Title III Administrative and Financial Requirements Policy #1: Defining and Prioritizing Services for Populations with Greatest Social Need and Greatest Economic Need

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 Section 312 45 CFR Part 1321.9(c)(1)(iv & v)
Operating Category	Title III Administrative and Financial Requirements

Policy

1. AAAs must use Older Americans Act Title III funding to serve older adults and individuals caregiving with greatest social needs and/or greatest economic needs. These populations must be prioritized to receive services.

2. Greatest social need is defined as the need caused by noneconomic factors, which include for individuals eligible for OAA-funded services:

A. Physical and mental disabilities;

B. Language barriers;

C. Cultural, social, or geographical isolation, including due to:

· i. Racial or ethnic status;

· ii. Native American identity;

· iii. Religious affiliation;

· iv. Sexual orientation, gender identity, or sex characteristics;

· v. HIV status;

· vi. Chronic conditions;

· vii. Housing instability, food insecurity, lack of access to reliable and clean water supply, lack of transportation, or utility assistance needs;

· viii. Interpersonal safety concerns;

· ix. Rural location; or

· x. Any other status that:
a. Restricts the ability of an individual to perform normal or routine daily tasks; or
b. Threatens the capacity of the individual to live independently; or

D. At the discretion of the AAA, other needs as further defined by AAAs based on local or individual factors.

3. Greatest economic need for individuals eligible to receive OAA-funded services is defined as the need resulting from an income level at or below the Federal poverty level and, at the discretion of the AAA, other local and individual factors, including geography and expenses.

4. AAAs are encouraged to use reliable data to identify populations of individuals with greatest social need and greatest economic need.

5. MBA requires AAAs to use a multi-faceted approach to prioritize services to those in greatest social need and greatest economic need. This policy identifies those required actions as specified under “Procedures” below.

Procedures

Identifying and Prioritizing Populations with Greatest Social Need and Greatest Economic Need

1. AAAs and service providers must use the definitions in this policy to determine the priority populations to be served by Older Americans Act funding.

2. AAAs, in preparing their Area Plans, must identify specific populations with greatest social need and greatest economic need within their Planning and Service Area (PSA). To the extent practicable, AAAs should use data to quantify or estimate the numbers of individuals meeting various criteria within the definitions of greatest social need and greatest economic need in the PSA or specific communities within the PSA.

3. If AAAs would like to augment either or both definitions of greatest social need or greatest economic need, the AAA should do so as part of the Area Plan process by describing additional priority populations to be served and data supporting the inclusion of additional priority populations.

4. As part of the Area Plan development and review process, AAAs should consult with their Advisory Councils and community partners about where gaps exist in the PSA to serve these populations and how OAA funding may be used to supplement existing services or fund services where none exist. AAAs must also solicit input on gaps as part of their public comment processes related to review of the draft area plan.

5. Allowable services include those defined in Provision of Title III Services Policy #1: A Listing and Definitions of Allowable Services.

6. AAAs must include a question in their Requests for Proposals asking prospective service providers to identify which populations with greatest social need and greatest economic need they serve.

7. AAAs are required to use a combination of a minimum of three of the following methods to prioritize services.

A. Locate services in communities with significant populations with greatest social needs and greatest economic needs.

B. Ensure that service sites are conveniently accessible by public transportation for individuals able to take this mode of transit in geographic areas where public transit is reasonably available in the community.

C. Engage community partners dedicated to serving specific populations to promote awareness of Title III-funded services. For example, promote OAA-funded services in a newsletter through an organization serving providing services to LGBTQ+ populations or to individuals with low incomes.

D. Promote Title-III funded services at local events organized around populations of interest.

E. Conduct a needs assessment, gap analysis, or other analysis of resources available to support one or more subgroups within the definitions of greatest social need and greatest economic need. This may be helpful in informing the AAA how it might fill in gaps in services within the PSA.

F. Contract or provide grant funds to providers offering culturally competent health and/or social services.

G. Use inclusive images and language in marketing and promotional materials.

H. Other strategies proposed by the AAA to reach individuals with greatest social needs and greatest economic needs.

Advisory Committees and GSN/GEN Considerations

8. AAAs are encouraged to consider the full breadth of the populations included in the definitions of greatest social need and greatest economic need in recruiting and nominating individuals to serve on their Advisory Councils and governing boards.

9. AAAs must annually share information with their Advisory Committees about the effectiveness of their strategies to serve populations with greatest social need and greatest economic need. AAAs may determine the optimal timing for such information-sharing. Information may include the following:

A. Numbers and proportions of individuals served who meet one or more criteria for greatest social need or greatest economic need based on NAPIS data completion.

B. Feedback from community organizations about whether existing strategies are working and how they might be improved

C. Numbers of partnerships with organizations dedicated to serving populations with greatest social need and greatest economic need and the populations served by those partner organizations.

D. Other information determined relevant by the AAA

Data Collection on Client Demographic Characteristics

10. In the process of making annual updates to National Aging Program Information System (NAPIS) forms, MBA may periodically add select additional questions that may further inform the extent to which services are being provided to individuals with greatest social need and greatest economic need.

11. AAAs must educate service providers through an annual training session about the importance of and process for comprehensive data collection on NAPIS forms for registered services to assess how many individuals in priority populations are being served. Service providers are required to attend such training. AAAs must maintain records of attendance at such training.

12. MBA requires all fields on the NAPIS form to be completed. If a client refuses to provide certain data, the service provider must choose “Unknown”, “Unavailable” or “Client Declined to Answer” from a drop-down list of choices. Comprehensive collection of NAPIS form data provides essential information on client demographic characteristics and the degree to which OAA funds are serving individuals with greatest social needs and greatest economic needs.

General

1. AAAs must establish policies and procedures for direct service providers that are aligned with this policy.