Department  of Health  and  Human  Services 
ADM  NITRATION  ON  AGING 
AND 
OFFICE  OF 
INSPECTOR  GENERAL 
STATE  IMPLEMENTAmON  OF  THE 
STEWARDSlm?  REQUIREMENTS  OF 
THE  OLDER  AMERICANS  ACT  ADMINISTRATION  ON  AGING 
The  Administration  on Aging  (AoA)  is the  principal  Federal  agency designed  to carry out  the 
provisions  of the  Older  Americans  Act (OAA).  It advises  the Secretary  of Health  and  Human 
Sexvices and other  Federal  agencies  on  the characteristics,  circumstances  and needs  of older 
individuals.  Further,  it develops  policies,  plans,  and programs  designed  to promote  their 
welfare. 
AoA  administers  three  grant  programs  under  the  Older  Americans  Act.  The  largest  program  -
- Title  III of the Act  -- consist  of formula  grants  to States  to establish  State  and community-
based  programs  for older  individuals  with  the  purpose  of preventing  the  premature 
institutionalization  of older  individuals.  The  second  program  -- Title  VI -- consists  of 
discretionary  grants  with  the same  purpose  as Title  III, but  to meet  the  unique  needs  of older 
Native  Americans.  The  third  program  -- Title  IV -- is also discretionary.  Its purpose  is to fund 
research,  demonstration,  and  training  activities  to elicit  knowledge  and  techniques  to improve 
the circumstances  of older  Americans.  (The  1992 Amendments  to the  OAA  created  a fourth 
program  -- Title  VII  -- which provides  funds for State  activities  to protect  the  rights  of 
vulnerable  older  people.  prior  to the  1992 Amendments,  Title  III of the  O&l  provided  the 
funds for these  activities.) 
OFFICE  OF  INSPECXOR  GENERAL 
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  Semites  (HHS) 
programs  as well as the  health  and welfare  of beneficiaries  seined  by those  programs.  This 
statutory  mission  is carried  out  through  a nationwide  network  of  audits,  investigations,  and 
inspections  conducted  by three  OIG  operating  components:  the  Office  of Audit  Services,  the 
Office of Investigations,  and  the  Office of Evacuation  and  Inspections.  The  OIG  also informs 
the Secretary  of HHS  of program  and management  problems  and recommends  courses  to 
correct  them. 
Thc OIGS Office  of Evaluation  and  Inspections  (OEI)  conducts  short-term  management  and 
program  evaluations  (called  inspections)  that  focus on issues of concern  to the  Department, 
the Congress,  and the  public.  The  findings  and  recommendations  contained  in these  inspection 
reports  generate  rapid,  accurate,  and up-to-date  information  on the efficienq,  vulnerability, 
and effectiveness  of departmental  programs. 
THIS  REPORT 
This report  is the  result  of a joint  effort  between  AoA  and OIG/OEI  to assess the 
implementation  of Title  111of the  Older  Americans  Act.  OIG  staff in the  New York  and 
Dallas  regional  offices  provided  technical  support  to the joint  project.  AoA  staff in New York 
and Dallas  directed  the  project  with  all regional  offices participating  in the development  of 
instruments  and data  collection. 
For  additional  information,  please  contact: 
AoA  John  Dia~  Regional  Program  Director-Dallas  214-767-2971 
OIG  Jack  Molnar,  Project  Leader-New  York  21~-264lg9~  Department  of Health  and  Human  Services 
ADMINISTMTION  ON  AGING

AND 
OFFICE  OF 
INSPECTOR  GENERAL 
STATE  IMPLEMENTAmON  OF  rHF. 
STEWARDSHIP  REQUIREMENTS  OF 
THE  OLDER  AMERICNS  ACT 
APRKL 1993  OEI-02-91-01512
 EXECUTIVE  SUMMARY 
PURPOSE 
To review  State  Units  on Aging  (SUA)  implementation  of the  stewardship 
requirements  of Title  III of the  Older  Americans  Act  (OAA). 
BACKGROUND 
In an effort  to strengthen  its stewardship  of the  O*  the  Commissioner  of the 
Administration  on Aging  (AoA)  requested  technical  assistance  from  the  Office  of 
Inspector  General  (OIG)  in designing  a review  of their  primary  Title  III grantees  --
SUAS.  After  reviewing  traditional  and  current  stewardship  activities,  and  discussing 
potential  approaches  for future  efforts,  we agreed  that  a review  of individual  States 
would  be  instituted  in such a way  as  to  provide  the  commissioner  with  an overview  of 
how States  are  implementing  key  components  of Title  III.  In order  to conserve 
limited  travel  funds  the  reviews would  be  conducted  on a sample  of States  and  would 
focus  on only five programmatic  areas  -- stewardship,  targeting,  ombudsman,  nutrition, 
and  financial  management. 
This report  on stewardship  addresses  the  primary  operating  relationship  between  each 
SUA  and  its area  agencies  on aging.  It focuses  on issuing guidance  on and  monitoring 
implementation  of the  key  requirements  of Title  III of the  OAA,  including  the  area 
planning  process. 
METHODOLOGY 
The  reviews  were  conducted  in a stratified,  random  sample  of 20 States  based  upon 
the  population  of individuals  over  60 years  of age in each  State.  In the  first step  of 
the  sampling  process,  States  were  divided  into  four  strata  based  upon  the  number  of 
older  individuals  in each  State.  In the  second  step,  five States  were  selected  from 
each  stratum.  This  stratified,  random  sample  permits  a  generalization  of findings  from 
the  20 sample  States  to the  Nation. 
FINDINGS 
Area Planniizg And  Review  Work Welt  But There Are A Few Weaknesses 
43 percent  do not  address  coordination  with  mental  health  agencies 
 
36 percent  do not  address  evaluation  of outreach 
 
29 percent  do not  address  coordination  with long term  care  agencies 
 
Waiven Are  Commq  But Do Not Always  Follow l?mcedunx 
Most  States  grant  direct  service  waivers 
 
Many  States  do not  follow adequate  proportion  waiver  requirements 
 
i  Ass essmen@ Atkkess  Mwt  Requiremenfi,  But Not Always Annual& 
One-third  of States  do not  conduct  annual  on-site  assessments  of area  agencies 
 
A variety  of methodologies  are  used  to assess  area  agencies  on aging 
 
Coordination  with mental  health  and  long term  care  agencies,  as well as 
 
evaluation  of outreach,  is often  missing from  assessments 
All Area Agencies  on Aging Evakate  Activi&s  And  ConAct  Mlk  Heatigs,  But Many 
Do Not Access  %  Effectiveness of Outreach 
Only half  of States  report  all of their  area  agencies  have  conducted  annual 
 
outreach  evaluations 
State Agencies I?wide  Technical Ass&tance And  naintig  TOAd&ss  Area Agencks  on 
A~ngDeficiencies 
s 63 percent  of States  still report  having  unmet  training  and  technical  assistance 
needs  that  must  be  addressed 
ii  TABLE  OF  CONTENTS 
E=CXJTIVE  SUMMARY  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..i 
INTRODUCHON  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...1 
  Area  Planning  And  Review  Have  Weaknesses  . . . . . . . . . . . . . . . . . . . . . . . . . .  4 
b  WaiversAre  Common  . . . . ..  O. ..  O. . . . . . . ..O...  . . . . . . . . . . . . . . . ..O.  6 
  Assessments  NotAlwaysAnnual  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  6 
  Many  AAAs  Do  NotAccess  Outreach  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .  9 
SUAsProvideTechnical/kistance  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ...10 
 
