\. 
" .
Department of Health and Human Servces

OFFICE OF 

GENERA 
INSPECTOR 
AGllG 
TION ON 
TIE il 
STEWARSHI 
OF  OF 
OLDER AMRICANS ACf: 
The Methodology 
VI. 
Richard P. Kusserow 
INSPECfOR GENERA 
MACH 199  ., 
, ' 
" .
. .' " 
, . 

" .  " ' '
OFFCE OF INSPECTOR GENERA

The mission oftheOfficeofJnspector Genera (OIG)'as mandated by Public Law95"452 
as amended , is to protectth(:integrity of the Deparment of Heath and Human Se 
(HS) programs as welIas the heatqand Voelfare , of beneficiares served by thoser ypirCoegsr! t.m ' ,s. 
missionis9f 
Ths ' statuory , , out ' througl1' a nationwide network ,of audits, investigations 
and , inspetions' condu  tedbythree OlGoperatig ' COIlPOl entS: the , Offce, of Audit ,SerVices 
the Office of InvestigatioIls,andthe Offce of Evaluation and. Inspections. , 'Te Old also 
informs the Secretar)' of HHS of program , and management problems, and recommends 
courses to correct them. 
OFFCE OF AUDIT SERVICES 
The OIG' s Office ofAJlditServices (OAS) provides all auditig services for HHS  eitherby 
conducting' audits with its own audit resources or by overseeing audit work done by others. 
Audits examine theperforrance of HHS programs and/or, its gratees and contractors in "
caring out their respective responsibilities and are intended to provide independent

assessments ofHHS progras and operations in or er to reduce waste, abuse, and,

mismanagement and to promote economy and effciency throughout the Deparment.

OFFCE OF INESTIGA TIONS

The OIG' s Office of Investigations (Ol) conducts criminal , civil, and administrative 
investigations of allegations of wrongdoing in HHS programs or to HHS beneficiares and of 
unjust enrchment by providers. The investigative efforts of OI lead to criminal convictions 
administrtive sanctions, orcivil moneypenaIties. The OI also oversees State Medicaid 
fraud control units which investigate and prosecute fraud and patient abuse in the Medicad 
program. , 

OFFCE OF EVALUATION AN INSPECTIONS 
The OIG' s Offce of Evaluation and Inspections (OEl) conducts short-term management and 
program evaluations (caled inspections) that focus on issues of concern to the Deparment 
the Congress, and the public. The findings and recommendations contaned in these 
inspection reports generate rapid, accurate, and up-to-date information on the effciency, 
vulnerability, and effectiveness of deparmenta programs. 
This report was prepared in the New York Regional Office under the direction of Thomas F. 
, Tully, Regional Inspector General of Region II, Office of Evaluation and Inspections, and 
Alan S. Meyer, Deputy Regional Inspector General. Paricipating in this project were the 
following OIG personnel: 
Jack I. Molnar  Project Leader

Le 
K. Bostick Region VI

Susa E. Hardwick  Headquarters
 Departent of Health and Human Servces 
OFFICE OF

GENERA 
INSPECTOR 
AD~S~TION 
AGllG

ON 
TIE il 
STEWARSIl OF 
OF 
OLDER AMRICANS ACf: 
The Methodology 
Richard P. Kusserow 
INSPECfOR GENERA 
"0 
OEI-0-91-01510
""a  .......... ... ....... .... .. .. ..'".  ........ 
......... .............. ... .. .. .. .. .. ..  ." . . . ..  ..  ..  ..  ..  ..
..  ..  ...   ...   ...   ...   ...   ...   ...   ....    ....    ....    ....    ....    ....    ....    ....    ....    ....    ....    ....    ....    ....    ....    ....    .....     .....     .....     .....     .....     .....     .....     .....    . ... .   . ... .   . .. .  . ..  . .. .  . ...    ....    ..... 
TABLE OF CONTENTS 
INODUCTION 
Purpse 
Background 
COMPLIACE REVIEW METHODOLOGY 
Sampling 
Data Collection 
Traning 
Analysis and Reportng 
Schedule. . . . . . . . . . . . . . . . . . . . . . . . 
Stewardship Compliance Review. . . . . . . . . . . . . . . . . . . . A
APPENIX A: 

Targeting Compliance Review  . . . . . . . . . . . . . . . . . . . . . B
APPENIX B: 

Financial Management Compliance Review  . . . . . . . . . . . .. C
APPENIX C: 

Nutrtion Services Compliance Review  D- I 
APPENIX D: 

Ombudsman Compliance Review  . . . . . . . . . . . . . . . . . . . E
APPENIX E: 
 INTRODUCTION

PURSE 
Ths report trsmits the methodology for the review of State Units ' on Aging (SUA) 
compliance with the requirements of Title II of the Older Americans Act (OAA). 
BACKGROUN 
In order to strengthen the Administrtion on Aging s (AoA) stewardship of the OAA, the 
Commissioner of AoA has requested technical assistace from the Offce of Inspector 
Genera (OIG) in designing an assessment of their primar grantees -- SUAs. In June 1991 
OIG staf met with key AoA headquarers and regional staff to identify trditional and 
current stewardship activities , and to discuss potential approaches for future efforts. As 
result, parcipants agree that in addition to reinstituting the monitoring of individual States 
there was a nee to provide the Commissioner with an overview of how States are 
implementing key components of Title II -- Grants for State and Community Programs on 
Aging. Accordingly, OIG staf would assist AoA in developing national, stadardized 
compliance review instrments for key components of Title II and in writing a report 
summaring States' compliance with the Act. It was also agree the compliance reviews 
would be conducted on a saple of States to conserve trvel dollars. 
Designing the compliance review took a number of steps. The first step was a meetig 
between OIG and selected AoA regional staff to branstorm approaches and issues. This took 
place durig a three-day session in Washington, D.  , where specific Federal reportng and 
operational requirements for SUAs and Area Agencies on Aging (AAAs) and potential 
monitorig strtegies were discussed. 
The second step was to drat the instrments which would contan the compliance review 
qtueesstions and criteria, and would serve as the one place to record al data. Two writing
, composed of OIG and AoA staf, shared ideas and approaches initially, and then 
created ealy versions of the instrments. These were shared with AoA Headquarers staff 
and each regional office for comments, and then revised to reflect comments. 
During the third step, OIG and AoA staf pre-tested the instruments and data collection 
methodology. Ths necssitated conducting actual compliance reviews for each of the five 
instrments in three different regions. We found, durig the pre-test, that a great dea of 
time was lost explaiing criteria (interpreting law and regulation) and seaching for 
documentation. Based on these reviews, we modified each of the instruments and changed 
the data collection methodology. The most significant change to the methodology requires  sharng copies of the review instrments with the States prior to the site 
visit. We believe 
States are aware of and understad the review criteria being used during the 
that  if 
compliance review, they wil be better prepared to provide required documentation and to 
discuss speific compliance issues.  SAME 
STATES

