Provision of Title III Services Policy #5: Legal Services
This content is part of a public comment period. For more information, refer to Minnesota Board on Aging – State Plan on Aging.
Note: We updated content on this page on April 17, 2025. Changed content is indicated with [add] and [delete].
Authority Reference | Standards for Title IIIB Legal Assistance Programs, 1994 Standards for the Provision of Civil Legal Aid, 2021 45 CFR 1321.93 |
Operating Category | Provision of Title III Services |
Policy
Definitions
1. Legal services is the provision of high quality, high impact, cost effective legal services to older adults living within the State of Minnesota. The Minnesota Board on Aging, through its Area Agencies on Aging, fund civil legal service providers to provide a coordinated system of legal services to all older Minnesotans, with a focus on addressing the needs of the most vulnerable including those isolated due to social or economic disparities.
2. Legal assistance is measured on an hourly basis (1 hour = 1 unit of service) and means:
A. Legal advice and representation provided by a licensed attorney in good standing (meaning an individual is on active status and authorized by the Supreme Court of Minnesota to practice law within the state) to older individuals with economic or social needs; and
B. Includes-
Legal advice and representation may be provided [add] in-person [end add] [delete] face-to-face [end delete], by telephone, or by electronic communication and includes, but is not limited to, advice and consultation, litigation, administrative representation, brief services (including preparing legal documents), and pro se assistance.
Direct supervision is oversight of the provision of services by a professional licensed to provide such services [add], [end add] [delete] in order [end delete] to ensure appropriate quality and scope of services. Direct supervision includes, but is not limited to, personal review of work product and real time availability to respond to questions from the persons being supervised.
3. Community legal education is measured on a per session basis (1 session = 1 unit of service) and means:
Education and information presented to older adults by an individual authorized to provide legal assistance, which informs individuals about legal rights or benefits and how to access legal services statewide.
Education and information is a method of preventing greater legal problems by equipping seniors, caregivers and family members with knowledge about their rights, how to exercise those rights and who to turn to for help in exercising those rights. Therefore, each session should provide general information about legal rights of older Minnesotans, allow for an opportunity to communicate questions directly to a Title III B funded legal service provider, offer resources and/or referrals, and establish adequate follow-up procedures to assure that individuals are aware of opportunities to request assistance from and/ or access to the legal system.
[add] As community legal education sessions are unique events with one session equating to one unit of service, the Final Older Americans Act Service Definitions, the MBA does not count individuals “served” through each education session. Efforts should be made to diversify the venues and/or types of education sessions, and align community legal education session formats with targeting requirements. [end add]
A session may include various formats, such as the following:
A. A virtual presentation (if it is recorded, it only counts the first time it is presented as a resource by the agency);
B. An in-person session, with an opportunity for participants to ask questions; or
C. A newsletter, which counts as one session at the time of publication, provided that readers may pose follow up questions or offer feedback.
Obligations of the AAA
1. The AAA must select and procure through contract the legal assistance provider or providers best able to provide legal assistance as defined in this policy. AAAs must select and award funds to the legal assistance provider(s) that best demonstrate the capacity to conduct legal assistance, which means having the requisite expertise to fulfill the requirements of the Act and all applicable Federal and State requirements for provision of legal assistance.
2. AAAs must enter into contracts with selected legal assistance providers that demonstrate the appropriate staffing (number of individuals; language access options; etc.) capacity to deliver legal assistance. AAAs must include provisions in their grants or contracts with legal assistance providers that assist older individuals in:
These provisions are described in detail under the Procedures section of this document.
3. AAAs must ensure that providers engage in community legal education and targeted legal outreach to ensure that older adults within historically marginalized populations, including those specifically contemplated under the Older Americans Act, receive information about their rights, benefits and how to access necessary legal services.