APPENDICES 
&  Appendix  A  . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ..A-l  INTRODUCTION 
PURPOSE 
To  review  State  Units  on Aging  (SUA)  implementation  of the  stewardship 
requirements  of Title  III of the  Older  Americans  Act  (OAA).  In this report,  the  term 
stewardship  refers  to the  primary  operating  relationship  between  each  SUA  and  its 
area  agencies  on aging.  It focuses  on issuing guidance  on and  monitoring 
implementation  of the  key requirements  of Title  III of the  0~  including  the  area 
planning  process. 
BACKGROUND 
Under  the  O@  the  Administration  on Aging  (AoA)  serves  as the  principal  Federal 
advocate  for older  individuals,  providing  national  leadership  in the  development  of 
programs  to address  their  needs.  Through  Title  III of OAA  (Grants  for State  and 
Community  Programs  on Aging),  AoA  encourages  and  assists  WAS  and  area  agencies 
on aging  (AAAs)  to implement  a system  of coordinated  community-based  services  to 
prevent  the  premature  institutionalization  of older  individuals  by allowing  them  to 
remain  in their  own community. 
Under  Title  III, AoA  distributes  approximately  $765 million  in formula  grants  to States 
based  on the  age  60+  population  within  each  State.  The  SUAS use  about  5 percent 
of the  grant  on administration,  and  then  fund  AAAs  who then  contract  for the 
supportive  services,  nutrition  services  and  multipurpose  senior  centers.  The  single 
largest  component  of Title  III, the  nutrition  program,  provides  approximately  $450 
million  for congregate  and  home-delivered  meals.  Other  key program  components 
include  supportive  services  (i.e., access  services,  in-home  services  and  legal  assistance) 
and  the  Ombudsman  program  which  serves  as an advocate  for residents  in long term 
care  facilities. 
One  of AoAs major  administrative  responsibilities  is to provide  stewardship  over  the 
States  implementation  of the  Title  III  program.  However,  AoAs  capacity  to  carry  out 
its  stewardship  responsibilities  declined  substantially  during  the  1980s  due  to  a 
significant  reduction  in resources.  More  specifically,  AoA  sustained  a 47 percent 
reduction  in staff  and  75 percent  reduction  in travel  funds.  Each  regional  office  had 
only $2,000 annually  for travel.  Because  they  could  not  monitor  SUAS, AoA  became 
further  and  further  removed  from  the  activities  of the  SUAS and  their  area  agencies 
on aging. 
In  an  effort  to  strengthen  its  stewardship  of the  0~  the  Commissioner  of AoA 
requested  technical  assistance  from  the  Office  of Inspector  General  (OIG)  in 
designing  a review  of their  primary  Title  III  grantees  -- SUAS.  In response  to the 
Commissioners  request,  OIG  staff met  with key AoA  headquarters  and  regional  staff 
to identifj  traditional  and  current  stewardship  activities,  and  to discuss potential 
1  approaches  for future  efforts.  AS a result,  we  agreed  that  the  review  of individual 
States  would  be  instituted  in such  a way  as  to  provide  the  Commissioner  with  an 
overview  of how  States  are  implementing  key  components  of Title  III.  The  OIG 
agreed  to assist AoA  in developing  national,  standardized  review  instruments  for key 
components  of Title  III and  in writing  a report  summarizing  States  implementation  of 
the  Act.  We  also  agreed  that  in order  to conserve  limited  travel  funds  the  reviews 
would  be  conducted  on a sample  of States  and would  focus  on only five programmatic 
areas  -- stewardship,  targeting,  ombudsman,  nutrition,  and  financial  management. 
Designing  the  review  began  with the  meeting  of a review  team  of OIG  and  selected 
AoA  regional  staff.  They  brainstormed  approaches,  identified  Federal  reporting  and 
operating  requirements  for SUAS and  AAAs,  and  drafted  instruments  containing  the 
review  questions  and  criteria.  The  draft  instruments  were  shared  with  AoA 
headquarters  staff and  each  regional  office for comments,  and  then  revised  to reflect 
comments. 
The  OIG/AoA  review  teams  pre-tested  the  instruments  and  data  collection 
methodology  by conducting  reviews  for each  of the  five instruments  in six States 
located  in four  different  Federal  regions.  The  pre-test  identified  that  a great  deal  of 
time  was lost explaining  criteria  (interpreting  law  and  regulation)  and  searching  for 
documentation.  Accordingly,  the  review  team  modified  each  of the  instruments  and 
changed  the  data  collection  methodology.  The  most  significant  change  to the 
methodology  required  the  sharing  of the  review  instruments  with the  States  prior  to 
the  site  visit  in  the  belief  that  if States  are  aware  of ancl understand  the  review  criteria 
being  used  during  the  review,  they  will be  better  prepared  to  provide  required 
documentation  and  to  discuss  specific  issues. 
METHODOLOGY 
The  reviews  were  conducted  in  a stratified,  random  sample  of 20 States  based  upon 
the  population  of individuals  over  60 years  of age  in each  State.  These  are  the  same 
data  used  to  allocate  Title  III  funds  among  States.  In  the  first  step  of the  sampling 
process,  States  were  divided  into  four  strata  based  upon  the  number  of older 
individuals  in  each  State.  In  the  second  step,  we  selected  five  States  from  each 
stratum.  This  stratified,  random  sample  permits  US to  generalize  findings  from  the  20 
sample  States  to  the  Nation.  Table  I indicates  those  States  selected  for  the  review 
process  (See  Table  I). 
We  also used  sampling  techniques  during  site visits to each  State  for the  reviews  of 
specific  area  plans  and  assessments.  In these  instances,  we selected  a simple,  random 
sample  of 10 AAAs  prior  to the  visit to review  on-site.  For  those  States  with  less than 
10 AAAs,  all AAAs  were  included  in the  review. 
2  TABLE  I 
SAMPLE  STATES 
Stratum  1  Stratum  2  I  Stratum  3  Stratum  4 
California  Michigan  Wisconsin  New Hampshire 
Pennsylvania  Indiana  Colorado  North  Dakota 
New York  Massachusetts  Oklahoma  Nevada 
Texas  Georgia  Maine  District 
Florida  North  Oregon  of Columbia 
Carolina  Montana 
The  data  collection  was  conducted  in two  phases  -- an AoA  regional  office  desk 
review  and  an on-site  review  at the  SUA.  During  the  desk  review  phase,  we looked  at 
area  plan  guidance  and  program  instructions,  as-well  as the  States  assessment 
instruments  for AAAs  to determine  if they  are  consistent  with Federal  law and 
regulations.  We  also reviewed  priority  services  waivers  and  targeted  populations 
participation  data  from  the  State  Program  Report  for Title  III. 
Following  the  desk  review,  each  State  was sent  a proposed  agenda  for the  site visit, a 
listing of the  AAAs  whose  area  plans  and  assessment  reports  will be  reviewed,  a COpy 
of the  stewardship  review  instrument  (Appendix  A),  and  the  findings  from  the  desk 
review  to be  discussed  during  the  site visit. 
The  review  instrument  focused  on the  guidance  SUAS issued  to AAAs,  on key 
requirements  of Title  III, and  on the  instruments  and  procedures  they  use to  assess 
AAAs  with  those  requirements.  A review  of area  plans  and  assessment  reports 
determine  whether,  and  to what  extent,  they  reflect  OAA  requirements.  The 
instruments  also focus  on the  issues  of SUA  operating  procedures,  and  on training  and 
technical  assistance  activities. 
We  entered  data  from  the  stewardship  review  instruments  into  three  databases.  One 
database  contained  the  responses  to the  open- and  closed-ended  questions  on the 
instrument  and  the  other  two contained  the  reviews  of 151 area  plans  and  assessments. 
The  number  of responses  to questions  vary because  some  questions  did not  apply  to 
the  four  States  in Stratum  4-- NH,  ND,  NV, & DC  -- which  are  single planning  and 
service  area  (SPSA)  States. 
The  percentages  cited  in this report  are  based  on the  responses  to specific  questions 
contained  in the  review  instrument.  The  responses  are  weighted  to reflect  the  sampling 
plan  and  are  projected  to the  Nation.  The  precision  at the  90-percent  confidence 
intervals  vary for each  question  from  plus  or minus  6 to 21 percent  based  upon  the 
nature  of the  question  (categorical  or continuous)  and  the  number  of respondents  to 
each  question. 
3  FINDINGS 
AREA  PLANNING  AND  REVIEW  WORK  WE~  BUT  THERE  AREA  FEW 
wEAKNEsEs 
All States  have  issued  guidance  to their  area  agencies  on aging  (AAAs)  on the 
development  and  content  of area  plans.  In general,  they  have  fully addressed  Section 
306 of the  Older  Americans  Act  (OAA),  which  outlines  what  an area  plan  shall 
contain  and  what  AAAs  will do.  The  States  guidance  satisfactorily  addresses  a 
majority  of the  areas  outlined  in Section  306.  For  a majority  of the  States,  this 
guidance  delineates  or highlights  the  specific  Section  306 provisions  with  the 
expectation  that  the  AAAs  specify how they will accomplish  these  legislative  mandates. 
(However,  in at least  28 percent  of the  States  general  boilerplate  assurance 
statements  are  used  to certi~  compliance  with  Section  306.)  In these  instances,  there 
is no indication  in the  area  plans  as to how the  AAA will meet  the  Section  306 
requirements. 
Three  criteria  that  are  important  to the  overall  development  of a comprehensive 
service  system were  not  addressed  by a significant  percentages  of States  in their 
 
