Title III Administrative and Financial Requirements Policy #11: Availability of Funds and Payments from MBA to AAAs
This content is part of a public comment period. For more information, refer to Minnesota Board on Aging – State Plan on Aging.
Authority Reference | 45 CFR Part 75.305 45 CFR 1321.9(c)(2)(xviii) Minnesota Statutes 16A.124 and 16A.1245 |
Operating Category | Title III Administrative and Financial Requirements |
Policy
1. AAAs may not enter into grants or contracts or in any way encumber monies until after receiving, signing, and returning an official Area Plan contract from the MBA. Payments will not be made to AAAs or service providers until funds are encumbered and grant agreements or contracts are fully executed.
2. The MBA shall make periodic payments to AAAs for Area Plan administration and for provision of direct service. Methods and procedures for payment shall minimize the time elapsing between receipt of funds by the AAA and their disbursement, in accordance with federal and state requirements. The method and schedule for requesting reimbursement (payment) shall be specified in the grant contract agreement.
3. The MBA encourages AAAs to plan carefully for their cash management needs.
4. The MBA will make payments either in advance or reimbursement or a combination of both. Payments shall not be made on grants or contracts with past due progress reports, unless MBA has provided the AAA a written extension. Reimbursement is the preferred method of payment. However, MBA will make advance payments in certain situations as described below.
5. Grantee requests for reimbursement must correspond to the line items in the approved grant budget (for example, personnel costs or equipment). MBA will review each request for reimbursement against the approved grant budget, grant expenditures-to-date and the most recent grant progress report prior to approving payment.
6. Advance payments are permissible in the following circumstances:
A. In order to make advance payments, MBA must include a written justification in the grant agreement or otherwise prepare a written justification that describes the specific need to utilize advance payments. The written justification must be approved prior to encumbrance. A record of the signed justification must be maintained in the grant file.
B. The terms of advance grant payments and settlements must be reflected in the grant contract agreement. All advance payments on grants over $50,000 must be reconciled prior to requesting another advance payment, within 12 months of issuance, or within 60 days of the end of the grant period.
C. Advance payments must be limited to the minimum amounts needed and be timed to be in accordance with the actual, immediate cash requirements of the AAA in carrying out the purpose of the approved program or project. The timing and amount of advance payments must be as close as is administratively feasible to the actual disbursements by the AAA for direct program or project costs and the proportionate share of any allowable indirect costs.
D. The AAA must maintain advance payments of Federal awards in interest-bearing accounts, unless the best reasonably available interest-bearing account would not be expected to earn interest in excess of $500 per year on Federal cash balances and the depository would require an average or minimum balance so high that it would not be feasible within the expected Federal and non-Federal cash resources.
E. Interest earned amounts up to $500 per year may be retained by the non-Federal entity for administrative expense. Any additional interest earned on Federal advance payments deposited in interest-bearing accounts must be remitted annually to the Department of Health and Human Services.
7. The MBA has 30 days from the date payment request was received to complete payment for a valid, complete and accurate payment request. MBA must promptly review an invoice and communicate any concerns to the AAA within 10 days of the receipt of the payment request. If it is necessary for the AAA to provide additional information and/or resubmit a corrected invoice, the 30-day time limit ends. When the AAA provides the needed information and/or submits a corrected invoice, a new 30-day period starts. MBA must pay the corrected invoice within the 30-days from the date the corrected invoice is received from the AAA. MBA prioritizes payment of all AAA corrected invoices or requests where additional information is needed.
8. In accordance with both federal regulations and state law, the AAA must make timely payment to subgrantees and contractors. AAAs must pay subgrantees and contractors within ten days of the AAA’s receipt of payment from the state for undisputed services provided by subgrantees or contractors.
Procedures
1. When AAAs submit requests for either an advance payment or reimbursement, the AAA must:
A. Complete the payment request workbook that provides MBA the necessary information to evaluate the payment request.
B. Use the most current version of the payment request workbook and complete all tabs in the workbook.
C. Provide signed PDFs of payment workbook tabs where requesting an advance payment or reimbursement.
D. Provide a copy of the Excel version of the payment workbook when any tab is updated to generate a PDF payment request. Failure to provide the Excel version of the payment workbook may result in a request from the MBA to AAA to provide additional information.
2. AAAs are expected to upload all executed grant agreements and contracts into Grant Utility prior to submitting a payment request. MBA uses those grant agreements and contracts in reviewing an AAA’s payment request. MBA will not issue either an advance payment or reimbursement for direct services until a contract for which a payment request is submitted is uploaded to Grant Utility.
3. Payments requests must be made via email to MN.DHS.MBAFinance@state.mn.us.
A. Subject line should be: "AAA Name" “Payment type” Month-Yr (for example, XXAAA Nutrition January 2024)
B. AAAs should include only one payment request per email.
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