AAA Operations Policy #1: Area Plan Development and Approval

This content is part of a public comment period. For more information, refer to Minnesota Board on Aging – State Plan on Aging.

Authority Reference	OAA, Sec. 306 OGM 08-04 Policy on the Use of Grant Agreements 45 CFR Part 1321.65
Operating Category	AAA Operations

Policy

1. The MBA shall issue annual instructions for a uniform Area Plan format, content, duration, and prescribed process and deadline for submittal. The Area Plan cycle is a four-year cycle with annual updates; and a new one-year budget to be submitted each year.

2. The Area Plan is the foundation for each AAA’s plan to serve older adults with greatest social needs and greatest economic needs as well as family caregivers in a specific Planning and Service Area. It must describe the priority populations to be served, information related to the service needs for those priority populations, and a detailed plan for how Older Americans Act funds will be effectively used to support these priority populations as well as to leverage non-OAA funds within the Area Plan. An AAA may award grant/contracts only for activities included in its approved Area Plan.

3. Although MBA will provide more details for each four-year Area Plan cycle and annual updates through its annual instructions, Area Plans must always include the following general content:

A. Identification of populations within the planning and service area at greatest economic need and greatest social need, which must include the populations as set forth in the § 1321.3 definitions of greatest economic need and greatest social need and may include additional populations at the AAA’s discretion.

B. At the start of each four-year Area Plan cycle, assessment and evaluation of unmet need, such that each area agency shall submit objectively collected, and where possible, statistically valid, data with evaluative conclusions concerning the unmet need for supportive services, nutrition services, evidence-based disease prevention and health promotion services, family caregiver support services, and multipurpose senior centers. The evaluations for each area agency shall consider all services in these categories regardless of the source of funding for the services. This assessment requirement may be satisfied by analyzing the regional implications of a statewide analysis; by the AAA conducting a separate assessment; or by the AAA using the results of a related regional assessment conducted by another entity.

C. The services, including a definition of each type of service; the number of individuals to be served; the type and number of units to be provided; and corresponding expenditures proposed to be provided with funds under the Act and related local public sources under the Area Plan;

D. Plans for how direct services funds under the Act will be distributed within the planning and service area, in order to address populations identified as in greatest social need and greatest economic need;

E. Requirements for program development and coordination activities as set forth in § 1321.27(h) and outlined in AAA Operations Policy #6: Program Development and Coordination.

F. Minimum adequate proportion requirements as described in AAA Operations Policy #4: Minimum Adequate Proportion.

G. If an AAA wants to provide information assistance and/or outreach directly, the AAA will have an opportunity to indicate this during the Area Plan submission process.

H. If an AAA wants to provide services directly other than information assistance and outreach, the AAA must submit a waiver request as described in MBA Operations Policy #9: Waiver Requests. For each time approval is granted to an AAA to provide direct services, the AAA must demonstrate its efforts to identify service providers in a subsequent waiver request prior to being granted a subsequent approval.

I. If the AAA requests to allow up to 25% of its Title III, part C–1 funds to be used as set forth in § 1321.87(a)(1)(i) through (iii) for shelf-stable, pick-up, carry-out, drive-through or similar meals to complement the congregate meal program, it must provide the following information to the State agency:

· i. Evidence, using participation projections based on existing data, that provision of such meals will enhance and not diminish the congregate meals program, and a commitment to monitor impact on congregate meals program participation;

· ii. Description of how provision of such meals will be targeted to reach those populations identified as in greatest economic need and greatest social need;

· iii. Description of the eligibility criteria for service provision;

· iv. Evidence of consultation with nutrition and other direct services providers, other interested parties, and the general public regarding the need for and provision of such meals; and

· v. Description of how provision of such meals will be coordinated with nutrition and other direct services providers and other interested parties.

4. Area Plans shall also:

A. Incorporate services which address the incidence of hunger, food insecurity and malnutrition; social isolation; and physical and mental health conditions;

B. Provide, to the extent feasible, for the furnishing of services under the OAA through self-direction; and

C. Develop objectives that coordinate with and reflect the State plan goals for services under the OAA.

5. In developing its Area Plan, an AAA must solicit and meaningfully consider the views of its Advisory Council and other community members, especially older individuals, family caregivers, service providers, and the public with a focus on those in greatest economic need and greatest social need.

A. The AAA must make its proposed Area Plan available for public comment for a minimum of 30 calendar days, unless there is an emergency situation for which MBA agrees a shorter timeframe for public review and comment is appropriate.