guidance  to the  AAAs.  Specifically:  -
1) 43 percent  of States  do not  address  the  requirement  that  AAAs  coordinate 
Title  III-B  mental  health  services  with the services  of other  mental  health 
agencies  (Sec. 306(a)(6)(M)); 
2)  36 percent  of States  do not  address  the  requirement  that  the  AAAs  will 
conduct  an  annual  evaluation  of the  effectiveness  of outreach  to eligible 
individuals  for the  program  with special  emphasis  on various  targeted 
populations  in our  programs  (Sec.  309(a)(6)(A)). 
3)  29 percent  of States  do not  address  the  requirement  to involve  long term 
care  facility providers  in community-based  system  of long term  care  (Sec. 
306(a)(6)(K));  and 
To  better  understand  why these  criteria  were  missing in the  States  area  plan  format, 
we asked  each  State  that- failed  to address  these  critiria  to explain  how they  ensure 
that  AAAs  were  meeting  the  specific  requirements  of the  Older  Americans  Act.  This 
recognized  that  SUAS can  make  AAAs  aware  of a requirement  without  necessarily 
including  it in their  area  plan  format  or guidance.  In a majority  of cases,  however, 
States  did not  make  AAAs  aware  of the  requirements  nor  did they  review  area  plans 
to insure  that  requirements  were  addressed.  This  occurred  in 5 of the  7 States  in our 
sample  that  did not  have  guidance  on coordination  of Title  III mental  health  services, 
and  in 4 of the  5 States  that  did not  have  guidance  on conducting  an annual  evaluation 
4  of outreach  or on facilitating  the  involvement  of long-term  care  providers  in 
coordinating  community  based  long-term  care. 
Two other  Sections  of 306 were  frequently  not  addressed  in the  States  guidance. 
Forty-four  percent  of States  do not  address  volunteer  opportunities  for older 
individuals  in day care  services  for  children  and  adults,  and  in respite  care  for families 
(Sec. 306(a)(6)(E)),  and  27 percent  of States  do not  address  the  stipulation  that  AAAs 
compile  and  provide  list of higher  education  courses  (Sec. 306(a)(6)(0)). 
Most  States  (76 percent)  use  the  area  plan  as a larger  planning  document  to 
incorporate  State  requirements  and  informational  needs  of the  State  agencies  in 
addition  to those  stipulated  in Section  306.  Most  frequently  these  include: 
1) non-AoA  Title  III funded  Federal  and  State  programs; 
2)	 additional  programmatic  areas  (e.g., AAA  accomplishments,  program 
evaluation  objectives,  corporate  eldercare)  and  financial  information  (e.g., 
carryover,  performance-based  contracting);  and 
3)	 additional  administrative/management  areas  required  by the  State  Agencies 
(e.g., area  agency  on aging administrative  goals,  affirmative  action  plans, 
mission  statements  and  client  tracking  objectives). 
Planning  cycles and  update  frequencies  vary significantly  among  the  States:  36 percent 
have  a 4-year  area  plan  cycle; 38 percent  a s-year  plan  cycle; and  26 percent  a 2-year 
cycle.  In reviewing  the  actual  dates  of the  area  plans,  43 percent  operate  under  the 
Federal  fiscal year  calendar;  the  remainder  have  fiscal years  with  other  starting  and 
ending  dates.  Most  States  (86 percent)  require  AAAs  to update  the  area  plans  at 
least  annually.  However,  9 percent  update  every  two years,  and  the  remaining  5 
percent  update  on an as needed  basis. 
All  States  have  formal  procedures  to review  area  plans.  State  agencies  send  written 
notices  to AAAs  when  plans  do not  meet,  or only partially  meet,  the  States  review 
criteria.  Technical  assistance  is provided  by phone  or in writing.  Responses  are 
required  from  the  AAAs  to the  review  (usually  in 30 to 45 days)  and  acceptable 
revisions  must  be  presented. 
Though  not  stipulated  in  the  language  of the  OAA  or  related  regulations,  22 percent 
of States  grant  AAAs  conditional  approvals  of  deficient  area  plans.  These  AAAs 
receive  their  funding  allocation,  but  are  notified  that  funds  can  be  withheld  if 
conditions  are  not  addressed  by  a specific  date.  Conditional  approvals  most  often 
result  from  inadequate  information,  or the  non-submission  of specific  programmatic  or 
fiscal components  required  by the  States  in their  instructions.  Thirty  percent  of the 
AAAs  in such States  were  conditionally  approved  at the  time  of the  review. 
For  those  Section  306  requirements  most  often  not  addressed  in the  actual  area  plans, 
5
 a close  correlation  was found  between  the  lack  of SUA  guidance  and  the  lack  of AAA 
discussion  in the  actual  area  plans.  For  example,  we noted  earlier  the  lack  of 
guidance  on higher  education,  mental  health,  and  day or respite  care.  In the  review  of 
151 area  plans  we found  that  45 percent  of the  plans  do not  address  the  criterion  to 
list higher  education  courses;  45 percent  do not  address  criterion  to coordinate  with 
mental  health  agencies;  and  30 percent  do not  address  the  criterion  to provide 
opportunities  in day care  centers. 
WAIVERS  ARE  COMMON,  BUT  DO  NOT  ALWAYS  FOLLOW  PROCEDURES 
Section  307(a)(10)  stipulates  that  an AAA  cannot  directly  provide  supportive  services, 
nutrition  services,  or in-home  services,  unless  the  State  approves  a waiver.  Most 
States  (86 percent)  have  criteria  for approving  requests  for the  direct  provision  of 
supportive,  nutritional,  or in-home  services  by the  AAAs.  States  report  that  State 
regulations  and/or  policy usually  stipulate  these  criteria.  In general,  documentation  is 
required  from  the  AAAs  assuring  no other  available  provider  can  effectively  and 
efficiently  provide  that  service  in terms  of program  quality  and  economic  cost.  AIso, 5 
percent  of States  prohibit  any direct  provision  of services  by any of their  AAAs. 
Most  States  (79 percent)  grant  approval  to their  AAAs  to directly  provide  supportive, 
nutritional  or in-home  services.  Among  the  AAAs  in those  States:  41 percent  directly 
provide  supportive  services;  36 percent  directly  provide  nutrition  services;  and  24 
percent  directly  provide  in-home  services. 
Section  306(b)(l)  of O- permits  each  State  to waive  the  requirements  for 
expending  an adequate  proportion  of Title  III-B funds  for access  services,  in-home 
