AAA Operations Policy #12: Reallocation of Funds Between AAAs

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

Authority Reference	45 CFR 1321.49(e)(6)
Operating Category	AAA Operations

Policy

1. For purposes of this policy, “reallocation” refers to the redistribution of funds between Minnesota AAAs. Further, “reallotment” refers to the process of returning federal funds to ACL or the process of receiving additional federal funding redistributed from other states. This policy focuses on reallocation, while the Reallotment policy and procedures is described in MBA Operations Policy #13: Reallotment.

2. MBA expects that AAAs will fully expend their allotted Title III awards within the original timeframe funds are available (typically two years from the date of award). MBA and AAAs are aware that demand for services exceeds available funding and therefore want to ensure allocated state and federal funding is strategically, efficiently, and fully spent. MBA will take steps within the original award period to ensure funds are spent in Minnesota to the maximum degree possible.

3. MBA may reallocate funding within the State when an AAA voluntarily or otherwise returns funds, subject to MBA policies.

4. If an AAA voluntarily returns Title III funds to the MBA, the AAA must provide evidence that its governing board or chief elected official approves the return of funds.

5. MBA will monitor AAA progress in obligating and spending grant dollars over the course of an Area Plan Year. MBA will use the presence of unobligated balances as an indicator that AAAs are not on track to fully spend their allocations. Unobligated balances are defined as identified funds that are not awarded through a fully signed and executed contract with a provider for the identified calendar year. MBA will provide technical assistance to AAAs to help ensure funding is obligated and spent.

6. Each year, MBA will ask each AAA to report the following:

A. Near the end of the Area Plan year: any unobligated balances as well as the AAA’s interest in receiving funds redistributed from other AAAs;

B. Near the end of February: any unspent obligated balances from the immediately preceding Area Plan year.

MBA will use this information to implement an annual redistribution process for unobligated funding and unspent obligated funding as described under “Procedures” below.

7. Consistent with this policy, unobligated and unspent obligated Title III funds must be redistributed to all AAAs who request funds available for reallocation after the steps of this policy have been carried out.

A. The funds must be reallocated through the IFF; however, the IFF, for this purpose only, must be modified proportionally to include only those AAAs that request redistributed allocations.

B. AAAs may indicate they do not wish to receive reallocated funding from other AAAs through an annual reporting process; if an AAA indicates it does not wish to receive additional funding, the AAA will not receive additional funding.

8. MBA also recognizes it is the policy of the Administration for Community Living to ensure Title III awards are fully spent to the greatest degree possible. Federal regulations require MBA to provide notice to ACL if Minnesota has Older Americans Act funds that will not be fully spent within the award period and the state intends to release those funds back to the federal government to be reallotted to other states. This policy and procedure is described in MBA Operations Policy #13: Reallotment.

Although MBA has not historically released OAA funding back to the federal government, it is possible that underspent funds among Minnesota AAAs as described in this policy could trigger the reallotment process.

Procedures

1. Each AAA should carefully track obligated and unobligated balances throughout the course of each Area Plan year and obligate their funding through contracts and/or grant agreements with service providers.

2. Each AAA should carefully track expenditures and ensure they are spending their obligated funding.

3. During each quarterly check in meeting with each AAA, MBA staff will raise any concerns about the rate at which AAAs are obligating and spending their grant dollars.

4. MBA will reach out in writing to AAAs each fall with a form and instructions and ask AAAs to document on a date near the end of the Area Plan Year:

A. AAAs must report on the “MBA Area Plan Older Americans Act Title III Awards: Unobligated Reporting and Redistribution Interest Form”:

· 1. Whether they have fully obligated all Title III funds or whether they have unobligated Title III funds;

· 2. If they have unobligated Title III funding, what the specific amount of Title III unobligated funding is; and

· 3. Whether or not they request to receiving any Title III funds that may become available through the redistribution process.

5. Near the end of February, on a specific date to be communicated by MBA each year, AAAs must report the amount of any obligated, unspent funding from the immediately preceding Area Plan year.

6. At the end of February, on a specific date to be communicated by MBA each year, AAAs must upload final Area Plan budgets for their Area Plan Grant agreement ending the immediately preceding Area Plan year to Foundant.

7. MBA will use information provided by AAAs under Procedure paragraphs 4 and 5 to determine what amounts are available for redistribution to AAAs interested in receiving redistributed funding. Amounts available for redistribution must be redistributed through the IFF.

A. If an AAA does not wish to receive potential reallocated funds from other AAAs, MBA will proportionally adjust the IFF to remove that AAA from distribution of any potentially reallocated funds.

B. MBA will communicate by mid-March of each year the amounts of funding to be redistributed to each AAA which expressed interest in receiving redistributed funding.

8. AAAs receiving redistributed funding must upload an updated budget for the current Area Plan year incorporating the redistributed funding amounts on or near March 31 of each year to Foundant.

9. MBA will redistribute funding by April 30 of each year through a contract amendment to the AAAs’ current Area Plan year grant agreement.