

What the assessment has to evaluate

Under 460.104(a)(4), the initial in-person comprehensive assessment “must at a minimum include the evaluation of” eleven things: physical and cognitive function and ability; medication use; participant and caregiver preferences for care; socialization and availability of family support; current health status and treatment needs; nutritional status; home environment, including home access and egress; participant behavior; psychosocial status; medical and dental status; and participant language. Each of the eight disciplines (primary care provider, registered nurse, master’s-level social worker, physical therapist, occupational therapist, recreational therapist or activity coordinator, dietitian, home care coordinator) must “evaluate the participant in person and develop a discipline-specific assessment”.

In person is the rule, and CMS’s manual draws the line that matters for a checklist: the team “cannot substitute assessments completed by non-PACE community providers or reports contained in copied medical records”. The outside record does not replace the assessment. It is what “medication use”, “current health status and treatment needs” and “medical and dental status” are evaluated against, because none of the three can be assessed from the participant’s recollection alone.

The checklist

Each row names the document, who has it before the organization does, and the rule or form that makes it necessary. “Prior provider” means a hospital, physician, specialist, pharmacy or facility the applicant used before PACE.

Document Who holds it Why it is needed
Signed release for medical and financial information and Medicare and Medicaid eligibility status The applicant signs it; the organization keeps it 460.152(a)(2) requires it at intake; 460.210(b)(15) requires it in the record
Enrollment agreement: name, sex and date of birth, Medicare and Medicaid status and numbers, other insurance, premiums, conditions of enrollment and disenrollment, the authorization for information exchange with CMS and the state, effective date, signature The applicant and the organization 460.154, items (a) to (t); 460.210(b)(11)
Proof of age 55 or over and of residence in the service area The applicant 460.150(b)(1) and (b)(3)
The state’s nursing facility level of care determination The state administering agency or its delegate, from the organization’s and the physician’s inputs 460.150(b)(2); 460.152(a)(3); renewed at least annually under 460.160(b)
The physician’s certification of level of care, with diagnoses A prior provider: the applicant’s own physician State rule; see the state table below
The Medicaid financial application, where the applicant is not already enrolled The applicant, with the organization’s help 460.152(a)(1) requires the premium and spenddown consequences to be explained; the application itself is the state’s
The organization’s own assessment that the applicant can live safely in the community, including the care support network and the home The organization 460.150(c)(1); 460.152(a)(4); documented if enrollment is denied, 460.152(b)(3)
Medication records: the current list as prior providers and the pharmacy hold it Prior providers 460.210(b)(8); the “medication use” domain, 460.104(a)(4)(ii)
Hospital discharge summaries, and a summary of emergency and inpatient care Prior providers: the hospital, the skilled nursing facility 460.210(b)(9) and (b)(2)(i), “if applicable”
Laboratory, radiology and other test reports Prior providers 460.210(b)(7); the “current health status” and “medical and dental status” domains
Physician orders in force at intake Prior providers until the organization’s primary care provider writes new ones 460.210(b)(12)
Advance directives The applicant, or a prior provider’s chart 460.210(b)(14), “if applicable”
Caregiver, guardian or next-of-kin contacts; power of attorney or guardianship papers where they exist The applicant and family 460.210(b)(10); the “availability of family support” and “preferences for care” domains, 460.104(a)(4)(iii) and (iv)
The eight discipline-specific assessments, and the plan of care within 30 days of enrollment The organization’s interdisciplinary team 460.104(a)(2), (b) and (f); 460.210(b)(3)
An interim care management strategy for the gap between enrollment and the initial assessment The organization CMS PACE Manual chapter 8, §20.1: guidance, not regulation

What the state wants from the physician

The federal rule says the state determines level of care and says nothing about how. Each state does it with a form, and for most of them the form is signed by a physician the organization does not employ. That is the one document in the checklist with a hard expiry and a named signer, and the one a program most often waits on.