Strtu 1  Strtu 2  Strtu 3  Stratwn -4 
Caiforna  Michigan  Wiscnsin  New Hampshire 
Penylvana  Indiana  Colorado  North Dakota 
New York  Massachusetts  Oklahoma  Nevada 
Texas  Georgia  Maie  District of Columbia 
Florida  Nort Carolina  Oregon  Montaa 
We wil also employ sampling techniques during our visits to the States for our reviews of 
AAA area plans and assessments. In some States, the number of AAAs could excee 30 
which would ta the limited resources available to the reviews. Therefore, prior to our visit 
to each State, we wil select a simple, random sample of 10 AAAs to review on-site. 
DATA COLLECTION 
The actual data collection wil be conducted in two phases -- a desk review and an on-site 
review at the SUA. Durig the desk review phase, AoA Regional Program Directors (RD)
wil send a letter to each SUA selected in the sample announcing the compliance review 
listing compliance review criteria, and requesting selected documents. The documents 
requested wil include area plan guidance and program instructions for each of the review 
area s assessment instrments for AAAs. The AoA staff wil 
, as well as a copy of the State 
review these prior to the site visit to determine if they are consistent with Federal law and 
regulations. The desk review wil also include an assessment of priority services waivers and 
a review of tageted populations parcipation data from the State Program Report. 
Following the desk review, the RPD wil send a second letter to each SUA in the sample. It 
wil provide a proposed agenda for the site visit, a listing of the ten AAAs whose area plans 
and assessment reports wil be reviewed, copies of the compliance review instrments 
(Appendices A-E), and findings from the desk review to be discussed during the site visit. 
The instrments share a common approach to data collection. Initially, the instrments focus 
on the guidance SUAs issued to AAAs on key requirements of Title II, and on the 
instrments and proceures they use to assess AAA compliance with those requirements. A 
review of area plans wil determine whether, and to what extent, they reflect OAA 
requirements. The review of area-specific 
assessment reports wil determine compliance. 
The instrments also focus on the issues of SUA operating procedures , and on training and 
technica assistace activities. The Ombudsman instrument is an exception since all 
Ombudsman activities are cared out by the SUA and do not require the involvement of 
AAAs.  trng, 
During the  the procedures for conducting the compliance review wil be discussed 
tea 
in deta. Ths wil assure that each review  functions similarly on-site, that data are 
being collected in the proper sequence, and that all components of the five compliance 
reviews are being covered. With regard to sequencing, certin tasks will be identified for 
completion in a parcular order. 
The AoA staf wil also nee to develop key data collection skills -- interviewing and 
recrding. The interviewing skills wil assure that all questions wil be asked the same way. 
Varance in how questions are asked can affect the integrity of the review findings. 
Recrding conventions wil be reviewed to assure that responses and quantitative data are 
recorded in the same manner by all review teams. Lastly, during the training sessions team 
members wil receive some trning in the analysis of open-ended questions. 
AN 
ANALYSIS  REPORTING 
The analysis of the compliance review data wil be led by AoA and OIG staff in Regions 2 
and 6. In the lead Regions, OIG/ AoA teams wil enter data from the compliance review 
instrments into automated databases. The AoA regions wil be given responsibility for the 
analysis of open- ended questions in different programmatic areas. This wil give all AoA 
regions an opportunity to parcipate in the analysis phase of the report. 
Once the analysis is completed , the lead Regions wil develop one-page briefing papers for 
each of the compliance review areas. These wil serve as the basis for a story conference 
with the Commissioner. At the story conference, the lead teams will brief the Commissioner 
on fmdings, respond to questions, and discuss drafting the reports and recommendations. 
Six compliance review reports wil be written. One report wil be written for each of the 
five compliance review instruments and wil present findings based on a weighted-frequency 
distrbution of key questions. A sixth report wil present a overview or summar 
of the five 
programmatic reports and wil focus on cross-cutting issues. The reports wil contan, where 
appropriate, recommendations for strengthening SUA operations or AoA stewardship.  APPENDIX A
 --,-..-.
------------------------------------------
STEWARSHIP COMPLIACE REVIEW

HHS/AOA - 03/20/92 
State  Date 
Prary 
Respondent  Telephone 
Review Tea Leder  Telephone 
Prir to 
the on-sie visi, obtain a copy of the Area Plan fomzat provided to Area Agencies 
on Aging (AAs) from the State Agency on Aging (State Agency). 
Review and detemzine 
whether or not the Area Plan fomzat addresses the crieri identified in the following 
in the approprie column reflecting these codes: 
table. Indicate your responses with an 

Y (Yes)  Total Compliance with Crieri

P (Partl) =  Partl Compliance with Crieri

N (No) =  Not in Compliance with Crieri 
CRIRI 
COMMNTS 
Sec. 306(a)(2) 
contain an assurace that an adequate proportion of

Title m-B win be expended for acces home

, in-
and legal assistace

expended in previous

spify anualy, amounts 
fisc year for access, in-home and legat asistace;

Sec. 306(a)(3) & 1321.3 
designate communty focal points for selVices; 
Sec. 306(a)(4) 
establish and maintain informtion and referrl

service;

Sec. 306(a)(5) 
assure that preference is given to selVing those of

greatest economic or social nees (particularly low-
income miorities)... 
have proposed methods to selVe those of greatest 
ecnomic or social nees... 
Stewardship - Final  CRIERI 
COMMNTS

assure each service provider agreement wil spify
how the service provider will serve low-income 
miorities...in at leat the sae proporton.. 
us 
identify numbers of and desribe method 
serve low-income miorities in previous fiscl 
year... 
asre use of outreach methods... with special 
emphasis on rura elderly, greatest economic or 
soial nee (with paricular attention to low-income 
miorities), and severe disabilities; 
Se. 306(a)(6) 
conduct periodic (at leat anually) evaluations 
Ar 
conduct public hearigs on  Plan activities... 
conduct an anual evaluation on outreach... 
provide tehnca assistace to service providers... 
consider views of reipients of service in the 
development and admistration of Area Plan... 
monitor, evaluate, and comment on policies, 
actions...
affecting elderly... 
provide volunteer opportties for older individuas 
in day care services for children and adults and 
resite for famiies... 
establish an Area Agency advisory council.. 
develop and publish methods for determng 
priority of services. .. 
elD  establish proceure for cordinating Title 
progrms with other Federal programs as spified 
in Sec. 2D3(b)... 
ell  faciltate cordination with communty-bas, long-
ca 
term  services... 
el2  identify agencies and organizations workig in area 
of abus, neglect, and exploitation of older people... 
e13  determe unet service nees of abuse, neglected 
and exploited older individuals.. 
el4  facilitate involvement of long-term care providers in 
cordinating community-based long-term care 
service... 
elS  cordinate priority service with Alzheimer s disea 
organizations... 
Stewardship - Final  (If additnal space is required, use the back of the previous page. 
Beyond that required by Sec. 306 of OAA, what significant items have you added to area 
plan formats?

