Department of Health and Human Services

OFFICE OF 

INSPECTOR GENERAL 

C S O
OST  HARING FOR  LDER 

A A S
MERICANS  CT  ERVICES

Daniel R. Levinson

Inspector General 

September 2006

OEI-02-04-00290
 Office of Inspector General 

http://oig.hhs.gov 
The mission of the Office of Inspector General (OIG), as mandated by Public Law 95-452, 
as amended, is to protect the integrity of the Department of Health and Human Services 
(HHS) programs, as well as the health and welfare of beneficiaries served by those 
programs.  This statutory mission is carried out through a nationwide network of audits, 
investigations, and inspections conducted by the following operating components: 
Office of Audit Services 
The Office of Audit Services (OAS) provides all auditing services for HHS, either by 
conducting audits with its own audit resources or by overseeing audit work done by 
others.  Audits examine the performance of HHS programs and/or its grantees and 
contractors in carrying out their respective responsibilities and are intended to provide 
independent assessments of HHS programs and operations.  These assessments help 
reduce waste, abuse, and mismanagement and promote economy and efficiency 
throughout HHS. 
Office of Evaluation and Inspections 
The Office of Evaluation and Inspections (OEI) conducts national evaluations to provide 
HHS Congress, and the public with timely, useful, and reliable information on 
significant issues.  Specifically, these evaluations focus on preventing fraud, waste, or 
abuse and promoting economy, efficiency, and effectiveness in departmental programs.  
To promote impact, the reports also present practical recommendations for improving 
program operations. 
Office of Investigations 
The Office of Investigations (OI) conducts criminal, civil, and administrative 
investigations of allegations of wrongdoing in HHS programs or to HHS beneficiaries 
and of unjust enrichment by providers.  The investigative efforts of OI lead to criminal 
convictions, administrative sanctions, or civil monetary penalties. 
Office of Counsel to the Inspector General 
The Office of Counsel to the Inspector General (OCIG) provides general legal services to 
OIG rendering advice and opinions on HHS programs and operations and providing all 
legal support in OIG' s internal operations. OCIG imposes program exclusions and civil 
monetary penalties on health care providers and litigates those actions within HHS. 
OCIG also represents OIG in the global settlement of cases arising under the Civil False 
Claims Act, develops and monitors corporate integrity agreements, develops compliance 
program guidance, renders advisory opinions on OIG sanctions to the health care 
community, and issues fraud alerts and other industry guidance.    E X E C U T I V E   S U M M A R Y  

OBJECTIVES 
To assess the extent to which States have implemented cost sharing 
under the Older Americans Act (OAA). 
To determine whether States implementing cost sharing under the OAA 
do so in accordance with requirements designed to protect low-income 
individuals access to services.  
BACKGROUND 
The Administration on Aging (AoA) has asked the Office of Inspector 
General to assess States implementation of cost sharing.  In 2000, 
amendments to the OAA allowed States to implement cost sharing for 
certain OAA services.  Cost sharing provides a mechanism for States to 
expand services to a growing number of Americans 60 years of age and 
older.  However, there is a general concern that cost sharing could 
negatively impact participation of certain individuals, particularly those 
with low incomes.  This study is intended to provide relevant 
information to AoA and to Congress as they consider any changes to cost 
sharing during the current reauthorization of the OAA.   
The OAA was enacted in 1965 and authorized a range of social service 
and nutrition programs.  It also created AoA, which carries out its 
responsibilities by coordinating with State Units on Aging (State Units), 
Area Agencies on Aging (area agencies), tribal organizations, and local 
service providers. AoA distributes funds to States through Title III, 
Grants for State and Community Programs on Aging.  Title III-B funds 
supportive services, Title III-C funds nutrition services, Title III-D 
funds disease prevention services, and Title III-E funds the National 
Family Caregiver Support Program. 
The amendments to the OAA include a number of requirements for 
States that choose to implement cost sharing.  These requirements are 
intended to ensure that low-income older individuals can obtain 
services.  Pursuant to the OAA, States and area agencies must develop 
cost-sharing plans.  The OAA further provides that States require area 
agencies and local service providers to exclude individuals with incomes 
at or below the Federal poverty line from cost sharing; not deny services 
to individuals who do not pay; account for payments; and inform 
recipients about cost sharing.  Also, States must establish sliding scales 
for cost sharing based on income.  Additionally, AoA must determine the 
impact of cost sharing on participation rates.  
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  i  E X E C U T I V E   S U M M A R Y  
This study looks at the extent to which States have implemented cost 
sharing and whether they have implemented it in accordance with 
statute requirements. We based this study on data gathered from 
multiple sources:  a written survey completed by State Unit 
representatives from all 50 States, Puerto Rico, and the District of 
Columbia; a review of relevant State documents regarding cost sharing 
implementation, program revenue, and participation; structured 
interviews with State Unit representatives, area agency officials, and 
State data officials; and a review of AoAs National Aging Program 
Information System/State Program Reports (NAPIS/SPR) and 
individual State data.  AoA collects participation data for many of the 
OAA services through the NAPIS/SPR.  AoA uses the NAPIS/SPR data 
to plan and manage activities performed and services provided under 
the OAA. 
FINDINGS 
States implementation of cost sharing for OAA services is limited. 
Twelve States have implemented cost sharing for at least one OAA 
service.  None of these States has implemented cost sharing for all OAA 
services for which cost sharing is allowed.  Further, in at least 6 of the 
12 States, fewer than 350 individuals participate in cost sharing in each 
of these States. 
The States that have implemented cost sharing do not always follow 
OAA requirements for cost sharing that are designed to protect low-
income individuals access to services.  The States that have 
implemented cost sharing do not always follow key OAA requirements. 
Nine States have not developed cost-sharing plans to ensure that the 
participation of low-income individuals receiving services will not 
decrease with the implementation of cost sharing.  Five States permit 
individuals with incomes at or below the Federal poverty line to cost 
share.  Six States either deny services to individuals who do not pay or 
make cost sharing appear mandatory.  Three States have not 
established sliding scales as required by the OAA.  Six States do not 
have policies for accounting for cost-share payments.  Finally, none of 
the States has created the required written materials that explain cost 
sharing to recipients. 
AoA has provided limited guidance to States and State officials are 
often confused about features of cost sharing under the OAA.  AoA 
has provided limited guidance to States on implementing cost sharing in 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  ii  E X E C U T I V E   S U M M A R Y  
accordance with the OAA.  AoA conducted an initial training session for 
its regional offices.  However, the training did not cover key 
requirements such as the plans States are required to develop and the 
written materials that explain cost sharing that States must create.  In 
addition, we found that AoA officials have limited information about 
how States are implementing cost sharing.  For instance, they have 
little knowledge about States plans regarding cost sharing, their sliding 
scales, accounting for cost-share payments, or informing recipients 
about cost sharing. Finally, we found that officials from States and area 
agencies often are confused about cost sharing for OAA services. 
AoAs participation data cannot be used to determine the impact of 
cost sharing on participation rates. AoA is required to conduct an 
annual evaluation of cost sharing to determine its impact on the 
participation rates of individuals targeted by the OAA. AoA collects 
participation data for many OAA services through the NAPIS/SPR. We 
found that States report data in the NAPIS/SPR differently and that the 
demographic data in the NAPIS/SPR are incomplete.  As a result, data 
in the NAPIS/SPR do not present a complete picture of participation 
and, therefore, cannot be used to measure any impact cost sharing 
might have on overall participation or on participation of low-income 
individuals and other subgroups specified in the OAA.  
RECOMMENDATIONS 
Based on these findings, we recommend that AoA: 
Ensure that States cost-sharing practices comply with requirements 
designed to protect low-income individuals access to services.  AoA 
should address State and area agency practices that permit low-income 
individuals to participate in cost sharing.  AoA should also address 
State and area agency practices that deny services to older individuals 
due to income or failure to make a cost-share payment, as well as 
practices that make cost sharing appear mandatory.  In addition, AoA 
should address the States lack of cost-sharing plans, sliding fee scales, 
policies for accounting for payments, and written material that explain 
cost-sharing.   
Provide additional guidance to States about implementing cost 
sharing in accordance with the OAA. AoA should provide additional 
guidance to States regarding how to implement cost sharing in 
accordance with OAA requirements.  The guidance should address 
issues such as (1) developing plans to ensure that the participation of 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  iii  E X E C U T I V E   S U M M A R Y  
low-income individuals will not decrease with the implementation of cost 
sharing; (2) excluding low-income individuals from cost sharing;             
(3) prohibiting the denial of services; (4) establishing sliding scales;         
(5) developing procedures to account for cost-sharing payments; and      
(6) preparing written materials to inform recipients about cost sharing.  
AoA should also develop additional strategies to keep States informed 
about these issues.  
Improve the quality of the NAPIS/SPR data so that any effects of 
cost sharing can be measured. AoA should improve the quality of its 
data to measure any future impacts cost sharing may have on 
participation rates, as required by the OAA.  During the course of this 
study, AoA has addressed some of the data problems.  Specifically, the 
NAPIS/SPR now retains records with missing data elements; the 
NAPIS/SPR now collects some demographic data for recipients of Title 
III-E services; and AoA is no longer required to approve waivers to 
States. However, AoA has not addressed the differences in State 
reporting. 
When addressing these differences, AoA needs to give clear and 
consistent instructions to States and consider whether to continue 
directing States to report information for all services, including those 
funded solely by State or local entities.  If the NAPIS/SPR includes data 
about non-OAA-funded services, then AoA needs to consider how it will 
determine any effects of cost sharing on participation in OAA programs 
and services, as required by the OAA.   
In addition, the inconsistency of AoAs participation data has 
implications beyond cost sharing.  This study focuses only on cost 
sharing, but the differences in data reporting raise questions regarding 
how AoA can use the data to effectively plan and manage activities 
funded under the OAA. This broader issue affects AoAs capacity to 
manage all aspects of these services, not only cost sharing. 
AGENCY COMMENTS  
AoA provided comments on the draft report.  In general, AoA agrees 
with our findings that cost sharing is limited and that States are 
confused about cost sharing.  AoA states that it has taken many steps to 
educate the Aging Network on cost sharing and does not agree with our 
finding that it has provided limited guidance to States.  AoA also states 
that our observations about NAPIS/SPR are outside the scope of the 
study and that it has made several improvements to NAPIS/SPR over 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  iv  E X E C U T I V E   S U M M A R Y  
the last 5 years. In response to our recommendations, AoA notes that it 
will follow up on our observations and correct instances of 
noncompliance with the provisions of the OAA.  AoA also plans to 
provide additional guidance to States on an ongoing basis and post more 
information on its Web site. 
OFFICE OF INSPECTOR GENERAL RESPONSE 
Where appropriate, we have made changes to the report based on AoAs 
comments.  
Because the OAA requires AoA to determine the impact of cost sharing 
on participation rates, and NAPIS/SPR is the only data AoA has on 
participation, we believe that it is necessary to include NAPIS/SPR in 
any discussion about whether cost sharing has had an impact on 
participation rates. 
We recognize that AoA has made several improvements to NAPIS/SPR 
over the last 5 years, many of which are noted in the report. However, 
despite these improvements, we found that the States that cost share 
report participation data in the NAPIS/SPR differently and include 
different populations in their counts.  This issue is important because it 
has potential implications beyond cost sharing.  These data provide 
essential information for AoA, including performance outcome 
information required by the Government Performance and Results Act 
and the Performance Assessment Rating Tool.  
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  v    T A B L E   O F   C O N T E N T S  

