PACE Applications and the Five-Year Lookback Period: What You Need to Know

A significant change in PACE program eligibility rules takes effect April 6. Families and caregivers should act promptly to understand how this policy shift may affect long-term care planning.

Effective April 6, the five-year Medicaid lookback period will apply to all PACE program applications filed on or after that date. This represents a substantial change for individuals and families who hope to rely on the Program of All-inclusive Care for the Elderly (PACE) to help aging loved ones remain in the community while receiving comprehensive medical and supportive services.

What Is PACE?

PACE — the Program of All-inclusive Care for the Elderly — is a comprehensive Medicaid program designed to coordinate and deliver all needed preventive, primary, acute, and long-term care services for individuals 55 and older who require a nursing home level of care but wish to remain living in the community. PACE provides an integrated alternative to nursing home placement and has historically offered certain eligibility advantages over traditional Medicaid.

What Is the Five-Year Lookback Period?

Under the Medicaid lookback rules, program reviewers examine an applicant’s financial history for the five years preceding the application date. They will be looking at all transactions of $1,000 or more relating to gifts, transfers of assets, or other financial transactions made during that window for less than fair market value can result in a period of ineligibility for benefits or a denial.

Until now, PACE applicants were not subject to the same lookback scrutiny applied to nursing home Medicaid applicants. This new rule brings PACE into alignment with traditional long-term care Medicaid policy. This new rule comes quickly after the insertion of the spousal asset limit into the PACE program on January 15, 2026.

What Should Families Do Now?

If you or a family member are considering applying for PACE, or if gifts or asset transfers have been made in recent years, it is important to consult with an elder law attorney before filing. Timing, documentation, and planning strategies matter significantly under these new rules. In some cases, acting promptly — before the April 6 effective date — may preserve options that would otherwise no longer be available.

Click here to read the formal policy announcement from Heather Ross, Deputy Chief Operating Officer, Eligibility Policy and Implementation

We are closely monitoring this development and will continue to update clients as additional guidance is issued. Please do not hesitate to contact our office with questions.

This article is provided for informational purposes only and does not constitute legal advice or create an attorney-client relationship. Every situation is unique. Contact our office to discuss how this change may affect your family’s planning.