4. Recognizing that the resources of the OAA are inadequate to meet the needs of all those seeking services, the AAA will provide oversight and offer direction, based on a review of case statistics, conversation with the Legal Assistance Developer, and information related to OAA priorities and legal trends, to legal service providers [add], thereby [end add] ensuring [add] adoption of [end add] case acceptance priorities that [delete] require the provision of [end delete] [add] focus [end add] legal assistance to eligible persons with the greatest social and economic needs with particular attention to low-income minority individuals and socially, physically or geographically isolated individuals. [add] AAAs will additionally provide support and assistance to legal service providers in relation to any older adult legal needs surveys or legal risk detector programs instituted by the provider at the request of the SUA. [end add]
5. If the AAA contracts with multiple legal service providers, or if multiple AAAs contract with a single legal service provider, AAAs should coordinate to ensure uniformity in contract standards and reporting requirements related to deliverables.
6. AAAs must engage in joint planning and development sessions regarding the provision of legal needs within the planning and service area and service areas of their Title III B legal service provider. [delete] These planning [end delete] [add] Planning [end add] sessions should occur at least every other year, or annually, if determined through contract, and include the AAA, legal service provider and State Legal Assistance Developer. [add] Planning sessions should also incorporate information identified from the most recent applicable Legal Needs Surveys and Surveys of Older Adults. [end add] This coordinated approach will help ensure consistency in contracts and requirements, better understanding of need and service provision within regions, and effective priority planning across providers.
7. The AAA shall engage in joint-planning and cross-training efforts with legal assistance providers. Legal assistance is part of the continuum of aging services. The AAA shall make best efforts to communicate the important impacts of legal assistance on the lives of older Minnesotans to other service providers, and coordinate legal assistance with other contracted service areas by inviting participation of legal assistance providers with other AAA contracted services including caregiving, housing, nutrition, special access [add], [end add] respite [add], [end add] etc.
8. The AAA shall, under the direction of and in conjunction with the State Legal Assistance Developer:
[add] 9. [end add] The AAA shall use effective monitoring tools to allow for assessment of contractual compliance, ensure consistency with the guidelines outlined in this section and standards, evaluate the quality and impact of programs, review program goals and outcomes, and oversee collection and submission of accurate data from legal providers in accordance with MBA requirements. Monitoring includes ensuring timely submission to the MBA of verified program data such as: quarterly OAAPS reports, quarterly program narrative reports, quarterly updated Grant Utility data, legal service specific site visit documents and other assessment pieces as set out under the Record Keeping and Reporting section of this document.
10. Funding of the Legal Service Provider
A. The AAA shall ensure that legal services are adequately funded pursuant to federal and state guidelines, and that appropriate legal services are provided in every county within the planning and service areas.
B. Each year of the Area Plan, the AAA shall award the legal service provider a minimum funding level equal to 10% of the new obligational authority (NOA) under Title IIIB funds. [add] In addition to the 10 percent, AAAs must provide each legal service provider $1,000 per year to support participation at conferences, trainings, and other continuing education opportunities relevant to serving older Minnesotans as described below. [end add]
AAAs shall work to identify additional funding sources and provide technical assistance for legal service providers who choose to apply for these programs. Examples of potential funding opportunities include funding through other OAA Titles, the Legal Assistance Enhancement Program, the Live Well at Home grants, or other state or federal grant opportunities. Possible program expansions include, but are not limited to: expansion of services to and enhanced supports for caregivers (example: caregiver training to address the legal needs of the person receiving care); focused attention on special access programs targeted at reducing barriers to legal services for marginalized communities (example: pairing legal services with a grantee working to expand crisis or shelter opportunities for vulnerable older adults in rural communities ); language access for LEP elders; or, supplemental services (legal and/or financial consultation) for older adult caregivers per year to contracted legal service providers for the purpose of skills development. These funds are to be used by the legal service provider to attend conferences, trainings or other symposiums that further education in elder law issues or assist with advocacy, writing, trial skills development or other legal and/or technical skills to enhance the quality of legal services provided and benefit clients served through OAA funds. The money cannot be carried over between fiscal years and any money not spent by the provider for this purpose can be reallocated to provision of direct legal services (not legal education or outreach), after consultation with and approval by the AAA.