EXECUTIVE SUMMARY . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . i

I N T RO DUC T IO N  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  1

F I N D IN G S  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  8

States implementationof cost sharing limited . . . . . . . . . . . . . . . .  8

States do not always follow key OAA requirements  . . . . . . . . . . .  10

AoA has provided limited guidance to States  . . . . . . . . . . . . . . . .  13

AoAs data cannot be used to determine impact  . . . . . . . . . . . . . .  15

R E C O MMEN D A T ION S  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  18

  AgencyComments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  19

Office of Inspector General Response. . . . . . . . . . . . . . . . . . . . . . .  19

APPENDIXES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  21

  AgencyComments. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  21

A C K NO WL E D G M E N T S  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  42
   I N T R O D U C T I O N  

OBJECTIVES 
To assess the extent to which States have implemented cost sharing 
under the Older Americans Act (OAA). 
To determine whether States implementing cost sharing under the OAA 
do so in accordance with requirements designed to protect low-income 
individuals access to services. 
BACKGROUND 
The Administration on Aging (AoA) has asked the Office of Inspector 
General (OIG) to assess States implementation of cost sharing.  The 
year 2000 amendments to the OAA allowed States to implement cost 
sharing for certain OAA services.  AoA defines cost sharing as a method 
of allowing a recipient to share in the cost of the service received.  Cost 
sharing provides a mechanism for States to expand services to a 
growing number of Americans 60 years of age and older.  However, 
there is general concern that cost sharing could negatively impact 
participation of certain individuals, particularly those with low 
incomes. 
This study looks at the extent to which States have implemented cost 
sharing and whether they have implemented it in accordance with the 
OAA. It is intended to provide relevant information to AoA and to 
Congress as they consider any changes to cost sharing during the 
current reauthorization of the OAA. 
The Older Americans Act 
The OAA was enacted in 1965 to improve the quality of life for older 
individuals.  It created AoA and authorized a range of social service and 
nutrition programs. AoA distributes funds to States through Title III, 
Grants for State and Community Programs on Aging.  The funds under 
Title III are divided as follows:   
o	 Part B funds supportive services, such as transportation, personal 
care, homemaker, chore, adult day care, and legal assistance.   
o	 Part C funds nutrition services, such as congregate and home-
delivered meals and nutrition education. 
o	 Part D funds disease prevention and health promotion services. 
o	 Part E funds the National Family Caregiver Support Program, 
which was created in 2000 to provide services to family caregivers. 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  1  I N T R O D U C T I O N  
These services include respite care to temporarily relieve caregivers 
from their responsibilities, as well as supplemental services which 
complement the care provided by caregivers and include such 
services as home modifications, emergency response systems, and 
transportation. 
States allotments are based on the number of residents 60 years and 
older.  All older individuals are eligible to receive OAA services, but 
States must assure that preference is given to those in greatest 
economic or social need, particularly minority older individuals and 
older individuals residing in rural areas. 
The Administration on Aging 
AoA administers the grants under the OAA.  AoA carries out its 
responsibilities by coordinating with State Units on Aging (State Units), 
Area Agencies on Aging (area agencies), tribal organizations, and local 
service providers. AoA is required under the OAA to provide technical 
assistance and consultation to States with respect to programs for older 
individuals.1  In 2004, AoAs budget was $1.37 billion.  AoA has    
10 regional offices that assist States in serving the older population.   
Each State and U.S. Territory has a State Unit. It is primarily 
responsible for the planning, policy development, administration, 
coordination, priority setting, and evaluation of all State activities 
related to the objectives of this Act.2  Most State Units divide the State 
into planning and service areas and designate a public or private 
nonprofit agency or organization as the area agency for each area.  
These agencies develop and implement area plans for their respective 
planning and service area.  Some smaller States, such as Delaware and 
Rhode Island, are not divided into planning and service areas and do 
not have area agencies. 
Cost Sharing Amendments to the Older Americans Act 
Amendments to the OAA in 2000 allow States to cost share for certain 
services under Title III.  Prior to 2000, States were not allowed to 
charge fees to individuals using services funded by the OAA.3  However, 
States were allowed to solicit and collect voluntary contributions from 
recipients of OAA services. 
1 42 U.S.C.  3012(a)(6). 

2 42 U.S.C.  3025(a)(1)(c).

3 States were allowed to charge fees to recipients of State or locally funded services. 

  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  2  I N T R O D U C T I O N  
As stated in the year 2000 amendments, States are allowed to 
implement cost sharing for all services except for those explicitly 
excluded.4  Services that States are allowed to cost share include, but 
are not limited to, Part B personal care, homemaker, chore, adult day 
care, assisted transportation, and transportation; Part D disease 
prevention and health promotion; and Part E respite and supplemental 
services.  
Requirements for States that Cost Share  
The OAA places a number of requirements on States that choose to 
implement cost sharing.5 These requirements are intended to ensure 
that cost sharing does not discourage low-income older individuals from 
obtaining services.  Key components of these requirements are listed 
below. 
Development of plans.  The OAA requires States and area agencies to 
develop plans before implementing cost sharing.  These plans should be 
designed to ensure that the implementation of cost sharing will not 
decrease the participation of low-income older individuals (with 
particular attention to low-income minority individuals and older 
individuals residing in rural areas) receiving OAA services. 
Exclusion of low-income older individuals. States may not permit cost 
sharing by individuals with incomes at or below the Federal poverty 
line. 
No denial of services. States must require that area agencies and local 
service providers not deny services to an older individual due to the 
individuals income or the individuals failure to make a cost-share 
payment. 
Sliding scales.  States are required to establish a sliding scale based 
solely on individual income and the cost of delivering services. States 
cannot consider any assets, savings, or other property owned by older 
individuals when creating their sliding scales.  
Accounting and use of cost-share payments. States must ensure that area 
agencies and service providers establish appropriate procedures to 
safeguard and account for cost-share payments.  States also must 
4 	 The year 2000 amendments specifically state that certain services, such as information 
and assistance, outreach, elder abuse prevention, and meals, are excluded from cost 
sharing. 
5 42 U.S.C.  3030c-2. 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  3  I N T R O D U C T I O N  
require area agencies and service providers to use collected cost-share 
payments to expand the service for which the payments were given. 
Informing recipients. States must create written materials that explain 
the criteria for cost sharing, the sliding scale, and the stipulation that 
services cannot be denied to an older individual due to income or failure 
to make a cost-share payment.  States must require the area agencies 
and service providers to widely distribute the written materials.  
The area agencies in States that implement cost sharing may request a 
waiver to the States cost sharing policies when a significant proportion 
of individuals receiving services in the area have incomes below the 
threshold established by the State or when cost sharing poses an 
unreasonable administrative or financial burden on the area agency.  
The OAA also requires AoA to conduct a comprehensive evaluation of 
cost sharing to determine its impact on participation rates.  This 
evaluation should be conducted no later than 1 year after the 
enactments of the year 2000 amendments to the OAA and annually 
thereafter. AoA must take corrective action if it finds cost sharing has 
had a disparate impact upon low-income or minority older individuals or 
older individuals residing in rural areas.6 
National Aging Program Information System and State Performance Reports 
AoA collects participation data for many OAA services through the 
National Aging Program Information System/State Performance 
Reports (NAPIS/SPR). The NAPIS/SPR contains overall participation 
and demographic data for certain Title III-B services such as personal 
care, homemaker, chore, adult day care, and assisted transportation 
services.  For services under Title III-E, the National Family Caregiver 
Support Program, the NAPIS/SPR includes participation data but not 
demographic data.  The NAPIS/SPR does not contain any data on the 
number of people participating in cost sharing for any of these services. 
AoA uses the NAPIS/SPR data to plan and manage activities performed 
and services provided under the OAA. 
The State Units gather data from their area agencies and then submit 
the data to AoA.  Some States and area agencies collect additional 
information on participation not required for the NAPIS/SPR.  For 
example, an area agency may collect demographic data on recipients of 
6 42 U.S.C.  3030c-2(d). 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  4  I N T R O D U C T I O N  
caregiver support services.  AoA conducts a number of checks on the 
data that States submit to the NAPIS/SPR.  
Prior Studies 
OIG conducted two studies about cost sharing for AoA prior to the year 
2000 amendments to the OAA. The first report in October 1990, Cost 
Sharing for Older Americans (OEI-02-90-01010), assessed States 
experiences with State programs for older individuals that provided 
services on a cost-sharing basis.  It found that recipients responded 
positively to cost sharing, cost sharing was seen as effective and 
efficient, and extending cost sharing to Title III had strong support. 
The second report in May 1996, Cost Sharing Under the Older 
Americans Act (OEI-05-95-00170), described States practices of cost 
sharing for State services and discussed potential implementation 
issues for the expansion of cost sharing to OAA services.  This study 
found that 36 States reported having some kind of cost-share program 
for at least 1 State-funded service for older individuals.  States varied 
greatly in terms of which services they cost shared, and how 
responsibilities were distributed among the State Units, area agencies, 
and service providers.  The study also stated that AoA needed to pay 
special attention to fee schedules, income declaration and verification, 
billing and collection activities, and policies on payment default before 
cost sharing is implemented. 
METHODOLOGY 
We based this study on data gathered from multiple sources:  a written 
survey completed by State representatives from all 50 States, Puerto 
Rico, and the District of Columbia; a review of relevant State documents 
regarding cost-sharing implementation, program revenue, and 
participation; a review of the NAPIS/SPR and individual State data; 
and structured interviews with State Unit representatives, area agency 
officials, and State data officials.  For the purposes of this report, we 
refer to the District of Columbia and Puerto Rico as States. 
Scope 
This study focuses on States implementation of cost sharing for OAA-
funded services.  This study does not include States experiences in 
implementing voluntary contributions for OAA services or their 
experiences in implementing cost sharing for State-funded services. 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  5  I N T R O D U C T I O N  
This study addresses Part B and Part E and does not address Part D.  
Initial research indicated that cost sharing for Part D was rarely, if 
ever, used.  Part C services are excluded from cost sharing. 
Written State Survey 
We conducted a written survey of State Unit representatives from all   
50 States, Puerto Rico, and the District of Columbia to identify the 
States that have implemented cost sharing for services funded by the 
OAA. We received responses from all.  As discussed below, we reviewed 
documentation from each State reporting cost sharing to verify their 
responses. 
Document Review 
We reviewed all cost-sharing plans, policies, and procedures for the 
States that have implemented cost sharing.  We identified the services 
that are cost shared.  We also determined how each State has 
implemented cost sharing and has addressed the requirements for 
States that choose to cost share.  We focused our review on how States 
determine eligibility; establish sliding scales; collect, account for, and 
use payments; and inform recipients.  We also reviewed relevant 
financial and service reports from States and area agencies, when 
available, and any written materials States and area agencies use to 
explain cost sharing to recipients.  Finally, we reviewed training 
materials produced by AoA and information from AoAs Web site. 
NAPIS/SPR and State Data 
We analyzed all available participation data from the NAPIS/SPR for 
each of the cost-sharing States.  As noted earlier, the NAPIS/SPR 
contains statewide participation data for OAA services.  It does not 
contain the number of individuals participating in cost sharing.  We also 
collected and analyzed all available participation data for cost-shared 
services from each of the States, including available area agency data. 
Structured Interviews with State and Area Agency Officials 
We conducted structured interviews with officials from the State Units 
in each of the cost-sharing States.  We focused our discussions on the 
services that are cost shared and how the State and area agencies have 
implemented cost sharing for these services. We paid particular 
attention to how each State has addressed the requirements regarding 
eligibility, sliding scales, accounting for payments, and informing 
recipients about cost sharing.  We also discussed any guidance the State 
has provided to its area agencies.  We conducted 12 interviews from 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  6  I N T R O D U C T I O N  
February to March 2005.  In this study, we refer to the State Unit 
representatives we interviewed as State officials. 
We also conducted structured interviews with area agency officials from 
a purposive sample of area agencies in the States that have 
implemented cost sharing.  We interviewed officials from all cost-
sharing area agencies in States that had three or fewer cost-sharing 
area agencies.  We interviewed officials from three selected cost-sharing 
area agencies in States that had more than three cost-sharing agencies. 
We selected the area agencies based on States estimates of the number 
of people participating in cost sharing.  Specifically, we selected one 
area agency with high participation, one in the middle, and one with low 
participation.  The interviews focused on the area agencies experiences 
with implementing cost sharing for OAA services.  In total, we 
interviewed officials from 21 area agencies.  We conducted these 
interviews from March to May 2005. 
We also conducted structured interviews with data officials from all cost 
sharing States to determine what types of data States report to the 
NAPIS/SPR. These interviews were conducted from May to June 2005.  
Standards  
Our review was conducted in accordance with the Quality Standards 
for Inspections issued by the Presidents Council on Integrity and 
Efficiency and the Executive Council on Integrity and Efficiency.  
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  7    F I N D I N G S

