The IntusCare team just returned from the NPA Spring Policy Conference in D.C., and if there’s one takeaway for PACE organizations, it’s this: future regulatory changes are uncertain. But amid the swirl of speculation, PACE organizations must comply with the CY 2025 PACE Final rule now, and prepare for shifts in how payments will be calculated in 2025. In this blog we break down those changes and how CareHub can help you stay grounded, compliant, and ready for whatever might come next.

What’s new in 2025?

Let’s start with the big one: the CY 2025 PACE Final Rule, § 460.106. It signals a major shift toward more holistic, person-centered care, and more rigorous documentation.

If you’re feeling the pressure to update your workflows, you’re not alone. But there’s good news: CareHub was built for this. As the only EMR created by PACE experts for PACE teams, it’s ready to help you stay compliant, nimble, and participant-focused both today and tomorrow.

Here’s a quick recap of what’s changing—and what’s next on the horizon:

Comprehensive care plans, reimagined

Under the new CMS requirements, care plans must address every facet of a participant’s health, including physical, behavioral, social, and environmental. That includes:

• Physical Health: Skin integrity, dentition, pain management, ADLs, nutrition, mobility. Basically, head to toe.
• Social & Environmental Factors: Living safely in the community, transportation, communication needs, center attendance, and more.
• Mental & Behavioral Health: Chronic conditions, psychiatric diagnoses, and behavioral health needs that require treatment or monitoring.

This isn’t just a checklist—it’s a commitment to seeing the whole person.

More specifics for intervention plans

The Final Rule also outlines clear requirements for each intervention in the care plan:

• Specific Interventions – What are you doing? Be clear.
• Timelines – When is it happening? Put it on the calendar.
• Measurable Outcomes – What’s the goal?
• Evaluation Criteria – How will you know if it’s working?
• Participant Preferences – What matters most to them?

The goal? Personalized care that is easy to track and even easier to improve.

How CareHub helps you comply (and thrive)

Managing new requirements with old systems is a recipe for burnout, but CareHub was purpose-built to keep you compliant without sacrificing your team’s time, focus, or sanity.

Here’s what makes it different:

• Automated due dates: Stop tracking tasks in spreadsheets.
• Intus suggestions: Reduce documentation burden through AI-suggestions in IDT morning meeting, assessments, and care planning.
• Integrated task management: Assign, track, and complete care plan actions.
• Real-time IDT collaboration: Keep everyone aligned directly in the EMR without the email chains.
• Powerful analytics & dashboards: Monitor progress, outcomes, and quality all in one place.

With CareHub you aren’t just staying compliant. You’re getting smarter, faster, and more aligned as a team.

Looking ahead to 2026: Don’t wait for HCC v28 to catch you off guard

Several discussions in DC focused on the major shift in how PACE payments will be calculated in 2026. The Centers for Medicare & Medicaid Services (CMS) is implementing transformative updates to PACE payment calculations in 2026, driven by two critical shifts:

• Transition to the 2024 CMS-HCC Model (v28): Blended risk adjustment – For calendar year 2026, CMS will calculate PACE risk scores using a blend of the 2024 CMS-HCC model (v28) and the current 2017 CMS-HCC model (v22), with a full transition to v28 by 2029.
• Encounter Data Processing System (EDPS) Mandate: EDPS requires more granular encounter data in HIPAA-compliant formats, phasing out legacy RAPS submissions.

Here’s the issue

Many legacy EMRs don’t allow for EDPS exports—making it nearly impossible to adapt in time. CareHub is different:

• EDPS-Ready infrastructure that allows for automated conversion of clinical documentation into EDPS-compliant submission files.
• Compliance and revenue integrity are at the forefront, allowing for the identification of potential high-impact diagnoses in both versions 22 and 28, allowing for accurate revenue.

With CMS requiring PACE encounter data improvements in 2025 to support the 2026 transition, delayed EDPS adoption can negatively impact your organization with potential penalties and under-captured risk scores during the v28 phase-in.

2016 regs opening doors in 2025

The 21st Century Cures Act was signed into law back in 2016, but 2025 might be the year that it makes a real difference for PACE. Last week a court ruling accelerated a long-overdue reckoning with EMR interoperability. The message is clear: blocking access to participant data isn’t just bad practice, it’s a legal liability. If you missed our take on the Real Time Medical Group case ruling and why it matters for PACE, read the blog here.

CareHub is built with this future in mind: open, connected, and ready to power a truly holistic view of participant care.

Stay ready. Today and tomorrow.

Future regulatory change is uncertain, but with the right tools, it doesn’t have to be overwhelming.

Whether you’re navigating compliance with the 2025 Final Rule or prepping for 2026 payment reform, CareHub is the EMR that evolves with you, designed by PACE people, for PACE performance.

👉 Ready to see it in action?

Visit the CareHub website to learn more or request a demo today.