ACL COVID-19 Response · Program Reporting Guidance · Page 4 

# PROGRAM REPORTING GUIDANCE – COVID RESPONSE

## ACL Title III Older Americans Act – State Program Report (SPR)

May 11, 2020 – Revision 1: Includes revised guidance on reporting of expenditures on Section II.A & II.E

ACL is issuing this guidance regarding programmatic reporting on the FFCRA and CARES Act supplemental grant funds, as well as services provided by states exercising flexibility under a major disaster declaration (MDD). ACL instructs states to use the annual State Program Report (SPR), which is the existing process for reporting OAA services. ACL is not creating any new timeframes, service definitions, or new data elements for reporting. ACL is giving guidance and examples for states to use the existing annual SPR requirements and State Reporting Tool (SRT) system to report COVID response activities. Due to COVID response, ACL understands that clients, service units, expenditures, and expenditures per unit will differ greatly from prior year SPR reports. ACL asks states to do their best under challenging conditions to include detail on how COVID has affected program operations via narrative information reported on Section IV.A of the SPR and variance explanations, as appropriate. 

In terms of fiscal reporting, FFCRA and CARES Act funds are issued under a separate grant award number; therefore, funds must be accounted for separately from the regular issuance of Title III Older Americans Act funding. States are required to continue maintaining appropriate records and documentation to support the charges against the Federal awards.

Because grant funds were awarded before programmatic reporting guidance was disseminated, ACL understands that grantees may be tracking these funds in a variety of ways depending on grantee reporting system and administration of funds. ACL urges states to work closely with their aging services providers to update them on COVID-related programmatic reporting information and to coordinate the timing and format for those providers to report on the number of people served and the number of units of service provided using FFCRA, CARES Act, and any other supplemental COVID-related funds, in accordance with this guidance. 

ACL appreciates the commitment and responsiveness of the national aging network regarding the unprecedented COVID public health emergency. ACL encourages states to include programmatic reporting of expenditures related to COVID response that are usually outside the normal realm of operations. Subject to each program’s policies and procedures, such expenditures may include:

Payment of senior center utilities even if no programming was occurring in the senior center for a period of time due to COVID;

Payments for use of other sites (e.g., congregate meal sites, senior centers) or to other staff (e.g., former congregate meal site staff) for preparation and distribution of meals and other supplies;

Increased expenditures per unit of service due to the need to provide staff with personal protective equipment; and

Coverage of administrative leave for employees that were unable to work due to COVID program closures.

Such expenditures should be included with the service for which they are reported.

ACL intends to use the data collected to show accountability for the supplemental funding received, as well as to demonstrate the scope and reach of the aging network’s involvement in COVID response. ACL thanks the members of the national aging network for their efforts to report accurate, complete data regarding service to older adults and family caregivers.

ACL recognizes that as programs respond to a “new normal” future guidance regarding programmatic reporting may be needed, and ACL will work with the aging network in order to develop this future guidance.

# Service Definitions and Units as applied to COVID Response

## Section I.A, I.B, I.C, and I.D Reporting

*Services to Older Adults*

States should report services to Elderly Individuals by Service on Section I.A-D. ACL understands that due to increased demand and volume under emergency response conditions, there may be higher levels of missing client demographic data. ACL encourages States and aging services providers to collect and report demographic data to the greatest extent practicable. ACL also expects that any significant missing data and variances be explained, including those variances related to COVID response.

The following are **existing SPR Title III service definitions**, with examples updated for how to report due to COVID response. This list is not exhaustive. These are the categories ACL identified as applicable given how services are being delivered related to COVID response.

**Please see Section II.E Other Services for information on how to report services to Elderly Individuals that are not separately reported in Sections I.A, I.B, I.C, or I.D.**

ACL is not creating any new timeframes, service definitions, or new data elements for reporting. Please see the following excerpts from the current State Program Report definitions that may also apply, which include:

**B. Standardized names, definitions and service units are provided for the services that are singled out in the SPR for reporting**

**Personal Care** (1 Hour) -- Personal assistance, stand-by assistance, supervision or cues. 

**Chore** (1 Hour) -- Assistance such as heavy housework, yard work or sidewalk maintenance for a person. 

**Adult Day Care/Adult Day Health** (1 hour) – Personal care for dependent elders in a supervised, protective, and congregate setting during some portion of a day. Services offered in conjunction with adult day care/adult day health typically include social and recreational activities, training, counseling, and services such as rehabilitation, medications assistance and home health aide services for adult day health. 