States implementation of cost sharing for OAA  Twelve States have implemented cost 
services is limited  sharing 
Twelve States have implemented 
cost sharing for at least one OAA service in at least one part of their 
State. These 12 States are Alabama, Arizona, Arkansas, Delaware, 
District of Columbia, Michigan, Minnesota, Montana, Ohio, Puerto Rico, 
Rhode Island, and Virginia.  The 12 States receive approximately   
$97.5 million through Title III-B and Title III-E, which is about  
19 percent of Title III-B and Title III-E total grant dollars.7 
Half of these 12 States have implemented cost sharing in all or nearly 
all areas of their State.8  Two other States have implemented it in only 
one area agency in their State, while the remaining four States have 
implemented it in about half of their area agencies. 
None of the 12 States has implemented cost sharing for all allowed OAA 
services 
None of the 12 States has implemented cost sharing for all OAA services 
for which cost sharing is allowed.  Eight of the twelve States each cost 
share for one or two different OAA services.  The other 4 States each 
cost share for between 6 and 11 different services.   
States most commonly cost share for respite services, homemaker 
services, or supplemental services.  Table 1 lists the Title III-B and Title 
III-E services that are cost shared, as well as the number of States and 
area agencies cost sharing for them.  Nine States cost share for respite 
services, which offer temporary relief for caregivers.  Five States cost 
share for homemaker services and five States cost share for 
supplemental services, which complement the care provided by 
caregivers. Multiple States and area agencies also cost share for adult 
day care, chore, personal care, and transportation. 
7  Calculations used fiscal year 2004 Final Allocation for Title III  Grants for State and 
Community Programs on Aging. 
8  Note that 3 of the 12 States do not have area agencies.  These States are the District of 
Columbia, Delaware, and Rhode Island. 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  8  F I N D I N G S  

Cost-Shared  Table 1: Cost-Shared Services Funded by Titles III-B and III-E 
Services Funded by 
Titles III-B and III-E Number of States that  Number of Area Agencies 
Service  Cost Share for Service  that Cost Share for Service 
Title III-B  Homemaker  5*  31 
Adult Day Care  5*  19 
Chore  5  16 
  Personal Care  3  27 
  Transportation  3  13 
  Home Maintenance/Repair  3  14 
  Medical Assessment  1  8 
  Care/Medication Management  1  3 
  Assisted Transportation  1  5 
  Visiting  1  1 
Socialization/Recreation  1  1 
  Respite III-B  1  1 
Title III-E  Respite III-E  9**  50 
  Supplemental Services  5*  23 
Counseling  3  3 
Adult Day Care  1  4 
  Safety Services  1  2 
  Transportation  1  2 
  Assisted Transportation  1  1 
* Includes one State that does not have area agencies. 
 ** Includes two States that do not have area agencies. 
Source:  Office of Inspector General analysis of State and area agency documents and interviews, 2005. 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  9  F I N D I N G S  
Six of the twelve States report limited participation in cost sharing  
The number of people participating in cost sharing is limited in at least 
six States. Officials from 3 States each estimate having 55 or fewer 
individuals who participate in cost sharing, and officials from 2 more 
States each estimate having about 350 individuals who participate in 
cost sharing.9  An official from a sixth State could not give an estimate 
for the number of individuals cost sharing statewide, but AoA data 
indicate that it could not be high.  This State cost shares for only  
1 service and the total participation for that service is about 
130 individuals.   
The other six States likely have higher numbers of individuals cost 
sharing. These States are larger and cost share for more services in 
more areas of their States.  An official from 1 of these States estimates 
that a total of 1,878 individuals participate in cost sharing statewide.  
Officials from the other five States could not provide estimates. 
The States that have implemented cost sharing  The States and area agencies that 
do not always follow OAA requirements for cost  have implemented cost sharing do 
not always follow key OAA 
sharing that are designed to protect low-income 
requirements that are intended to 
individuals access to services 
ensure that individuals with low 
incomes can obtain OAA services.  Table 2 presents the number of cost-
sharing States that have practices that conflict with key requirements. 
9  Statewide counts may be duplicative because recipients may be receiving multiple 
services. 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  10  F I N D I N G S  

Table 2: Cost-Sharing States with Practices Not in Accordance with the OAA Requirements 
State or Area Agency  Cost-Sharing States  
Practice 
A  B  C  D  E  F  G  H  I  J  K  L  Total 
Has not developed cost- 
sharing plan that 
X  X  X  X  X  X  X  X  X  9 
addresses participation 
of low-income individuals 
Permits individuals with 
incomes at or below the 
X  X  X  X  X  5 
Federal poverty level to 
cost share 
Denies services or 
makes cost sharing  X  X  X  X  X  X  6 
appear mandatory  
Has not developed a 
sliding scale for all  X  X  X  3 
services 
Does not have a policy 
for accounting of cost- X  X  X  X  X  X  6 
share payments 
Has not created written 
materials that explain  X  X  X  X  X  X  X  X  X  X  X  X  12 
cost sharing 
Source:  Office of Inspector General analysis of State and area agency documents and interviews, 2005. 
Nine States have not developed cost-sharing plans that address the 
participation of low-income individuals 
The OAA requires States and area agencies to develop plans prior to 
implementing cost sharing.  These plans should be designed to ensure 
that the implementation of cost sharing will not decrease the 
participation of low-income older individuals receiving OAA services.10 
Four of the twelve States have not developed any plans that address 
cost sharing.  Five more States have cost-sharing plans or policies but 
they do not specifically address the participation of low-income 
individuals. The remaining three States have policies that specifically 
state that their respective cost-sharing program is designed to ensure 
that participation of low-income individuals will not decrease.   
10  42 U.S.C.  3030c-2(c)(2). 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  11  FFF III NNN DDD III NNN GGG SSS  
Five States permit individuals with low incomes to cost share 
The OAA prohibits States from permitting cost sharing by individuals 
with incomes at or below the Federal poverty line.11 However, five 
States permit individuals with incomes below the Federal poverty line 
to cost share. Specifically, four States have fee schedules indicating 
that individuals with incomes at or below the Federal poverty line are 
expected to make cost-share payments. Another State excludes these 
individuals from participating in cost sharing for one OAA service in the 
State but not for another. 
Half of the 12 States either deny services or make cost sharing appear 
mandatory 
Pursuant to the OAA, States that cost share must require that area 
agencies and local service providers not deny an older individual 
services due to income or failure to make a cost-share payment.12 
However, two States deny services due to an individuals income or 
failure to make a cost-share payment. An area agency in one State has 
a policy to suspend services when payments are not made. An official 
from another State reports that the practice in her State is to deny 
services when recipients do not pay, although exceptions are sometimes 
made. 
An additional four States have collection methods that make cost 
sharing appear mandatory. In these States, recipients sign cost-sharing 
agreements. The agreements contain phrases such as payment 
required and bills are due and do not explain that services will not be 
denied for nonpayment. One area agency calls the cost-share payment a 
copayment. This agency also bills the recipient if he or she misses a 
scheduled service. 
Three States have not established sliding fee scales for all of their cost-
shared services 
The OAA requires States that cost share to establish a sliding scale to 
determine payment rates.13 One State has not developed any scales. 
The official from this State says she was not aware that States were 
allowed to develop such scales. In this State, recipients are not charged 
for the first year of service. They are charged half the cost for the 
second year of service and the entire cost thereafter. Two other States 
11 42 U.S.C.  3030c-2(a)(3). 
12 42 U.S.C.  3030c-2(a)(5)(E). 
13 42 U.S.C.  3030c-2(a)(4). 
OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  12  F I N D I N G S  
use a sliding scale for some, but not all, of OAA services for which they 
cost share. 
Half of the 12 States do not have policies for the accounting of cost-share 
payments 
Pursuant to the OAA, States that cost share must ensure that area 
agencies and service providers establish appropriate procedures to 
safeguard and account for cost-share payments.14  Six of the twelve 
States that cost share do not have procedures specifically for the 
accounting of cost-share payments.  Officials from the area agencies in 
these six States report that they have not received any specific guidance 
from their State about accounting for cost-share payments.  
None of the States has created the required written materials on cost 
sharing 
Pursuant to the OAA, States that cost share must create written 
materials that explain the criteria for cost sharing, the sliding scale, 
and the fact that services cannot be denied to an older individual due to 
income or failure to make payment. States must require the area 
agencies and service providers to widely distribute the written 
materials.15 
None of the 12 States that cost share have created the written materials 
to explain cost sharing to recipients. State officials in all 12 States 
expect their area agencies or providers to inform recipients about cost 
sharing. The area agency officials whom we interviewed report that the 
area agencies or providers inform recipients about cost sharing during 
the intake process or prior to providing the service.  However, only 1 of 
the 21 area agencies we interviewed had written materials that 
provided detailed information about cost sharing for recipients. 
AoA has provided limited guidance to States and  AoA has not provided States with 
State officials are often confused about features  comprehensive guidance on cost 
sharing 
of cost sharing under the OAA 
AoA has provided limited 
guidance to States on implementing cost sharing in accordance with the 
OAA.  AoA conducted for its regional offices an initial training session 
that included training materials that were distributed to them to share 
14 42 U.S.C.  3030c-2(a)(5)(B).