11. AAAs must monitor data reported by legal services providers as described in greater detail under the Procedures section of this document.
Capacities of Legal Service Provider
Selected legal assistance providers shall exhibit the capacity to:
1. Retain staff with expertise in specific areas of law affecting older individuals with economic or social need, including the priority areas identified in the Act;
2. Demonstrate expertise in specific areas of law that are given priority in the Act, including income and public entitlement benefits, health care, long-term care, nutrition, consumer law,
housing, utilities, protective services, abuse, neglect, age discrimination, and defense of guardianship, prioritizing focus from among the areas of law based on the needs of the community served;
[delete] A. Defense of guardianship means advice to and representation of older individuals at risk of guardianship and older individuals subject to guardianship to divert them from guardianship to less restrictive, more person-directed forms of decisional support whenever possible, to oppose appointment of a guardian in favor of such less restrictive decisional supports, to seek limitation of guardianship and to seek revocation of guardianship; [end delete]
[add] A [end add] [delete] B [end delete]. Defense of guardianship includes:
3. Provide effective administrative and judicial advocacy in the areas of law affecting older individuals with greatest economic need or greatest social need; [add] and [end add]
[delete] 4. Support other advocacy efforts, for example, the Long-Term Care Ombudsman Program, including requiring a memorandum of agreement between the State Long-Term Care Ombudsman and the legal assistance provider(s) as required by section 712(h)(8) of the Act (42 U.S.C. 3058g(h)(8)); and [end delete]
[add] 4 [end add] [delete] 5 [end delete]. Effectively provide legal assistance to older individuals residing in congregate residential long-term settings as defined in the Act in section 102(35) (42 U.S.C. 3002(35)), or who are isolated as defined in the Act in section 102(24)(c) (42 U.S.C. 3002(24)(c)), or who are restricted to the home due to cognitive or physical limitations.
Obligations of Legal Service Provider
1. Legal Assistance providers must be licensed in accordance with Minnesota Statutes Chapter 481.
2. The provisions and restrictions in this policy apply to legal assistance provider(s) when they are providing legal assistance under section 307(a)(11) of the Act (42 U.S.C.3027(a)(11)).
3. Legal Assistance providers shall:
A. Provide legal assistance to meet complex and evolving legal needs that may arise involving a range of private, public, and governmental entities, programs, and activities that may impact an older adult’s independence, choice, or financial security; and
B. Maintain the expertise and capacity for and provision of effective administrative and judicial representation, which means the expertise and ability to provide the range of services necessary to adequately address the needs of older adults through legal assistance in administrative and judicial forums, as required under the Act. This expertise and capacity includes providing the full range of legal services, from brief service and advice through representation in administrative and judicial proceedings.
C. Conduct administrative and judicial advocacy as is necessary to meet the legal needs of older adults with economic or social need, focusing on such individuals with the greatest economic need or greatest social need:
D. Maintain the expertise required to capably handle matters related to the priority case type areas specified under the Act, including income and public entitlement benefits, health care, long-term care, nutrition, housing, utilities, protective services, abuse, neglect, age discrimination [add], [end add] [delete] and [end delete] defense of guardianship [add], and consumer issues [end add].
E. Maintain the expertise required to address any matters that are related to preserving, maintaining, and restoring an older adult’s independence, choice, or financial security.
F. Maintain the capacity to provide effective legal assistance and legal support to other [add] elder justice [end add] [delete] advocacy [end delete] efforts, including, but not limited to, the Long- Term Care Ombudsman Program serving the planning and service area, as required by section 712(h)(8) of the Act (42 U.S.C. 3058g(h)(8)), and maintain the capacity to form, develop and maintain partnerships with programs or agencies that support older adults’ independence, choice, or financial security.
G. Maintain and exercise the capacity to effectively provide legal assistance to older adults regardless of whether they reside in community or congregate settings, and to provide legal
assistance to older individuals who are confined to their home, and older adults whose access to legal assistance may be limited by geography or isolation.