**Case Management** (1 Hour) -- Assistance either in the form of access or care coordination in circumstances where the older person is experiencing diminished functioning capacities, personal conditions or other characteristics which require the provision of services by formal service providers or family caregivers. Activities of case management include such practices as assessing needs, developing care plans, authorizing and coordinating services among providers, and providing follow-up and reassessment, as required. 

**Information and Assistance (**1 Contact) -- A service that: (A) provides individuals with information on services available within the communities; (B) links individuals to the services and opportunities that are available within the communities; (C) to the maximum extent practicable, establishes adequate follow-up procedures. Internet web site “hits” are to be counted only if information is requested and supplied. 

**Assisted Transportation** (1 One Way Trip) -- Assistance and transportation, including escort, to a person who has difficulties (physical or cognitive) using regular vehicular transportation. 

**Transportation** (1 One Way Trip) – Transportation from one location to another. Does not include any other activity. 

**Legal Assistance** (1 hour) -- Legal advice, counseling and representation by an attorney or other person acting under the supervision of an attorney. 

**Information and Assistance** (1 Contact) -- A service that: (A) provides individuals with information on services available within the communities; (B) links individuals to the services and opportunities that are available within the communities;

**Outreach** (1 Contact) – Intervention with individuals initiated by an agency or organization for the purpose of identifying potential clients (or their care givers) and encouraging their use of existing services and benefits. 

**Note:** The service units for information and assistance and for outreach are individual, one-on-one contacts between a service provider and an elderly client or caregiver. An activity that involves contact with multiple current or potential clients or caregivers (e.g., publications, publicity campaigns, and other mass media activities) should not be counted as a unit of service. Such services might be termed public information and reported on the public information category. They may also be reported in “Section II.E. – Utilization and Expenditures Profiles, Other Services Profile.”

**Self-Directed Care** (People Served, Title III Expenditures, Total Expenditures) An approach to providing services (including programs, benefits, supports, and technology) under this Act intended to assist an individual with activities of daily living, in which (A) such services (including the amount, duration, scope, provider, and location of such services) are planned, budgeted, and purchased under the direction and control of such individual; (B) such individual is provided with such information and assistance as are necessary and appropriate to enable such individual to make informed decisions about the individual’s care options; (C) the needs, capabilities, and preferences of such individual with respect to such services, and such individual’s ability to direct and control the individual’s receipt of such services, are assessed by the area agency on aging (or other agency designed by the area agency on aging involved); (D) based on the assessment made under subparagraph (C), the area agency on aging (or other agency designated by the area agency on aging) develops together with such individual and the individual’s family, caregiver (as defined in paragraph (18)(B)), or legal representative – (i) a plan of services for such individual that specifies which services such individual will be responsible for directing; (ii) a determination of the role of family members (and others whose participation is sought by such individual) in providing services under such plan; and (iii) a budget for such services; and (E) the area agency on aging or State agency provides for oversight of such individual’s self-directed receipt of services, including steps to ensure the quality of services provided and the appropriate use of funds under this Act. From Section 102(46) of the Older Americans Act of 1965, as amended. 

**Note:** In prior versions of the State Program Report Definitions, Self-Directed Care was called Cash and Counseling. 

**Other Services** – A service provided using OAA funds that do not fall into the previously defined service categories. Expenditures on “Other Services” in Section II.A. Line 15 is required. 

**Health Promotion and Disease Prevention** – Services that include health screenings and assessments; organized physical fitness activities; evidence-based health promotion programs; medication management; home injury control services; and/or information, education, and prevention strategies for chronic disease and other health conditions that would reduce the length or quality of life of the person 60 or older. Since service units could be so diverse they would not provide meaningful results they are not included. 

**Note:** FY 2012 Congressional appropriations now require Title III-D funding be used only for programs and activities demonstrated to be evidence-based. For more information, see Department of Health and Human Services Appropriations Act, 2012 (Division F, Title II of P.L. 112-74).