Don  (Check if applicable) 
t Know

A-4  Stewardship - Final  Doe the State Agency have any criteria for approving the direct provision of supportve 
servce, nutrtion services, or in-home services'? 
, What are they'?
Yes  (If yes) 

(2) 
(3) Don
(Check if applicable) 
t Know

10.	 Are any AAAs approved by the State Agency to directly provide supportive services 
nutrtion services or in-home services'? 
Yes 
(If No, sldp to queston 12)

No 
Don  (Check if applicable)

t Know 

11.	 What are the number of AAAs providing each'? 
Number of AAAs directly providing supportive services 
Number of AAAs directly providing nutrition services 
Number of AAAs directly providing in-home services 
Don t Know  (Identify whether Don t Know applies to a
, b 
or combinatn): 
12.	 State Agencies have the ability to waive the adequate proportion requirement for Title II-
record response) 
for accss services. How many AAAs have  (Fill-in with a-c and
been grated waivers for: 
Access services'?

In-home services'?

Legal assistace services'?

Don t Know  (Identfy whether Don t Know applies to a
, b

or combinatn): 
(NOTE:  A1TACHMENT B PERTAINS TO IN-HOUSE DESK REVIEW OF AM WAIVERS 
MISSING OR INDICATES DISCREPANCIES, ASK 
-IF ANY INFORMATION 	 IS 
ABOUT THESE DURING THE ON-SITE VISIT AT THIS POINT) 
A-6	 Stewardship - Fina  CRIRI 
COMMNTS

us 
identify numbers of and desribe methods 
serve low-income miorities in previous fiscl 
yea... 
as us of outrh methods... with special 
emphasis on rural etderIy, great ecnomic or
-sial nee (with particular attention to low-income 
miorities), and severe disabilties; 
Se 
306(a)(6) 
conduct periodic (at leat anualIy) evaluations

conduct public hearigs on Area Plan activities... 
conduct an anual evaluation on outreach... 
provide technca assistace to service providers... 
consider views of recipients of service in the 
devetopment and admistration of Area Plan... 
monitor, evaluate, and comment on policies, 
actions.. .affecting elderly... 
provide volunteer opportties for older individuas 
in day care service for children and adults and

reite for families... 
Ar 
establish an  Agency advisory council.. 
determg 
develop and publish methods for 
priority of service... 
proure 
e10	 establish  for cordinating Title m 
programs with other Federat programs as specified 
in Sec. 203(b)... 
ell	 faciltate coordination with communty-based , long-
term care services... 
e12	 identify agencies and organizations workig in area 
of abus, neglect, and exploitation of older peple... 
abus, 
e13	 determe unet service nees of  neglected, 
and exploite older individuals... 
e14	 facilitate involvement of tong-term care providers in 
cordinating communty-bas long-term 
service... 
e15	 cordinate priority services with Alzheimer s disea 
organzations... 
e16	 cordinate Title moB mental health service with the 
services of other mental health agencies and 
organzations... 
Stewardship - Final  (If additnal space is required, use the back of the previous page. 
15.	 Beyond that required by Federa law or regulation significant items have you added to 
, what 
your assessment instrument for assessing AAAs? 
- Don
(Check if applicable) 
t Know

16.	 How frequently does the State Agency perform an assessment of all AAAs? 
Annualy 
Biannually

Quarerly

Other  (Specif time period)

- Don
(Check if applicable)
t Know 

17.	 What were the beginning and ending dates of the last complete cycle of assessments of all 
AAAs? 
Beginning Date 

Ending Date 

Stewardship - Final  20.	 Provide a brief description of how each procss is used to monitor the performance of 
(Descriptin should be provied for each applicable response provided in questn 
AAs. 
19) 
21.	 What were the most common deficiencies reveaed in the last cycle of assessments of the 
Area Agencies?

Don  (Check if applicable)
t Know 

Stewardship - Final  26.	 (Fill-in the remainder of the question with a, b, and c. Indicate 
Have you analyze the: 
response for each) 
a. evaluation of activities? 
(1) 
What are your primar observations based on the analysis? 
Yes (If Yes), 
(2)
(3) Don
(Check if applicable)
t Know 

b. 
results of public heangs? 
(1) 	
What are your primar observations based on the analysis?
Yes (If Yes), 

(2)
(3) Don
(Check if applicable)
t Know 

c. evaluation of outreach?

(1) 
What are your primar observations based on the analysis?
Yes  (If Yes), 
(2)
(3) Don
(Check if applicable)
t Know 

Stewardship - Final  :!!
29.	 Doe the State Agency have any unmet training or tehnical assistace nees related to 
stewardship activities? 
a. 	
Pleae describe:
Yes (lfyes), 
Don  (Check if applicable) 
t Know

30.	 The preselected sample of 10 Area Agencies on Aging were identified prior to the on-sie 
visi. This sample is to be used throughout the compliance review process for all five 
areas, the firs compliance review being Stewardship. 
For the sample AAs, obtain the 
most current Area Plan. Review each Area Plan and 
detennine the extent to which the plan addresses the statutory and regulaory crieri 
identified in Atachment A. Record your responses on the following table using these 
codes: 
Y (Yes) =  Total Compliance with Crieri 
Part 
P (Part) =  Compliance with Crieri 
NN (SNoC)  = Not in Compliance with Crieri
No Stae Crieri (State Agency does not assess this 
Fedeml crieri 
 identified through in-house review of 
State Agency s assessment tool and relaed materis) 
Other Finding (provide explanaton and indicate by 
reporl number and crieri number in the Comments 
section following the table) 
Criteri 
Stewardship - Final  el2 
e13 
el4 
elS 
el6 
el7 
el8 
COMMS: 
Stewardship - Final  elO 
el2 
e13 
el4 
elS 
Stewardship - Final  ,...

ACHM 
IT 
CRIER 
STEWARSHIP 
Sec. 306(a)(2) 
contan an assurace that an adequate proporton of Title II-B wil be expended for 
acCss home, and legal assistace 
, in-
specify annually, amounts expended in previous fiscal yea for access  home and 
, in-
legal assistace; 
Sec. 306(a)(3) & 1321.3 
designate community foca points for services; 
Sec. 306(a)(4) 
referr 
establish and maintan information and  services; 
Sec. 306(a)(S) 
assure that preference is given to serving those of greatest economic or social nees 
(parcularly low-income minorities)...

have proposed methods to serve those of greatest economic or social nees...

assure each service provider agreement wil specify how the service provider wil serve

low-income minorities.. .in at least the same proporton...

identify numbers of and describe methods used to serve low-income minorities in

previous fiscal yea...

assure use of outreach methods... with speial emphasis on rural elderly, greatest 
economic or social nees (with parcular attention to low-income minorities), and 
severe disabilties; 
Sec. 306(a)(6) 
conduct periodic (at least annually) evaluations 
conduct public heangs on Area Plan activities... 
conduct an annual evaluation on outreach... 
provide technical assistace to service providers... 
consider views of recipients of services in the development and administration of Area 
Plan.. .

monitor, evaluate, and comment on policies , actions... affecting elderly...