State The instrument What the rule says
Pennsylvania Form MA 570, the Physician Certification Form, with the Functional Eligibility Determination OLTL Bulletin 59-20-03 (2020): the MA 570 “must be current (not more than one year old) and may only be signed by a Medical Doctor (MD) or Doctor of Osteopathic Medicine (DO)” licensed in Pennsylvania or a bordering state; the state “will not accept an MA 570 signed by a physician in training, physician assistant or certified registered nurse practitioner”. The form asks the physician to “list all diagnoses with ICD codes related to patient’s need for care” and to check exactly one level of care
Colorado The Professional Medical Information Page (PMIP), with the case management agency’s LTSS assessment The PACE and CMA Handbook (November 2023): the PMIP is “signed by the individual’s physician”, and for new enrollees its “signature date must be prior to and no earlier than six months from the Certification Start Date and no later than 90 days from the LTSS Assessment date”. The applicant also signs a release “to allow PO and CMA to access financial and medical records”
Florida Form 5000-3008, the Medical Certification for Medicaid Long-term Care Services, with a CARES in-person visit The ADRC mails the form; the applicant’s “medical provider (Florida licensed physician, Advanced Practice Registered Nurse or Physician Assistant)” completes it; “the completed form must be returned to the ADRC, or the individual will not move forward”
California The nursing facility level of care determination form DHCS Policy Letter 02-14: organizations “must conduct an assessment for each beneficiary to determine if they meet the NFLOC requirements prior to enrollment”, on the form, “submitted electronically to the PACE LOC Review Inbox” for a DHCS nurse’s review
Michigan The online Nursing Facility Level of Care Determination (LOCD) The Medicaid Provider Manual: conducted “within fourteen (14) calendar days from the date of enrollment” by “a health professional (physician, registered nurse, licensed practical nurse, clinical social worker (BSW or MSW), or physician assistant) representing the proposed provider”
Ohio The Department of Aging’s assessment, on an ODM-approved tool, with PASRR OAC 173-50-03 (June 2026): the Department “is responsible for the level-of-care assessment” and “may delegate this responsibility”; OAC 5160-3-08 rests the criteria on the tool and, for cognitive impairment, a diagnosis “by a physician”
Louisiana The LOCET telephone screening, then the interRAI Home Care assessment Medicaid’s PACE chapter: “the PACE applicant must receive a face-to-face assessment to determine NFLOC criteria prior to PACE enrollment”, by OAAS-certified assessors, who may be PACE staff
Oklahoma The UCAT Part III, by a nurse, in the home OAC 317:35-18-5: the nurse “sends the UCAT, Part III to the designated OHCA nurse staff member for review and level of care determination”

Pennsylvania’s and Colorado’s forms both ask the physician for the diagnoses behind the need for care; Florida’s asks the medical provider to certify it; Louisiana’s safety criteria rest on a physician who “has documented” the condition. Each of those is a document the physician writes from the chart, which means the chart has to be current with the hospital, the specialists and the pharmacy before the form is worth signing. A physician who signs an MA 570 from a chart that is missing the last admission certifies a level of care from last year’s picture.

What the rule does not say

Nothing in 42 CFR Part 460 or the CMS manual requires a PACE organization to request or obtain records from prior providers. The release at 460.152(a)(2) is permission, not a duty. The record “must contain” discharge summaries, test reports, medication records and advance directives, but four of those carry “if applicable”, and 460.210(c) on transfer of records is about sending copies “between treatment facilities”, not collecting them at intake. The assessment domains require the evaluation of medication use and health status; the rule leaves it to the team to find out what they are.

So the retrieval is the organization’s choice and the record’s completeness is the organization’s obligation, and the two meet at the first assessment visit. Vivlio’s own intake checklist, written from what PACE teams ask for, is the operational version of this article: the last six to twelve months of progress notes, the last two or three office visits, the history and physical, specialist consults, physical and occupational therapy notes, cognitive scores, discharge summaries, imaging, labs from the last six months, the medication list, behavioral health. None of those lookback windows is in a rule. They are what an interdisciplinary team needs to evaluate the eleven domains in person without starting from the kitchen drawer, and the rule’s “if applicable” is doing a lot of work for a population in which every one of them usually applies.

PACE intake records is the page about retrieving all of it at once, through the national record networks on the release the applicant has already signed, organized by section before the first visit. The initial comprehensive assessment, PACE enrollment and the level-of-care form carry the regulation text behind the rows above.

The record

This is what arrives.

The portal itself, rendered from the product's own source over a synthetic patient. Every line carries the organization that released it and the date it arrived.

