AAA Operations Policy #5: AAA Requests to Provide Services Directly

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 307(a)(8)(A) and (a)(10) 45 CFR Part 1321.9 (c)(1)(vi)) and 1321.65(b)(7)
Operating Category	AAA Operations

Policy

1. AAAs generally must use grants/contracts with service providers to provide direct services to older individuals. The only exceptions to this policy are for information & assistance and outreach services, which may be provided directly by the AAA at the discretion of the AAA, and other services if specifically authorized by MBA.

2. AAAs may be permitted to temporarily provide other Title III-funded services directly if the MBA determines that direct provision of a service by the AAA is necessary due to:

A. Provision of such services by the AAA is necessary to assure an adequate supply of such services;

B. Such services are directly related to such AAA’s administrative functions; or

C. Such services can be provided more economically and with comparable quality, by the AAA.

3. If an AAA wishes to directly provide a service other than information & assistance services or outreach, the AAA must submit a waiver request to MBA consistent with MBA Operations Policy #9: Waiver Requests.

4. Waiver requests to provide direct services may be submitted for any service (other than for information assistance services or outreach) for which the AAAs normally enter into agreements with community-based service providers to deliver and pay for with Older Americans Act Title III-B, III-C1 and C2, III-D and III-E funds.

5. An AAA wishing to provide information & assistance or outreach services directly may do so by notifying MBA as part of the Area Plan submission process. These services are not subject to the waiver request process and may be provided for the entirety of the four-year Area Plan cycle or the portion of it that is remaining at the time the AAA determines it would like to provide information & assistance or outreach services directly.

6. When AAAs act as direct service providers, AAAs must abide by the same requirements as other entities providing OAA services.

Procedures

1. AAAs shall request to provide services directly other than information & assistance and outreach services by completing the MBA Waiver Request Form to be submitted as part of its Area Plan, consistent with MBA Operations Policy #9: Waiver Requests. An Area Agency on Aging may also request consideration of a waiver outside of the Area Plan process by submitting the waiver request in letter format to the Executive Director.

2. AAAs should include the following information in a waiver request related to direct provision of services:

A. Rationale for the request, including how it meets 2(a) through (c) above;

B. Its impact on services for older people;

C. The type and amount of funding involved; and

D. Acknowledgement that the AAA governing board has approved submission of the waiver request.

3. Waiver requests to allow direct service provision will be evaluated by taking into consideration the rationale for the waiver request; the cost of providing a service; the quantity of the service; and the quality of the service.

4. All approved waivers for direct service provision are valid for a maximum of one year.

5. For each time approval is granted to an AAA to provide direct services through the waiver process, the AAA must demonstrate its efforts to identify and engage service providers prior to being granted a subsequent approval.

6. AAAs wishing to provide information & assistance services or outreach directly should indicate this through the first year of the Area Plan submission process. Additional details about how to do this will be incorporated into the Area Plan instructions. Indicating this plan to offer information & assistance and/or outreach services is only necessary once over the four-year Area Plan cycle.

7. MBA will communicate to the AAA in writing about whether or not the waiver request is approved.