15 42 U.S.C.  3030c-2(a)(5)(G).

  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  13  F I N D I N G S  
with States. However, the training did not cover key requirements, 
such as the plans States are required to develop and the written 
materials that explain cost sharing that States must create. AoA also 
posted a few frequently asked questions about cost sharing on its Web 
site; however, the information has since been removed.16 A table 
comparing the 1992 and 2000 amendments to the OAA is currently 
available on AoAs Web site, but it is difficult to find.  The information 
does not readily come up in searches and only appears at the end of 
several different menu prompts.  Lastly, AoA officials report that they 
provide technical assistance to individual regional offices or States 
when questions arise. 
In addition, based on our interviews, we found that AoA officials have 
limited information about how States are implementing cost sharing.  
For instance, they have little knowledge about States plans regarding 
cost sharing, their sliding scales, accounting for cost-share payments, or 
informing recipients about cost sharing.   
Officials from some State and area agencies do not fully understand cost 
sharing 
Officials from several States and area agencies are confused about 
features of cost sharing for OAA services.  Based on our written survey 
of all States and subsequent interviews with State and area agency 
officials and our review of relevant documentation, we found that 
officials from 13 of 52 States did not correctly understand the status of 
cost sharing in their State.  Specifically, officials in eight States 
confused State-funded services with those funded by the OAA. Officials 
in three States confused voluntary contributions or their voucher and 
reimbursement programs with cost sharing.  Additionally, officials in 
two States could not identify which area agencies in their States have 
implemented cost sharing. 
16 There are currently two questions about cost sharing posted on AoAs Web site but they 
are very general. 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  14  F I N D I N G S  

AoAs participation data cannot be used to  AoA is required to conduct 
determine the impact of cost sharing on  an annual evaluation of 
cost sharing to determine 
participation rates 
its impact on participation 
rates, with particular attention to low-income and minority older 
individuals and older individuals residing in rural areas.17  AoA collects 
participation data for many OAA services through the NAPIS/SPR.  As 
mentioned previously in this report, the NAPIS/SPR does not contain 
information specific to cost sharing but it does contain the total number 
of people participating in many of the services that are cost shared.  
AoA uses the NAPIS/SPR data to plan and manage activities performed 
and services provided under the OAA. 
We found that States report data in the NAPIS/SPR differently and that 
the demographic data in the NAPIS/SPR are incomplete.  As a result, 
the data in the NAPIS/SPR do not present a complete picture of 
participation and, therefore, cannot be used to measure any impact that 
cost sharing might have on overall participation or on participation of 
low-income individuals and other subgroups specified in the OAA.   
States report participation data in the NAPIS/SPR differently 
Interviews with data officials in the 12 cost-sharing States show that 
States report participation data in the NAPIS/SPR differently.  
Specifically, data officials in seven States say that they include 
recipients of services funded solely by State or local entities in addition 
to recipients of OAA-funded services.  In contrast, data officials in the 
other five States say that they do not include recipients of services 
funded solely by State or local entities when reporting to the 
NAPIS/SPR. 
The differences in reporting may be due to conflicting instructions that 
AoA provides to States. AoA officials report that they instruct States to 
count all recipients receiving services through the State Units, whether 
the services are OAA-funded or not. They note that reporting 
participation in this way is in line with the mission of the OAA to 
leverage these funds with other State and local money. At the same 
17 42 U.S.C.  3030c-2(d). 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  15  F I N D I N G
 S  
time, AoAs Web site instructs States to count recipients of services that 
are funded in whole or in part by the OAA.18 
Demographic data in the NAPIS/SPR are incomplete   
At the time we reviewed the data, we found that the demographic data 
in the NAPIS/SPR were incomplete.  Although AoA has taken steps to 
resolve this issue, the NAPIS/SPR data do not currently provide a 
complete picture of participation for subgroups of the population. 
Therefore, the data cannot be used to measure whether cost sharing has 
had any impact on participation for the subgroups specified in the OAA, 
including low-income individuals. 
Specifically, we found that the original design specifications for the 
NAPIS/SPR required States to omit the demographic data for recipients 
missing any data element.  Consequently, States had to delete all 
characteristics for a record that was missing an element such as race, 
ethnicity, disability status, or rural residence. AoA officials believe that 
this design specification resulted in significant undercounting of clients 
in the client-detail tabulations.  These officials also report that they 
have no way of determining which characteristics were most affected by 
the design specification.19  Although AoA has changed the design 
specifications and the NAPIS/SPR now retains records with missing 
data elements, AoA officials stated that they . . . do not believe that any 
of the quantitative program data now available can be employed to 
make inferences about the impact of cost sharing on program 
participation by vulnerable individuals.20 
We also found that the data in the NAPIS/SPR do not include 
demographic information for all States.  AoA was required to grant 
States waivers from submitting demographic data for Title III-B 
services. 21  AoA officials report that they have not received this 
information from more than 40 States in any fiscal year. As of 2005, 
however, AoA is no longer required to approve the waivers. 
18 U.S. Administration on Aging, Instructions For Completion of Title III and VII SPR.  
Available online at http://www.aoa.gov/prof/agingnet/napis/spr/spr_guidance/newn97.asp. 
Accessed August 10, 2006. 
19 Letter from AoA to Office of Evaluation and Inspections (January 24, 2005). 
20 Ibid. 
21 AoA was required to grant States waivers from submitting demographic data for 
recipients of Title III-B services by the initial Office of Management and Budget 
conditions of approval for the NAPIS/SPR data collection and the Paperwork Reduction 
Act of 1995. 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  16  F I N D I N G S  
Further, the NAPIS/SPR does not include demographic data for Title 
III-E services. States have not been required to report demographic 
data for any Title III-E services, which include respite and 
supplemental services, two of the most commonly cost shared services. 
AoA officials report that States must now report certain demographic 
data for recipients of Title III-E services. 
States report that area agencies commonly have problems collecting 
accurate participation data 
State data officials in the nine cost-sharing States with area agencies 
report that area agencies commonly have problems collecting and 
reporting accurate participation data.  The data officials note problems 
with limitations of their data systems, difficulties interpreting data 
definitions and requirements, and an inability to collect complete data.  
Data officials in these States report that they often have to estimate the 
number of persons served by the area agencies due to the problems their 
agencies experience collecting accurate data.  AoA officials acknowledge 
that the NAPIS/SPR data are not consistently available for area 
agencies.22 
22 Letter from AoA to Office of Evaluation and Inspections (January 24, 2005). 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  17    R E C O M M E N D A T I O N S  