Stewardship - Final  ATIACHMNT B

AOA IN-HOUSE DESK REVIW OF AAA WAIVERS 
AA 
Identi from in-house documents those  which have received an approved waiver. On the 
following table list each. Review the in-house documentaton and determine whether each 
addresses questns a-e. Record your responses on the table using these codes: 
Yes 
No (provide explanaton and indicate by AA)

Dtischrepeanc y (pCrovioe exmplamnatoen annd tindi cates bye AAc wthat ithe ndisc)rep ancy
  is in

AA 
Missing informaton (provide explanaton and indicate by  what the 
discrepancy is in the Comment section) 
Prior to the submission of the waiver, did the Area Agency conduct a public hearing? 
was the reord of the hearing submitted with the waiver request to the State 
1/ the answer to question a was yes, 
Agency? 
Prior to the grating of the waiver, did the State Agency publish the intention to grant such a waiver with the 
justification at leat 30 days prior to the effective date of the decision to grant the waiver? 
Were any hearigs convened by the State Agency durig the 30-dy period in response to requests from individuals 
or service providers from the area?

Did the State Agency provide to the U.S. Commssioner on Aging, through the appropriate AoA Regional Offce, a 
report regarding the waiver along with a copy of the notice of public hearing and minutes of the hearings conducted 
by the Area Agency and the State Agency (if appropriate)? 
STATE 
HEARNG  STATE  STATE  PROVIDED AOA 
PUBLIC  REORD  PUBLISHED  HEARING  REPORT ON
HEARNG	 SUMITTD  INTENT 30  DURNG 30  WAIVER WITH 
AAA WI WAIVR	 HELD WWITAHI R  DAYS PRIOR  DREASYPSO INNS E  CNOOPTYIC OEF OF
BEFORE 
REQUE, IF  EFFCTIVE  HEARNG AN 
SUBMISSON 
HEARNG  DATE OF  REQUES  MINUES OF 
OF WAIVER 
 HELD  DECISION  (IF AN  AN HEARINGS 
(0) 
(b)  (e)  (d)  (e) 
Stewardship - Final  SIATE 
HEAG 
SIATE  SIATE  PROVIDED AOA 
PUBLIC  REORD PUBLISHED  HEARING  REPORT ON 
HEARNG  SUMITID INTENT 30  DURNG 30  WAIVER WITH 
AA WI WAIVR  HELD WITH DAYS PRIOR  DAYS IN  COpy OF 
WAIVER RESPONSE  NOTICE OF 
BEFORE 
REQUE. IF EFFCTIVE  HEARING AN 
SUBMISSION 
OF WAIR  HEARNG  DATE OF  REQUESS  MINU OF

(a)  HELD DECISION  (IF ANY  AN HEARNGS

(b)  (c)  (d)  (e) 
COMMNTS:

(If additonal space is required, use the back of the previous page. 
Stewardship - Final  APPENDIX B
 TARGETIG COMPLIACE REVIEW

HHS/AOA - 03/20/92 
State  Date 
Prary 
Respondent  Telephone 
Review Tea Leder  Telephone 
In our ealier interview on stewardship, we discussed how your assessment instrument 
addresses tageting. What other procedures do you use to review and evaluate each Area 
Agency on Aging  (eg. on-site/desk review)? 
s (AAAs) performance in tageting? 
- Don
(Check if applicable)
t Know 

DFid ethed Staete Argaenc y fuinsdecrtea sp eyifice acativitsies? in s upport of tageting during the last two
4)
(If Yes, go to questn 3)
Yes 
No  (If No, go to queston 
Don  (If Don t Know, go to queston 4) 
t Know 
Targeting - Final  Describe and give examples of the following activities underten by the State Agency in 
support of tageting durig the last  (Read list and check those with 
two fisca yeas? 
offirmve responses. For each affinnatve response,  examples of that activit, 
identify 
where applicable. 
ACTIVY  EXAMPLES OF ACTIVY 
Altered fuding formula
 Not Applicable

Monitored/assessed AAs  (1) 
(2) 
Conducted traing conferences, meetings  (1) 
workshops 
(2) 
Dissemiated techncal assistace/informtion  (I) 
(2) 
Conducted data analysis  Not Applicable

Formed State-level tak force or advisory  (I) 
commttee 
(2) 
Implemented specific objectives in the State  (1) 
Plan 
(2) 
Targeting - Final  ACTIVY  EXAMPLES OF ACTIVY 
Established paricipation targets  (1) 
(2) 
(Identi):  01(1) 
Other, 
n1. 
01(2) 
02. 
02(1) 
02(2) 
Describe and give examples of activities implemented by AAAs to increase the parcipation 
(Probe for infonnaton on: outreach, specializaon of services 
of tageted populations. 

designed for specifc target groups, staffing, provider and site selection) 
TARGET ACTIVIE  EXAMPLES OF TARGET 
ACTIVIES 
Outreach  (1) 
(2) 
Speialization of Services Designed for  (1)

Speific Target Group

(2) 
B-4  Targeting - Final  Prior to this visit, we sent you a table entitled "Target Population Parcipation." The data 
come from your State Program Reports for the last three yeas. What factors affect your 
trends? 
The next few questions focus on the service nees of low-income-minorities. Does the 
State Agency have diffculty in obtaning the required low income-minority data? 
- Yes
, Please explain the diffculties being encountered by the State Agency: 
Don  (Check if applicable) 
t Know 
AAAs have difficulty in obtaning the required low income-minority data? 
8. Do the 
- Yes
, Please explain: 
Don  (Check if applicable) 
t Know 
What are examples of the " succssful" methods used by service providers to satisfy the 
servce nees of low- (as contained in the service plan of 
income minority individuals 
proviers complying with OAA Sec. 306(a)(5)(A)(ii) and Regulaon 1321. 65(b)) 
- Don
(Check if applicable)
t Know 

Targeting - Final 
B-6  13.	 What are some examples  successful outreach techniques used by AAAs in reaching 
' of 
tagete 
populations? 
- Don
(Check if applicable)
t Know 

14.	 If identified, how does the State Agency address outreach deficiencies of the AAAs? 
- Don
(Check if applicable) 
t Know

IS.	 Did the State Agency conduct an annual evaluation last year of its effectiveness in outreach 
to tagete populations, as stipulated in Section 307(a)(8)? 
What outreach activities were found to be most effective?
Yes  (If Yes) 

(1) 
- Don
(2)	 (Check if applicable)
t Know 

Don  (Check if applicable)
t Know 

Targeting - Final  19. What do you see as the major success of the State Agency s tageting effort? 
- Don
(Check if applicable)
t Know 

20.	 What are the major obstacles to effective tageting that  (at either the 
stil must be addressed 
AA 
State or  level)? 
- Don
(Check if applicable)
t Know 

21.	 What speific activities should AoA underte to assist State Agencies' and AAAs' tageting 
efforts? 
- Don
(Check if applicable)
t Know 

22.	 Are there any other issues or comments regarding tageting you would like to share with us? 
(INTERVIEW COMPLETED)

Targeting - Final  , identify the source of the data and the yea that the data was 
For each tageted population
avaiable. (For example, a source could be identified as the Bureau of Census, 1990). 
TARGETED POPULATIONS  DATA SOURCE  DATA AVAILABLE 
a. 60 + population

b. Minority population

c. Fral/Disabled

d. Rur 
e. Low-income non-miority 
f. Low-income miority

Specif:
g. Other, 

(1) 
(2) 
(3) 
Targeting - Final  I. FraDisabled

J. Rura

K. Low-Income 
Non Minority 
L. Low-Income 
Minority 
Targeting - Final  APPENDIX C
 -------------
FIANCIA MAAGEM COMPLIACE REVIEW 
HHS/AOA - 03/20/92 
State  Date 
Prary 
Respondent  Telephone 
Review Tea Leder  Telephone 
---..-_-_a__--__---
Prir to the on-sie visi, obtain copies of policies, procedures, and other guidance to Area 
Agencies on Aging (AAs) on financial management from the State Agency on Aging 
(State Agency). Review and detennine whether or not these issuances address the crieri 
identified in the following table. Indicate your responses with an X in the approprie 
column reflecting these codes: 
Y (Yes)  Total Compliance with Crieri

