Question: Our organization's Program for All-inclusive Care for the Elderly (PACE) subsidizes the housing of some very low-income persons so that they can participate in PACE. While PACE is a capitated payment for all health services, housing costs are not included. Should we count the cost of housing as community benefit?

Recommendation: PACE, a program for persons dually eligible for Medicare and Medicaid, provides access to care for a vulnerable population (low-income, elderly consumers), and thus is eligible to be considered a community benefit program. Since housing costs are not included in the program's payment rate, we recommend that the cost of housing be included and be reported in Category A3.

(Updated November 2015)