AAA Operations Policy #6: Program Development and Coordination

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

Note: We updated content on this page on June 5 and June 18, 2025. Changed content is indicated with [add] and [delete].

Authority Reference	45 CFR 1321.3 Definition of PD & C & 1321.27(h) OGM 08-09 Policy on Grant Progress Reports
Operating Category	AAA Operations

Policy

1. Program development and coordination (PD & C) activities “means those actions to plan, develop, provide training, and coordinate at a systemic level those programs and activities which primarily benefit and target older adult and family caregiver populations who have the greatest social needs and greatest economic needs, including development of contracts, commercial relationships, or private pay programs”.

2. PD & C activities must only be expended as a cost of State plan administration, area plan administration, and/or Title III, part B supportive services.

A. MBA may allow AAAs to use up to 25% of its new Title III B allotment for PD&C activities in its PSA; additional amounts may be allowed with an approved waiver request. PD&C activities shall have a “positive and direct impact on the enhancement of services to older persons.” [6/18/25: add] It should not be assumed that PD&C funds will be awarded annually. MBA reserves the right to evaluate each AAA’s PD & C request annually and make determinations about what amounts, if any, are appropriate to award in a given year.

· i. As a general policy, MBA prioritizes direct service delivery. [end add]

B. However, MBA shall not fund PD & C as a cost of supportive services under area plans until each AAA has first spent 10 percent of their administrative budget on the administration of area plans.

· i. AAAs shall, consistent with the area plan and budgeting cycles, share information about proposals to pay for PD & C as a cost of Title III, part B supportive services to the general public for review and comment as part of its public comment period and public hearing for the draft Area Plan. Information shared with the public must be clear how funds could be spent on Title III-B direct services if not used for PD & C activities as well as the rationale to spend those funds on PD & C activities instead.

3. Expenditures by MBA and AAAs on PD & C activities are intended to have a direct and positive impact on the enhancement of services for older individuals and family caregivers in the PSA.

4. MBA shall review, consider, and award PD&C funds annually as a part of the Area Plan review and approval process.

A. MBA, when awarding funds, shall evaluate proposed [6/5/25: add] use of Title III-B [end add] funding for PD & C activities with the following criteria:

· i. In general, Program Development activities are:
1. Time limited, generally 2-3 years in length
2. Work that is tied to identified service(s) or service delivery gap(s), based on demographic trends or AAA assessment of needs or issues, and identified in the Area Plan; and gaps that are appropriately addressed by AAA leadership through work with other agencies or businesses that develop a service or system that will fill the identified gap; or
3. Development of contracts, commercial relationships, or private pay programs.

· ii. Coordination activities are agency liaison functions, coordination and education/technical assistance activities designed to strengthen job knowledge and skills of providers of aging services, or public education activities.

· iii. PD&C activities shall:
1. Leverage non-OAA funds/resources
2. Demonstrate collaboration among agencies; and
3. Improve service delivery or foster joint planning activities.
4. Be designed to achieve specified outcomes

· [6/5/25: add] iv. The extent to which other factors, such as the existence of wait lists for services, may impact whether some portion of funding proposed to be used for PD & C should be used on Title III-B services instead. [end add]

5. PD&C outcomes included in the Area Plan shall reflect roles and outcomes found in the MBA State Plan on Aging, MBA position statement on roles of AAAs, or Area Plan format.

A. PD&C outcomes shall not include activities that are a part of administration of the Area Plan. Such administrative activities are appropriately reflected under Title III A.

· i. Examples of such administrative activities not to include:
1. Development and implementation of the Area Plan (except PD&C outcomes),
2. Outreach, and
3. Holding an annual or regularly scheduled conference(s).

· ii. Examples of activities appropriate to PD&C would be those focused on specific outcome measures, e.g.:
1. A special resource publication intended for public distribution, and
2. Training/education sessions intended to strengthen skills of service providers.

B. The difference between seemingly identical types of activities, funded under Area Plan administration or PD&C is that PD&C shall focus on a specific outcome (see section c.iii above) and are more unique than administrative activities which are routine day-to-day functions of the AAA.

6. If an AAA wishes to use PD & C funding to develop a contract, commercial relationship, or private pay program, the AAA must also abide by the terms of the applicable respective policy (AAA Operations Policy #7: Contracts and Commercial Relationships or AAA Operations Policy #8: Private Pay Programs).

Procedures

1. AAAs proposing to use administrative or Title III-B supportive services funding for PD& C activities must:

A. Include the following information in their annual budget proposals:

· i. A narrative description of how PD & C funds will be used;

· ii. A proposed timeline for activities funded with PD & resources;

· iii. Identify specific desired outcomes, including how those outcomes will be measured, or products; and

· iv. A line item budget.

B. AAAs shall document how they have solicited public review and comment of their intention to spend a portion of Title III-B Supportive Services funds for PD & C activities during 30-day comment period and public hearing prior to submitting their proposed Area Plan budget to MBA.

C. AAAs must document progress in reaching their PD& C outcomes as part of the contents of their half-year narrative report.

2. AAAs must anticipate that MBA cannot pay any AAAs for PD & C costs until each AAA has spent 10 percent of its administrative budget.

A. AAAs are reminded to invoice MBA promptly for administrative expenditures.

B. AAAs may not invoice for PD & C in their initial advance request.

C. AAA requests for payment for PD & C expenditures will be denied until the 10 percent threshold for each AAA is met.

D. AAAs should anticipate submitting a first payment request for PD & C expenditures in April of each year, unless MBA informs AAAs the 10 percent threshold has been met earlier and therefore AAAs may submit payment requests for PD & C.

[6/18/25: add] If a PD & C request is denied, the AAA must resubmit the PD & C request at a future point. [end add]