P (Parl) =  Partl Compliance with Crieri

N (No) =  Not in Compliance with Crieri 
During the desk review not include those items necessary to
, if the policy materils do 

make a detenninatn of compliance (Y, P, or N), mark NA (Not Available) in the 
Comments sectin of the table. 
CRIRI 
COMMNTS 
AA 
Stale Agency approves all  contracts with 
profitmag gratee 
OM Sec. 212 
Title II expenditures in rural area equal or 
exce 105 % of specified expenditures in FY 1978 
OAA Sec. 307(a)(3)(B) 
AA 
admistrative expenditures statewide do not 
exce 
the 10% limitation 
OAA Sec. 304(d)(1)(A) 
There is no fuding at the 85-15 match for 
progra development and coordinated activities 
until the specified percentage is expended 
statewide for AA admistration 
45 CFR 1321.7(f)(14) 
Financial Management - Final  CRIRI 
COMMNTS 
Eah AA reta recrds for 3 yrs aftr the date 
tht the AA 
submits its fial expenditure report 
or the date on which resolution of audit 
excetions, litigation, etc. ocur (whichever date 
is later)

45 CPR 92.42 & 74 Subpart D 
opportty to mae 
Paricipants are given an 
volunta contributions 
45 CPR 1321.67(a)(I) 
Limitations on trfers betwee congregat and 
home-delivered meat allotments 
45 CPR 1321.45 
Privacy of contributions 
45 CPR 1321.67(a)(2) 
Safegurds and accounting for contributions 
45 CPR 1321.67(a)(3) 
Support service contributions are used to expand 
support service 
45 CPR 1321.67 
In applying program income, the deduction 
alternative is not used 
45 CPR 1321.73 
AA admistration is fuded from Title II B 
and/or Title II C, only 
OAA Sec. 303(c) 
Statewide trafers between Title II B & C do not 
exce 30 
OAA Sec. 308(b)(5)(B) 
Retention of Federal governent fiancial interet 
in  senior centers 
OAA Sec. 312 
AAs spnd State Agency prescribed percentages 
on spified categories of service 
OAA Sec. 307(a)(22) and 306(a)(2) 
Audits for governental and non-governmental 
AAs 
OMB Circular A-128 , A-133 
us 
Nutrition services contributions are 
incre meals, for acces, or for authorize 
service. 
OAA 307(a)(13)(C)(ii) & 45 CPR 1321.67 
Financial Management - Final  aditna 
(If  space is required, use the back of the previous page) 
Note: Under the Single Audit concept, the tenn "grantee " refers to the AA, when the AA is 
an independent agency or organizaon. Otherwise, the tenn "grantee " refers to the 
multpurpose agency or organizan, when the AA is a separae organizaonal unit within 
such multpurpose agency or organizaon.

How does the State Agency ensure that audits of its 
gratees wil be conducted in 
accordace with the law and the  (i. e., through which methods) 
regulations? 
AAAs must budget funds for audits 
gratees are directed to have audits conducted in accordance with specified 
OMB Circulares 
(Identify the specifc procedure and explain) 
Other 
What was the last fisca yea during which audits were made of the State Agency

gratee?

Beginning date 

Ending date 

4f pet1ain to the last fiscal year in which audits were made:
Questons 4c 

sie visi, list the  preparaon for the on
Prir to the on- sample grantees below. In 
sie visi, ask the State Agency to have available for each sample AA: 
the type of audit conducted (A-128 or A-
I33) for the last fiscal year (identified 
a and b) and 
at questn 

the name of the audit agency conducting that audit. 
For each of the sample AAs, fill-in the approprie infonnaton on the 
following 
table. 
C-4  Financial Management - Final  Prr 
to the on-sie visi, list the sample grantees below. In preparan for the on-sie 
visi, ask the Stae Agency to have availale audit findings 
for the most recently 
AA. 
completed A-128 or A-133 audit of each sample  For each of the sample AAs, 
each approprie column to designate any deficiencylies that were 
place a check mark in 

specifed in tha AA' s audit findings. 
FIINGS 
AUDIT  (Check all applicable) 
Inte 
Non-compliance
GRAE 
Control  with Law or  Questioned  Other 
Weaes 
Regulations  Costs  (Identify) 
(1) 
(2) 
(3) 
(4) 
(5) 
(6) 
(7) 
(8) 
(9) 
(10) 
Financial Management - Final 
C-6  The Final SF- (fll- in Title 
269 Report shows that $  in amount prior to on-site visi) 
il funds was allocted for State Agency administrtion. What was the  actual amount expended? 
b(Indicyate a mount) 
I nee to review documentation confirming  Check as approprie:

this information. 
Documentan is  or will be mae available
provided  is unavailable

on (date) 
Don  (Check if applicable) 
t Know 
documented expenditures 
If received, review the documentaton and detennine whether the 

indicate tha more than $300, 000 percent of the Tile III allotments 
, or more than 
(whichever is greater) was lient on State Agency administraon. This may require your 
calculang the  percent figure. 
Indicate your finding: a.  More than $300, 000 or more than  percent was 
spent 
$300,  was spent 
- Don 000 or less than  5% 
t Know (Check if applicable) 
Only if the documented expenditures are more than $300  percent, ask 
000 or more than 
OthelWise, skip to queston 10. 
questn  9. 
What is the reaon(s) for the additional  (More funds could have been spent if an 
expenditures? 
percent was approved by AoA (OAA 308(b). 
aditna  75 
Not Applicable

10.  The Final SF- (fll-in amount prior to on- was 
269 Report shows that $  sie visi) 
alocted for the State ombudsman program from Title III-B resources. What was the actual 
amount expended?

by 
(Indicate amount) 
I nee to review documentation confirming this information.  Check as approprie:

or wil be made available

Documentaton is provided  is unavailable 
on (date)
Don  (Check if applicable)
t Know 

C-8  Financial Management - Final  Prir to the on-sie visi, detennine if the State Agency reported any transfers among allotments 
during the la Federa fiscal year. lf none 
were reported, go to queston  16.  lf transfers were 
reported, ask the following approprie questions (pre-marked prior to the on-sie visi), depending 
upon the type of transfer(s) which occurred. 
14.	 Prior to our visit, we reviewed fisca data to determine if any trasfers occurred among 
alotment durig the last Federal fisca yea.  (Fill-in with a, b, or 
Tbe State Agency reported 
both a and be as review indicated): 
B and Title il-
Trnsfers between Title il-
C in the amount of : 

(f-
in amount prior to on-sie visi).

