Recently, regulatory changes were made to account for requests made prior to the creation of an initial plan of care. Regulators reasoned that it was unfair to expect a PACE Organization to conduct a service determination request on a participant who has not completed initial assessments and plans of care, thus a “carve out” exception was made for this scenario. In the case that a participant requests a service prior to the finalization of the initial plan of care (often during an initial assessment), the IDT must:
- Document the request when made, and in the initial plan of care
- Include the request in the initial plan of care discussion with the IDT
- Document that the request will or will not be provided (with a rationale if denied) in the initial plan of care
*An IDT may still choose to process an SDR prior to the Initial Plan of Care, and may consider doing so if a denial is likely in order to provide appeal rights.