## Section I.E and I.F Reporting

*Services to Caregivers*

ACL is not creating any new timeframes, service definitions, or new data elements for reporting. Please see the following excerpt from the current State Program Report definitions that apply:

**Counseling** --(1 session per participant) Counseling to caregivers to assist them in making decisions and solving problems relating to their caregiver roles. This includes counseling to individuals, support groups, and caregiver training (of individual caregivers and families). 

**Respite Care** --(1 hour) Services which offer temporary, substitute supports or living arrangements for care recipients in order to provide a brief period of relief or rest for caregivers. Respite Care includes: (1) In-home respite (personal care, homemaker, and other in-home respite); (2) respite provided by attendance of the care recipient at a senior center or other nonresidential program; 3) institutional respite provided by placing the care recipient in an institutional setting such as a nursing home for a short period of time as a respite service to the caregiver; and (for grandparents caring for children) summer camps. If the specific service units purchased via a direct payment (cash or voucher) can be tracked or estimated, report those service unit hours. If not, a unit of service in a direct payment is one payment. 

**Supplemental services** –Services provided on a limited basis to complement the care provided by caregivers. Examples of supplemental services include, but are not limited to, home modifications, assistive technologies, emergency response systems, and incontinence supplies.

**Information Services** (1 activity) -- A service for caregivers that provides the public and individuals with information on resources and services available to the individuals within their communities. [Note: service units for information services are for activities directed to large audiences of current or potential caregivers such as disseminating publications, conducting media campaigns, and other similar activities.] 

**Access Assistance** (1 contact) -- A service that assists caregivers in obtaining access to the services and resources that are available within their communities. To the maximum extent practicable, it ensures that the individuals receive the services needed by establishing adequate follow-up procedures. [Note: Information and assistance to caregivers is an access service, i.e., a service that: (A) provides individuals with information on services available within the communities; (B) links individuals to the services and opportunities that are available within the communities; (C) to the maximum extent practicable, establishes adequate follow-up procedures. Internet web site “hits” are to be counted only if information is requested and supplied.]

## Section I.E Reporting

States should report Summary Characteristics of Caregivers Serving Elderly Individuals by Service on Section I.E. ACL understands that due to increased demand and volume, there may be higher levels of missing client demographic data. ACL encourages States and aging network providers to collect and report demographic data to the greatest extent practicable. ACL also expects that any significant missing data and variances be explained, including those variances related to COVID response.

States are encouraged to provide details about services provided in COVID response as a narrative entry in Section IV.A. 

## Section I.F Reporting

States should report Summary Characteristics of Grandparents and other Elderly Caregivers Providing Service to Children and Adults with Disabilities by Service on Section I.F. ACL understands that due to increased demand and volume, there may be higher levels of missing client demographic data. ACL encourages States and aging network providers to collect and report demographic data to the greatest extent practicable. ACL also expects that any significant missing data and variances be explained, including those variances related to COVID response.

States are encouraged to provide details about services provided in COVID response as a narrative entry in Section IV.A. 

# Service Expenditures as applied to COVID Response

## Section II.A Reporting

*Services to Older Adults*

States should include FFCRA and CARES Act expenditures, as well as expenditures by States exercising flexibility under a major disaster declaration (MDD) for services reported under Section II.A. 

Note: The COVID-19 crisis is expected to completely skew traditional meal service and meal counts. As a result, ACL is holding harmless meal counts from 2019 and will apply them to 2020 and 2021 NSIP allocations. States are not required to complete line 4a or 8a in the SPRs submitted for FFY 2020 and 2021. 

Screenshot of Section II.A provided for reference:

States should report Expenditures as follows:

Note: If regular Title III-E funds are used under MDD flexibilities for services reported on Section II.A, include the amount in the Total Service Expenditure and include the amount of Part E funds spent as a narrative entry on Section IV.A.

States should also make a narrative entry in Section IV.A regarding FFCRA and CARES Act expenditures by Part, as well as any funds expended when exercising flexibilities under a MDD.