Not Applicable

by 
I nee to review documentation confirming  Check as
(If applicable) 
 this information. 
approprie: Documentaton  or wil be made
is provided 	 is unavailable 

on (date) 
available 
Review the documentaton and indicate below whether or not documented transfers 
between Tile lIl-B and Tile Ill-C exceed 30 percent of either of these allotments. 
Yes 
Don t Know 
Transfers between Title il- ! and Title il- 2 in the amount of: 

(fl-in amount prir to on-sie visi).

Not Applicable

I nee to review documentation confirming  Check as
(If applicable) 
 this information. 
approprie: Documentaton  or will be made
is provided 	 is unavailable 

on (date) 
available  by 
Review the documentatn and indicate below whether or not documented transfers 
between Tile Ill- l and Tile Ill- 2 exceed 30 percent of either of these allotments. 
Yes (If YES, ask queston 15)

No (If NO, go to question 16)

Don t Know (If Don t Know, go to question 16)

Financial Management - Final  Revew and detennine whether or not the assessment instruments address the financia 
management crieri identied in the following table. Indicate your responses with an X in 
the approprie column reflecting these codes: 
Y (Yes)  Total Compliance with Crieri 
P (Partl) =  Partl Compliance with Crieri 
N (No)  Not in Compliance with Crieri 
During the desk review, if the assessment instrument and  not include 
relaed materils do 
those items necessary to make a detenninatn of compliance (Y, P, or N), mark NA (Not
Availe) in 
the Comments section of the table. 
CRIRI 
COMMNTS 
State Agency approves all AA contracts with

profitmag gratee

OAA Sec. 212

NOT APPLICABLE TO AAA 
AA admistrtive expenditures statewide do not

exce 
the 10 % limitation

OAA Sec. 304(d)(I)(A) 
There is no fuding at the 85-15 match for 
program development and coordinated activities 
until the specified percentage is expended

statewide for AA admistration

45 CFR 1321.7(f)(14)

Each AA retains rerds for 3 yrs after the date

tht the AA 
submits its fial expenditure report

or the date on which reslution of audit

exceptions, litigation, etc. occurs (whichever date

is later)

45 CFR 92.42 & 74 Subpart D 
Parcipants are given an opportty to mae

voluntary contributions

45 CFR 1321.67(a)(I) 
Limtations on trafers between congregate and

home-delivered meal allotments 
45 CFR 1321.45 
Privacy of contributions 
45 CFR 1321.67(a)(2) 
Safegurd and accounting for contributions 
45 CFR 1321.67(a)(3) 
Support services contributions are used to expand 
support service 
45 CFR 1321.67 
Financial Management - Final  aditna 
(If  space is required, use the back of the previous page) 
Financial Management - Final  apply to the most recent area plan year:
Questns  23  and  24 
23.	 How many contrcts did AAAs award to profitmakng firms? 
(Indicate number)

Don  (Check if applicable)

t Know 

None 
State Agency? 

24.	 If any contracts were made with profitmakng firms, how many firms were approved by the
(Indicate number)

Don  (Check if applicable)

t Know 
25.	 In Fisca Yea 1978, what was the tota amount of the expenditures  rural areas from Title 
in 
, Title V (multipurpose senior centers), and Title VII (nutrtion)? 
Title II Expenditures

Title V Expenditures 
Title VII Expenditures 
Don  (Check if applicable) 
t Know 
26.	 What was the tota amount of the Title II expenditures (only) in rural areas included in the 
most recnt Final SF-269 Report?

Don  (Check if applicable)
t Know 

27.	 The preselected sample of 10 Area Agencies on Aging were identified prior to the on-sie 
to be used throughout the compliance review process for all five 
visi. This sample is 
compliance review being Stewardship. 
areas, the firs 
Financial Management - Final  ... 
..'.'''.''....''...  '''.'.-'''.'.''....
I J

l; 1

J!ijJMJ 
COMMEJlS: 
ONTERVIEW COMPLETED)

Financial Management - Final  APPENDIX D
 ----------------------------------------
NUON 
SERVICES COMPLIACE REVIEW

HHS/AOA - 03/20/92

State  Date 
Prry 
Respondent  Telephone 
Review Tea Leder  Telephone 
policies, procedures, and other guidance to Area 
Prir to the on-sie visi, obtain copies of 
(AA) on nutrin 
Agencies on Aging  servces from the State Agency on Aging (State 
crieri 
Agency). Review and detennine whether or not these issuances address the 
approprie 
identified in the following table. Indicate your responses with an X in the 
column reflecting these codes: 
Crieri 
Y (Yes)  Total Compliance with 
P (Partl) =  Partl Compliance with Crieri 
N (No)  Not in Compliance with Crieri 
During the desk review, if the policy  not include those items necessary to 
materis do 
make a detenninaton of compliance (Y, P, or N), mark NA (Not Available) in the 
Comments section of the table. 
CRIERI  COMMNTS 
Congregate Meas 
I. Eligibility for 
60+ 
OAA 307(a)(13)(A) 
Handicapped (0: 60) living with 
participant 
OAA 307(a)(13)(1) 
Handicapped (0: 60) living at meal site 
OAA 307(a)(13)(A) 
Spous ( 0: 60) of participant 
OAA 307(a)(13)(A) 
Volunter ( 0: 60) worker 
OAA 307(a)(13)(1) 
2. Eligibilty for Home Delivered Meals 
60+ 
OAA 307(a)(13)(A)(B) 
Nutrition Service - Final  ."..';;(""":..,;::.;;;
CRIRIA	 COMMNTS 
Handicapped (.: 60) living with

participant

OAA 307(a)(13)(I; 45 CFR

1321.7(1)(12); AoA-PI-89-o2

Spous ( .: 60) of paricipant 
OAA 307 (a)(13)(A); 45 CFR 1321.69B 
Volunter ( .: 60) worker 
OAA 307 (a)(13)(I 
nee 
I&R for other participant 
45 CFR 1321.65(d)(t) 
Provide caed, frozen, or supplemental

meals

OAA Part C- , Section 336

Meals in weather emergency

45 CFR 1321.65(e)

USDA Cash/Commodities 
Use by Title Il-C fuded providers for 
the provision of eligible meals regardless 
of the funding source 
OAA 311(a)(I) & (2) 
Cah purchases only U.  grown foo 
OAA 311(b)(2) 
Prompt reporting to USDA 
OAA 311(c)(I)(B), 311(b)(2);

USDA Foo Distribution Regulations,

, m
Par 250.42(C)(5)(i)	
%#AA. 
#WM
Food service maagement companes	 tH?4% 
:%1
reciving donated foods have contract  :",:-.:x,, 
with the nutrition service provider	 mWi.M 
USDA Regulations, Part 250, Subpart	 fu111

B(12)(c)	 #0x:,"t.,'l'='W''::'',;,:' 

:.:"'x"' 
Ony IlC gratee get USDA

III

reimbursment 
OAA 311(a)(I)  ktR

Maita for 3 years records of cah

reived and distribute

USDA Food Distribution Regulations

Par 250.42(c)(iii)	 %WW
f.;-r::::; 
Establish proceures for the prompt 
and equitable disbursement of USDA 
cah recived 
OAA 311(b)(2) 
Nutrtion Service

Lotion of nutrition sites

OAA 307(a)(13)(D)