services  and  legal  assistance.  Regarding  this adequate  proportion  requirements,  33 
percent  of States  grant  waivers  to their  AAAs.  Of these  States:  2 percent  granted 
waivers  for access  services  to 27 percent  of their  AAAs;  22 percent  gave waivers  for 
in-home  services  to  18 percent  of their  agencies;  and  16 percent  provided  waivers  for 
legal  assistance  to 6 percent  of their  agencies.  However,  82 percent  of these  States 
did not  publish  their  intent  to grant  the  waiver,  nor  did they  provide  AoA  with  a 
report  on the  waiver,  as required  in Section  306(b)(2)(A). 
ASSESSMENTS  ADDRESS  MOST  REQUIREMENTS,  BUT  NOT  ALWAYS 
ANNUALLY 
Generally,  States  concentrate  their  on-site  assessment  efforts  on reviewing 
programmatic  areas  and  issues  considered  as SUA  or AoA  priorities.  The  on-site 
assessment  review  often  concentrates  on reviewing  AAAs progress  in implementing 
area  plans  and,  in the  case  of single planning  and  service  area  States,  service 
providers  progress  in implementing  service  plans. 
Ass essment Ihstnunent  Content And  Format 
States  are  generally  addressing  many  of the  requirements  identified  in Section  306. 
6  However,  a significant  percentage  of States  do not  address  certain  areas  identified  in 
Section  306(a)(6),  which  stipulates  activities  AAAs  will do. 
Some  of the  more  significant  activities  frequently  missing  on assessment  instruments 
are: 
1) 47 percent  do not  have  criteria  to determine  if AAAs  conduct  an  annual 
evaluation  of outreach  (Sec. 306(a)(6)(A)); 
2)  46 percent  do not  have  criteria  to determine  if AAAs  coordinate  Title  III-B 
mental  health  services  (Sec. 306(a)(6)(M))  or to identi~  agencies  working  in 
areas  of abuse,  neglect  and  exploitation  (Sec. 306(a)(6)(J));  and 
3) 44 percent  of States  do not  have  criteria  to determine  if AAAs  facilitate 
involvement  of long-term  care  providers  in coordinating  community  based 
long-term  care  services  (Sec.  306(a)(6)(K)). 
Other  criteria  frequently  missing from  State  assessment  instruments  are:  1) 60 percent 
of States  do not  address  area  agencies  activities  in providing  volunteer  opportunities 
in day care  services  for children  and  adults  (Sec.  306(a)(6)(E));  and  2) 54 percent  do 
not  determine  if AAAs  compile  a list of higher  education  courses  (Sec.  306(a)(6)(0)). 
Regarding  those  criteria  missing from  SUA  assessment  instruments,  States  were  asked 
to explain  how they  ensure  that  AAAs  were  meeting  the  related  requirements  of the 
OAA.  A majority  of the  responses  revealed  that  the  States  do not  review  AAAs 
activities  in those  areas.  For  example,  all of the  States  not  having  the  criterion 
regarding  conducting  an annual  evaluation  of outreach  reported  that  they  do not 
review  AAAs  activities.  This  could  help  explain  in part  why only half  of the  States 
report  that  all of their  AAAs  conducted  the  annual  evaluation  of the  effectiveness  of 
outreach. 
Regarding  compiling  listings of higher  education  courses,  all of the  States  without  the 
criterion  reported  that  they  do not  review  this activity.  One  State  commented  that  its 
highest  priority  is to  ensure  the  efficiency  and  operations  of those  programs  and 
activities  that  address  those  most  in need.  Efforts  to ensure  that  AAAs  are  compiling 
and  providing  information  on higher  education  courses  were  therefore  not  a priority. 
Most  States  have  also  added  other  significant  items to their  assessment  instruments 
to  obtain  a comprehensive  review  of their  AAAs.  These  include  review  items  on: 
1) additional  State  requirements  on programs  (e.g., targeting,  nutrition 
volunteer,  senior  centers,  eldercare); 
2) area  agency  on aging administration  and  program  management  (e.g., policies 
and  procedures,  staffing  and  organization); 
3) additional  State  requirements  on financial  management  (e.g., procurement, 
contract  management,  accounting  systems); 
7  4) review  of non-AoA  programs  administered  by the  AAAs;  and 
5) identification  of best  practice  models. 
In conducting  this review, we obtained  an overview  of a variety  of methods,  used  by 
sample  States,  to assess  their  AAAs.  In one  State  agency,  a field administration  unit 
(part  of the  larger  umbrella  agency  in which the  SUA  is housed)  conducts  quarterly 
site visits of the  area  agencies  to review  management  issues and  track  achievement 
of goals and  objectives.  This  allows SUA  staff to focus  on the  in-depth  evaluation  of 
the  operations  of the  area  agencies  during  their  on-site  visit. 
Another  State  agency  reported  that  it conducts  its overall  assessment  in a three-cycle 
process  starting  with  the  area  plan  development  and  review  process.  In the  second 
cycle, the  area  agency  completes  a compliance  review  checklist  that  the  State  agency 
staff reviews  and  verifies,  based  on available  documents  at  the  State  agency.  In the 
third  cycle, the  State  agency  program  and  fiscal staff conducts  the  on-site  review  of the 
management  of the  agencies  programs. 
And  another  State  agency  conducts  a focused  assessment  in addition  to its overall 
assessment.  The  focused  assessment  is conducted  on a specific  area  of concern  (e.g., 
subcontractor  monitoring)  identified  as a specific  weakness  of the  area  agencies  based 
on the  previous  years  assessments.  Through  the  focused  assessment,  the  State  agency 
is able  to conduct  a comprehensive  evaluative  review  which would  identi~  specific 
areas  of weakness  and  pinpoint  areas  needing  technical  assistance.  Through  this 
process,  the  State  agency  can determine  how specific  programs  are  operating  and 
assist in identi~ng  best  practice  models  for use by other  AA&. 
Frequency Of On-Site Assessrnenfi 
The  statutory  basis  for  the  expectation  that  State  agencies  assess  and  monitor  the 
activities  of AAAs  is seen  in  Section  307(a)(8).  Through  the  years,  AoA  and  many 
State  agencies  have  interpreted  and  instituted  the  practice  of conducting  an  annual 
on-site  assessment  of area  agencies  to  evaluate  their  programs  and  activities.  Only  32 
percent  of States  report  conducting  on-site  assessments  of  all AAAs  annually;  another 