States use of cost sharing for OAA-funded services is limited.  Of the 
States that cost share, not all have followed OAA requirements for cost 
sharing that are designed to ensure that low-income individuals have 
access to services.  To date, AoA has provided limited guidance to States 
about implementing cost sharing. Also, AoAs participation data cannot 
be used to determine the impact of cost sharing on participation for low-
income individuals and other groups targeted by the OAA. Based on 
these findings, we recommend that AoA: 
Ensure that States cost-sharing practices comply with requirements 
designed to protect low-income individuals access to services.  AoA 
should address State and area agency practices that permit low-income 
individuals to participate in cost sharing.  AoA should also address 
State and area agency practices that deny services to older individuals 
due to income or failure to make a cost-share payment, as well as 
practices that make cost sharing appear mandatory.  In addition, AoA 
should address the States lack of cost-sharing plans, sliding fee scales, 
policies for accounting for payments, and written material that explain 
cost sharing. 
Provide additional guidance to States about implementing cost 
sharing in accordance with the OAA. AoA should provide additional 
guidance to States regarding how to implement cost sharing in 
accordance with OAA requirements.  The guidance should address 
issues such as (1) developing plans to ensure that the participation of 
low-income individuals will not decrease with the implementation of cost 
sharing; (2) excluding low-income individuals from cost sharing;             
(3) prohibiting the denial of services; (4) establishing sliding scales;        
(5) developing procedures to account for cost-sharing payments; and      
(6) preparing written materials to inform recipients about cost sharing.  
AoA should also develop additional strategies to keep States informed 
about these issues.  
Improve the quality of the NAPIS/SPR data so that any effects of 
cost sharing can be measured. AoA should improve the quality of its 
data to measure any future impacts cost sharing may have on 
participation rates, as required by the OAA.  During the course of this 
study, AoA has addressed some of the data problems.  Specifically, the 
NAPIS/SPR now retains records with missing data elements; the 
NAPIS/SPR now collects some demographic data for recipients of Title 
III-E services; and AoA is no longer required to approve waivers to 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  18  R E C O M M E N D A T I O N S  
States. However, AoA has not addressed the differences in State 
reporting. 
When addressing these differences, AoA needs to give clear and 
consistent instructions to States and consider whether to continue 
directing States to report information for all services, including those 
funded solely by State or local entities.  If the NAPIS/SPR includes data 
about non-OAA-funded services, then AoA needs to consider how it will 
determine any effects of cost sharing on participation in OAA programs 
and services, as required by the OAA.  
In addition, the inconsistency of AoAs participation data has 
implications beyond cost sharing.  This study focuses only on cost 
sharing, but the differences in data reporting raise questions about how 
AoA can use the data to effectively plan and manage activities funded 
under the OAA.  This broader issue affects AoAs capacity to manage all 
aspects of these services, not only cost sharing. 
AGENCY COMMENTS 
AoA provided comments on the draft report.  In general, AoA agrees 
with our findings that cost sharing is limited and that States are 
confused about cost sharing.  AoA states that it has taken many steps to 
educate the Aging Network on cost sharing and does not agree with our 
finding that it has provided limited guidance to States.  AoA also states 
that our observations about NAPIS/SPR are outside the scope of the 
study and that it has made several improvements to NAPIS/SPR over 
the last 5 years. In response to our recommendations, AoA notes that it 
will follow up on our observations and correct instances of 
noncompliance with the provisions of the OAA.  AoA also plans to 
provide additional guidance to States on an ongoing basis and post more 
information on its Web site.  The full text of the comments is included in 
Appendix A. 
OFFICE OF INSPECTOR GENERAL RESPONSE 
Where appropriate, we have made changes to the report based on AoAs 
comments.  
Because the OAA requires AoA to determine the impact of cost sharing 
on participation rates, and NAPIS/SPR is the only data AoA has on 
participation, we believe that it is necessary to include NAPIS/SPR in 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  19  R E C O M M E N D A T I O N S  
any discussion about whether cost sharing has had an impact on 
participation rates. 
We recognize that AoA has made several improvements to NAPIS/SPR 
over the last 5 years, many of which are noted in the report. However, 
despite these improvements, we found that the States that cost share 
report participation data in the NAPIS/SPR differently and include 
different populations in their counts.  This issue is important because it 
has potential implications beyond cost sharing.  These data provide 
essential information for AoA, including performance outcome 
information required by the Government Performance and Results Act 
and the Performance Assessment Rating Tool. 
  OEI-02-04-00290  COST SHARING FOR OLDER AMERICANS ACT SERVICES  20  APPEND X
Agency Comments
r-""~
( /t DEPARTMENTOFHEALm &.HUMA SERVICES
~'- Ofce of the Assistnt Secrtary
Admfn.!.tration on Aging
Washington D.C. 20201
0
JUN ! 2 2005 -..., 
0" 'J
n ,
0"; (":? 'i
fTC; :)
TO: Daniel R. Levinson cl'.r'
fT- ..:
Inspector Gener /. 1' I /'~, A~. . :.):-"
:::
EdwiL. Wa1er~ ir.:
FROM: c. ,.-.- .Ji
-I
Deputy Assistat Seceta for Policy and Progrms ~0 ui
SUBJECl: Adminstron onAgig Comments in Response to
Report: "Cost Shang for Older Amerca Act Serice,"
OIG Draft 
OEI-02-04-00290
Summary of  Comments
The Administrtion on Agig (AoA) recgnze the crtical importce of assessin
progr  imlemenon, and more importtIy, progr perormce caed out under
the Older Amerca Act In regntion of  the requiements of  the Older Amerca Act
(OM), and the evdent cistace th  imlementation of cost shg under the OAA
wa ver  limite AoA requested th Offce of Inpector General (OIG) to undere an
!'aluaton of cost sharng for OM serce.
In commentig on the findings of the OIG related to cost  shng under the OM, AoA
wants to acknowledge the diffculty 9fthe tak we reuesed the OIG to perform. AoA
knew that implementation of cost sharg under the OM was ver limited, and felt tht it
would remain so even though cost sharng for related statefuded progrs was
common. We believe tht the OIG work confied that implementaton of cost shag
under the OM is and wi reai ver liited Ver few staes have implemented it for
OAA fuded progr, and for those who have implemented it at all, the level of
implementation was usualIy ver limted both in tenu of coverge across the state an of
servce included It should be D9ted that the OM does not reuie sttes to implement
cost shg, so this outcome does not violate the intent of  the OM in any way. We had
hope to lear more about the barers that have caused sttes to choose not to tae
advatage"ofths new provision. However, that type of anlysis did not oc. As a
result, the review did Dot provide the tye of  information that would sere AoA and the
aging network to help to modifY program requirements of  the Act in a way th would
allow the OM to be mode, and allow the network to tae" advantage of the positive
aspects of cost shag, whie protecting the nees of elderly individuals at greaest social
and economic risk.
AoA appreciates the obsertions of  the OIO related to conce about compliance by the
States with the cost shang provions of  the OM. However, we do not believe that the
OEI.02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 21 APPEND X
Page 2 - Daniel R. Levison
stdy was adequate to ma generalizatons about the impa of state and local actions
across OM programs. Dat provided by the OIG on the numbe of  individus
parcipat in cost sharg clealy indicae that implementaton ha  not bee exteive
enough to have had a signficat effec on any broad OAA client population grup. The
OIG da indicate th cost sh under the OM Isnot ocng to any signficat
degree for any progr activity. AoA wil follow up on the obseratous of the OIG to
corr,ect ince of non-compliance with the provisions of  the OM where they may
exst. We also  believe that if fuer implementation of  cost sharng occ, .it  will
requie ongoin confirmation of compliance with the provisions of the OM.
We apprete th the  stdy was able to correct may ofits ealier obseratons
assoiated with the Natonal Agig Progr Inormaton System (NAlIS). We believe
th the diffcuties the study encounter reflec litaons with the methodlogy and
the limts of implementtion of cost shg, an not problem with the NAPIS system.
The NAPIS da  system is, in fact, well maged and cordinated AoA works ver
closely with representaves of ste and ar agenes on agig to ensre th  th data
colIected under the NAPIS system is focused on chctercs an data th  supprt
crtica and necesa program management acvity. In the pas five yea, AoA the
state, area agencies, nationa assoiatons of stat an ar agencies, and highly
expeence OAA progr data vendors have put signficat effort into the improvement
of OM prgr dat and ths signfica and ext~ve collabraon will Continue.
State implementadon of rost-sharig
Based on AoA's experence in workig with the sttes to imlement cost sharng and
other provisions under the Act we believe that many  of  the conclnsonsofthe stuy
about Sta exection of the cost-sharg provisions do not adequately reflect th(:
complexity of  the issue under the Older Amercas Act nor do th give a complete
pictue of  how the states ar implementing Cost-shag.
Firt, a required element under the OM of  Sta an Area plan is.th they enure the
parcipation of low-income individuals thughout thei repetive plan in ALL OAA
serce, includg those tht are cost shared (see State plan atchmentsA&B). AoA
does not believe it is nees or effecve for States at tl tie to set up a Separte plan
relat to cost-sharg, becuse ther is litte evdence of plans to mae it extensive, and
becuse broader prograr dat indicate signficat  protecons of client populations. The
data below indicate tht States and AAs are effecvely addsing the tagetig of
serce to individuals with low-incomes thughout thei resve State and Ar plan
10% of  U.S. elders are poor; 28% ofOAA cllents are poor.
16% of elders are miority; 22% of clients are miority.
24% of U.S. elders reside in rural area; over 21% of OAA cUents are rural.
Second, under the Older Amercan Act, States, AA and providers are reuired to
allow older individuals to contrbute to the cost of  thei servce. This requireent  often
creates diffcuties for State attptin to implement cost sharg. On the one hand, the
cost shag provision doe not allow for charg fee to low-inc'me tndividus, while
OEI.02-04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 22 APPEND X
Page 3 - Danel R. Levinson
other provisions requi title II provider to give all parcipats the oppty to
voluntaly contrbute to the cost of their serice. Melding these provisions togeter
under a syste where parcipats self declar thei incomes ca get trck and takes
extr plang. Ths is an isue that AoA is  trng to addres fuer in follow-up
gudace to Regional AoA offce and State agencies on agig. AoA plas to  expand
previous "frequently asked questions" related to cost-shag, post the inormation on its
website, and prvide additiona guidace to the States on an ongoing basis for Staes that
are cost sharg.
Th may States have cost shag provions under thei own stae-funded progrs .
or frm other source. When dicussing cost sharng actvities with States, it is AoA's
expeence tht States someties confu  the cost shg protocols of other fuding
soures with those of OM progt, parcularly give the fidig that in 6 of the 12
stats which implement cost sharg under the OAA fewer th 350 inviduas
partcipate. These data indicate th the larger. issue may not be confion by State when
implementing cost sharng, but rather tht co shag uner the OM barly exist 
at all.
Fourt many States have indica tht they wan to be able to us cost shang to  expand
mdwiedlrigneg  rOeuMres  pforro ag tg rwwigi thpo ptuhlaetiiro no owf n succfu sSentiaotres ,f uand etdht  ctohesyt  swahnat ntgo  pber oagblre.  tIof
States are incorrectly implementi CO.st sharg under the OAA one of the n: resous
may be becus ,co sha proviions under the OM do not genery meld well with
their own cost sharg program.
AoA guidance to the States on cost-sharig.
Whle we appreciate the OIG's recommendations for how AoA ca improve the level of
trni on cost sharng under the OM, we do not support the reprt's conclusion that
little guidace has bee provided. Since the enactment of cost shag under  the OAA
AoA has taen seeral stregies and actons to educate the agig serce netork on
this prvision, including the followig actvities:
 'AoA developed a PowerPoint preention, and conducted a videonfernce
dug thefut six months following the enactent of  the provision. (4/2001)
 Regional Offces used the PowerPoint preention with the Staes in their region
durng plaied trning sessions, and made copies of  the preenation avaiable to
State Agencies.
 AoA conducted a conference cal with Regiona AoA offces dedcated to the
discussion of cost sharng; cost shang question were fielded by AoA durng
other conference cals, as neeed. (216/02)
 AoA followed up the conference call with an email to Regional offce givig
fuer direcon on cost shar and providing a copy of  the statutory language.
(217/02)
 AoA developed "frequently asked questions" (FAQs) on aU of  the chages in the
2000 amendments, including cost sharg, and made those F AQs available on the
website for over two year. As mentioned above, AoA plan to expand the FAQs
and post again on the website.
OEI-02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 23 APPEND X
Page 4 -' Danel R. Levinson
 AoA worked with the Regional Offce to conduct a surey of  States relatd to
thei cost sharg actities. (9/200)
 Regional Offce have contiued to provide technica assistace on cost sha
(along with comprehenive TA on the ente OM) durng orientation training
with new Stae agency staff and durg provider, AM and State agency traing
conferecemee, as approprate.
 AoA contiues to wor with Regional Offces to resnd to cost shag inquires,
as needed. (1112000 to preent) Docuenon of cae-by-casegudace is
majntaed at Regional Offces of AoA in trp report and email corrpondence.
