Cost Sharing Policy Options Under Consideration
This content is part of a public comment period. For more information, refer to Minnesota Board on Aging – State Plan on Aging.
On May 22, 2025, MBA program operations committee (POC) recommended scaling back some of the services to which cost sharing currently applies by eliminating cost sharing for visitor and telephone reassurance. Staff were instructed to draft policy and procedures in accordance with POC guidance. The revisions are included in the policy below.
MBA is considering changing its Cost Sharing policy and is seeking feedback on this during the public comment period. This document provides background information and explains the options under consideration. The current policy is included at the end of this document for further context and information.
Background:
The Older Americans Act has two ways in which older adults can help pay for part of services.
Most provisions of Older Americans Act federal regulations are requirements that must be implemented. One exception to this is related to Cost Sharing.
Important policy provisions include the following:
- Nutrition
- Information & Assistance & Benefits Counseling
- Ombudsman
- Elder Abuse Prevention
- Legal Assistance or Other Consumer Protection
- Any service provided by a tribal organization
Regardless of whether states choose to implement cost sharing, all clients must have the opportunity to contribute to the cost of services they receive through voluntary contributions. Any changes to MBA’s current policy on cost sharing will not change how voluntary contributions are implemented.
If states implement cost sharing, cost sharing must generally be implemented on a statewide basis. AAAs may apply for waivers for very limited purposes.
Services for which Cost Sharing currently applies:
The MBA has four options under consideration:
1. Maintain cost sharing for all services to which cost sharing currently applies (and make modest updates incorporated in the policy below to comply with federal rules).
2. Scale back some of the services to which cost sharing currently applies by eliminating cost sharing for Visitor, Telephone Reassurance, and Counseling funded with III-B.
3. Scale back almost all cost sharing except for Caregiver Support services.
4. Eliminate all Cost Sharing and focus solely on voluntary contributions.
Title III Administrative and Financial Requirements Policy #16: Cost Sharing and Required Actions by AAAs and Service Providers
Note: We updated content on this page on June 23, 2025. Changed content is indicated with [add] and [delete].
Authority Reference | OAA, Sec. 315 45 CFR 1321.9(c)(1)(vii) and 1321.9(c)(2)(xi) |
Operating Category | Title III Administrative and Financial Requirements |
Policy
1. In order to generate revenue to provide services to more older Minnesotans and to diversify funding streams to pay for services, MBA requires the use of cost sharing as permitted by Sec. 315(a) of the OAA.
2. Cost sharing is required for all of the following OAA Title III-funded services (unless provided to an individual with income at or below the federal poverty level, an individual receiving services through a Medicaid waiver or Alternative Care program, or for any service provided through a tribal organization):
A. Homemaker
B. Chore
C. Transportation
D. Home Modification
E. Assisted Transportation
[delete] F. Title III-B telephone reassurance
G. Title III-B Visitor [end delete]
[add] F. [end add] [delete] H. [end delete] Counseling funded by III-B
[add] G. [end add] [delete] I. [end delete] Health Promotion Activities
[add] H. [end add] [delete] J. [end delete] All Caregiver Support Services
[add] I. [end add] [delete] K. [end delete] Respite Care
3. Cost sharing is prohibited for the following services and populations:
A. Information and assistance, outreach, and benefits counseling.
B. Ombudsman, elder abuse prevention, legal assistance, or other consumer protection services.
C. Congregate and home delivered meals.
D. Any services delivered through tribal organizations.
E. To persons at or below the federal poverty level.
F. Persons receiving services through a Medicaid Waiver Program (CADI, CAC, DD, EW, BI), the Alternative Care Program, or the Essential Community Supports Program.
4. An AAA may request and receive a waiver to the cost sharing requirement if it can be adequately demonstrated that:
A. A significant proportion of persons receiving services under the OAA subject to cost sharing in a specific geographic area within the PSA have incomes below the Federal Poverty Level.
B. Cost sharing would be an unreasonable administrative or financial burden upon the AAA.
5. AAAs must report cost sharing contributions as part of their financial reporting to MBA. Cost sharing contributions must be recorded separately from voluntary contributions.
6. Amounts collected are considered program income. See Title III Administrative and Financial Requirements Policy #17: Program Income for further information.
7. For those services for which cost sharing is required:
A. The recommended level of cost-sharing is 50%. For those individuals unable to cost-share at the 50% level, a cost-share sliding scale — based solely on gross income levels and cost of delivering services — provided by MBA shall be used to determine the cost-share amount. Each service provider must identify their unit of service cost as the basis for the cost-share sliding scale.
B. The service provider must share information about each Title III service it offers on its website and in a hard copy, print format. This information must include a description of the service, the value of the service expressed as a dollar amount, and a sliding fee scale. The information must also advise clients of the opportunity to contribute towards the cost of the service.
C. The service provider must protect the privacy and confidentiality of each individual (with respect to the declaration or non-declaration of individual income and to any share of costs paid or unpaid by an individual).
D. Participant income level will be based on self-reported gross income of the older adult service recipient. Personal assets, savings, and/or other property are not to be considered. Income verification is not allowed. A means test shall not be utilized to determine eligibility for Title III services.
E. Related to caregiver services, in cases where the caregiver and the care receiver are married and at least one is 60+ years old, both incomes will be used to determine the cost-share amount. The two- person household income column on the cost-share sliding scale will be used to determine the cost share amount.
F. The service provider may not deny service to any individual unable or unwilling to make a contribution for service. All primary sources of payment, including home and community-based Medicaid waiver programs, the Alternative Care Program, and Essential Community Supports should be maximized and used first for qualifying clients.
G. Co-payment “statements” may be provided to clients [add] , [end add] but must not carry forward a balance due amount.
H. The service provider shall have written policies and procedures on how they will implement and administer the cost-sharing policy.
I. The service provider shall establish and maintain separate fund codes established for cost sharing revenue for each service. The funds shall not be co-mingled with funds received under any other agreement. The service provider is responsible for regular deposit of program income.
Procedures
1. AAAs must ensure language in in requests for proposals and contracts or grant agreements with service providers accurately describes their required activities with respect to requesting [add] , collecting, [end add] and tracking cost sharing as well as their obligations to maintain confidentiality about whether contributions are made and secure handling of cost share payments.
2. Service providers must request a cost sharing contribution for those Title III services for which cost sharing applies. 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 poviders must only solicit cost sharing contributions from clients they know to have income at or above 100% FPL.
4. Service providers must apply the MBA-provided sliding scale contribution schedule to their unit cost of service.
5. MBA will issue [add] a notification [end add] [delete] an Information Memorandum [end delete] 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 100% of the FPL for households of various sizes.
6. Service providers must develop clear communications materials explaining cost sharing 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 and AAAs must protect privacy and confidentiality of each recipient with respect to the recipient’s income and payment of cost sharing contribution or lack of cost sharing contribution.
8. Service providers must establish and follow procedures for regular accounting of all cost sharing contributions received.
9. Service providers must establish and follow procedures for safeguarding cost sharing contributions received, including secure handling of any cash contributions, checks, or electronic payments and prompt deposit of such payments into a bank account.
10. AAAs must report cost sharing contributions separately from other sources of program income on a discrete line in their standard budget reporting.
11. AAAs seeking a waiver from soliciting cost share must submit the waiver through the Area Plan submission process. The waiver request shall be evaluated based on consideration of the substantial share of the population served within the PSA that is below the income thresholds required for cost sharing or how implementation of cost sharing creates undue administrative burden for the AAA.
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