Nutrition Services - Final  At this point, you should have completed the in-house compliance review of the policies, 
AA 
procedures, and other guidance provied to  on nutrion services. For each crieri Ia-
Igg indicatng an entry of NO, PARTIAL, or NOT AVAIlALE list it in the firs column of 
questn  prir to the on-sie intervew. NOTE: For those items marked NA as a result of the 
desk review, Stae Agency responses may indicate convertng the NA to Y, P, N, or to NA (State 
Agency meets crieri at the State level) or NSC (State Agency does not address this applicable 
during the on-sie visi following the brief explanaton 
Federa crieri). Ask questn

initng 
the intervew. 
A few weeks ago, AoA requested copies of the policies, proceures, and other guidance provided 
to the Area Agencies on Aging concerning nutrtion services. These were reviewed against 
speific nutrtion criteria contaned in the Older Americas Act and the Title II regulations. 
Durig ths review, we identified issuances which only parally addressed specific criteria, or we 
were unable to identify issuances addressing speific criteria. For these, I nee to understad: 
How the State Agency directs and guides the AAAs to ensure that nutrition services 
requirements are met for those criteria not addressed or parially addressed. 
Criteria # with

, Paral, or

Not Available entry  A!!ency Resoonse 
D-4  Nutrition Services - Final  Review and detennine whether or not the assessment instroments address the nutrin 
semce crieri identfied in the following table. Indicate your responses  in the 
with an 
reflecting these codes: 
approprie column 
Y (Yes)  Total Compliance with Crieri 
Part 
P (Part) =  Compliance with Crieri 
N (No) =  Not in Compliance with Crieri 
During the desk review, if the assessment instroment and relaed  not include 
materils do 
those items necessary to make a detenninatn of compliance (Y, P, or N), mark NA (Not 
Available) in the Comments sectin 
of the table. 
CRIERI 
COMMNTS 
1. Eligibilty for Congregate Meals

60+

OAA 307(.)(13)(A)

Handicapped ( 0: 60) living witb

participant

OAA 307(a)(13)(I)

Handicapped ( 0: 60) living at mea site

OAA 307(.)(13)(A)

Spouse ( 0: 60) of participant

OAA 307(a)(13)(A)

Volunteer ( 0: 60) worker 
OAA 307(.)(13)(1) 
2. Eligibilty for Home Delivered Meals

60+

OAA 307(.)(13)(A)(B)

Handicappe ( 0: 60) living with 
paricipant

OAA 307(a)(13)(I; 45 CFR

1321.7(f)(12); AoA-PI-89-02

Spouse ( 0: 60) of p.rticipant

OAA 307 (a)(13)(A); 45 CFR 1321.69B

Volunteer (0:60) worker 
OAA 307 (.)(13)(1) 
nee 
I&R for other paricipant 
45 CFR 1321.65(d)(f) 
Provide caed, frozen, or supplemental

meals

OAA P.rt C- , Section 336

Meals in weather emergency

45 CFR 1321.65(e)

D-6  Nutrition Services - Final  gg. 
CRIRI	
COMMNTS 
Other nutrition service 
OAA Par C - Section 331(3) 
List other nutrition servces in State: 
Speial menus

OAA 307(a)(12)(G) 
List special menus in State: 
as.	 Assure competition in provider selection

OAA Sec. 501(b), Comprehensive Older

Americans Act Amendment of 1984;

45 CFR Part 92, 36(8) "Procurement"

bb.  Voluntary Contrbutions

Collect and safegurd cah

OAA 307(a)(13)(C)(i) 
ce.	 Collection of food stamps 
45 CFR 1321.65(c) 
dd.	 Confidentiality 
45 CFR 1321.67(a)(2) 
00.	 6. Health and Safety

State and local licensing requirements

45 CFR 1321.5 
ff.	 Health department inspections

45 CFR 1321.75

Fire department inspections

45 CFR 1321.75

For each crieri 4a-4gg indicatng an entry of NO, PARTIAL, or NOT AVAILABLE
, list it in 
prior to the on-sie interview. NOTE: For those items marked 
the firs column of queston 

NA as a result of the desk review, State Agency responses may indicate convertng the NA to Y 
, N, or to NA (State Agency meets crieri at the State level) or NSC (State Agency does not 
address this applicable Federal crieri). Ask queston  during the on-site visit. 
A few weeks ago, AoA also requested a copy of the assessment instrument and any applicable 
tools used by the State Agency to assess compliance and performance of AAAs with nutrition 
service law and regulations. These were reviewed against specific nutrition service criteria 
contaned in the Older Americans Act and the Title II regulations. During this review, we 
identified issuances which only parially addressed specific criteria, or we were unable to identify 
, I nee to understad: 
issuances addressing specific criteria. For these
Nutrition Services - Final  aditna 
(If  space is required, use the back of the previous page) 
What criteria, not required by Federa law or regulation , has the State Agency included in' 
its assessment instrment for nutrtion programs? 
- Don
(Check if applicable) 
t Know

How oftn doe the State Agency assess the Title II-funded nutrition programs? 
Annually 
Every 6 months

Every quarer 
Monthly 
(Define) 
Other 
What are the sta and end dates for the last completed cycle of on-site assessments? 
a. Sta date 

b. End date 

Nutrition Services - Fina  11.  Whch of the following activities does the State Agency use to monitor the Title Il-funded 
(Read the following list and check responses. 
nutrtion programs? 

Review of report (USDA, Progra Performance, or other State reports 
regarding the planned number of meas to be served contrasted with the 
number of meas actuly served). 
Commodity withdrawals

USDA cash disbursements

(Explan): 
Other 
- Don
(Check if applicable) 
t Know

12.  What are the most common deficiencies in the nutrition program in this State? 
Don  (Check if applicable) 
t Know

13.  What technica assistace or trning has the State provided to address these deficiencies? 
- Don
(Check if applicable)
t Know 

Nutrition Services - Final  16.  What factors does the State use in determining the cost of meas: 
FACTORS 
CONGREGATE MEALS  HOME DELIVERED MEALS 
Uses unit cost per mea 
(Circle if applicable) 
Don t Know

(Circle if applicable)

