Collabria Care PACE CMS Penalty: Approved Care Left Waiting

The Centers for Medicare & Medicaid Services imposed a $48,833 penalty on Collabria Care’s PACE program after finding failures to provide approved care, act on recommendations and arrange services on time. The agency’s findings reach the work between a clinical decision and an actual appointment. If you handle referrals, hospital discharge reports or scheduling, that is work you know: who approved the service, who was supposed to arrange it and what happened next.

The agency issued the civil money penalty notice on April 29, 2026, to Collabria Care in Napa, California. This page follows the scheduling and recommendation failures behind that action. Our PACE evidence page follows the broader record trail into government payment. Collabria’s notice identifies breakdowns at separate stages of care, from a recommendation awaiting review to an approved service awaiting arrangements.

What Did CMS Find at Collabria Care?

The agency found failures in providing approved services, handling recommendations and arranging care within required timeframes. Each finding concerns a different handoff inside the organization, and each points to records an employee or contractor may recognize.

Approved Services Went Unprovided

The agency found that Collabria lacked adequate processes to track approved services and ensure they were scheduled and provided. The agency identified seven instances of necessary specialist consultations not provided and seven instances of ordered laboratory work not completed. It also identified two instances involving ordered durable medical equipment, and one each involving imaging, a medical device and a clinical screening.

The people left waiting were frail older adults who depended on PACE for their care. The agency tied the failures to inadequate documentation, tracking and monitoring across care settings. For a referral coordinator or clinician, the useful comparison is between the approval, the arrangements and the provider’s account of what actually happened. The order begins that history. The service record shows whether care followed.

Hospital and Specialist Recommendations Lost Their Follow-Through

The agency identified eight instances in which recommended services were never provided or the interdisciplinary team never discussed whether they were necessary. The recommendations came from hospital discharge reports and specialist physicians. It found ineffective processes both for acting on those recommendations and for documenting the team’s review, including reasons for not approving them.

A discharge report brings another provider’s assessment back into the PACE care system. The team has to consider the recommendation, decide what the participant needs and document its response. The notice also explains that the medical record must contain reasons when a recommended service is not approved or provided. That gives someone handling discharge information a concrete comparison: the recommendation received, the decision recorded and the care that followed.

Approved Care Missed the Scheduling Clock

CMS separately identified 21 instances in which medications or team-approved services were not arranged or scheduled within the required timeframes. Its examples spanned specialist consultations, laboratory tests, durable medical equipment, imaging, occupational therapy and weekly skin checks. The agency concluded that services were not provided as quickly as participants’ conditions required. We expect all-inclusive care to include getting it on the calendar.

The count describes failures to arrange or schedule within the required time. Actual delivery has its own urgency-based duty, so the calendar and the completed service need separate examination. A scheduler may know when approval reached the scheduling process. A therapist or specialist may know when the participant finally received care. Those records answer different questions about the same service.

The Care Duties Behind Collabria’s Scheduling Failures

PACE pays an organization to take responsibility for an integrated package of medical and social services. The Programs of All-Inclusive Care for the Elderly bring together Medicare-covered care, Medicaid-covered care and additional services the interdisciplinary team finds necessary to improve and maintain a participant’s health. The organization receives prospective monthly payments and assumes financial risk for that benefit across settings.

The team assesses the participant, develops and carries out a written care plan, and monitors whether the plan meets the person’s needs. Collabria’s notice explains that the organization must arrange contracted care when it cannot provide covered services directly. Tracking and monitoring follow the participant across settings, including care delivered by outside providers. A referral leaving the center is still part of the center’s care responsibility.

The scheduling duties in Collabria’s notice have specific starting points. Medication dispensing must be arranged and scheduled as quickly as the participant needs, no later than 24 hours after the primary care provider’s order. Other approved services must be arranged or scheduled as quickly as needed, no later than seven calendar days after the team or a team member first approves them, with a narrow exception for routine or preventive services.

Recommendation review has its own clock. Appropriate team members review hospital, emergency-department or urgent-care recommendations within 48 hours after discharge, sooner when needed. Other employee or contractor recommendations require review within seven calendar days, again sooner when the participant needs it. The recommendation date, review date and approval date therefore mark different decisions in the care history.

CMS added the newer clocks in its April 2024 final rule, generally applicable to coverage beginning January 1, 2025. For someone who worked on these processes, the original order or recommendation and its date identify the duty that belonged beside the scheduling entry.

What Did the Collabria Penalty Require?

The agency imposed a civil money penalty after its audit and required additional monitoring to ensure the deficiencies were corrected. If you worked on corrective action, the changed process, subsequent scheduling records and follow-up care can explain what the organization actually did about the problem.

Suncoast Shows Why the Service Record Matters

In its Suncoast PACE penalty notice, CMS distinguished 13 necessary specialist consultations that were not provided from 13 scheduled consultations whose completion the organization could not document. One finding concerns care not received, while the other concerns missing evidence of completion. The difference matters to the person who arranged the visit and the provider who was supposed to perform it.

Collabria’s notice likewise describes separate failures in providing care, handling recommendations and making timely arrangements. We follow each finding into the record that can explain it: an order, a recommendation, a calendar entry or a provider report.

Which Records Connect Care Failures to Government Payment?

The original care record, the organization’s account to CMS or the state, and the affected payment records connect care failures to government money. PACE’s monthly capitation places the obligation to provide care alongside a payment stream that continues across the month. Our answers about PACE care and capitation explain that connection across the program. Here, the starting point is what happened after a recommendation or approval.

A clinician may know why a service was necessary, while a scheduler knows when arrangements were attempted. A contractor may hold the completion report, and a compliance employee may know which account reached an auditor. PACE’s recordkeeping rules require dated, authenticated entries, contractor reports, orders and recommendations, including reasons for not approving or providing recommended services. Original written communications about care, health or safety must remain accessible even when the organization uses a summary.

We compare that service history with the exact information the organization submitted, who prepared or approved it and what those people knew. An internal warning and the response can place knowledge of an outstanding service beside a later claim that the work was complete. That is an evidence question for the insider who saw both versions of the story.

The financial side then follows the particular payment and agreement. The CMS model program agreement sets out Medicare and Medicaid payment terms and enrollment reconciliation. For a particular organization, its executed terms, accepted submissions, payment records and later adjustments show how the account of care connected to government money.

If you are considering reporting PACE program fraud, we work with you on the service history, the representation and the money it affected. A whistleblower case under the False Claims Act can pay 15% to 30% of what the government recovers. Your knowledge of where a recommendation stopped or how an unfinished service was described can give that inquiry its starting point.

You Know Where the Arrangements Stopped

If you saw approved care sit unscheduled or recommendations disappear between providers and the care team, speak to one of our Whistleblower Experts about where the care stopped. We build your strongest PACE whistleblower case with you around those decisions and their connection to government payment, bringing in healthcare fraud whistleblower lawyers who understand capitation and care delivery. We stay beside you as the clinical, scheduling and financial accounts come together.