35 percent  report  doing  so  on  a semi-annual  basis.  The  remaining  33 percent  of 
States  conduct  them  less  frequently  (e.g.,  every  18 months,  every  two  years). 
A closer  review  of the  6 sample  States  who reported  not  doing  at least  an annual  on-
site evaluation  shows that  two reported  that  their  official policy is to do an annual 
on-site  visit; however,  in practice  this has not  taken  place.  One  of these  States  did it 
every 2 years  and  the  other  tried  to do them  all but  missed  several  area  agencies  in its 
annual  review.  For  the  other  States,  one  conducted  an annual  on-site  assessment  for a 
quarter  of its agencies;  another  did the  on-site  assessment  every  18 months  (to 
correspond  to their  3-year  Area  plan  cycle); and  two  States  reported  that  their  last  on-
site  assessments  of  area  agencies  took  place  in FYs  1989  and  1988. 
In  discussing  their  experiences  in conducting  the  annual  on-site  assessments,  several 
8  States  commented  on the  severe  State  budgetary  constraints  they  are  experiencing 
which  have  affected  the  operations  of the  State  agency.  These  budgetary  constraints 
have  resulted  in the  reduction  of State  agency  staff and  travel  funds  which  have 
impacted  on their  ability to conduct  annual  assessments.  These  constraints  have  also 
forced  the  States  to re-examine  the  frequency  and  the  content  of their  on-site  reviews. 
States  have  commented  that  the  practice  of conducting  an annual,  on-site  assessment 
review  may not  be  feasible  in the  near  future  in light of continuing  budgetary 
constraints. 
Other Methodbbgia  Used To Monitor AAAs 
Beyond  periodic,  on-site  assessments,  States  use  other  methodologies  to monitor  the 
performance  of AAAs.  In some  instances  this monitoring  addresses  criteria  not 
included  in the  formal  assessment.  Most  frequently  this monitoring  is as follows: 
1) Ninety-six  percent  of States  use  on-site  reviews.  These  on-site  reviews  used 
to verify documentation  and  data  submitted  on program  and  financial 
reports,  and  to follow-up  on identified  issues.  They  are  also used  to attend 
public  hearings,  advisory  council  meetings,  training  seminars,  and  to observe 
actual  provision  of services  by providers; 
2)  Seventy-eight  percent  utilize  the  review  and  analysis  of monthly  or quarterly 
program  and  fiscal reports.  Reports  are  reviewed  for trends  and 
comparison  of actual  and  projected  service  and  financial  data.  These 
reports  allow States  to monitor  service  costs, service  provision,  participation 
rates,  and  targeting  efforts  of area  agencies.  Telephone  contacts  and/or  on-
site visits are  use to follow up  on deficiencies  revealed  through  the  reports; 
and 
3)  Twenty-eight  percent  conduct  desk  reviews  of self assessment  forms. 
Follow-up  site visits or telephone  interviews  are  usually  used  to veri@ 
responses. 
ALL  AAAs  EVALUATE  ACIWITES  AND  CONDUCT  PUBLIC  HEARINGS, 
BUT  MANY  DO  NOT  ASSESS  THE  EFFECIIVENESS  OF  OUTREACH 
Section  306(a)(6)(A)  of OAA  stipulates  that  the  area  agency  on  aging  will  conduct 
periodic  evaluations  of,  and  public  hearings  on,  activities  carried  out  under  their  area 
plan,  and  will  conduct  an  annual  evaluation  of the  effectiveness  of outreach  to  eligible 
individuals  for  the  program,  with  special  emphasis  on  specific  targeted  populations. 
All  States  report  their  AAAs  have  conducted  both  the  annual  evaluations  of area  plan 
activities  and  the  annual  public  hearings.  However,  only  49 percent  report  that  all of 
their  AAAs  have  conducted  the  annual  evaluation  of the  effectiveness  of  outreach.  Of 
those  States  who  report  that  not  all  of their  AAAs  have  conducted  the  annual 
evaluation  of outreach,  29 percent  of States  did  not  know  whether  the  evaluations 
9  have  occurred;  the  remaining  States  report  from  12.5 to 85 percent  of their  W 
have  conducted  the  evaluation  of the  effectiveness  of outreach. 
Though  not  a requirement  of O- 42 percent  of States  report  analyzing  the  A&% 
evaluations  of outreach.  Of those  States,  36 percent  commented  that  effective 
outreach  in a time  of level  and  limited  service  dollars  has  raised  additional 
programmatic  concerns.  It creates  waiting  lists and  a demand  for services  that  area 
agencies  have  difficulty  supplying. 
SUAs  PROVIDE  TECHNICAL  ASSISTANCE  AND  TRAINING  TO  ADDRESS 
AAA  DEFICIENCIES 
The  most  commonly  reported  deficiencies  identified  by the  SUAs assessments  of 
AAAs were: 
contracting,  monitoring  and  provision  of technical  assistance  to 
subgrantees  or service  providers; 
administrative  and  management  issues  (e.g., training,  shortage  of staff); 
program  administration  (e.g., service  coordination,  documentation  of 
services,  needs  assessments); 
reporting  (e.g., data  collection,  analysis,  delinquent  reports);  and 
weaknesses  in various  programmatic  areas  (e.g., targeting  and  low-
income  participation:  advisory  council  composition  and  use,  outreach). 
Regarding  the  type  of technical  assistance  provided  by the  State  agencies,  States  have 
attempted  to address  many  of the  deficiencies  identified  in the  assessments.  The  most 
common  types  of technical  assistance  and  training  provided  by States  are  in the  areas 
oh  1) program  administration  and  management  (e.g., area  plan  development  and 
planning,  monitoring  and  assessments,  recruitment  of staff,  directors  training);  2) 
grant/financial  management  (e.g., budgeting,  preparation  of RFPs,  financial 
management,  performance-based  contracting);  3) reporting;  and  4) State  policies  and 
procedures  (e.g., policy  and  program  interpretations).  In addition,  a wide variety  of 
specific  programmatic  areas  were  identified.  These  include  nutrition  services,  advisory 
councils,  serving  older  persons  with disabilities,  implementation  of the  Americans  with 
Disabilities  Act  and  its impact  on OAA  programs,  targeting  and  community-based 
systems  of care. 
States  also  use  other  methods  to determine  and  identify  the  need  for technical 
assistance  and  training.  They  include: 
direct  requests  from  area  agencies  and  providers;