Vivlio portal, release 5.30.0, rendered from source · Synthetic patient, no PHI

Rivera, Elena

Date of birth03/18/1958
Viewing records from facility:

Showing 1–10 of 27 records

Date of ServiceRecord TitleFacilityDepartment/LocationProviderTransaction Date
08/27/2026Progress NoteNorthside Regional Medical CenterInternal MedicinePriya Natarajan, MD09/02/2026
08/14/2026Consult NoteAtlanta Cardiology AssociatesCardiologyMarcus Bell, MD09/02/2026
07/30/2026Admission DischargeNorthside Regional Medical CenterInpatientHannah Okafor, DO09/02/2026
07/22/2026Clinical DocumentPeachtree Family MedicinePrimary CareDaniel Reyes, MD09/02/2026
06/09/2026Image DocumentLakeview Imaging PartnersRadiologySunil Mehta, MD09/02/2026
05/12/2026Operative NoteNorthside Regional Medical CenterSurgeryGrace Lindqvist, MD09/02/2026
03/03/2026Patient HistoryPeachtree Family MedicinePrimary CareDaniel Reyes, MD09/02/2026
01/15/2026Progress NoteAtlanta Cardiology AssociatesCardiologyMarcus Bell, MD09/02/2026
12/02/2025Clinical DocumentLakeview Imaging PartnersRadiologySunil Mehta, MD09/02/2026
10/21/2025Consult NoteNorthside Regional Medical CenterEndocrinologyRina Adeyemi, MD09/02/2026

Demographics

DOB: 03/18/1958
Age: 68 years old
Gender: Female
Email: N/A
Phone: (404) 555-0134
Address:
1420 Willow Creek Dr
Decatur, GA 30030

Data Summary

Encounters: 14 records
Labs: 22 records
Diagnostic Tests: 6 records
Medications: 11 records
Notes: 9 records
Plan of Care: 3 records
Hospitalizations: 1 record
Surgeries: 2 records

Encounters

Go to Encounters
Office visit
Follow-up, atrial fibrillation
Marcus Bell, MD
08/14/2026
Hospital
Chest pain, observation
Hannah Okafor, DO
07/30/2026
Office visit
Diabetes management
Daniel Reyes, MD
07/22/2026
Telephone
Medication question
Daniel Reyes, MD
06/18/2026

Vitals

Go to Vitals
Blood Pressure128/82 mmHg
08/27/2026
Heart Rate72 bpm
08/27/2026
Weight164 lb
08/27/2026
BMI27.3
08/27/2026

Allergies

Penicillin- Hives
03/03/2026
Sulfonamides- Rash
03/03/2026

Immunizations

Influenza, seasonal
10/02/2025
COVID-19, mRNA
10/02/2025
Tdap
05/11/2022

Problem List

Type 2 diabetes mellitus
Daniel Reyes, MD
07/22/2026
Atrial fibrillation
Marcus Bell, MD
08/14/2026
Essential hypertension
Daniel Reyes, MD
07/22/2026
Hyperlipidemia
Daniel Reyes, MD
07/22/2026

Care Team

Daniel Reyes, MD
Primary care
Peachtree Family Medicine
Marcus Bell, MD
Cardiology
Atlanta Cardiology Associates
Rina Adeyemi, MD
Endocrinology
Northside Regional Medical Center

Showing 1–10 of 22 records

Date of ServiceCollection DateTestResultFacilityFull RecordTransaction Date
08/27/202608/27/2026Comprehensive metabolic panelFinalNorthside Regional Medical CenterLaboratory Report09/02/2026
08/27/202608/27/2026Hemoglobin A1cFinalNorthside Regional Medical CenterLaboratory Report09/02/2026
08/27/202608/27/2026Lipid panelFinalNorthside Regional Medical CenterLaboratory Report09/02/2026
08/14/202608/14/2026Prothrombin time / INRFinalAtlanta Cardiology AssociatesLaboratory Report09/02/2026
08/14/202608/14/2026Basic metabolic panelFinalAtlanta Cardiology AssociatesLaboratory Report09/02/2026
07/30/202607/30/2026Troponin I, high sensitivityFinalNorthside Regional Medical CenterLaboratory Report09/02/2026
07/30/202607/30/2026CBC with differentialFinalNorthside Regional Medical CenterLaboratory Report09/02/2026
07/30/202607/30/2026BNPFinalNorthside Regional Medical CenterLaboratory Report09/02/2026
07/22/202607/22/2026Hemoglobin A1cFinalPeachtree Family MedicineLaboratory Report09/02/2026
07/22/202607/22/2026Urine microalbumin / creatinineFinalPeachtree Family MedicineLaboratory Report09/02/2026

