Provision of Title III Services Policy #2: Requirements for Client Eligibility, Periodic Assessment, and Person-Centered Planning

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	Older Americans Act 102(40) and 373 (c)(1) 45 CFR Part 1321.3 (definitions of “periodic” and “older relative caregiver”); 1321.9(c)(1)(i); 1321.81; 1321.91
Operating Category	Provision of Title III Services

Policy

1. The Older Americans Act establishes eligibility requirements to receive OAA-funded services.

A. The Older Americans Act requires an individual to be at least 60 years old to be eligible to receive most Title III-funded services.

B. To receive Title III B-funded registered supportive services an individual must be 60 years of age or older;

C. To receive Title III C-funded home-delivered meals, an individual must meet one of these eligibility categories:

· i. Client (age 60 or older),

· ii. Spouse of client (regardless of age), or

· iii. Individual with disability under age 60 (who lives with an eligible client age 60 or older).

· iv. Volunteer (individual of any age providing volunteer services during meal hours),

D. To receive Title III C-funded congregate meals, an individual must meet one of these eligibility categories:

· i. Client (age 60 or older),

· ii. Spouse of client (regardless of age),

· iii. Staff age 60+ (who work at congregate dining site),

· iv. Volunteer (individual of any age providing volunteer services during meal hours), or

· v. Individual with disability under age 60 (who lives in a housing facility occupied primarily (i.e., more than 50%) by older adults at which congregate nutrition services are provided).

E. To receive Title III D-funded health promotion services, an individual must be 60 years of age or older;

F. To receive Title III E-funded caregiver support, an individual must meet one of these eligibility categories.

· i. Adults caring for older adults (meaning the care receiver is 60 years or older), who are informal providers of in-home and community care. The caregiver and care receiver do not necessarily live together and do not have to be related.

· Ii. Adults providing informal in-home and community care for individuals of any age with Alzheimer’s disease or a related disorder with neurological and organic brain dysfunction. The caregiver and care receiver do not necessarily live together and do not have to be related.

· iii. Caregivers who are 55 years or older and is a grandparent, step-grandparent, or other relative (other than the parent) of a child by blood, marriage or adoption and is an informal provider of in-home and community care.
The caregiver:
1. Lives with the child;
2. Is the primary caregiver of the child because the biological or adoptive parents are unable or unwilling to serve as the primary caregiver of the child; and
3. Has a legal relationship to the child, such as legal custody or guardianship, or is raising the child informally;

· iv. Caregivers who are 55 years or older and a parent, grandparent, or other relative by blood, marriage, or adoption of an individual with a disability [as defined in Section 3 of the Americans with Disabilities Act of 1990 (42 USC 12103)] ages 19-59 and is an informal provider of in-home and community care. The caregiver lives with the individual.

· v. For respite care and supplemental services only, to family caregivers of adults aged 60 and older or of individuals of any age with Alzheimer’s disease or a related disorder, the individual for whom they are caring must be determined to be functionally impaired because the individual:
(1) Is unable to perform at least two activities of daily living without substantial assistance, including verbal reminding, physical cueing, or supervision;
or
(2) Due to a cognitive or other mental impairment, requires substantial supervision because the individual poses a serious health or safety hazard to themself or others.

2. Registered services include the following:

A. Homemaker

B. Chore

C. Assisted Transportation

D. Home-Delivered Meals

E. Congregate Meals

F. Nutrition Counseling

G. Caregiver Counseling

H. Caregiver Support Groups

I. Caregiver Training

J. Caregiver Respite (In-home, Out-of Home, Out-of Home Overnight, Other Respite)

K. Self-Directed Supportive Services

L. Self-Directed Caregiver Support Services

M. Special Access

N. Supplemental Services

3. Service providers are required to assess whether an individual meets the eligibility criteria for a registered service by [add] asking the individual all questions on the National Aging Program Information System (NAPIS) registration form [end add] [delete] conducting an in-person assessment [end delete]. [add] Service providers may work with an individual by phone, on line, or in person to complete the questions on the form. However, the service provider must obtain the client’s signature on the form in person in a timely manner. “Timely manner” varies according to the type of service and is further defined below. [end add] The in-person [add] signature [end add] [delete] assessment [end delete] is not required for Title III-E services.

A. [add] Completion of the NAPIS form must occur near the time an individual begins to receive a registered service as described below and at least annually thereafter. [end add] [delete] Initial and annual renewal assessments must be conducted in person. [end delete]

B. During the assessment, the service provider is required to ask every client all of the questions on the NAPIS form related to their needed service. A response must be recorded on the NAPIS form for each question.

· i. If clients are reluctant to provide requested information, the service provider should explain the information is needed for eligibility purposes and to help build a service plan for them. The service provider should also assure clients their information will be treated as confidential information.

· ii. If a client refuses to provide certain data, the service provider must record this on the paper form or choose an option from a drop-down list on the electronic form indicating the client refused to respond to the question.

· iii. This information must be recorded on a [delete] National Aging Program Information System ( [end delete] NAPIS [delete] ) [end delete] form in either electronic or hard copy form.

