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Housekeeping

• This webinar is being recorded

– Recordings and slides can be found 

https://acl.gov/about-acl/administration-aging-programinstructions

– Please allow 1-2 weeks for recording and slides to post

• All attendees are in listening only mode

• Place all Questions in the Q&A box 

– Questions will be answered live

• CART Services are provided, if needed please click 

the link in the chat box! 

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Intrastate Funding Formula

State Plan Guidance (SPG)

OAA Funding Formula Training

Alice Kelsey and Rhonda Schwartz

ACL/AOA

October 20, 2021
Training Overview

• Purpose: Review the Intrastate Funding Formula Guidance 

as it applies to state plans

• What we will cover:

- Due Dates

- Interstate Funding Distribution

- Intrastate Funding Formulas

> OAA funds subject to IFF 

> OAA requirements

- IFF Elements – Required/Optional

- Process Requirements for IFF Changes

- Single PSA Requirements

- Other State Plan Guidance Trainings

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State Plans Due to ACL on 

July 1, 2022

• Arizona

• Arkansas

• District of Columbia

• Indiana

• Minnesota

• Mississippi

• North Dakota

• Ohio

• Oklahoma

• Texas

• Vermont

• Washington

• Wisconsin

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State Plans Due to ACL on 

July 1, 2023

• Alaska

• American Samoa

• Colorado

• Connecticut

• Georgia

• Guam

• Hawaii

• Louisiana

• Michigan

• Missouri

• Montana

• Nebraska

• New Hampshire

• New York

• North Carolina

• Norther Marianas

• Oregon

• Rhode Island

• Utah

• Virginia

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State Plans Due to ACL on

July 1, 2024

• Alabama

• Delaware

• Idaho

• Illinois

• Maine

• Nevada

• Pennsylvania

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State Plans Due to ACL on

July 1, 2025

• California

• Florida

• Iowa

• Kansas

• Kentucky

• Maryland

• Massachusetts

• New Jersey

• New Mexico

• Puerto Rico

• South Carolina

• South Dakota

• Tennessee

• West Virginia

• Wyoming

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Interstate Funding

• Interstate Funding Formula: How ACL allocates funds to States

• Statutorily Defined in the OAA

– Title III Part B, C & D

▪ State’s population aged 60+

– Title III Part E

▪ State’s population aged 70+

– NSIP

▪ Number of eligible meals served in the prior year

– Title VII

▪ State’s population aged 60+

• Minimum Allocations: Title III and Title VII

• Hold Harmless: Title III Parts B and C1 and Title VII

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Intrastate Funding

• Intrastate Funding Formula (IFF): How a State 

allocates funds to the PSAs 

– The SUA must distribute Title III B, C-1, C-2 & E 

per IFF approved by ASA

– Title III D funding may be distributed per a 

different formula approved by ASA

– NSIP must be allocated per State Policy

– Title VII not subject to IFF

• ASA Advance Approval Required for Changes

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Title IIID

• If a State elects to use a different formula 

for Title III D, the formula should give 

priority to areas of the State:

1. Which are medically underserved; and

2. In which there are large numbers of 

individuals who have the greatest 

economic and social need for such 

services

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Distribution of Funding

• After any State Plan and/or LTCO funding 

has been allocated, the remaining funds for 

Title III must be distributed via the IFF to 

the PSAs

– Funds may not be held or expended at the 

State level

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Older Americans Act

OAA, Sec. 305(a)(2)(C) 

“States shall, 

(C) in consultation with area agencies, in accordance with 

guidelines issued by the Assistant Secretary, and using the best 

available data, develop and publish for review and comment a 

formula for distribution within the State of funds received under 

this title that takes into account-

(i) the geographical distribution of older individuals in the 

State; and 

(ii)the distribution among planning and service areas of 

older individuals with greatest economic need and older 

individuals with greatest social need, with particular 

attention to low-income minority older individuals.”

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Older Americans Act Continued

OAA, Sec. 305(d) 

(d) The publication for review and comment required by 

paragraph (2)(C) of subsection (a) shall include—

(1) a descriptive statement of the formula’s assumptions and 

goals, and the application of the definitions of greatest 

economic or social need, 

(2) a numerical statement of the actual funding formula to be 

used, 

(3) a listing of the population, economic, and social data to be 

used for each planning and service area in the State, and 

(4) a demonstration of the allocation of funds, pursuant to the 

funding formula, to each planning and service area in the 

State. 

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Requirements

• Descriptive Statement

• Data Source

• Factors and Weight

• Allocation by PSA

• Numerical/Mathematical Statement

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Descriptive Statement

• Descriptive Statement must include the formula’s:

– assumptions and goals, and 

– the application of the definitions of greatest economic 

or social need

• Discloses if, prior to distribution under the IFF to 

the AAAs, funds are deducted from Title III funds 

for: 

– State Plan Administration and/or Long Term Care 

Ombudsman allocations 

• A statement explaining how NSIP funds are 

distributed

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Descriptive Statement: Part D

• A separate descriptive statement may be 

provided for Title III Part D, to target 

– medically underserved areas and areas in which 

there are a large number of older individuals who 

have the greatest economic and social need for 

such services

• If a separate formula is used for Part D, a 

separate descriptive and 

numerical/mathematical statement is required

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HRSA - Medically Underserved 

Areas

• Defined by HRSA as having a shortage of 

primary care health services within 

geographic areas 

(https://bhw.hrsa.gov/workforce-shortageareas/shortage-designation#mups) 

• MUA Find tool: 

https://data.hrsa.gov/tools/shortage-area/muafind

• Can locate MUAs at State/County/Census 

Tract levels

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Data Sources

• List of the data used by planning and service area 

• Provide the source of the data used to run in the IFF

• States must use the “best available data” 

