MBA Operations Policy #7: Maintenance of Effort

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	OAA, Sec. 374 45 CFR 1321.9(c)(2)(vi)
Operating Category	MBA Operations

Policy

1. State Unit on Aging

A. The MBA must spend for both services and administration at least the average amount of State funds reported and certified as expended under the State plan for these activities for the three previous fiscal years. If MBA spends less than this amount, the Assistant Secretary for Aging reduces the State’s allotments for services under Title III by a percentage equal to the percentage by which the State reduced its expenditures.

B. The amount certified must at least meet minimum match requirements from State resources.

C. Any amount of State resources included in the Title III maintenance of effort certification that exceeds the minimum amount mandated becomes part of the permanent maintenance of effort; and

D. Excess State match reported on the Federal financial report does not become part of the maintenance of effort unless the State agency certifies the excess.

2. AAAs

A. In general, federal funds should not be used to supplant state or local resources in place prior to the award. Federal funds should be used to expand services, unless otherwise specified in law or regulation.

B. Except as provided in Sec. 374 of the Older Americans Act, there is no statutory basis for Maintenance of Effort requirements for AAAs or their service providers.

Procedures

1. MBA is required to certify maintenance of effort has been met by August 1 of each year for the federal fiscal year that ended September 30 of the prior calendar year.

2. MBA will document how it meets its maintenance of effort requirement by certifying amounts needed to meet MOE requirements expended on the Federal financial report.

3. MBA’s calculation process and sources of state spending used to meet MOE are described below.

A. Calculation process used to complete the maintenance of effort certification is a multiple step process

Step 1. Compute minimum match from State funding

· i. Pull expenditure data for OAA Title III using Statewide Integrated Financial Tools (SWIFT)

· ii. Determine state [add] and/or local [end add] share for each type of spending
a. [delete] State Admin–all five OAA Title III subparts [end delete] [add] State Plan and Area Plan Administration [end add]
(i) Divide expenditure total by .75
(ii) Then multiply by [delete] .05 [end delete] [add] .25 [end add]
(iii) Result equals state [add] and/or local [end add] share [add] for State Plan and Area Plan Administration [end add] [delete] State Admin [end delete]
b. [delete] AAA Admin & [end delete] Direct service – only OAA Title III B, C1, [add] and [end add] C2 [delete and E [end delete] subparts. [add] (Note: direct service support for state long-term care ombudsman program is exempted from the match requirement) [end add]
(i) Divide expenditure total by .85
(ii) Then multiply by [delete] .05 [end delete] [add] .15 [end add]
(iii) Result equals state share for [delete] AAA Admin and [end delete] Direct Service [add] for OAA Title III B, C1, and C2 [end add]
[add] c. There is no state or local share for Subpart D, Evidence-based Health Promotion.
d. Direct Service for Subpart E
i. Divide expenditure total by .75
ii. Then multiply by .25
iii. Result equals local share for Direct Service for Subpart E [end add]

· iii. Add together results for state [add] and/or local [end add] share to find total state [add] and/or local [end add] share for reporting period

[delete] Step 2. Compare minimum state share identified in Step 1 to previous total from prior year maintenance of effort certification process [end delete]

Step [delete] 3 [end delete] [add] 2 [end add]. Identify total actual outlays from state funding sources (data pulled from SWIFT)

Step [delete] 4 [end delete] [add] 3 [end add]. Compare total actual state outlays to average amount of State funds spent the three previous fiscal years.

[add] Step 4. Compare total actual state outlays to minimum match requirements and ensure amount to be certified as MOE meets at least minimum match requirements. [end add]

Step 5. Complete certification form

B. Sources of State funding used to complete MOE certification may include any combination of the following as needed to meet the minimum MOE requirement:

· i. Senior Nutrition Programs

· ii. Consumer information and assistance and long-term care options counseling

· iii. Long-term care options counseling at critical care transitions

· iv. Prescription Drug Assistance

· v. Return to Community Grants

C. MBA will share its certified MOE at the next MBA Board meeting following the August 1 submission deadline.