H. Maintain the capacity to provide legal assistance in the preferred language used by older individuals seeking and/or receiving legal assistance who are limited-English proficient (LEP), including in oral and written communication.
I. Maintain staff with knowledge of the unique experiences of older adults with economic or social need and expertise in areas of law affecting such older adults.
J. If not a Legal Services Corporation (LSC) project grantee, coordinate services with existing LSC in the region.
K. Engage in joint-planning and cross-training efforts with the aging network, to include work with the AAAs, the State and direct service programs of the Minnesota Board on Aging.
L. Ensure high quality, cost-effective and high-impact services are delivered, or that clients are appropriately referred to other agencies or organizations for services.
M. Provide the full scope of representation and services as appropriate in applicable Minnesota State and Federal courts and administrative forums.
N. Report aggregate, non-identifying, client and case data in accordance with MBA and AAA monitoring requirements as described in detail in the Procedures section of this document.
O. Work with the AAA and State Legal Assistance Developer to ensure that a legal needs assessment including areas specific to older adults is developed and released on a regular basis.
P. [delete] To the extent possible, each legal service provider should develop [end delete] [add] Develop, to the extent possible, [end add] a pro bono panel of attorneys and advocates, or coordinate with the local pro bono provider, to expand the provision of legal assistance for older adults within the service area and meet case priorities under the Older Americans Act.
Q. Use [delete] funds received from the [end delete] AAA [add] funding received [end add] for the purpose of legal assistance and legal education to enhance [delete] assistance [end delete] [add] services [end add] to eligible individuals and, to the extent practicable, [add] prioritize [end add] [delete] target [end delete] unmet needs of vulnerable populations. Additionally, any voluntary contributions should be used to expand services and supplement (not supplant) OAA funds.
R. Although a provider may ask about the person’s financial circumstances as a part of the process of providing legal advice, counseling, and representation, or for the purpose of identifying additional resources and benefits for which an older person may be eligible, or to meet MBA requirements for reporting on client characteristics; a provider shall not means test as a condition of providing service.
S. [delete] Providers must create [end delete] [add] Ensure [end add] case acceptance priorities [add] for older adult representation [end add] and [add] prioritizing [end add] [delete] targeting [end delete] plans [delete] using [end delete] [add] use [end add] current OAA guidance, input from the AAA, recent [add] older adult [end add] legal needs [delete] assessments (if available) [end delete] [add] surveys [end add] and other relevant information regarding [add] met and [end add] unmet legal needs within the region. [add] Providers will work with AAAs, the LAD, and other aspects of the elder justice community to engage in a survey of the legal needs of older adults on a regular basis. [end add] Priorities and prioritization plans should be reviewed jointly, by the AAA and service provider, at least every other year, to ensure appropriate prioritization. Plans should be developed in consultation with the AAA and other partners, as appropriate, to allow for joint identification of sub-groups of elders who are most vulnerable and in need of legal assistance. Based on these plans, providers will establish written procedures for case intake, acceptance and rejection. Sub-groups that should be considered for priority legal assistance services shall include:
This list is not exhaustive, nor in a priority order, but represents a range of possibilities. In addition, consideration should be given on the local level to the existence and availability of other resources to meet the legal needs of locally identified target populations.
T. [delete] Providers shall offer [end delete] [add] Offer [end add] quarterly community legal education sessions, with a minimum of four distinct sessions per year. Sessions should differ in duration, presentation type (such as: written/ verbal/ in-person/ virtual). Session rate / cost must include items such as staff time for preparation and presentation, driving, supplies and materials, and other aspects as determined necessary through negotiations.
U. [delete] The provider will have such [end delete] [add] Hold [end add] office hours and [add] engage [end add] targeted outreach efforts (including, but not limited to off-site clinics or legal kiosks), and [delete] will [end delete] be available to make home visits as necessary, to make legal assistance reasonably accessible to vulnerable and isolated older persons in the provider’s area.