– Most current US Census

– More recent US Census estimates from the American 

Community Survey; 

– Other more recent data of equivalent quality available in 

the State also may be considered

• Warning -- use only of decennial US Census data

– Only updating data once each decade may result in 

significant demographic changes that could lead to 

substantial changes in funding allocations among the 

planning and service areas

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American Community Survey

• https://www.census.gov/programssurveys/acs

• Conducted each year by U.S. Census 

Bureau

• Data available in 1-year estimates (12 

months of data) and 5-year estimates (60 

months of data)

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Comparison – ACS Surveys

1-year estimate

• Data only for populated 

areas 65,000+

• Smallest sample size

• Less reliable

• More current data

5-year estimate

• Data for all areas

• Largest sample size

• More reliable

• Less current data (due to 

inclusion of data over 5 

year period)

Source: https://www.census.gov/programssurveys/acs/guidance/estimates.html; retrieved 10/12/2021

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ACS Survey Subjects

• https://www.census.gov/programssurveys/acs/guidance/subjects.html

• Subjects include social, housing, economic 

and demographic characteristics

• Information available by disability status

– e.g., cognitive, ambulatory, self-care, and 

independent living difficulty

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Factors and Weights

• A descriptive statement of each factor

– e.g., 65+, with limited English proficiency; and

• Weight/percentage used for each factor 

– e.g., 65+, with limited English proficiency = 15%

• Factors should help to achieve the OAA requirement 

that preference be given to older individuals with 

– greatest economic need, and 

– older individuals with greatest social need,

– Particular attention given to:

▪ low-income older individuals, including 

o low-income minority older individuals, 

o older individuals with limited English proficiency, and 

o older individuals residing in rural areas

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Factors & Weights

Equity Considerations

• Do the factors help to distribute funds as 

contemplated by the OAA?

• Even if the other IFF requirements are met, a 

State may be asked to update the factors.

• Examples to consider:

- 50% of funds go out as base, 70% of remainder by age 60+

- Age as sole indicator of frailty/need for assistance

- Living alone as sole indicator of social isolation

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Allocation by PSA

• Demonstration of the allocation of funds, 

pursuant to the funding formula, to each 

planning and service area in the State

• Allocations of funds by planning and 

service area based on the IFF segmented 

by Part of Title III 

– e.g., chart of PSA X, IIIB Supportive Services, 

$900,000

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Planning and Service Area

• The IFF should allocate funds by planning and 

service area

• An Area Agency on Aging’s (AAA) region may 

include more than one planning and service 

area (PSA)

• Older Americans Act Sec. 102 (43) 

– The term ‘‘planning and service area’’ means an 

area designated by a State agency under section 

305(a)(1)(E), including a single planning and 

service area described in section 305(b)(5)(A)

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Numerical/Mathematical Statement

• Required for Parts B, C, D, and E

– i.e., would allow member of general public to input 

data to see results of various scenarios

• A separate numerical/mathematical statement may 

be provided for Title III Part D 

– To target the medically underserved and which there 

are a large number of older individuals who have the 

greatest economic need for such services

– If a separate formula is used, a separate descriptive 

and numerical/mathematical statement is required 

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Numerical/Mathematical Statement

Continued

• May include numerical statement on how 

state funds, Title VII, Title III-B 

Ombudsman, and/or NSIP funds are 

distributed, but is not required

– Prior approval is not required for amendments 

– Informational amendments should be 

submitted if there are changes

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Minimum Allocations

• States may use a minimum allocation of funds in 

their IFFs to ensure viable funding across the entire 

state

• Examples (not an all-inclusive list):

– Fixed dollar amount of minimum allocation by Part; 

– Minimum percentage of the total state allocation by 

Part;

– Allocation received must at least equal the allocation 

received in a specified year;

– No PSA may receive more than a specified 

percentage or dollar figure reduction in any given year 

from the prior year

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IFF Amendment - Process

• Formula amendments are approved in advance by the ASA in the 

State Plan

– If amendment does not coincide with new State Plan submittal, changes 

must be submitted as a State plan amendment for advanced approval

• Proposed statement and formula must be published for review and 

comment by older persons, other appropriate agencies and 

organizations and the general public

• AAAs must be consulted and offered an opportunity for input

• Public hearing can be held at same time as State Plan hearing

– Hearing notice must clearly indicate that the IFF is being changed

• Process requirements apply any time the formula is amended

• Submission to ACL must show compliance with the requirements

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IFF Amendments - Requirements

• The publication for review and comment must 

include—

(1) a descriptive statement of the formula’s 

assumptions and goals, and the application of 

the definitions of greatest economic or social 

need,

(2) a numerical statement of the actual funding 

formula to be used,

(3) a listing of the population, economic, and social 

data to be used for each planning and service 

area in the State, and

(4) a demonstration of the allocation of funds, 

pursuant to the funding formula, to each planning 

and service area in the State.

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Single Planning & Service Area 

States and Territories

• Alaska

• American Samoa

• Delaware

• Guam

• Northern Mariana 

Islands

• Nevada

• New Hampshire

• North Dakota

• Rhode Island

• South Dakota

• Washington, D.C.

• Wyoming

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Single PSA Requirements

• Must Include:

– descriptive statement as to how the state 

determines the geographical distribution of the 

Title III funding, and 

– how the state targets the funding to reach 

individuals with greatest economic and social 

need, with particular attention to low-income 

minority older individuals

• Numerical/mathematical statement is not 

required

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State Plan Guidance Trainings

• State Plan Guidance Overview (9/27/2021): 

https://acl.gov/about-acl/administration-agingprogram-instructions

• Developing Performance Measures with Clear 

Outcomes: November 15th at 2:00 EST

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Questions

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