Quality ortheNAPISISPR Data
The spec intent of  the study requested was to beter underitad Cost shag unde the
OM, and not to provide anecota obseatons abut the overll data and informaton
available frm NAPIS/SPR. On ths latter point, the rert went well beyond the intent of
the sty  an the consnts of  its own metodologica design and led to obseratons
that faed to incorprate significat relevant data AoA expres the followig serious
conce abut the validity of the study methodology and conclusions regardig
NAPIS/SPR, although we do recgne ,that the report now acknowledgeS the cotion
of some of those obseations.
 Ther is no valid basis for making generons about an enterrise-wide,
national information system in a study tht addesses the lite implementaon
of  cost sharg. Given the timig of the legislative prvision, the fa that
implementaon was discetona, and the clea effec that implementaon Was
severely limted there should have bee no expecttion that rertng on cost
shag would be incorporated into NAPIS.
 In the 12 sttes where some level of cost shag was implemented the number of
perons parcipating in cost sharg (a tota numbe of pacipants is not
provided but individua sttes reortedly rage frm 55 peons to i ,878 persons)
is a ver small fraction of  the tota number of  perons seed under the OM in
these same stes (over 1.4 milion peons).
 Approxily 50% of these states have implemented cost shag in only limited
ars of  the state and none has implemented cost sharg for all of  the allowable
Title II serce.
 The NAPIS/SPR has never bee nor will it be, designed as a client tracking
system. It is desgned to provide broad agggated progr and management
inormaton to AoA, consistent with what ha been deeed accptale and
adequate, and approved by the Offce of  Maagement and Budget (OMB) for
AoA. SUAs, AAs and providers fruently collect and maita addtional
client level information for loc management purses, but this data is not to be
conf with the aggrgated NAPIS/SPR format aIlowed for AoA by OMB.
Whle the report offere a broad recmmendaton for AoA to ".. .improve the quaty of
its da.. .," it faled to identifY the ver specific and extenive data imprvement effort
that have character the NAPIS system over the last five yea. AoA, the National
Association of State Units on Aging, a major nationaI NAPIS data vendor, other
OEI.02.04-00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 24 APPEND X
Page 5 - Daniel R. Levison
experence dat constats, and numerous individua state and area agencies have bee
actively enged in the modemiaton and iiprovement of  the  NAP  IS da syst over
the last five yea, and th effort  contiues. In the recet, signficat, and OM:-
approved revision of  the NAPIS data reuirements (and  reprtg system) that have
taken effec for the FY 2005 reportng perod, AoA and its data  improvement parers
sought formal input frm the entie aging netork of state and ar agcies no fewer
than four ties. AoA and its da improvement coalition  have continued to pur the
long-te modertion of  data programs through the NAPIS Dat Magement Study,
. which aga has puued inut and paricipation in a varet of  meda from agig netork
entities.
The stuy faled to identify these effort and intiatives becus thes efforts are
signficatly beyond the scope of  the sty the OIG was eiigagedto pero:i. AoA ha
formaly  occpied signficat professional  entities that are qualified to gude the Agency
and the Netork in puring improvements to these importt daa operations, and AoA
wilI look to these entities for recmmendatons related to the imprvement of  the NAPIS
system. To effectively  manage and rert on program actvities, AoAhas grtly
enced acc to tiely, ace, and integrte data an inormation. AoA has taen
several importt steps to ensue the avaiabilty of  ths essential inormation: (I)
development of  the Nationa Agig Program Inormtion Syste and the State Progr
Reprt (1995) as revised and imlemen for FY 2005 reprtng, (2) proviion of
softar support and  tr (State Reportg Tool - SR1) to falitate state submiion
of the SPR to en tiely and accate SPR inormaton, and (3) extensive procedural
gudance on the use of  thes tools and contiuay updag responses to Frequently
Asked Questions (F AQ) frm the Agig Netor NOTE: The insctons discussed in
the last paragrph on page 15 and footnote #18, reference the previous verion of
NAPIS/SPR. The FY 2005 NAPIS/SPR
(http;llww.aoa.irv/Drof/airgletAPIS/docsSPR_Modified_Fonn_1 i .08.04'Pd~ and F AQs
(htt:llww.a6uov!urotiaiiiretIAPIS/SPRlSPR irdaceIAPIS-FAOs03032006.d ) ar the
. most recnt and correc versions of  these documents These developments cleary
provide detaled rertirg inrmaton and insctions regag the inclusion of servces
fuded thugh the OM, stte genera! revenue and other source.
The SPR provides essential informon on the charactenstics of clients including:
demograpluc and diility dat; the tyes and levels of serce, such as the number of
persns serce and the unts of servce provided by the network on aging; expenditues
of OM fuds and from other sourcs; and adstrive information about SU As and
AAs, including staff  levels and rensibilties, as welI as the number of  volunteer
providing support The 010 reor (page 16) states tht "...dat in the NAPIS/SPR do
not include (client) demographic data information for al states." Whe some sta have
not prviously reported client demogrphic data i i of  the 12 states tht have
implemented cost sharng have submitt some level of client deogrhic inormation.
As required  under former OAA stattory authority, the 12th state recived a waiver of
demographic reportng responsibilty. Such waiver were reqired by OMB conditions of
approval for the former verson of  the NAPrS system.
OEI.02-04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 25 APPEND X
Page 6 - Daniel R. Levinson
The SPR dat provdes essetial infonntiOii for AoA. These data have provided
signficat peormance outcome inormon requied by the GovenentPerformance
and Rests Act (GPRA) an the Perormce Assssient Rati Tool (PART). AoA's
abilty to recently receve a P ART  score of8 i, and OMB lugbghng of the quaity of
AoA perormance mea in the FY 2005 Preident's Budget is bas to a consderable
degee on obtaing nec managent inormation from NAPISISPR.
As pa of contnuous quality imovement and to fuer refie  the data reprtg
procees in the Agig Network AoA enter into a coopetve agrent with the
National Associaton of  State Units on Agig (NASUA) to identify ways for AoA, SUAs,
and MA to imprve the effciency and effecven of 
rertg and to reuc the
burden of informaton colIecon. The stdy is focus on cost-effecve ways to:
i. Defie the common data requents necsa for policy and management
decision makg, includg stte and loca initiatives (includig advoccy) so as to limit
feder requien to a sub-set of ste and local reuients .
2. Elinat the need for elderly individuals  and cagiver to provide identifyng
inormation repedy to varous serce prviders
3. Improve data colIection methods and syss so as to insure obtanig
unduplica coun ofindividuas acrss serce prvide and gegrhic locatons
4. Reduce  the expee of report sysem  fragmentation by tag advatage of
network ecomies of scae for informaton  sytem development and management
without compromiin competition in the maretlac
Whle stilI in the dr stages, the report wil assis AoA in fuerng the integty of data
and informaton  supplied by the Agig Netork.
OEI-02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 26 APPEND X
ATTACHMENT A
Plan Assurances and Required Activities
Listing of State 
Older Americans Act, As Amended in 2000
By signing this document, the autorized Dffcial commits the State Agency  on Aging to
performing all  listed assurances and required activities.
This attachment, along with requirements listed in the State Plan Guidance Program
Instruction (PI) and attachment 8 State Plan Provisions and Information Requirements,
make up the package of instrctions for development of State Plans.
ASSURANCES
Sec. 305(a)- (c), ORGANIZATION
(a)(2)(A) The State agency shall, except as provided in subsection (b)(5), designate
for each such area (planning and servce area) after consideration ofthe views offered
by the unit or units of general purpose local government in such area, a public or
private nonprofit agency or organization as the area agency on aging for such  area.
(a)(2)(8) The State agency shall provide assurances, satisfactory to the Assistant
Secretary, that the State agency wil take into account, in connection with matters of
general policy arising in the development and administration of the State plan for any
fiscal year, the views of recipients of supportive sGrvces or nutrition services, or
individuals using multipurpose senior centers provided under such plan.
(a)(2)(E) The State agency shall provide assurance that preference wil be given to
providing services to older individuais with  greatest economic need and older
individuals with greatest social need, with particular attention to low-income minority
individuals and older individuals residing in rural areas and include proposed methods
of carring out the preference In the State plan.
(a)(2)(F) The State agency shall provide assurances that the State agency wil
require use of outreach efforts described in section 307(a)(16)..
(a)(2)(G)(ii) The State agency shall provide an assurance that the State agency wil
undertake specific program development, advocacy, and outreach efforts focused on
the needs of low-income minority older individuals and older individuals residing ;n
rural areas.
(c)(5) In the case of a State specified in subsection (b)(5), the State agency and area
agencies shall provide assurance, determined adequate by the State agency, that the
area agency on aging wil have the ability to develop an area plan and to carr out,
OEI.02-04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 27 APPENDIX
directly or through contractual or other arrangements, a program in accordance with
the plan within the planning and service area.
States must assure that the following assurances (Section 306) wil be met by its
designated area agencies on aaencies. or bv the  State in the case of sln(:le
planning and service area states.
Sec. 306(a), AREA PLANS
(2) Each area agency on aging shall provide assurances that an adequate proporton,
as requited under section 307(a)(2), of  the amount allotted for part B to the planning
and service area will be expended for the delivery of each of the following categones of
services-
(A) services associated with access to services (transportation, outreach,
information and assistance, and case management services);
(B) in-home services, including supportive services for familes of older individuals
who are victims of Alzheimer's disease and related disorders with neurological and
organic brain dysfunction; and
(C) legal assistance;
and assurances that the area agency on aging wil report annually to the
State agency in detail the amount of funds expended for each such category
during the fiscal year most recently concluded.
(4)(A)(i) Each area agency on agil1g shall proVide assurances that the area agency on
aging wil set speCific objectives for providing services to older individuals with greatest
economic need and older individuals  with greatest social need, include specific
objectives for providing  services to low-income minority individuals and older
individuals residing in rural areas, and include proposed methods of carrng out the
preference in the area plan.
(4)(A)(ii) Each area agency on aging shall provide assurances that the area agency
on aging wil include in each agreement made with a provider of any servIce under
this title, a requirement that such provider will-
(I) specify how the provider intends to satisfy the service needs of low-income minority
individuals and older individuals residing in rural areas in the area served by the
provider;
(II) to the maximum extent feasible, provide services to low-income minorit
individuals and older individuals residing in rural areas in accordance with their need
for such services; and
(ill) meet specific objectives established by the area agency on aging, for providing
. services to low-income minority individuals and older individuals residing in rural
areas within the planning and service area.
(4 )(A)(ii) With respect to the fiscal year preceding the fiscal year for which such
plan Is prepared, each area agency on aging shall-
2
OEI.02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 28 APPEND X
(I) identify the number of low-income minority older individuals and older individuals
residing in rural areas in the planning and service area;
(II) describe the methods used to satisfy the servce needs of such minority older
individuals; and
(III) provide information on the extent to which the area agency on aging met the
objectives described in clause (a)(4)(AXi).
(4)(BXil Each area agency on aging shall provide assurances that the area agency
on aging wil use outreach efforts that wil identif individuals eligible for assistance
under this Act, with special emphasis on-
(I) older individuals residing in rural areas;
(II) older individuals with greatest economic need (with partcular attention to
low-income minority individuals and older individuals residing in rural areas);
(III)  older  individuals with greatest social need (with particular attention to low-income
minority individuals and older individuals residing in rural  areas);
(IV) older Individuals wit severe diSabilties;
(V) older individuals with limited English-speaking abilty; and
(Vi) older individuals with Alzheimets disease or related disorders with neurologicai and
organic brain dysfunction (and the caretakers of such individuals);
and inform the older individuals referrd to in (A) through (F), and the caretakers of such
individuals, of the availabilty of such assistance.
(4)(C) Each area agency on agency shall provide assurance that the area agency on
aging will ensure that each activity undertaken by the agency, including planning,
advocacy, and systems development, wil include a focus on the needs of low-income
minority older individuals and older individuals residing in rural areas.
(5) Each area agency on aging shall provide -assurances that the area agency on
aging wil coordinate planning, identification, assessment of needs, and provision of
servces for older individuals with  disabilities, with partcular attention to individuals
wwithi stevehre  disdabiiltises,a wibth iagelnctiesi theat sdev.elo p .or provide services for individuals
(9) Each area agency on aging shall provide assurances that the area agency on
aging, in canying out the State Long-Term Care Ombudsman program under section
307(a)(9), wil expend not less than the total amount of funds appropriated under this