[add] V. Adopt and abide by the Memorandum of Understanding (MOU) between the Office of Ombudsman for Long Term Care and Legal Service Providers as required by section 712(h)(8) of the Act (42 U.S.C. 3058(g)(h)(8). The MOU will be incorporated into the fully executed contract between the AAA and the provider. [end add]
Other Legal Assistance Provider Requirements
1. A legal assistance provider may not require an older person to disclose information about income or resources as a condition for providing legal assistance under this part.
[delete] 2. A legal assistance provider may ask about the person’s financial circumstances as a part of the process of providing legal advice, counseling, and representation, or for the purpose of identifying additional resources and benefits for which an older person may be eligible. [end delete]
[add] 2 [end add] [delete] 3 [end delete]. A legal assistance provider and its attorneys may engage in other legal activities to the extent that there is no conflict of interest nor other interference with their professional responsibilities under this Act.
[add] 3 [end add] [delete] 4 [end delete]. Legal assistance providers that are not housed within Legal Services Corporation grantee entities shall coordinate their services with existing Legal Services Corporation projects to concentrate funds under this Act in providing legal assistance to older adults with the greatest economic need or greatest social need.
[add] 4 [end add] [delete] 5 [end delete]. Nothing in this section is intended to prohibit any attorney from providing any form of legal assistance to an eligible client, or to interfere with the fulfillment of any attorney’s professional responsibilities to a client.
[add] 5 [end add] [delete] 6 [end delete]. Legal assistance provider [delete] attorney [end delete] [add] attorneys, [end add] [delete] staff [end delete] and non-attorney personnel under the supervision of legal assistance attorneys [add], [end add] must adhere to the applicable [add] Minnesota [end add] Rules of Professional Conduct.
Restrictions on Legal Assistance
1. No legal assistance provider(s) shall use funds received under the Act to provide legal assistance in a fee generating case unless other adequate representation is unavailable or there is an emergency requiring immediate legal action. All providers shall establish procedures for the referral of fee generating cases.
A. ‘‘Fee generating case’’ means any case or matter which, if undertaken on behalf of an eligible client by an attorney in private practice, reasonably may be expected to result in a fee for legal services from an award to a client, from public funds, or from the opposing party.
B. Other adequate representation is deemed to be unavailable when:
2. A provider may seek and accept a fee awarded or approved by a court or administrative body or included in a settlement.
3. When a case or matter accepted in accordance with this section results in a recovery of damages, other than statutory benefits, a provider may accept reimbursement for out-of-pocket costs and expenses incurred in connection with the case or matter.
Legal Assistance Provider Prohibited Activities
1. Prohibited activities of legal assistance providers (inclusive of all individuals employed by the provider) include the following political activities:
A. No provider or its employees shall contribute or make available funds, personnel, or equipment provided under the Act to any political party or association or to the campaign of any candidate for public or party office; or for use in advocating or opposing any ballot measure, initiative, or referendum;
B. No provider or its employees shall intentionally identify the Title III program or provider with any partisan or nonpartisan political activity, or with the campaign of any candidate for public or party office; or
C. While engaged in legal assistance activities supported under the Act, no provider or its employees shall engage in any political activity.
2. No funds made available under the Act shall be used for lobbying activities including, but not limited to, any activities intended to influence any decision or activity by a nonjudicial Federal, State, or local individual or body.
A. These limitations are not intended to prohibit an employee from:
B. A provider may use funds provided by private sources to engage in lobbying activities if a government agency, elected official, legislative body, committee, or member thereof is considering a measure directly affecting activities of the provider under the Act;
C. While carrying out legal assistance activities and while using resources provided under the Act, by private entities or by a recipient, directly or through a subrecipient, no provider or its employees shall:
a. Rioting or civil disturbance; activity determined by a court to be in violation of an outstanding injunction of any court of competent jurisdiction; any illegal activity; any intentional identification of programs funded under the Act or recipient with any partisan or nonpartisan political activity, or with the campaign of any candidate for public or party office.