Showing 1–6 of 6 records

Date of ServiceTestResultAuthorizing ProviderFacilityFull RecordTransaction Date
08/14/2026Echocardiogram, transthoracicFinalMarcus Bell, MDAtlanta Cardiology AssociatesDiagnostic Report09/02/2026
08/14/2026ECG, 12 leadFinalMarcus Bell, MDAtlanta Cardiology AssociatesDiagnostic Report09/02/2026
07/30/2026Chest X-ray, 2 viewsFinalHannah Okafor, DONorthside Regional Medical CenterImage Document09/02/2026
07/30/2026ECG, 12 leadFinalHannah Okafor, DONorthside Regional Medical CenterDiagnostic Report09/02/2026
06/09/2026CT abdomen and pelvis with contrastFinalSunil Mehta, MDLakeview Imaging PartnersImage Document09/02/2026
12/02/2025Mammogram, screening, bilateralFinalSunil Mehta, MDLakeview Imaging PartnersImage Document09/02/2026

Showing 1–10 of 11 records

Start DateEnd DateMedicationFacilityFull RecordTransaction Date
08/14/2026-Apixaban 5 mg tabletAtlanta Cardiology AssociatesConsult Note09/02/2026
08/14/2026-Metoprolol succinate ER 50 mg tabletAtlanta Cardiology AssociatesConsult Note09/02/2026
07/30/202608/06/2026Aspirin 81 mg tabletNorthside Regional Medical CenterAdmission Discharge09/02/2026
07/22/2026-Metformin 1000 mg tabletPeachtree Family MedicineClinical Document09/02/2026
07/22/2026-Empagliflozin 10 mg tabletPeachtree Family MedicineClinical Document09/02/2026
07/22/2026-Lisinopril 20 mg tabletPeachtree Family MedicineClinical Document09/02/2026
07/22/2026-Atorvastatin 40 mg tabletPeachtree Family MedicineClinical Document09/02/2026
05/12/202605/19/2026Oxycodone-acetaminophen 5-325 mg tabletNorthside Regional Medical CenterOperative Note09/02/2026
05/12/202605/19/2026Cefazolin 2 g injectionNorthside Regional Medical CenterOperative Note09/02/2026
03/03/2026-Levothyroxine 75 mcg tabletPeachtree Family MedicinePatient History09/02/2026

Showing 1–9 of 9 records

Date of ServiceTypeFacilityFull RecordTransaction Date
08/27/2026Progress NoteNorthside Regional Medical CenterProgress Note09/02/2026
08/14/2026Consultation NoteAtlanta Cardiology AssociatesConsult Note09/02/2026
07/30/2026Discharge SummaryNorthside Regional Medical CenterAdmission Discharge09/02/2026
07/30/2026History and PhysicalNorthside Regional Medical CenterAdmission Discharge09/02/2026
07/22/2026Progress NotePeachtree Family MedicineClinical Document09/02/2026
06/18/2026Telephone EncounterPeachtree Family MedicineClinical Document09/02/2026
05/12/2026Operative NoteNorthside Regional Medical CenterOperative Note09/02/2026
03/03/2026Progress NotePeachtree Family MedicinePatient History09/02/2026
01/15/2026Progress NoteAtlanta Cardiology AssociatesProgress Note09/02/2026

Showing 1–3 of 3 records

DateTypeFacilityFull RecordTransaction Date
09/11/2026Follow-up appointmentAtlanta Cardiology AssociatesConsult Note09/02/2026
08/14/2026Medication planAtlanta Cardiology AssociatesConsult Note09/02/2026
07/22/2026GoalPeachtree Family MedicineClinical Document09/02/2026

Showing 1–1 of 1 records

Date of ServiceFacilityFull RecordTransaction Date
07/30/2026Northside Regional Medical CenterAdmission Discharge09/02/2026

Showing 1–2 of 2 records

Date of ServiceFacilityFull RecordTransaction Date
05/12/2026Northside Regional Medical CenterOperative Note09/02/2026
09/23/2024Northside Regional Medical CenterOperative Note09/02/2026
The Vivlio portal, release 5.30.0, rendered from its own source: a patient's Electronic Records, with the Full Records grid, the Highlights cards and every parsed tab. The patient, the facilities, the providers and every record shown are synthetic.

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