MBA Operations Policy #11: MBA Monitoring of AAAs

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].

Policy

1. The MBA conducts periodic monitoring and assessment of all activities carried out under the Area Plans. The purpose of such monitoring and assessment are to:

A. Assure that programs of the AAA are being conducted in compliance with federal and state policies.

B. Understand the need for training, technical assistance, and policy changes/clarifications for AAAs.

C. Provide the MBA with a flow of information that assists the MBA with its management, coordination, advocacy, and planning responsibilities.

D. Determine whether corrective action by an AAA is necessary.

2. Monitoring and assessment activities by the MBA can take one or more of the following forms:

A. In person site visits

B. Periodic virtual meetings with each AAA

C. Desk review of standard fiscal and program reports as well as review of PeerPlace data.

D. Review of special and individual reports or surveys that may be requested.

E. Written correspondence.

F. Phone communications.

G. Area Plan and amendment reviews and subsequent follow up.

H. Annual fiscal audits and reconciliations.

3. When an AAA receives a direct service waiver, the MBA will directly monitor how the AAA is providing the direct service in accordance with all applicable federal and state policies and standards.

4. MBA must carry out in person site visits of each AAA at least annually and prior to when a final payment is made for the Area Plan year. In extraordinary circumstances, such as a pandemic or another significant unanticipated situation of extended duration, the MBA may conduct monitoring visits virtually.

A. Each year, the MBA will consult with AAAs about the scheduling of each AAA’s monitoring visit. The MBA will also create a template for each year’s monitoring visit outlining the protocol for the conduct of the assessment. Assessments may be a fiscal assessment, a general program compliance assessment, concentrate primarily on one program or area of development, or a combination.

B. A formal report of written monitoring findings will be sent to the AAA following the on- site visit, including a compliance checklist and, if needed, identification of any issues where corrective action is needed within 14 business days of when the site visit is completed.

5. If, as the result of monitoring or assessment, a corrective action is needed, it will be documented as part of the written monitoring findings. MBA will ask the AAA for documentation the issue has been corrected within 30 days of the AAA’s receipt of the written monitoring findings (or a plan for remedying an issue if the timeframe for addressing it would reasonably take longer than a 30-day period). MBA will continue to monitor for compliance in correcting the finding and provide technical assistance to the AAA. MBA’s goal is to help AAAs carry out their responsibilities in a compliant and effective manner.

A. If the AAA does not make substantive progress in resolving findings or implementing a corrective action plan, MBA has authority to take other steps to ensure the AAA is meeting its obligations, especially for material deficiencies. Such steps may include temporarily withholding funds or, in extraordinary circumstances, initiating de-designation of the AAA’s status.

Procedures

1. The MBA will establish an electronic grant file for each AAA. The grant file shall be the centralized repository for all monitoring information about each AAA. Documentation related to monitoring shall be maintained consistent with state record retention requirements.

2. Appropriate MBA staff will be assigned responsibility for conducting various types of monitoring and documenting their reviews. MBA staff will use consistent processes as described in this Policy for monitoring compliance.

3. As part of its ongoing, desk review monitoring processes, MBA staff will review financial reporting and payment requests to ensure the following:

A. AAAs are obligating and spending funds in a timely manner for allowable purposes;

B. AAAs are meeting match requirements

C. AAAs have provided standard documentation needed as part of the payment request process, which MBA will communicate at the start of each calendar year.

4. Each annual site visit will include a review of financial controls and financial management processes. AAAs should anticipate MBA will do the following:

A. Request the AAA pull files for a sample of service providers for at least three contracts for amounts [add] of $50,001 or greater [end add] [delete] greater than $50,000 [end delete], to review the following:

· i. AAAs show documentation from the service provider’s a pre-award risk assessment. This documentation should include the dates the pre-award risk assessment was conducted; the findings of that assessment; and whether a need for enhanced monitoring was identified.

· ii. AAAs show documentation they have conducted financial reconciliation [delete] for grants and contracts that are $50,000 and more [end delete]; and whether any issues arose that required remediation as a result of that process.

· iii. AAAs show documentation they have a current contract in place with the service provider that resulted from a competitive procurement process and that the contract plus any extension amendments have not exceeded a five-year period in duration.

· iv. AAAs show documentation their practice for awarding grants and contracts to service providers did not result in supplantation of funds.

· v. AAAs show service providers are soliciting voluntary contributions for services.