D. None of the funds made available under the Act may be used to pay dues exceeding a reasonable amount per legal assistance provider per annum to any organization (other than a bar association), a purpose or function of which is to engage in activities prohibited under these regulations. Such dues may not be used to engage in activities for which Older Americans Act funds cannot be directly used.
Procedures
Contracts between AAAs and Legal Service Providers
AAA contracts with legal assistance providers must include the following provisions:
1. The contract shall specify that legal assistance provider(s) shall demonstrate capacity to:
A. Maintain expertise in specific OAA legal priority areas, as defined elsewhere in this policy.
B. Prioritize representation and advice that focus on the specific areas of law that give rise to problems disparately experienced by older adults with economic or social need.
C. Maintain staff with the expertise, knowledge, and skills to deliver legal assistance as described in this section.
D. Engage in reasonable efforts to involve the private bar in legal assistance activities authorized under the Act, including groups within the private bar furnishing services to older individuals on a pro bono and reduced fee basis.
E. Ensure that attorneys and personnel under the supervision of attorneys providing legal assistance will adhere to the applicable Rules of Professional Conduct including, but not limited to, the obligation to preserve the attorney-client privilege.
2. The contract shall include provisions:
A. Describing the duty of the area agency to refer older adults to the legal assistance provider(s) with whom the area agency contracts. In fulfilling this duty, the area agency is precluded from requiring a pre-screening of older individuals seeking legal assistance or from acting as the sole and exclusive referral pathway to legal assistance.
B. Requiring the contracted legal assistance provider(s) to maintain capacity to provide legal assistance in the preferred language used by older individuals seeking and/or receiving legal assistance, including oral, visual, sensory and written communication, and to ensure effective communication for individuals with disabilities, including by providing appropriate auxiliary aids and services where necessary, including the following:
C. Providing that the area agency will [delete] provide [end delete] [add] support the legal service provider in marketing education sessions and the AAA will itself engage in [end add] outreach activities that [delete] includes [end delete] [add] include [end add] information about the availability of legal assistance to address problems experienced by older adults [delete] that may have legal solutions [end delete], such as those referenced in sections 306(a)(4)(B) and 306(a)(19) of the Act (42 U.S.C. 3026(a)(4)(B) and 3026(a)(19)). [add] The AAA will also support the legal service provider in establishing new types of access such as the legal risk detector and outreach or information gathering processes such as an older adult legal needs survey. This support by the AAA will bolster the targeting efforts of the provider ensuring that persons served include [end add] [delete] This includes outreach to [end delete]:
a. Older adults with limited-English proficiency and/or whose primary language is not English;
b. Older adults with severe disabilities;
c. Older adults living in rural areas;
d. Older adults at risk for institutional placement; and
e. Older adults with Alzheimer’s disease and related disorders with neurological and organic brain dysfunction and their caregivers.
D. Providing that legal assistance provider attorney staff and non-attorney personnel under the supervision of legal assistance attorneys must adhere to the applicable Minnesota Rules of Professional Conduct.
E. Requiring that if the legal assistance provider(s) contracted by the area agency is located within a Legal Services Corporation grantee entity, that the legal assistance provider(s) shall adhere to the specific restrictions on activities and client representation in the Legal Services Corporation Act (42 U.S.C. 2996 et seq.). Exempted from this requirement are:
Annual Meetings and Activities
1. AAAs and legal service providers should discuss community legal education and outreach/prioritization goals on an annual basis. AAAs should encourage providers to offer education and information through a variety of forums and accessible formats including, but not limited to: in-person or virtual presentations; a staffed table/ booth/ exhibit at a public event or outreach engagement; formal presentation of legal issues and provider access information on radio, TV, or web site, and social media platforms. A provider is expected to use a variety of formats in order to engage targeted populations, an example of a work plan reflecting how such sessions could be developed and reported follows this section. AAAs should make efforts to facilitate education events for legal service providers with contracted and partner organizations.
