Title III Administrative and Financial Requirements Policy #5: Supplement, Not Supplant

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

Authority Reference	Older Americans Act, Sections 306(a)(9)(B)), 315(b)(4)(E), 321(d), 374, and 705(a)(4). 45 CFR Part 1321 Definitions (local sources) & Part 1321.9(c)(2)(xvi)
Operating Category	Title III Administrative and Financial Requirements

Policy

1. Funds awarded under the Older Americans Act must be used to supplement, not supplant, existing Federal, State, and local funds expended to support services for older Minnesotans.

2. Older Americans Act funding is intended to support part of a continuum of community-based services for older adults.

3. Within this context, “supplement” is defined as increasing the amount of resources spent on services for older adults by adding Older Americans Act funding to previously committed Federal, state or local sources paying for services for older adults or providing a new service not previously paid for by another funding source. Local sources include “funds from fundraising activities, reserve funds, bequests, or cash or third-party in-kind contributions from non-client community members or organizations.”

4. Conversely, “supplant” means reducing other Federal, state, or local funding sources spent on services for older adults by substituting Older Americans Act funding in their place.

Procedures

1. AAAs must ensure their local and regional partners, including local and regional governmental entities with whom they coordinate as well as service providers, are aware of this policy.

a. AAAs can demonstrate they have met this requirement by including information about this policy in their requests for proposals and their Area Plans when the Area Plans are available for public comment.

b. AAAs may choose to ensure local and regional partners are aware of this policy through other additional actions as well.

2. AAAs must not allow Older Americans Act funding to supplant or substitute for existing Federal, state, or local funding available to provide services to older adults. An example of supplantation is if an AAA used Older Americans Act funding to pay for services paid for with other Federal, state, or local funding sources in the prior year.

3. AAAs must attest that no supplantation is occurring as part of the annual Area Plan submission process by signing an assurance stating this is so.

4. AAAs must establish policies and procedures for service providers aligned with this policy and procedure.

a. Service providers should be aware they should bill the most appropriate source of federal funding for client services. For example, meals for clients on the Alternative Care/Elderly Waiver should be billed to AC/EW rather than Title III C-1 or C-2 funding.

b. In signing an agreement with a AAA to provide services, service providers must attest to the AAA that, to their knowledge, no supplantation is occurring as a result of Title III dollars paying for services through their agreement.