Act and expended by the agency in fiscal year 2000 in canying out such a program
under this title.
(11) Each area agency on aging shall provide information and assurances concerning
servces to older individuals who are Native Amencans (referred to in this paragraph
as "older Native Americans"), including-
(A) information concerning whether there Is a Significant population of older Native
Americans in the planning and service area and If so, an assurance that the area
agency on aging wil pursue activities, including outreach, to increase access of those
older Native Americans to programs and benefits provided under this tile;
3
OEI-02-04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 29 APPEND X
(B) an assurance that the area agency on aging wil, to the maximum extent
practicable, coordinate the services the agency provides under this title with services
provided under title VI; and
(C) an assurance that the area agency on aging will make servces under the area
plan available, to the same extent as such services are available to older individuals
within the planning and service area, to older Native Americans.
(13)(A) Each area agency on aging shall provide assurances that the area agency  on
aging wil maintain the integrity and public purpose of services provided, and service
providers, under this title in all contractual and commercial relationships.
(13)(8) Each area agency on aging shall provide assurances that the area agency
on aging wil disclose to the Assistant Secetary and the State agency-
(i) the identity of each nongovemmental entit with which such agency has a contract
or commercial relationship relating to providing any service to older individuals; and
(ii) the nature of such contract or such relationship.
(13)(C) Each area agency on aging shall provide assurances that the area agency will
demonstrate that a loss or diminution in the quantity or quality of the services
provided, or to be provided, under this title by such agency has not resulted and wil
not result from such non-govemmental contracts or  such commercial relationships.
(13)(0) Each area agency on aging shall provide assurances that the area agency
wil demonstrate that the quantity or quality of the services to be provided under this
title by such agency wil be enhanced as a result of such non-governmental contracts
or commercial relationships.
(13)(E) Each area agency on aging shall provide assurances that the area agency
wil, on the request of  the Assistant Secretary or the State, for the purpose of
monitoring compliance with this Act (including conducting an audit), disclose all
sources and expenditures of funds such agency receives or expends to provide
servces to older individuals.
(14) Each area agency on aging shall provide assurances thatfunds received under
this title wil not be used to pay any part of a cost  (including an administrative cost)
incurred by the area agency on aging to carr out a contract or commercial
relationship that is not carried out to implement this title. .
(15) Each area agency on aging shall provide assurances that preference in receiving
services under this title wil not be given by the area agency on aging to particular
older individuals as a result of a contract or commercial relationship that is not carried
out to implement this title.
Sec. 307, STATE PLANS
4
OEI.02.04,00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 30 APPEND X
(7)(A) The plan shall provide satisfactory assurance that such fiscal control and
fund accounting proceures will be adopted as may be necessary to assure
proper disbursement of, and accunting for, Federal funds paid under this tille to
the State, including any such funds paid to the recipients of a grant or contract.
(7)(8) The plan shall provide assurances that-
(i) no individual (appointed or otherwse) involved in the designation of the State agency
or an .area agency on aging, .or In the designation of the head of any subdivision of the
State agency or of an area agency on aging,  is subject to a conflct of interest
prohibited under this Act;
(ii) no officer, employee, or other representative of the State agency or an area
agency on aging is Subject to a conflict of interest prohibited under this Act; and
(iii) mechanisms are in place to Identify and remove conflcts of interest prohibited
under this Act.
(9) The plan shall provide assurances that the State agency wil carr out, through
the Offce of  the State Long-Term Care Ombudsman, a State Long-Term Care
Ombudsman program in accordance with section 712 and this title, and wil expend
for such purpose an amount that is not less than an amount expended by the State
agency with .funds received under this tite for fiscal year 2000, and an amount that is
not less than the amount expended by the State agency with funds received under
tille VII for fiscal year 2000.
(10) The plan shall provide assurance that the special needs of older individuals
residing in rural  areas wil betaken into consideration and shall describe how those
needs have been met and describe how funds have been allocated to meet those
needs.
(11 )(A) The plan shall provide assurances that area agencies on aging wil--
of legal assistance which can demonstrate the
(i) enter into contracts with providers 
experience or capacit to deliver .legal assistance;
(ij) include In any such contract provisions to assure that any recipient of funds under
division (A) will be subject to specifc restrictions and regulations promulgated under
the Legal Services Corporation Act (other than restrictions and regulations governing
eligibilty for legal assistance under such Act and governing membership of local
governing boards) as determined appropriate by the Assistant Secretary; and
(ii) attempt to Involve the private bar in legal assistance activities authorized under this
tille, including groups within the private bar furnishing services to older individuals on a
pro bono and reduced fee basis.
(11 )(8) The plan contains assurances that no legal assistance wil be furnished
unless the grantee administers a program designed to provide legal assistance to
older individuals with social or economic need and has agreed, if the grantee is not a
Legal Services Corporation project grantee, to Cbordinate its services with existing
Legal Services Corporation projects In the planning and service area in order to
concentrate the use of funds provIded under this title on individuals with the greatest
5
OEI-02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 31 APPENDIX
such need; and the area agency on aging makes a finding, after assessment,
pursuant to standards for service promulgated by the Assistant Secretary, that any
grantee selected is the entity best able to provide the particular services.
(11 )(D) The plan contains assurances, to the extent practicable, that legal assistance
furnished under the plan wil be  in addition to any legal assistance for older individuals
being furnished with funds from sources  other than this Act and that reasonable effort
will be made to maintain existing levels of legal  assistance  for older  Individuals;
(11 )(E) The plan contains  assurances that area agencies on aging wilgive priori
to legal assistance related to income; health Care, long-term care, nutrition,
housing, utilites, protective services, defense of guardianship, abuse, neglect, and
age discrimination.
(12) The plan shall provide, whenever the State desires to provide for a fiscal year for
services for the prevention of abuse of older individuals, the plan contains assurances
that any area agency on aging carring  out such services wil conduct a program
consistent with relevant State law and coordinated with existing State adult protective
service activities for-
(A) public education to identify and prevent abuse of Dlder individuals;
(8) receipt of reports of abuse of older individuals;
(e) active participation of older individuals participating in programs under this Act
through outreach,  conferences, and referral of such individuals to other social service
agencies  or sourcs of assistance where appropriate and consented to by the parties to
be referred; and
(D) referral of complaints to law enforcement or public protective service agencies
where appropriate.
(13) The plan shall provide assurances that each State will assign personnel (one of
whom shall be known as a legal assistance developer) to provide State leadership In
developing legal assistance programs for older individuals throughout the State.
of the older
(14) The plan shall provide assurances that, if a substantial number 
individuals residing in any planning and service area in the State are of limited
English-speaking abilty. then the State wil require the area agency on aging for
each such planning and service area-
outreach services under section 306(aX2XA), the
(A) to utilze in the delivery of 
services of workers who are fluent in the language spoken by a predominant number
of such older individuals who are of limited English-speaking abilty and
(8) to designate an individual employed by the area agency on aging, or available to
such area agency on aging on a full-time basis, whose responsibilties will include--
counseling assistance is
(i) taking such action as may be appropriate to assure that 
made available to such older individuals who are  of limited English-speaking abilty in
order to assist such older individuals In participating in programs and receiving
assistance under this Act; and
6
OEI-02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 32 APPEND X
(ii) providing gUidance to individuals engaged in the delivery of supportive services
under the area plan involved to enable such individuals to be aware of cultural
sensitivities and to take into account effectively linguistic and cultural oifferences.
(16) The plan shall provide assurances that the State agency wil require outreach
efforts that will identify individuals eligible for assistance under this Act, with  special
emphasis on--
(A) older individuals residing in rural areas;
(8) older individuals with greatest economic need (with particular attention to
low-income minority individuals and older individuals residing in rural areas);
(C) older individuals with greatest social need (with particularalterition to low-income
minority individuals and older individuals residing in rural areas);
(D) older individuals with severe disabilties;
(E) older individuals with limited English-speaking abilty; and
(F) older individuals with Alzheimets disease or related disorders with neurological and
organic brain dysfunction (and the caretakers  of such individuals);and inform the older
individuals referred to in clauses (A) through (F) and the caretakers of such individuals,
of the availability of such assistance.
(17) The plan shall prOVide, with. respect to the needs of  older individuals with severe
disabilties, assurances that the State will coordinate planning, identification.
. assessment of needs, and service for older individuals with disabilties with particular
attention to individuals with severe disabilties with the State agencies withprimary
responsibilty for individuals with disabilties, including severe disabilites. to enhance
services and develop collaborative programs, where appropriate, to meet the needs of
older individuals with disabilties.
(18) The plan shall provide assurances that area agencies on aging wil conduct efforts
to faciltate the coordination of community-based, long-term care services, pursuant to
section 306(a)(7), for older individuals who- .
(A) reside at home and are at risk of institutonalization because of limitations on their
abilty to function independently;
(8) are patients in hospitals and are at risk of prolonged instiutionalization; or
(C) are patients in long-term care facilties, but who can return to their homes if
community-based services are provided to them.
(19) The plan shall include the assurances and description required by section
705(a).
special efforts wil be made to
(20) The plan shall provide assurances that 
provide technical assistance to mInority providers of services.
(21) The plan shall
(A) provide an assurance that the State agency wil coordinate programs under this
title and programs under title VI, if applicable; and
7
OEI-02.04.00290 COST SHARING FOR OlOER AMERICANS ACT SERVICES 33 APPENDIX
(8) provide an assurance that the State agency wil pursue activities to increase
to all aging programs and
access by older individuals who are Native Americans 
benefits Provided by the .agency, including programs and benefits proVided under this
title, if applicable, and specify the ways in which the State agency intends to
implement the activities.
(22) If case managemEmt services are offered to provide acceSs to supportive
services, the plan shall provide that the State agency shall ensure compliance wit
the requirements specified In section 306(a)(8).
(23) The plan shall provide assurances that demonstrable efforts wil be made-
(A) to coordinate servces provided under this Act wih other State services that benefit
older individuals; and
(8) to provide multigenerational activities, such as opportunities for older individuals to
. serve as mentors or advisers in child care, youth day care, educational assistance,
at-risk youth intervention, juvenile delinquency treatment, and family support programs.
(24) The. plan shall proVide assurances that the State wil coordinate public
services within the State to assist older individuals to obtain transportation services
associated with access to servces provided under this title, to services under title
Vi, to comprehensive counseling services, and to legal assistance.
(25) The plan shall include assurances thatthe State has  in effect a mechanism to
provide for quality in the provision of in-home services under this tille. .
(26) The plan shall proVide assurances that funds received under this title wil not be
used to pay any part of a cost (including an administrative cost) incurred by the State
agency or an area agency on aging to carry out a contract or commercial relationship
that is not camed out to implement this title.
Sec.  308, PLANNING, COORDINATION, EVALUATION, AND
ADMINISTRATION OF STATE PLANS
(b)(3)(E) No application by a State under subparagraph (b)(3)(A) shall be approved'
Unless it contains assurances  that no amounts received by the State under this
paragraph will be used to hire any individual to fill a job opening created by the action
of the State in laying off or terminating the employment of any regular employee not
supported under this Act in anticipation of fillng the vacancy so created by hifing an
employee to be supported through use of amounts received under this paragraph.
Sec. 705, ADDITIONAL STATE PLAN REQUIREMENTS (as numbered  in