2. On an annual basis, the legal service provider will meet with a representative of the Office of the Ombudsman for Long Term care to discuss ongoing coordination, communication and appropriate targeting of services to the populations served by the OOLTC. [add] The existing MOU between legal provider and OOLTC will also be reviewed on an annual basis.[end add] If requested, the State Legal Assistance Developer will assist by facilitating these meetings. As possible, advocacy activities may also be coordinated with the local program office or regional ombudsman.
3. On an annual basis, the legal service provider will meet with a regional Senior Linkage Line representative from the local AAA to enhance understanding, ensure appropriate referral protocols and establish stronger working relationships between the two services of the AAA. If requested, the State Legal Assistance Developer will assist by facilitating these meetings.
4.The legal service provider will develop annual workplans for community legal education programs and outreach strategies [add] that incorporate the most recent information from older adult legal needs surveys, general legal needs studies, regional legal priorities and other relevant information [end add]. The AAA should share information regarding education programs and outreach plans with elder justice network providers and other AAA providers to allow for effective collaboration and appropriate prioritization of client subpopulations.
5. The State Legal Assistance Developer, working with AAAs, shall ensure that all state legal assistance providers receiving Title III B monies meet at least once annually to discuss statewide legal needs and propose targets for effective and quality legal services under the Older Americans Act. The purpose of this meeting is to coordinate community legal education sessions and the provision of legal services to older adults, and to engage in joint planning and cross training efforts with other legal assistance providers as well as members of the elder justice community and direct services of the MBA.
6. The State Legal Assistance Developer will schedule a minimum of two annual meetings with AAA staff involved with legal assistance programming. These meetings will be set in the second and fourth quarters of each year to review contract work plans, goals, progress and updated information regarding legal needs as identified through submitted reports and other data from the regional AAA and legal service provider. One of these meetings must include the legal service provider(s) currently serving as the AAA’s Title III legal provider.
Record Keeping and Reporting Requirements
1. Legal assistance providers will use the Older Americans Act Performance System (OAAPS) guidelines to collect and report client and case data to the AAA and MBA on a quarterly basis. The MBA will provide reporting instructions and specific definitions to ensure compliance with the OAAPS system. The OAAPS system follows a federal fiscal year, beginning each October 1 and ending September 30. As AAA contracts with service providers are on a calendar year schedule, beginning January 1 and ending December 31, the reporting timelines to be followed are set out below:
A. On January 10 (or a contractually defined date): Provider sends reporting information directly to AAA. On or before January 15, the AAA submits all reporting information received from provider (OAAPS spreadsheet, narrative, and persons served reports) to State Legal Assistance Developer via Foundant.
B. On April 10 (or a contractually defined date): Provider sends reporting information directly to AAA. On or before April 15, AAA submits all reporting information received from provider (OAAPS spreadsheet, narrative and persons served reports) to State Legal Assistance Developer via Foundant.
C. On July 10 (or a contractually defined date): Legal services provider sends reporting information directly to AAA. On or before July 15, AAA submits all reporting information received from provider (OAAPS spreadsheet, narrative, and persons served reports) to State Legal Assistance Developer via Foundant.
D. On October 10 (or a contractually defined date): Legal services provider sends reporting information directly to AAA. On or before October 15, AAA submits all reporting information received from provider (OAAPS spreadsheet, narrative, and persons served reports) to State Legal Assistance Developer via Foundant.
a. Reporting Templates include the following:
i. Narrative Template with Fillable Fields
ii. Upload Tool- Modified
iii. Reporting Documentation
iiii. Reporting Flow
2. AAA staff will ensure that legal services reporting is accurate, complete and will submit to MBA on or before the 15th day of the month following the end of the quarter. In addition, AAA staff must update legal service information within Grant Utility, including, but not limited to, persons served, units of service, financials, etc., on or before the [delete] 20th [end delete] [add] 15th [end add] day of the month following the end of each quarter.
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