· iv. These data must also be entered into the PeerPlace data application or its successor.
Comprehensive data collection for all data fields on the NAPIS form should be completed to conduct a more thorough screening of a client’s needs as well as to know their demographic characteristics. Such information is needed both to inform a person-centered plan and to help both the service provider and AAA know the degree to which they are serving individuals with the greatest economic need or greatest social need.

C. [add] In order to use Title III funds to pay for services, service [end add] [delete] Service [end delete] providers must record the client’s first and last name [add] and the client’s date of birth (with the exception noted under clause “i” below) [end add] on the NAPIS form [delete] and make every effort to document the client’s date of birth [end delete]. For services that will be provided at the client’s home, such as for home-delivered meals, the service provider must also record and enter the client’s address [add] on the NAPIS form [end add] [delete] into PeerPlace [end delete].

[add] i. For clients who do not know their specific date of birth, the service provider may work with that individual and obtain attestation that they are at least 60 years of age. [end add]

D. [add] Completion of the NAPIS form, including obtaining a signature in person, [end add] [delete] Collection of a client’s date of birth [end delete] must occur [add] in a timely manner. “Timely manner” means [end add] prior to beginning to receive services or within [add] the following timelines: [end add] [delete] 10 business days after the beginning of meal delivery and support services. [end delete]

[add]. i. Within seven calendar days for nutrition services.

ii. Within 21 calendar days (or sooner if more urgent circumstances indicate a need) for other registered services. [end add]

E. Clients are not required to verify their stated date of birth with an identification card such as a driver’s license or passport.

F. Clients (or their authorized representatives) must sign and date the NAPIS form [add] in person as described above when they first begin to receive a service and annually thereafter [end add]. In signing the form, the individual is attesting to the accuracy of the information they have provided as of the date the information was provided.

G. A client may not be denied service for refusing to provide date of birth or other information requested on the NAPIS form. [add] However, Title III funds may not be used to pay for meals for individuals without a date of birth on file (or, in the case of an individual who does not know their specific date of birth, an attestation that they are at least 60 years of age). This means the service provider must use another funding source to pay for meals provided to an individual whose date of birth or age attestation is not on file or to charge that individual for the service. [end add]

H. The service provider must read the “Tennessen warning” language included at the end of each NAPIS form that explains what information is being collected, why it is being collected, and how it will be used.

I. A physical copy of the NAPIS form must be maintained by the service provider. For security reasons, completed NAPIS forms and any data used to populate the NAPIS form may not be stored on a service provider’s laptop or transmitted via unsecure email. Service providers must not request or encourage consumers to send a completed NAPIS form via unsecure email.

J. Client information may not be directly entered into the PeerPlace database without use of the NAPIS form.

4. Service providers must conduct a periodic client assessment for registered services using the NAPIS form, meaning at minimum, once per federal fiscal year (October 1 through September 30). The assessment [delete] must be done in person and [end delete] must involve an updated attempt to gather data to fully complete a NAPIS form.

A. NAPIS forms are specific to the type of registered service being offered.

B. MBA will provide updated NAPIS forms to AAAs on an annual basis.

C. Service providers must use the most current NAPIS forms for initial and periodic assessments. AAAs are responsible for ensuring their service providers have and are using the most current forms.

5. Assessments of eligible clients serve as the foundation for their service plan. To the extent possible, service providers must use a person-centered planning approach to build a service plan for each client. ACL describes person-centered planning as “a process for selecting and organizing the services and supports that an older adult or person with a disability may need to live in the community. Most important, it is a process that is directed by the person who receives the support. The person-centered planning approach identifies the person’s strengths, goals, medical needs, needs for home- and community-based services, and desired outcomes.”

6. AAAs must monitor service provider compliance with these requirements.

Procedures

1. AAAs must include initial and ongoing periodic [delete] in person [end delete] assessment [add], including obtaining a signature in person on the NAPIS form, [end add] as a required duty for registered services in service provider contracts and grant agreements. Service providers should build this responsibility into their rates.

2. MBA will provide updated service-specific NAPIS forms on an annual basis with updated income thresholds related to the federal poverty level and any changes in other data fields.

3. Use of Electronic NAPIS Forms

A. AAAs must document annually whether each service provider intends to use an electronic version of the NAPIS form. Service providers using electronic forms must annually review and sign the “Minnesota Board on Aging Title III Provider Assurances for use of Fillable NAPIS Forms for Recipients of Older Americans Act Title III Services in Minnesota”.

4. Service providers (or, for those AAAs entering data on their providers’ behalf, the AAA) should enter initial and periodic assessment data into the PeerPlace data application promptly. This means the data should be entered by the 10th day of the month following when the data were collected.

5. AAAs must monitor client date of birth entered by service providers, specifically with respect to ensuring:

A. Clients meet the age eligibility criteria

B. That providers appear to be entering actual dates of birth, rather than a “dummy” date of birth.

· AAAs must compare rates of completion of this field and follow up with providers when there are concerns about whether providers are entering actual dates of birth.

6. AAAs must require service providers to participate in annual training on eligibility criteria, initial and ongoing periodic assessment, completion of NAPIS forms, and proper use of electronic NAPIS forms. The training will be provided by MBA in an on-demand format.

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