analysis  of monitoring  and  assessment  findings;

review  and  analysis  of program  and  fiscal reports;

changes  in Federal/State  program  priorities  and  policies;  and

State  agency  training  survey.

10  Despite  their  ongoing  technical  assistance  efforts,  85 percent  of States  report  their 
area  agencies  still have  unmet  training  and  technical  assistance  needs.  The  most 
common  are: 
program  and  financial  management  (particularly  in the  areas  of 
reporting,  management  information  systems,  and  monitoring); 
.	 resource  development  and  cutback  management; 
targeting; 
new network  personnel; 
advisory  councils;  and 
wide variety  of programmatic  areas  (most  frequently  mentioned-
outreach  and  use of volunteers). 
In  addition,  63 percent  of States  report  that  they  also  have  unmet  technical  assistance 
and  training  needs.  They  include  having  a better  understanding  of what  AoA  wants  in 
terms  of assessments,  monitoring  and  evaluation  of programs,  priorities  of Ao~ 
service  expectations  in terms  of quality  and  quantity,  and  identification  of best  practice 
models.  Other  State  unmet  technical  assistance  and  training  needs  are  targeting, 
reporting  (service  data  gathering  and  analysis),  and  a variety  of specific  program  areas 
(e.g., Americans  with Disabilities  Act,  cost  sharing  and  managing  with  declining 
resources). 
11
 APPENDIX 
A 
Review  Instrument  For  Stewardship  STEWARDSHIP  COMPLIANCE  REVIEW 
Department  of Health  and  Human  Services 
Administration  on Aging 
State  Date 
Primary  Respondent  Telephone 
Review  Team  Leader  Telephone 
-----------------------------------------------------------
1.  Prior to the on-site  visit,  obtmna copy of the Area Plan format  provided  to Area Agencies 
on Aging  (AAAs) j%om the stae  Agency  on A~ng (state  Agency).  Review  and determine 
whether  or not the Area  Plan format  dresses  the criteria  identified  in the following 
table.  Indica/e your  responses  with an X in the approp~e  column  reflecting  these  codes: 
Y (Yes)  =  Total Compliance  with Cderia 
P  (Pa71ial) =  Patil  Compliance  with Ctiteria 
N (No)  =  Not in Compliance  with Criteria 
CRITERIA  Y  P  N  CO~lME~TS 
al  Sec. 306(a)(2) 
contain  an assurance  that  an adequate  proportion  of 
Title  III-B  will  be expended  for  access,  in-home, 
and  legal  assistance,... 
az  speci&  annually,  amounts  expended  in previous 
fiscal  year  for  access,  in-home  and  legal  assistance; 
b  Sec. 306(a)(3)t?L1321.3 
designate community focal points for services; 
c  Sec. 306(a)(4) 
establish  and  maintain  information  and  referral 
services; 
dl  Sec. 306(a)(5) 
assure  that  preference  is given  to serving  those  of 
greatest  economic  or social  needs  (particularly  low-
income  minoritic9)... 
d~  have  proposed  methods  to serve  those  of greatest 
economic  or sociaI  needs... 
A-1  CRITERIA  Y  P  N  COMMENTS 
d3 
assure  each  service  provider  agreement  will  specifj 
how  the  service  provider  will  serve  low-income 
minorities  . . .in at least  the same  proportion... 
d4  identifi  numbers  of and  describe  methods  used  to 
serve  low-income  minorities  in previous  fiscal 
year. . . 
ti  assure  use of outreach  methods . . .with  special 
emphasis  on rural  elderIy,  greatest  economic  or 
social  needs  (with  particular  attention  to low-income 
minorities),  and  severe  disabilities; 
el  Sec.  306(a)(@ 
conduct  periodic  (at least  annually)  evaluations 
e2  conduct  public  hearings  on Area  Plan  activities... 
e3  conduct  an annual  evaluation  on outreach... 
e4  provide  technical  assistance  to service  providers... 
e5  consider  views  of recipients  of services  in the 
development  and  administration  of  &ea  Plan... 
e6  monitor,  evaluate,  and  comment  on policies, 
actions...  affecting  elderly  . . . 
e7  provide  volunteer  opportunities  for  older  individuals 
in day  care  services  for children  and  adults  and 
respite  for  families... 
e8  establish  an Area  Agency  advisory  council... 
e9  develop  and  publish  methods  for determining 
priority  of services... 
elo  establish  procedures  for coordinating  Title  III 
programs  with  other  Federal  programs  as specified 
in SW.  203(b) . . . 
ell  facilitate  coordination  with  community-based,  long-
term  care  services... 
e12  identifi  agencies  and  organizations  working  in areas 
of abuse,  neglect,  and  exploitation  of older  people... 
e13  determine  unmet  service  needs  of abused,  neglected, 
and  exploited  older  individuals... 
e14  facilitate  involvement  of long-term  care  providers  in 
coordinating  community-based  long-term  care 
services... 
e15  coordinate  priority  sewices  with  Alzheimers  disease 
organizations...  CRITERIA  Y  P  N  COMMENTS 
e16  coordinate  Title  III-B  mentai  health  services  with  the 
services  of other  mental  health  agencies  and 
organizations... 
e17  conduct  outreach  services  to older  Indians... 
e18  compile  and  provide  list of higher  education  courses 
available  to and  enrollment  policies  for older 
individuals  in each  planning  and  service  area... 
f  Sec.  306(a)(7) 
assure  proper  use  of Title  III-D  funds... 
1?  Sec.  306(a)(10) 
assure  proper  use  of Title  III-G  funds... 
At this point,  you  should  have completed  the in-house  compliance  review  of the area plan 
format  provided  to the AAAs.  For each criteria Ia-lg  indic~ng  an entry  of LVOor PARTL4.L, 
list it in the j%t  column  of questzon2 prior  to the on-site interview.  Ask question  2 duting  the 
on-site visit following  the bnef explantion  initiating  the interview. 
2.  A few  weeks  ago,  we  requested  a copy  of the  area  plan  format  provided  to the  Area 
Agencies  on  Aging  concerning  stewardship.  This  format  was  reviewed  against  Section  306 
of the  Older  Americans  Act.  During  this  review,  we  identWled  parts  of Section  306  which 
were  only  partially  addressed,  or  which  were  not  addressed  in your  area  plan  format.  For 
these,  I need  to understand  how  the  State  Agency  directs  and  ~~ides  the  MS  to  ensure 
that  stewardship  requirements  are  met  for  those  criteria  not  addressed  or partially  addressed 
in your area plan  format. 
Criteria  # with 
No or Partial  AEencv Res~onse 
A-3  (lf  additional  space  is required,  use the back  of the previous  page.) 
3.  Beyond that  required  by Sec.  306 of OAA,  what significant  items have you added to area 
plan formats? 
b.  Dont Know  (Check  if applicable) 
A-4  4.  What are  the begizming and ending dates of your most current  Area Plan 
Begitig  date -
::  Ending  date -
5.  IF UTI-YEAR  PLANS:  How often are they up-dated? 
6.  What  follow-up  procedures  do you have to address  sections  in Area Plans that did not meet 
or only partially  met criteria  of the State Agencys  Area  Plan  review? 
a. 
b.  Dont  Know  (Check ~~applicable) 
7. 
~e  anY*S  operathg  under  a conditiondly  approved  Area  Plan? 
a.	 Yes,  (If yes), 
(1)  HOW  m.ny  AA%  have condition  approval  for Area Plans? 
(indictie  number) 
(2)  What  factors  may genedly  result  in a condition  approval? 
(a) 
(b) 
(c) 
(d) 
(e)  Don t Know  (Check Z~applicable) 
b.  No  (1J No,  skzp to question  9) 
c.  Dont Know  (Check Z~ applicdle) 
8.	 What are State Agency  procedures  to bring  conditionWy-approvd  Area P1ans into full 
approval? 
a. 
b.  Dont Know  (Check z~applicdle) 
A-5  9.  Does the State  Agency  have  any  criteria  for  approving  the  direct  provision  of  supportive 
services,  nutrition  services,  or  in-home  services? 
a.  Yes  (If yes),  What are they? 
b.  No 
c.  Dont Know  (Check if applicable) 
10.  Are  any  &%As  approved  by the State Agency to directly  provide  supportive  services, 
nutrition  services  or in-home  services? 
a.  Yes 
b.  No  (If No,  skip to question  12) 
c.  Dont Know  (Check if applicable) 
11.  What  are  the  number  of AAAs  providing  each? 
a.  Number  of Ws  directly  providing  supportive  services 
b.  Number  of A&U  directly  providing  nutrition  sewices 
c.  Number  of AAAs  directly  providing  in-home  services 
d.  Dont  Know,  (Zdenti!  whether Don t how  applies  to a, b,  c, 