Example:

State exercised MDD flexibilities and used the following funding sources for Home Delivered Meals:

$9m of regular OAA Title III Part C2 funding,

$250k of regular OAA NSIP funding,

$5m of state general revenue and other sources (including state and local matching funds),

$2m in Program Income,

$500k of regular OAA Title III-D funding under the MDD flexibilities,

$1m of regular OAA Title III-E funding under the MDD flexibilities,

$6m in FFCRA OAA Title III Part C2 funding, and

$12m in CARES Act OAA Title III Part C2 funding

The State should also make a narrative entry in Section IV.A regarding FFCRA and CARES Act expenditures by Part, as well as any funds expended when exercising flexibilities under a MDD. See Section IV.A, example 1 for more detail.

## Section II.B & C Reporting**

*Services to Caregivers*

States should include FFCRA or CARES Act expenditures, as well as expenditures by States exercising flexibility under a major disaster declaration (MDD) for services reported under Section II.B & C. 

States are encouraged to provide details about Supplemental Services provided to Caregivers Serving Elderly Individuals and to Grandparents and other Elderly Caregivers Providing Service to Children and Adults with Disabilities in terms of COVID response. ACL encourages states to provide detail on the number of clients, units, and expenditures served via these Supplemental Services. 

The following are **ACL’s recommendations for how to report Supplemental Services under Section IV.A in the****SPR**, with examples updated for how to report due to COVID response. This list is not exhaustive. These are the categories ACL identified as applicable given how services are being delivered related to COVID response. 

Screenshot of Section II.B provided for reference:

States should report Expenditures as follows:

Note: If Title III-B, C, or D funds are used under MDD flexibilities for services reported on Section II.B or C, there is no column by the Subparts. Just include the amount of Part B, C, or D funds spent as a narrative entry on Section IV.A.

States should also make a narrative entry in Section IV.A. regarding FFCRA and CARES Act expenditures by Part, as well as any funds expended when exercising flexibilities under a MDD.

Example:

State exercised MDD flexibilities and used the following funding sources for Supplemental Services:

$4m of regular OAA Title III Part E funding,

$3m of state general revenue and other sources (including state and local matching funds),

$1m in Program Income,

$500k of OAA Title III-D funding under the MDD flexibilities,

$1m of OAA Title III-B funding under the MDD flexibilities, and

$2m in CARES Act OAA Title III Part E funding.

The State should also make a narrative entry in Section IV.A regarding FFCRA and CARES Act expenditures by Part, any funds expended when exercising flexibilities under a MDD, and any detail regarding Supplemental Services provided. See Section IV.A, example 2 for more detail.

## Section II.E Reporting 

*Services to Older Adults*

The following are **ACL’s recommendations for how to report services under Section II.E Other Services in the****SPR**, with examples updated for how to report due to COVID response. This list is not exhaustive. These are the categories ACL identified as applicable given how services are being delivered related to COVID response. 

Screenshot of Section II.E provided for reference:

States should report Expenditures as follows:

Note: Program Income Received is not reported on Section II.E, but is cumulatively reported for Other Services on Section II.A. The State should also make a narrative entry in Section IV.A regarding FFCRA and CARES Act expenditures by Part and any funds expended when exercising flexibilities under a MDD for services reported under Section II.E. 

Example:

State exercised MDD flexibilities and used the following funding sources for Consumable Supplies:

· $4m of regular OAA Title III Part B funding,

· $3m of state general revenue and other sources (including state and local matching funds),

· $1m in Program Income,

· $500k of OAA Title III-E funding under the MDD flexibilities, and

· $2m in CARES Act OAA Title III Part B funding.

The State should also make a narrative entry in Section IV.A regarding FFCRA and CARES Act expenditures by Part and any funds expended when exercising flexibilities under a MDD. See Section IV.A, example 3 for more detail.

## Section IV.A Reporting 

*Services to Older Adults & Services to Caregivers*

Section IV.A Developmental Accomplishments for Home and Community Based Services includes space for states to provide narrative descriptions by Service. States should make a narrative entry in Section IV.A. regarding any use of any funds expended when exercising flexibilities under a MDD or with FFCRA or CARES Act funds by Part. 

States are encouraged to provide details about services provided in COVID response as a narrative entry in Section IV.A. 