B. Request the AAA pull files for a sample of service providers for at least three contracts for $25,000 or less to review the following:

· i. AAAs show documentation they have reviewed how program income is generated and how it is being managed through the additive method in order to expand services.

· ii. AAAs show service providers are soliciting voluntary contributions for services.

C. Engage the AAA in a structured discussion about funding for Program Development and Coordination activities, including:

· i. Whether any current contracts and commercial relationships used PD & C funding to spur their development and, if so, whether PD& C funds have been reimbursed.

5. In addition to reviewing compliance with financial controls and financial management processes each year, the site visit will also involve review of the following on a rotating basis over the four-year Area Plan cycle.

A. Administrative

B. Nutrition

C. Supportive Services and Health Promotion/Disease Prevention

D. Caregiver Support Services

6. When MBA is examining each of the above areas (#5 A – D) on a rotating cycle, AAAs should anticipate MBA will request the AAA pull files for a sample of service providers and examine the following:

A. That Supportive Services funded with Title III-B funding meet the following requirements:

· i. Verification that a sample of five randomly selected individuals receiving one or more units of chore, homemaker, or transportation services (whose information is extracted from Peer Place) have a current NAPIS form on file (meaning it has been completed within the past year) and sufficient information has been gathered to determine the individual is eligible to receive chore, homemaker, or transportation services;

B. Requirements for C-1 and C-2 service providers are included under Number 6 below.

C. That Disease Prevention and Health Promotion services funded with Title III-D funding provided under the contract meet requirements for ACL’s Evidence-Based Definition as noted in Provision of Title III Services Policy #9: Health Promotion.

D. That Caregiver Support Services funded with Title III-E funding meet the following requirements:

· i. Verification that a sample of eight randomly selected individuals served by the service provider (whose information is extracted from Peer Place) receiving Caregiver Support services have a current NAPIS form on file (meaning it has been completed within the past year) and that sufficient information has been gathered to determine the individual is eligible to receive caregiver support services;
a. If the individual served did not provide responses to the NAPIS form questions, that should be noted on the form.

· ii. All individuals offering Caregiver Consultation services have participated in all appropriate training as required under Provision of Title III Services Policy #10: Caregiver Support Services.

E. Whether the service provider received any grievances as described in Title III Administrative and Financial Requirements Policy #19: Grievance Process and whether the grievance was satisfactorily resolved at the service provider level.

7. During any on-site monitoring review, regardless of its specific focus, AAAs will need to show documentation they conducted on site monitoring reviews of at least 1/3 of its congregate and home-delivered meal sites or 20 sites, whichever is fewer. The documentation needs to show which service providers received site reviews and at which locations, what program requirements were checked, and any findings from each review.

A. For purposes of counting, each visit counts as one visit regardless of the number of types of services or number of additional sites a central site supports. For congregate sites, this means a location that serves a congregate meal on site or offers “grab and go” meals. For home-delivered meals, this means a visit to a single residence to which a meal is delivered.

B. In addition to the annual criteria for visiting 1/3 or at least 20 of its congregate and home-delivered meal service providers, the AAA must ensure a different set of sites are visited each year. The AAA must also ensure each meal site receives a site visit at least every three years.

C. When a congregate site receives a monitoring visit, the AAA must check the following:

· i. That the on-site kitchen is preparing a meal in accordance with the health and safety standards of the Nutrition Policy;

· ii. That the site has a menu plan that meets the standards outlined in the Nutrition Policy;

· iii. That voluntary contributions are being solicited for the meal, that they are stored in a secure manner if a meal participant makes a cash voluntary contribution, and that any non-eligible participants in the meal pay the advertised cost of the meal.

D. When a home-delivered meal site receives a monitoring visit, the AAA must check the following:

· i. That the site at which the meal was prepared cooked the meal in accordance with health and safety standards described in the Nutrition Policy (or, alternatively, if the meal being delivered is a frozen meal, that any meals currently being prepared at the service provider’s central food preparation site meets health and safety standards);

· ii. A NAPIS form has been completed for the individual(s) receiving the meal.

· iii. That the meal has been transported using an insulated bag as required in the Nutrition Policy;

8. Information about the AAA’s progress in the following activities:

A. What activities did the AAA engage in to promote coordination with Title VI grantees?

B. What steps did the AAA take to ensure services were prioritized to individuals with greatest social need and greatest economic need?

9. MBA must provide each AAA with a follow up summary report from their site visit within 14 business days after the site visit has been conducted. The summary report must include any areas where changes or improvements are required, including whether any corrective action plans are required.