or combintion): 
1~,  State Agencies  have the ability  to waive the adequate  proportion  requirement  for Title III-B 
semices.  How  many  A&%  have  been  granted  waivers  for:  (Fill-in with a-c and record 
response) 
a.  Access  services? 
b.  In-home  services? 
c.  Legal  assistance  services? 
d.  Dont Know,  (Identi!  whether Don t how  applies  to a, b,  c, 
or combintin): 
/NOTE:  A7TACHMEATT B PERTNNS  TO IN-HOUSE  DESK REVIEW  OF MA  W/UVERS 
- IF ANY  INFORMLHTON IS MISSING  OR INDIC.TES  DISCREPMCIES,  ASK 
ABOUT  THESE  DURING  IHE  ON-SITE  VISIT /iT  1271S POINV 
A-6  13.  Prior to the on-site  visit,  obtan a COpyof the instrument  used by the St&e Agency  to 
assess  compliance  and pe~onnance  of AAAS with stewardship  lizw and reguhtions.  If the 
questions  on stewardship  are pati  of a larger review  instrument,  ask the State Agency  to 
identifi  or highlight  those items petimning to the review  of stewardship practices.  Have 
the St&e Agency  mark the instnxment(s)  with the applicable  ctieriu  (e.g.,  a, b,  C, etc.) 
using a provided  copy of the criteria.  This infonntional  request should be included  in 
the letter  that is sent to the State Agency  outlining  the  Complh.nce  Review.  Review  and 
determine  whether  or not the assessment  instruments  address  the stewardship  criteria 
iiientified  in the following  table.  Indicate your  responses  with an X in the approp~e 
column  reflecting  these  codes: 
Y (Yes)  =  Total Compliance  with Criteti 
P (Pati)  =  Patil  Compliance  with Giteriu 
N (No)  =  Not in Compliance  with Criteria 
Dunng the desk  review,  if the assessment  instrument  and retied  matetils  do n~  include 
those items  necessary  to make a determintion  of compliance  (1(, P,  or N),  mark  NA (Not 
AvailaMe)  in the Comments  section  of the table. 
coImlENTs 
CRITEIUA  Y  P  N 
al  Sec.  306(a)(2) 
contain  an assurance  that an adequate  proportion  of 
Title  III-B  will  be expended  for access,  in-home, 
and  legal  assistance,... 
b  Sec.  306(a)(3)~  1321.3 
designate  community  focal  points  for  services: 
c  Sec.  306(a)(4) 
establish  and  maintain  information  and  referral 
services; 
dl  Sec.  306(a)(5) 
assure  that  preference  is given  to serving  those  of 
greatest  economic  or social  needs  (particularly  low-
income  minorities)  . . . 
d2  have  proposed  methods  to serve  those  of greatest 
economic  or social  neals... 
d3  assure  each  service  provider  agreement  will  speci~ 
how  the  semice  provider  will  scne  low-income 
minorities...  in at least  the same  proportion  . . . 
A-7  COMMENTS 
CRITERIA  Y  P  N 
d5  assure  use of outreach  methods  . . .with  special 
emphasis  on  rural  elderly,  greatest  economic  or 
social  needs  (with  particular  attention  to low-income 
minorities),  and  severe  disabilities; 
el  Sec.  306(a)(6) 
conduct  periodic  (at least  annually)  evaluations 
e2  conduct  public  hearings  on Area  Plan  activities... 
e3  conduct  an annual  evaluation  on outreach... 
e4  provide  technical  assistance  to service  providers... 
e5  consider  views  of recipients  of services  in the 
development  and  administration  of Area  Plan... 
e6  monitor,  evaluate,  and  comment  on policies, 
actions...  affecting  elderly . . . 
e7  provide  volunteer  opportunities  for  older  individuals 
in day  care  services  for children  and  adults  and 
respite  for  families... 
e8  establish  an Area  Agency  advisory  council  . . . 
e9  develop  and  publish  methods  for determining 
priority  of services... 
e10  establish  procedures  for  coordinating  Title  III 
programs  with  other  Federal  programs  as specified 
in Sec.  203(b) . . . 
ell  facilitate  coordination  with  community-based,  long-
term  care  services... 
~1~  identi & agencies  and  organizations  working  in areas 
of abuse,  neglect,  and  exploitation  of older  people... 
e13  determine  unmet  service  needs  of abused,  neglected, 
and  exploited  older  individuals... 
e14  facilitate  involvement  of long-term  care  providers  in 
coordinating  community-based  long-term  care 
services... 
e15  coordinate  priority  services  with  Alzheimers  disease 
organizations... 
e16  coordinate  Title  III-B  mental  health  semices  with  the 
senices  of other  mental  health  agencies  and 
organizations... 
e17  conduct  outreach  services  to older  Indians... 
A-8  COMMENTS 
CRITERIA  Y  P  N 
e18  compile  and  provide  list of higher  education  courses 
available  to and  enrollment  policies  for older 
individuals  in each  planning  and  service  area... 
f  Sec.  306(a)(7) 
assure  proper  use  of Title  III-D  fi.mds... 
~  Sec.  306(a)(10) 
assure  proper  use  of Title  III-G  funds... 
For each cderiu  13a-13g  indicting  ~  entry of NO, PmT~,  or NOT AVLABLE,  list ii in 
the jirst  column  of que~on 14 pn.or to the on~site interview.  NOTE:  For those  items marked 
NA as a result of the desk  review,  State Agency  responses may indicate  conve~-ng  the NA to  Y, 
P, N,  or to CMSL  (Criteti  met at State level) or NSC (Sttie  Agency  does not address  this 
applicable  Fedeml  criteti).  Ask  question  14 dunngthe on-site  visit. 
14.  We  have  reviewed  your  assessment  instrument  for  AAAs  and  note  that  some  requirements 
of Sec.  306  of the  OAA  are  not  covered.  HOW do  you  ensure  that  MS  are  meeting  the 
requirements  of the  Older  Americans  Act  in the  following  areas? 
Criteria  # with 
No,  Partial,  or 
Not  Available  entrv  A~encv  Response 
(If adliitional  space  is required,  use the back of the previous  page.) 
A-9  15.  Beyond  that required  by Federal  law or regulation,  what si~nifica.nt items have you added to 
your assessment  instrument  for assessing  AAAs? 
a. 
b.  Dont Know  (Check if applicable) 
16.  HOW  frequently  does the State Agency  perform  on-site  assessments  of Ms? 
a.  Annually 
b.  Semi-annually 
c.  Quarterly 
d.  Monthly 
e.  Other,  (Specifi  time period) 
f.  Dont Know  (Check if applicable) 
17.  What  were the beginning  and ending  dates of the last complete  cycle of assessments? 
a.  Beginning  Date  -
b.  Ending  Date  -
18.  During  your last review  cycle,  were all AAAs assessed? 
a.  Yes 
b.  No,  (If No) (1)  How  A&h  were  assessed? 
(a)  nf 
W1 
Number  Assessed  Totid #  AA/h 
(b)  Dont Know  (Check if applicable) 
(2)  Why werent  all of the AAAs assessed? 
(a) 
(u  Dont Know  (Check if applicable) 
c.  Dont Know  (Check if applicable) 
A-10  19.  What other  processes  are in place to monitor  the performance  of -s?  (Check all 
applicable  responses) 
a.  On-site  review 
b.  Desk review  of self-assessment  form 
c.  Telephone  interviews 
d.  Other  (Specifi) 
(1)
\/ 
(2) 
(3) 
20.  Provide  a brief  description  of how  each  process  is USed  to  monitor  the performance  of 
AAAs.  (Description  should be provided for  each applicable  response provided  in question 
19) 
21.  What  were  the most common  deficiencies  revealed  in the last cycle of assessments  of the 
Area Agencies? 
a. 
b. 
c. 
d. 
e. 
f.  Dont Know  (Check if applicable) 
A-n  22.	 Has the State Agency  implemented  proc~ures  to ensure  that issues or concerns  mised 
during  an assessment  of an Area Agency on Aging are resolved? 
a.  Yes @~yes),  Please  describe: 
b.  No  (If no),  Why not? 
c.  Dont Know  (Check if applicable) 
23.	 What  percentage  of your  MS  conducted  the  annual  evaluation  of activities  carried  out 
under  the  Area  Plan?  [Sec.  306(a)(6)(A)] 
(Indic&e percentage) 
24.	 What  percentage  of  your  #@As  conducted  the  public  hearings  on  activities  carried  out  under 
the  Area  Plan?  [Sec.  306(a)(6)(A)] 
(Indicate percentage) 
25.	 What  percentage  of your MS  conducted the annualevaluation of the effectiveness  of 
outreach  (to  identify  and  inform  individuals  eligible  for  assistance,  with  special  emphasis  on 
the  rural  elderly;  those  of greatest  economic  or  social  need;  and  older  individuals  with 
severe  disabilities)?  [Sec.  306(a)(6)(A)] 
(Indicate percentage)  26.	 Have  you  analyzed  the:  (Fill-in  the  remt-underof the question  with a,  b, and C.  Indicate 
response for  each) 
a.  evaluation  of activities? 
(1)  Yes (If Yes), What  are  your  primary  observations  based  on  the  analysis? 
(2)  No