statute)
OEI.02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 34 APPEND X
(1) The State plan shall provide an assurance that the State, in carring out any
chapter of this subtitle for which the State receives funding under this subtitle, wil
establish programs in accordance with the requirements of the chapter and this
chapter.
(2) The State plan shall provide an assurance that the State wil hold public hearings,
and use other means, to obtain the views of older individuals, area agencies on aging,
recipients of grants under  title VI, and other interested persons and entities regarding
programs carred out under this subtitle. .
(3) The State plan shall provide an assurance that the State, in consultation with area
agencies on aging, wil identify and prioritize statewide activities aimed at ensuring that
older individuals have access to, and assistance in securing and maintaining, benefis
and rights.
(4) The State plan shall provide an assurance that the State will use funds made
available under this subtitle for a chapter in addition to, and wil not supplant, any funds
that are expended under any Federal or State law in existence on the day before the
date of the enactment of this subtitle, to carr out each of the vulnerable elder rights
protection activities described in the chapter.
(5) The State plan shall provide an assurance that the State will place no restrictions,
other than the requirements referred to in clauses (i) through (iv) of section
. 712(a)(5)(C), on the eligibilty of entities for designation as local Ombudsman entities
under section 712(a)(5).
(6) The State plan shall provide an assurance that, with respect to programs for
the prevention of elder abuse, neglect, 'and exploitation under chapter 3-
wil conduct a program of
(A) in carring out such programs the State agency 
services consistent with relevant State law and coordinated with existing State
adult protective service activities for-
(i) public education to identify and prevent elder abuse;
(ii) receipt of reports of elder abuse;
(iii) active participation of older individuals participating in programs under this Act
through outreach, conferences, and referral of such individuals to other social
service agencies or sources of assistance if appropriate and if the individuals to be
referred consent; and
(iv) referral of complaints to law enforcement or public protective service agencies if
appropriate;
(B) the State wil not permit involuntary or coerced participation in the program of
services described in subparagraph (A) by alleged victims, abusers, or their
households; and
(e) allinfomiation gathered in the course of receiving reports and making referrals
shall remain confidential except': .
(i) if all parties to such complaint consent in writing to the rele;:se of such infomiation;
9
OEI-02.04.00290 COST SHARING fOR OLDER AMERICANS ACT SERVICES 35 APPENDIX
(ii) if the release of such information is to a law enforcement agency, public
protective service  agency, licensing or certification agency, ombudsman program, or .
protection or advocacy system; or
(ii) upon court order.
REQUIRED ACTIVITIES
Sec. 307(a), STATE PLANS
agency on aging designated under section
(1 )(A)The State Agency requires each area 
305(a)(2)(A) to develop and submit to the State agency for approval, in accordance with
a uniform format developed by the State agency, an area plan meeting the
requirements of section 306; and
(8) The State plan is based on such area plans.
Note: THIS SUBSECTION OF STATUTE DOES NOT REQUIRE THA T AREA PLANS
BE DEVELOPED PRIOR TO STA TEPLANS AND/OR THA T STA TE PLANS
DEVELOP AS A COMPILA nON OF AREA PLANS.
(2) The State agency:
(A) evaluates, using uniform procedures described in section'202(a)(29), the need for
supportive servces (including legal assistance pursuantto 307(a)(11), information and
assistance, and transportation services), nutrition services, and multipurpose senior
centers within the State;
(8) has developed a standardized process to determine the extent to which public or
private programs and resources (including volunteers and programs and services of
voluntary organizations) have the capacity and actually meet such need;
(4) The State agency conducts periodic evaluations of, and public hearings on,
activities and projects carred out in the State under titles II and VII, including
evaluations of the effectiveness of services provided to individuals with  greatest
economic need, greatest social need, Or disabilties, with particular attention to low-
income minority individuals and older indMduals residing in rural areas. Note:
"Periodic" (defined in 45CFR Part 1321.3) means, at a minimum, once each fiscal year.
The State agency:
(5) 
(A) affords an opportunity for a public hearing upon request, in accordance with
published procedures, to any area agency on aging submitting a plan under this title, to
any provider of (or applicant to provide) services;
(8) issues guidelines applicable to grievance procedures required by section
306(a)(10); and
10
OEI.02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 36 APPENDIX
(G) affords an opportunity for a public hearing, upon request, by an area agency on
aging, by  a provider of (or applicant to provide) services, or by any recipient of services
under this title regarding any waiver request, including those under Section 316.
wil make such reports, in such form, and containing such
(6) The State agency 
information, as the Assistant Secretary may require, arid compiy with such requirements
as the Assistant Secretary may impose to insure the correctness of such reports.
(8)(A) No supportve services, nutrition services, or in-home services are directly'
provided by the State agency or an area agency on aging in the State, unless, in the
judgment of the State agency-
(i) provision of such services by the State agency or the area agency on aging is
necessary to assure an adequate supply of such servces;
(ii) such services are directly related to such State agency's or area agency on aging's
administrative functions; or .
(ii) such services can be provided more economically, and with comparable quality, by
such State agency or area 'agency on aging.
Signature and Title of Authorized Offcial Date
11
OEI-02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 37 APPENDIX
ATTACHMENT B
STATE PLAN PROVISIONS AND INFORMATION REQUIREMENTS
. The following provisions and information requirements are listed in the indicated
sections of the Older Americans Act, as amended in 2000. State Plans may address
the provisions and information requirements in a format determined by each State.
This attachment, along with requirements listed in the State Plan Guidance Program
Instruction (PI) and attchment A, State Plan Assurances  and Required Activities, make
up the package of instrctions for development of  State Plans. Italicized notes are
provided for the State agency's convenience as links to referenced citations.
Section I. State Plan Information Requirements
Information required by Sections 102,305,307 and 705 that must be provided in the
State Plan:
102(19)(G) - (required only if the State funds in-home servces not already defined
in Sec.  102(19)) The term "in-home services" includes other in-home services as
defined by the State agency in the State plan submitted in accordance with Sec. 307.
Section 305(a)(2)(E)
The State agency shall provide assurance that preference wil be given to providing
services to older individuals with greatest economic need and older individuals with
greatest social need, with particular attention to low-income minorit individuals and
older individuals residing in rural areas and include proposed methods of carryng out
the preference in the State plan;
Section 307(a)
(2) The plan shall provide that the State agency wil:
(e) Specify a minimum proportion of the funds received by each area agency on aging
in the State to carry out part B that wil be expended (in the absence of a waiver under
sections 306(b) or 316) by such area agency on aging to provide each of the categories
of services specifed in section 306(a)(2) (Note: those categories are access, in-home,
arid legal assistance).
Section (307ra)(3)
The plan shall:
OEI-02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 38 APPEND X
Secretary approves) the
(A) include (and may not be approved unless the Assistant 
statement and demonstration required by paragraphs (2) and (4) of section 305(d)
(concerning distribution of funds); (Nole: the Ustalement and dmonstration are the
numerical statement of the intrastal funding formula, and a demonstration of the
allocation of funds to each planning and service area)
(B) with respect to services for older individuals residing in rural areas:
(i) provide assurances the State agency wil spend for each fiscal year of the plan, not
less than the amount expended for such services for fiscal year 2000.
(ii) identify, for each fiscal year to which the plan applies, the projected costs of
providing such services (including the cost  of providing access to such services).
(ii) describe the methods used to meet the needs for such services in the fiscal year
preceding the first year to which such plan applies.
Section 307(a)(8)) (Include in plan if applicable)
(B) Regarding case management services, if the State agency or area agency on aging
is already providing case management services (as of  the date of submission of the
plan) under a Slate program, the plan may specify that such agency is allowed to
continue to provide case management serviCes.
(C) The plan may specify that anarea agency on aging is allowed to directly provide
information and assistance services and outreach.
Section 307(a)(10)
The plan shall provide assurance that the special needs of older individuals residing in
rural areas are taken into consideration and shall describe how those needs have been
met and describe how funds have been allocated to meet those needs.
Section 307(a)(15)
The plan shall, with respect to the fiscal year preceding the fiscal year for which such
plan is prepared-
(A) identify the number of low-Income minority older individuals in the State; and
(B) describe the methods used to satisfy the service needs of such minority older
individuals.
2
OEI.02.04.00290 ~OST SHARING FOR OLDER AMERICANS ACT SERVICES 39 APPEND X
Section 307(a)(21)
The plan shall:
(8) provide an assurance that the State agency wil pursue activities to increase access
by older individuals who are Native Americans to  all aging programs and benefits
provided by the agency, including programs and benefits provided under this title (tite
11), if applicable, and specify the ways in which the State agency intends to implement
the activties.
Section 705(a)(7)
In order to be eligible to receive an allotment under this subtitle, a State shall include in
the State plan submitted under section 307:
(7) a description of the manner in whIch the State agency wil carry out this title in
accordance with the assurances describe in paragraphs (1) through (6). (Note:
Paragraphs (1) of  through (6) of  this section are listed below)
In order to be eligible to receive an allotment under this subtitle, a State shall include in
the State plan submited under section 307:
(1) fin assurance that the State, in carrying out any chapter of this subtite for which the
State receives funding under this subtitle, wifl establish programs in accordance with the
requirements of the chapter and this chapter;
(2) an assurance that the State will hold public hearings, and use other means, to obtain
the views of older individuals, area  agencies on aging, recipients of grants under tite Vi,
and other interested persons and entities regarding programs carried out under this
subtitle;
(3) an assurance that the State, in consultation with area agencies on aging, will identify
and prioritize statewide activities aimed at ensuring that older individuals  have access
to, and assistance in securing and maintaining, benefis and rights;
(4) an assurance that the State wifl use funds made available under this subtitle for a
chapter in addition to, and will not supplant, any funds that are expended under any
Federal  or State law in existence on the day before the date of the enactment of this
subtite, to carry  out each of the vulnerable elder rights protection activities described in .
the Chapter;
(5) an assurance that the State will place no restrictions, other than the requirements
referred to in clauses (i) through (iv) of section 712(a)(5)(C), on the eligibility of entiies
for designation as local Ombudsman enuties under section 712(a)(5);
(6) an assurance that, with respect to programs for the prevention of elder abuse,
neglect, and exploitation under chapter 3-
(A) in carrying out such programs the State agency wil conduct a program of services
consistent with relevant State law and coordinated with existing State adult protective
service activities for:
(i) public education to identify and prevent elder abuse;
(ii) receipt of reports of elder abuse;
3
OEI.02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 40 APPEND X
older individuals participating In programs under this Act
(Iii) active participation of 
through outreach, conferences, and referral of such individuals to other social servce
agencls or sources of assistance. if appropriate and if the Individuals to be referred
consent; and
(iv) referrl of complaints to law enforcement or public protective service agencies if
appropriate;
(8) the State will not permit involuntary or coerced participation in the program of
servlcesdesCrbd in subparagraph (A) by alleged victims, abusers, or their
households; and
(e) all information gathered In the course of receiving reports and making rferrals
shall remain confidential except- .
(i) If all parties to such complaint consent in writing to the release of such Information;
(ii) If the release of such information is to a law enforcement agency, public protective
service agency, licensing or certifcation agency, ombudsman program, or protection or
advocacy system; or
(iii) upon court order.
4
OEI.02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 41 ~ ACKNOWLEDGMENTS
This report was prepared under the direction of Jodi Nudelman,
Regional Inspector General for Evaluation and Inspections in the New
Evaluation and
York regional office. Other principal Offce of 
who contributed include:
Inspections staff 
Nancy Harrison, Team Leader
Elizabeth Jones, Program Analyst
Thomas Zimmermann, Program Analyst
Lekesha Campbell, Program Analyst
Ayana Everett, Program Specialist
Elise Stein, Director, Public Health and Human Services Branch
Technical Assistance
Barbara Tedesco, Mathematical Statistician
OEI.02.04.00290 COST SHARING FOR OLDER AMERICANS ACT SERVICES 42