**Example 1 (expenditures reported on Section II.A):**

State exercised MDD flexibilities and FFCRA and CARES Act funding for $35.75m of Total Expenditures on Home Delivered Meals:

· $9m of regular OAA Title III Part C2 funding,

· $250k of OAA NSIP funding,

· $5m of state general revenue and other sources (including state and local matching funds),

· $2m in Program Income,

· $500k of OAA Title III-D funding under the MDD flexibilities,

· $1m of OAA Title III-E funding under the MDD flexibilities,

· $6m in FFCRA OAA Title III Part C2 funding, and

· $12m in CARES Act OAA Title III Part C2 funding.

State provided 10 meals per week for 12 weeks for 10,000 new clients as part of its COVID response for a Total Expenditure of $12,000,000. State provided 2,200,000 meals to 20,000 regular clients outside of its COVID response for a Total Expenditure of $22,000,000. State made $1,750,000 in capital expenditures to purchase delivery vehicles and walk-in coolers.

****

**Example 2 (expenditures reported on Section II.B or II.C):**

State exercised MDD flexibilities and CARES Act funding for $11.5m of Total Expenditures on Supplemental Services:

$4m of regular OAA Title III Part E funding,

$3m of state general revenue and other sources (including state and local matching funds),

$1m in Program Income,

$500k of OAA Title III-D funding under the MDD flexibilities,

$1m of OAA Title III-B funding under the MDD flexibilities, and

$2m in CARES Act OAA Title III Part E funding.

Homemaker-Delivery – 10,000 clients, 120,000 units, $2,500,000 Expenditures. State provided weekly shopping and grocery delivery for 12 weeks to family caregivers. 

Consumable Supplies – 10,000 clients, 150,000 units, $7,500,000 Expenditures. State provided $50 in supplemental groceries and household supplies each week for 12 weeks for 10,000 clients. State also provided 30,000 units of monthly internet access (10,000 clients for 3 months).

Assistive Technology/ Durable Equipment/ Emergency Response – 10,000 clients, 10,000 units, $1,500,000 Expenditures. State provided tablet computers to 10,000 caregivers to enable the caregivers to participate in caregiver support groups and interact with the older adults for whom they are caregiving. 

**Example 3 (expenditures reported on Section II.E):**

State exercised MDD flexibilities and CARES Act funding for $10.5m of Total Expenditures on Consumable Supplies:

$4m of regular OAA Title III Part B funding,

$3m of state general revenue and other sources (including state and local matching funds),

$1m in Program Income,

$500k of OAA Title III-E funding under the MDD flexibilities, and

$2m in CARES Act OAA Title III Part B funding.

Consumable Supplies – 10,000 clients, 150,000 units, $7,500,000 Expenditures. State provided $50 in supplemental groceries and household supplies each week for 12 weeks for 10,000 clients (120,000 units, $6,000,000 Total Expenditures). State also provided 30,000 units of monthly internet access for 10,000 clients for 3 months (30,000 units, $1,500,000 Total Expenditures).

# APPENDIX

## Program Reporting Guidance – COVID Response

### ACL Title III Older Americans Act – State Program Report (SPR) – Service Overview

ACL is not creating any new timeframes, service definitions, or new data elements for reporting. ACL is giving guidance and examples for states to use the existing SPR requirements and State Reporting Tool (SRT) system to report COVID response activities. Due to COVID response, ACL understands that clients, service units, expenditures, and expenditures per unit will differ greatly from prior year SPR reports. ACL asks states to do their best under challenging conditions to include detail on how COVID has affected program operations via narrative information reported on Section IV.A of the SPR and variance explanations, as appropriate. Please see the complete Reporting Guidance document for more detail.

The following are **existing SPR service names or recommended categories for Other Services and Supplemental Services**, with examples updated for how to report due to COVID response. This list is not exhaustive. These are the categories ACL identified as applicable given how services are being delivered related to COVID response:

****

## **Services to Elderly Individuals**

### **Existing SPR Definitions**

### **Recommended Service Category for Reporting of Other Services**

## **Services to Caregivers**

### **Recommended Service Category for Reporting of Supplemental Services**

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