(3)  Dont Know  (Check if applicable)

b.  results  of public  hearings? 
(1)  Yes (If Yes), What  are  your  primary  observations  based  on the  analysis? 
(2)  No

(3)  Dont Know  (Check if applicalde)

c.  evaluation  of outreach? 
(1)  Yes (If Yes), What  are  your  primary  observations  based  on  the  analysis? 
(2)  No

(3)  Dont Know  (Check if applicable)

A-13  27.  What  technicN  assis~ce  andtmkkg  hasthe  Stite  Agency  providd  to MsM  order  to 
address  any identifkd  deficiencies? 
If technical  assistance  or trmninghas been provided,  indicate  on the following  table the 
type  of technical  assistance  or trazningprovided,  how the need was determined,  and how 
the technical  assistance  or trmning was provided,  (e.g.,  memoranda,  consuhznts, 
telephone  caIls, on-site  visits,  etc.). 
L 
TECHNICAL  HOW  NEED  FOR  HOW  TECHNICAL 
ASSISTANCE  OR  TECHNICAL  ASSISTANCE  ASSISTANCE  OR 
TRAINING  PROVIDED  OR  TRAINING  TRAINING  PROVIDED 
DETERMINED 
(a) 
@) 
(c) 
(d) 
(e) 
(f) 
(9 
m) 
(i)  Dont Know  (Check if applicable) 
28.  Do the Ws  have any unmet training  or technical  assistance  needs  to their 
stewardship  activities? 
a.  Yes (If yes),  Please describe: 
. 
b.  No 
c.  Dont Know  (Check if applicable) 
A-14  29.  Does the State Agency  have any unmet  training  or technical  assistance  needs related  to 
stewardship  activities? 
a.  Yes (If yes),  Please  describe: 
b.  No 
c.  Dont Know  (Check if applicable) 
30.  l%e preselected  sample  of 10 Area Agencies  on Agrngwere identified  prior  to the on-site 
visit.  Khis sample  is to be used throughout  the compliance  review process for  all five 
areas,  the jirst  compliance  review  being Stewardship. 
For the sample AAAs,  obtun the most  current Area Plan.  Review  each Area  Plan and 
determine  the extent to which the plun  addresses  the statuto~  and regulatory  cdeti 
identified  in Attachment  A.  Recoti  your  responses  on the following  table  unngthese 
codes: 
. 
Y (Yes)  =  Total  Compliance  with Criteria 
P (Pa&)  =  Pa&  Compliance  with Cn!teti 
N (No)  =  Not in Compliance  with Ctien!u 
NSC  =  No State  Criteti  (State Agency  does not use this 
Federal  criteti  - identified  through  in-house  review  of 
St&e Agencys  area pkzn format) 
o  =  Other Finding  @rovide explan~on  and indicate  by 
repoti  number  and criteria  number  in the  Comments 
section following  the table) 
Name 
Sample  1  2  3  4  5  6  7  8  9  10 
Number 
Criteria 
al 
a2 
b 
A-IS  Name 
Sample  1  2  3  4  5  6  7  8  9  10 
Number 
c 
dl 
d2 
d3 
d4 
Ci5 
el 
e2 
e3 
e4 
e5 
e6 
e7 
e8 
e9 
e10 
A-16  Name 
Sample  1  2  3  4  5  6  7  8  9  10 
Number 
ell 
e12 
e13 
e14 
e15 
e16 
e17 
e18 
f 
g 
COMMEN:T S
A-17  31.  For the sample AAAs,  obtain the most cuwently  completed  annual  cycle of State Agency 
assessment  instnzments  and corresponding  assessment  repotis  (if any).  Review  the 
assessment jindings  and determine  the extent to which each of the sample  AAAs  were in 
compliiznce  with each of the cnteriuidentified  in Attachment  A.  Record your  responses 
on the following  table  using these  codes: 
Y ~es)  =  Total Compliance  with Criteti 
P (Pa&)  =  Pati  Compliance  with Criteria 
N (No)  =  Not in Compliance  with Criteria 
NSC  =  No Sta$e Ctieria  (State Agency  does not assess this 
Federal  criteriu - identified  through  in-house  review of 
State Agencys  assessment  tool and retied  m~eriuls)
CM.SL4 =  Cdeh  metal  State level 
o  =  Other Finding  (@ovide  exphn&on  and indicate  by 
repoti  number  and cziteriiz number  in the  Comments 
section following  the table) 
Name 
Sample  1  2  3  4  5  6  7  8  9  10 
Number 
Criteria 
al 
b 
c 
dl 
d2 
d3 
ti 
el 
A-18  Name 
Sample  1  2  3  4  5  6  7  8  9  10 
Number 
e2 
e3 
e4 
e5 
e6 
e7 
e8 
e9 
e10 
ell 
e12 
e13 
e14 
e15 
e16 
e17 
A-19  Name 
Sample  1  2  3  4  5  6  7  8  9  10 
Number 
e18 
f 
g 
COMMENTS: 
flNTERVIEW  COMPLETED] 
A-20