17.  Of the following, which USDA option did the State choose? 
Cash

Commodities

Cash and Commodities 
Don  (Check if applicable)
t Know 

18.  Why was this option chosen? 
Don  (Check if applicable)
t Know 

Nutrition Services - Final
 !il.ii

Criteria 
Final 
Nutrition  Service - y'g. g. 
amJ. ijprfIf  w&1.1%M 
:-:,:v;.w,.,.;:X,'.-m:'"
1m1myg 
COMMS: 
(INTERVIEW COMPLETED) 
Final
Nutrition  Services - gg. 
Ony mc grate get USDA reimbursment 
OAA 311(a)(1) 
Maita for 3 yea recrd of cah reived and distributed 
USDA foo distribution regulations, Part 250.42(c)(iii) 
Establish proceure for the prompt and equitable disbursement of USDA cash recived 
OAA 311(b)(2) 
4. Nutrtion Serice 
Lotion of nutrition sites 
OAA 307(a)(13)(D) 
Outreh to eligible individuas 
OAA 307(a)(l3)(E) 
Eah meal provides a mimum of 1/3 RDA 
OAA Par C - Section 331(1) 
Provide at leat one meal, 5 or more days per week 
OAA Part C - Section 331(1) 
Nutrition education services 
OAA Part C - Section 331(3) 
Other nutrition service 
OAA Par C - Section 331(3) 
Speiat menus 
OAA 307(a)(12)(G) 
aa.  Assure competition in provider selection 
OAA Sec. 501(b), Comprehensive Older Americas Act Amendments of 1984; 
45 CFR Par 92, 36(8) "Procurement 
bb.  5. Volunta Contrbutions 
Collect and safegu cah 
OAA 307(a)(13)(C)(i) 
foo staps 
ce.  Collection of 
45 CFR 132\.65(c) 
dd.  Confdentiality 
45 CFR 132\.67(a)(2) 
ee.  6. Heath and Safety 
State and tocalicensing requirements 
45 CFR 132\. 75 
ff.  Heath department inpetions 
45 CFR 1321.75 
Fire departent intions 
45 CFR 1321.75 
Nutrition Services - Final  APPENDIX E
 --------
------------------
OMBUDSMA COMPLIACE REVIEW

HHS/AOA - 03/20/92

State  Date 
Ombudsn 
Telephone 
Review Tea Leder  Telephone 
(Al citations refer to the Older Americans Act) 
Is the Office of the Long-Term Care Ombudsman located in the State Agency on Aging? 
(Hereafer the State Agency on Aging wil be referred to as the State Agency) 
(If Yes, go to question 2) 
Yes 
(If No): 
No 
(1)  Where is it locted? 
(2)  Is there a contrct between this agency and the State Agency? 
(a) 
Yes (If Yes, get copy) 
(b) 
(c)  Don  (Check if applicable) 
t Know

Is the agency that sponsors (houses) the Ombudsman responsible for licensing long-term 
cae (LTC) facilities or an association affiliated with LTC facilties? 
a. 
Yes (If Yes, discuss): 
Ombudsan - Final  Is there a State law governing the Ombudsman Program? 
Yes  (q Yes, get copy) 
Don  (Check if applicable)
t Know 

Does the Office of the Long-Term Care Ombudsman utilize sub-State ombudsmen? 
(q Yes, go to questn 5)

Yes 
(q No, go to queston 7)

No 
Describe the organizational relationship between the sub-State ombudsmen and the State 
Office of the Ombudsman. 
Are there any reportng or operations problems with sub- (Probe both) 
State ombudsman? 
Ombudsan - Final  10.	 (number provied in  9), how many professional and support staff are: 
Of that tota  questn 
(Complete queston using a, b, and c) 
PROFESSIONAL  SUPORT  DON' T KNOW 
(Indcate Number)  (Indcate Number)  (Check if Applicale) 
Ful-time employees? 
Par-time employees? 
Volunteers? 
11.	 What procures are in place to assure that Ombudsman employees and volunteers are 
qualfied and trained prior to investigating 
complaints? (Sec. 307(a)(12)(K))  (Probe for 
standrds for both employees and volunteers) 
12.	 Does the Ombudsman program formally certfy volunteers? 
, go to questn 13) 
Yes  (If Yes
(If No, go to queston 14) 
No 
13.	 What are the requirements for certfication? 
E-4	 Ombudsman - Final  Lo laws, regulations, and policies regarding LTC 
facilities  When was the last time traning was
(If No): 

conducted? 
Investigative techniques  When was the last
(If No): 

time trning was conducted?

17.	 Is there a formal (written) in-service trning currculum for employees? 
Yes  (If Yes, get copy) 
18.	 What are examples of the tys of  (Complete queston 
training provided in the last year to: 
using a, h, and c) 
a. paid full-
time staff 
b. paid par-time staff

c. volunters?

19.	 How do you coordinate activities with the protection and advocacy systems for individuals 
with developmenta disabilities and menta ilness?  (Get examples) 
(Sec. 307(a)(l2)(H)(v)) 
E-6	 Ombudsman - Final  23.  How do you encourage the parcipation by citizen organizations in the Ombudsman
progra? 
(307(A)(12)(A)(ii)) 
24.	 How does the State Agency identify and resolve any potential conflicts of interest affecting 
the Ombudsman, or any employee or representative of the Offce of the Ombudsman? 
(Sec. 307(a)(12)(F)(i),(ii),(iii)) 
25.	 How does the State ensure that no representative of the Office of the Ombudsman wil be 
held liable for the performance of offcial duties? (Sec. 307(a)(12)(I)) 
E-8	 Ombudsman - Final  29.	 Have any sactions ever been applied to any individual or entity? 
Yes  (If Yes): 
Describe the circumstaces , and the results of the saction. 
, the saction applied
CIRCUMSTANCES  SANCTION  RESULTS OF 
APPLIED  SANCTION 
(1) 
(2) 
(3) 
(4) 
(If additonal space is required, use the back of the previous page) 
30.	 How do you ensure residents of LTC facilities, throughout the State, are made aware of the 
Office of the Ombudsman? 
Ombudsman - Final  36.  Do you prioriti complaints? 
Yes  (If Yes),  How are complaints prioritized?  (Probe for process, definitons 
used, etc. 
37.  How do you ensure your staffs access to LTC facilities, residents, and residents' records? 
(Sec. 307(a)(12)(B), (K)) 
Ombudsman - Final  40.	 How do you ensure that the identity of any complainant or resident of a facility wil not be 
disclosed? (Sec. 307(a)(12)(D)) 
41.	 Has your Offce had to identify the complainant or resident of a facility without his or her 
permssion? 
a. 	
Please discuss the circumstaces and under what grounds the
Yes (If Yes), 

Offce disclosed this information. 
42.	 How is legal counsel made avaiable to the Offce of the Ombudsman? 
Ombudsman - Final  46.	 What was the date of your last annual report?(Sec. 307(a)(12)(H)) 
(Te "annua report" pertains to Ombudsman report as per Sec. 307(1)(12)(H) 
47.	 Were' policy, regulatory, and legislative recommendations made in this report? 
Yes 
48.	 Was the annual report submitted to the State agency responsible for licensing or certifying 
LTC facilties? 
Yes 
49.	 Was it submitted to the State legislature? 
Yes 
50.	 In genera, who else routinely receives the report? 
Ombudsman - Finat  ATTACHMT A

OMBUDSMA COMPLIACE CRITERIA 
307(a)(12)(A)  Full time ombudsan 
307(a)(12)(A)ii  Promote citizen organiztion participation 
307(a)(12)(B)  Protect confdentiality of records and fies 
307 (a)(12)( C)  Unionn reporting system 
307(a)(12)(D)  Non disclosure of identity of complainant 
307 (a)(12) (E)  Solicit views of AAAs, providers, & elderly 
307(a)(12)(F  Conflct of interes 
307(a)(12)(G)ii  Abilty to pursue remedies 
307(a)(12)(1)  Representatives not held liable 
Prohibit retaliation 
307(a) (12)(J)ii 
307(a)(12)(J)il  Provide sanction authority 
307(a)(12)OO  Invesigative training 
Ombudsman - Fina