Title III Administrative and Financial Requirements Policy #4: Non-Federal Share (Match)

This content is part of a public comment period. For more information, refer to Minnesota Board on Aging – State Plan on Aging.

Authority Reference	OAA, Sections 301(d)(1), 304(c), 304(d)(1)(A)), 304(d)(1)(D), 304(d)(2), 309(b), 316(b)(5), and 373(h)(2). 45 CFR Part 1321.9(c)(ii) 45 CFR Part 75.306 Minnesota Statutes 256.975 & 256.9752 Subd. 1(A) – (C)
Operating Category	Title III Administrative and Financial Requirements

Policy

1. The MBA requires AAAs and/or service providers to provide or spend specified proportions of matching funds for each Area Plan year for administrative and direct service costs as required by the Older Americans Act. MBA must also provide specified proportions of matching funds for administrative costs. Allowable proportions of federal funding and required non-federal share are as follows:

Type of Cost	Maximum Federal Share of Total Expenditures	Non-Federal Share (Match Requirement)
AAA Area Plan Administration	75%	25%
Title III-B Supportive Services	85%	15%
Title III-C 1 & C2 Nutrition Services	85%	15%
Title III-D Evidence-based Disease Prevention and Health Promotion Services	100%	0%
Title III-E Family Caregiver Support	75%	25%

2. Unless otherwise specified, match must be met with expenditures for the same type of services. For example, family caregiver support match requirements must be met with expenditures for family caregiver support services.

3. Unless otherwise specified, the non-federal match is to be met through local sources.

A. ACL has approved MIAAA to use tribal self-governance dollars to be used as match.

4. The non-federal share matching requirement has additional requirements for supportive services and nutrition services only as specified in 45 CFR 1321.9 (c)(2) (ii)(J)(2)(iii), which requires a minimum of 1/3 of the 15% match for supportive services and nutrition services to be met from State sources and 2/3 of the 15% match from State or local sources. Match may be pooled for supportive services and nutrition services.

5. The methodology for calculating the amount of the match requirement is described under “Procedures” below.

6. Non-Federal shared costs or match funds and cash and third-party in-kind contributions are acceptable if the funds meet the specified criteria below for match.

a. Local funds expended for a non-Title III funded program may be used to meet the match requirement for Title III expenditures when the non-Title III funded program:

· i. Is directly administered by the area agency;

· ii. Does not conflict with requirements of the Act;
iii. Is used to match only the Title III program and not any other Federal program; and

· iv. Includes procedures to track and account expenditures used as match for a Title III program or service.

b. Proceeds from fundraising activities may be used to meet the match as long as no Federal funds were used in the fundraising activity. Fundraising activities are unallowable costs without prior written approval from the Assistant Secretary on Aging, as set forth in 2 CFR 200.442.

· i. Should a AAA or one of its contracted service providers wish to conduct a fundraising activity using federal funds, the AAA must submit a written request on its own behalf or for that of its contracted service provider to MBA. The AAA must provide ample lead time for MBA to submit a request on the AAA’s or service provider’s behalf. Therefore, AAAs must provide MBA at least 90 days advance notice if they wish to conduct fundraising paid for with federal funds.
The AAA must also have a back-up plan for paying for the fundraising costs (or canceling the fundraising activity) if the Assistant Secretary disapproves the AAA’s request or does not respond to it in a timely way in order to provide prior written approval. AAAs undertaking these fundraising plans do so at their own risk and with the understanding the Assistant Secretary may decline the request or not respond in a timely manner.

· ii. Should a AAA decide to proceed with a request to use federal funding to pay for a fundraising activity, the AAA must describe the following in writing:
a. The nature of the fundraising activity, including how funds are being raised, when the fundraising will begin and end, and how the proceeds are to be used;
b. How the fundraiser will be promoted;
c. How the fundraiser would otherwise comply with regulations related to allowable costs (for example, federal funds cannot pay for alcoholic beverages).

c. Unrecovered indirect costs may be used as match for administrative costs. A AAA using unrecovered indirect costs must explain and document this through the Area Plan budgeting process.

d. Third-party in-kind donations, including valuation of volunteer time, shall be determined by the criteria stated in CFR Part 75.306(e) and (f) and Sec. 304(d)(2) of the OAA. Those criteria include, but are not limited to, the following:

· i. Volunteer services furnished by third-party professional and technical personnel, consultants, and other skilled and unskilled labor may be counted as matching funds if the service is an integral and necessary part of an approved project.

· ii. Rates for third-party volunteer services counted as match must be consistent with those paid for similar work by the AAA or grantee. In those instances in which the AAA or grantee does not have employees or contractors with the same skills as volunteers, rates must be consistent with those paid for similar work in the labor market in which the AAA or grantee competes for the kind of services involved. In either case, paid fringe benefits that are reasonable, necessary, allocable, and otherwise allowable may be included in the valuation for volunteer services.

7. AAAs and service providers may not use the following types of expenditures to meet match requirements:

A. State funding used by MBA to meet State maintenance-of-effort requirements, including Senior Nutrition Programs.

B. State or local public resources used to fund a program which uses a means test;

C. Consistent with 45 CFR Part 75.306(b)(5), other Federal funds may not be used to meet required match unless there is specific statutory authority to do so.

8. AAAs may use the following state funding sources toward their match requirement:

A. Consumer information and assistance and long-term care options counseling

B. Long-term care options counseling at critical care transitions

C. Prescription Drug Assistance

D. Return to Community Grants

E. Food Delivery Support

Procedures

1. To calculate the amount of the non-federal match, it is necessary to first calculate the total project cost. For example, for a $400,000 federal award for nutrition (which has a match of 15%), the calculation process would look like this:

Step One: Determine what number the federal award is as a percentage of the total project cost

$400,000 divided by 85% = $470,588 Total Project Cost

Step Two: Calculate the non-federal share match requirement based on the Total Project Cost (which is higher than the amount of the federal award)

$470,588 * 15% = $70,588 (Non-federal share or match requirement)

Typically, the calculation process for non-federal share would stop after completion of Step Two. Because this is a nutrition-based example in which at least one-third of the non-federal share must come from State sources, an additional step is necessary.

Step Three: Calculate the non-federal share requirement for local resources.

$70,588 is the total non-federal share requirement. Because this is a nutrition-based example, at least one-third of the non-federal share must come from state resources. $70,588 * .33 equals $23,294, which is the State share amount of the non-federal share.

The non-federal share requirement to be borne by local resources is the remaining two-thirds of the $70,588 or $46,588.

2. AAAs shall demonstrate how they will meet the non-federal share match requirements for Area Plan administrative and direct services in their Area Plan budget submission.

A. The AAA must identify whether they are using Title III expenditures, non-Title III program expenditures, and/or voluntary contributions to meet each non-federal share match requirement in their Area Plan budget submission.

B. If the AAA intends to use non-Title III program expenditures to provide required match, the AAA must explain the nature of their expenditures; how they meet the criteria in 3 (A) above; and demonstrate how it will track and account for those non-Title III expenditures.

3. AAAs shall submit required reporting on match expenditures as part of their standardized reports to MBA.

4. AAAs shall establish written policies concerning non-federal matching requirements for service providers.