Title III Administrative and Financial Requirements Policy #15: Voluntary Contributions
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 315(b) 45 CFR Part 1321.9 (c)(1)(vii) & (c)(2)(x) |
Operating Category | Title III Administrative and Financial Requirements |
Policy
1. Voluntary contributions, as defined in the OAA, means “donations of money or other personal resources given freely, without pressure or coercion, by individuals receiving services under the Act”.
2. Voluntary contributions shall be allowed and may be solicited for all Title III-funded services.
3. The suggested contribution levels shall be based on the actual total cost of services.
4. Voluntary contributions shall be encouraged for individuals whose self-declared income is at or above 185 percent of the Federal poverty level (FPL). Assets, savings, or other property owned by an older individual or family caregiver may not be considered when seeking voluntary contributions from any older individual or family caregiver.
5. The method of requesting voluntary contributions must be noncoercive, and the solicitation:
A. Must meet all the requirements of this policy; and
B. Be conducted in such a manner so as not to cause a service recipient to feel intimidated or pressured into making a contribution.
6. All recipients of services shall be provided:
A. An opportunity to voluntarily contribute to the cost of the service;
B. Clear information, including information in alternative formats and in languages other than English upon request, explaining there is no obligation to contribute, and the contribution is voluntary;
C. Protection of privacy and confidentiality of each recipient with respect to the recipient’s income and contribution or lack of contribution.
7. Means testing, meaning the use of the income, assets, or other resources of an older person, family caregiver, or the households of these individuals in order to deny or limit that person’s eligibility to receive services, is prohibited.
8. Services shall not be denied because the older individual or family caregiver will not or cannot make a voluntary contribution;
9. Amounts collected are considered program income and must be used to expand services. See Title III Administrative and Financial Requirements Policy #17: Program Income.
Procedures
1. AAAs must inform prospective service providers of the obligation to offer clients an opportunity to make voluntary contributions in their Requests for Proposals and contracts or grant agreements.
2. Service providers must offer clients the opportunity to make a voluntary contribution for all Title III services. Contributions may be made on site at the service delivery location or by mail or electronic payment if the service provider accepts electronic payments.
3. Service providers are not required to collect income information from participants in all services in order to implement this policy.
4. Service providers must establish a suggested voluntary contribution schedule based on the actual total cost of the service. AAAs must review this proposed schedule annually and approve it prior to its use.
5. MBA will issue a communication to AAAs each year advising them of annual updates to the FPL as determined by the federal government. This will inform AAAs and service providers of the income threshold for 185% of the FPL for households of various sizes.
6. Service providers must develop clear communications materials explaining voluntary contributions, including the suggested schedule, that there is no obligation to contribute, and the contribution is voluntary. AAAs must review these communications materials within the first month of the Area Plan year to ensure they reflect this policy.
A. This information must be provided in alternative formats and in languages other than English upon request in compliance with Federal civil rights laws.
7. Service providers must send out at least one written communication (either by email or by U.S. mail) per Area Plan year to each participant they have collected income information for and whose self-declared income is at least 185% of the FPL to encourage the participant to make a voluntary contribution.
8. Service providers and AAAs must protect privacy and confidentiality of each recipient with respect to the recipient’s income and contribution or lack of contribution.
9. Service providers must establish and follow procedures for regular accounting of all voluntary contributions received.
A. If the client mails a contribution to the service provider and does not specify the service to which the contribution relates, the service provider should examine their records to determine what services the client receives.
B. If a client specifies they are making a charitable contribution to the service provider and directs the contribution to be used in a particular manner, that contribution is not subject to this policy.
C. Service providers may not encourage clients to make general charitable contributions to their organizations in lieu of voluntary contributions for Title III-funded services.
10. Service providers must establish and follow procedures for safeguarding contributions received, including secure handling of any cash contributions, checks, or electronic payments and prompt deposit of such payments into a bank account.
11. AAAs must monitor and compare voluntary contribution levels across providers and services on an annual basis. Suggested metrics to use in making these comparisons include the percentage of clients making voluntary contributions and the average amount of voluntary contributions by service. Such comparisons are intended for learning purposes about strategies that effectively encourage voluntary contributions and to monitor for client understanding of the voluntary contribution policies. MBA will provide a forum for informal sharing of this information across AAAs.
12. AAAs must report voluntary contributions separately from other sources of program income on a discrete line in their standard budget reporting.
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