B. In addition to the public comment period, the AAA must hold at least one area-wide public hearing on the entire proposed Area Plan and on all annual amendments to the Area Plan and:

· i. Give at least two weeks advance public notice to older individuals, public officials, and other interested parties of the times, dates, and locations of the public hearing(s);

· ii. Hold the public hearing(s) at a time and location which permits older individuals, public officials, and other interested parties reasonable opportunity to participate;

· iii. Assure that complete copies of the proposed Area Plan including the full budget are available for review at the AAA office and at the public hearing(s), as well as available in print by request. Executive summaries of the major components and proposed amendments must also be available prior to the public hearing; and

· iv. Submit the Area Plan and annual amendments to the Advisory Council for review and comment before transmitting the Area Plan to MBA for approval.

C. The timeframe for the notice of and conducting of a public hearing may overlap with the 30-day time period for public review and comment.

6. MBA Review Process

A. The MBA’s review and approval of Area Plans shall be based on each Plan’s response to stated priority needs in the area and conformity to the required format, content, and deadlines for submittal and compliance with applicable federal and state laws and regulations and MBA policies and procedures.

B. MBA staff shall:

· i. Review outcomes and budget using the following criteria:
1. Appropriateness to identified needs and issues in Area Plan;
2. Reflection of the MBA Strategic Plan, MBA position statement on roles of AAAs, or Area Plan format in its rationale;
3. Probability that the activities will accomplish the stated targeted outcome measures/outcomes;
4. Degree to which outcomes are clear and measurable; and
5. Assurance through half-year reports that the AAA is making progress on the outcomes.

· ii. Provide technical assistance to AAAs about their Area Plan, as needed.

7. Once approved, the Area Plan must be kept current and up-to-date during the duration of the Plan through an amendment process. Annual Area Plan amendments and other non-technical amendments must go through the same public notice and comment process described earlier in this policy. For purposes of this policy, technical amendments include budget adjustments or minor changes. The final Area Plan must also be available to the public at the AAA office or in print upon request.

8. The development, submission and implementation of an Area Plan is a foundational responsibility of an AAA. An AAA cannot receive OAA funds without an approved Area Plan in place. MBA may initiate the process of withdrawing AAA designation if a AAA fails to submit a reasonably timely Area Plan without an approved extension; to resubmit an Area Plan that incorporates MBA-required conditions; or to resubmit a compliant Area Plan within required timeframes if the Board votes to disapprove an Area Plan.

9. If the Board votes to disapprove an Area Plan, MBA will provide a written notice to the Chairperson of the AAA’s board of directors of its intent to disapprove the Area Plan and what needs to be revised in the Area Plan for it to be approved. The AAA will have 10 calendar days from receipt of MBA’s written communication to resubmit a compliant plan. If the AAA does not submit a compliant plan in this timeframe, MBA will provide notice of action to the AAA of its decision to disapprove the Area Plan and of the AAA’s opportunity to request a hearing consistent with MBA Operations Policy #10: Hearings.

Procedures

1. MBA will issue annual Area Plan instructions in early May of each calendar year. AAAs must submit their Area Plans to MBA for review in August of each calendar year. MBA will identify a specific submission deadline as part of the annual Area Plan instructions.

2. AAAs must submit their Area Plans by MBA’s deadline or obtain written approval for an extension. Failure to submit an Area Plan in a reasonably timely fashion will result in the creation of a Corrective Action Plan for the AAA.

3. MBA staff and select MBA Board committee members will review and provide comments and questions on the proposed Area Plan. This feedback and any proposed conditions will be shared with the AAAs in October of each year. MBA must indicate in its feedback whether there are any issues in the proposed Area Plan that rise to the level of disapproval beyond the proposed conditions.

4. AAAs will present their proposed Area Plans to the MBA Board in October of each year. MBA staff will share their perspectives and a proposed motion for the Program Operation Committee’s consideration at that same Board meeting. The Program Operation Committee will vote on each AAA’s Area Plan. Approval of the Area Plan may be subject to conditions requiring action by the AAA.

5. Subsequent to the Program Operation Committee vote, the full MBA Board will vote on each AAA’s Area Plan and any recommended modification by MBA staff at its October meeting.

6. Following the MBA Board vote, MBA staff will work with AAAs to provide technical assistance, negotiate any final issues, and finalize the Area Plan. Each approved finalized Area Plan will be incorporated into a fully executed grant contract between MBA and each AAA. MBA and AAA staff will work diligently to have a fully executed contract in place that includes the Area Plan prior to December 15 of each year.

7. If the Board votes to disapprove an Area Plan, MBA will provide a written notice to the Chairperson of the AAA’s Board of Directors of its intent to disapprove the Area Plan and what needs to be revised in the Area Plan for it to be approved.

A. The AAA will have 10 calendar days from receipt of MBA’s written communication to resubmit a compliant plan.

B. If the AAA does not submit a compliant plan in this timeframe, MBA will provide notice of action to the AAA of its decision to disapprove the Area Plan and of the AAA’s opportunity to request a hearing consistent with MBA Operations Policy #10: Hearings.