. \. 

Department of Health and Human Servces


OFFICE OF 
 INSPECTOR GENERA 

TION ON AGllG 

STEWARSHI OF TIE il OF 

OLDER AMRICANS ACf: 

The Methodology 

VI. 

Richard P. Kusserow 

INSPECfOR GENERA 

MACH 199 
. ., . . , ., . 

OFFCE OF INSPECTOR GENERA


The mission oftheOfficeofJnspector Genera (OIG)'as mandated by Public Law95"452 

as amended , is to protectth(:integrity of the Deparment of Heath and Human Se ryiCes! . ' , (HS) programs as welIas the heatqand Voelfare , of beneficiares served by those progrtms. 

Ths ' statuory ,missionis9f , out ' througl1' a nationwide network ,of audits, investigations 

and , inspetions' condu tedbythree OlGoperatig ' COIlPOl entS: the , Offce, of Audit ,SerVices 

the Office of InvestigatioIls,andthe Offce of Evaluation and . Inspections. , 'Te Old also 

informs the Secretar)' of HHS of program , and management problems , and recommends 

courses to correct them. 

OFFCE OF AUDIT SERVICES 

The OIG' s Office ofAJlditServices (OAS) provides all auditig services for HHS eitherby 

conducting' audits with its own audit resources or by overseeing audit work done by others. 

Audits examine theperforrance of HHS programs and/or, its gratees and contractors in "

caring out their respective responsibilities and are intended to provide independent


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


mismanagement and to promote economy and effciency throughout the Deparment.


OFFCE OF INESTIGA TIONS


The OIG' s Office of Investigations (Ol) conducts criminal , civil, and administrative 

investigations of allegations of wrongdoing in HHS programs or to HHS beneficiares and of 

unjust enrchment by providers. The investigative efforts of OI lead to criminal convictions 

administrtive sanctions, orcivil moneypenaIties. The OI also oversees State Medicaid 

fraud control units which investigate and prosecute fraud and patient abuse in the Medicad 

program. , 


OFFCE OF EVALUATION AN INSPECTIONS 

The OIG' s Offce of Evaluation and Inspections (OEl) conducts short-term management and 

program evaluations (caled inspections) that focus on issues of concern to the Deparment 

the Congress, and the public. The findings and recommendations contaned in these 

inspection reports generate rapid, accurate, and up-to-date information on the effciency, 

vulnerability, and effectiveness of deparmenta programs. 

This report was prepared in the New York Regional Office under the direction of Thomas F. 

, Tully, Regional Inspector General of Region II, Office of Evaluation and Inspections, and 

Alan S. Meyer, Deputy Regional Inspector General. Paricipating in this project were the 

following OIG personnel: 

Jack I. Molnar Project Leader
 Le K. Bostick Region VI


Susa E. Hardwick Headquarters

Departent of Health and Human Servces 

OFFICE OF
 INSPECTOR GENERA 

AD~S~TION ON AGllG


STEWARSIl OF TIE il OF 

OLDER AMRICANS ACf: 

The Methodology 

Richard P. Kusserow 

INSPECfOR GENERA "0 

OEI-0-91-01510 ""a 
. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ......... .............. ........ 

. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .......... . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ... ....... .... .. . . . . . . . . . . . . . . .. .. ... .... .... . . . . . . . . . .

TABLE OF CONTENTS 

INODUCTION 

Purpse 

Background 

COMPLIACE REVIEW METHODOLOGY 

Sampling 

Data Collection 

Traning 

Analysis and Reportng 

Schedule. . . . . . . . . . . . . . . . . . . . . . . . 

APPENIX A: 
 Stewardship Compliance Review. . . . . . . . . . . . . . . . . . . . AAPPENIX B: 
 Targeting Compliance Review . . . . . . . . . . . . . . . . . . . . . BAPPENIX C: 
 Financial Management Compliance Review . . . . . . . . . . . .. CAPPENIX D: 
 Nutrtion Services Compliance Review D- I 

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


PURSE 

Ths report trsmits the methodology for the review of State Units ' on Aging (SUA) 

compliance with the requirements of Title II of the Older Americans Act (OAA). 

BACKGROUN 

In order to strengthen the Administrtion on Aging s (AoA) stewardship of the OAA, the 

Commissioner of AoA has requested technical assistace from the Offce of Inspector 

Genera (OIG) in designing an assessment of their primar grantees -- SUAs. In June 1991 

OIG staf met with key AoA headquarers and regional staff to identify trditional and 

current stewardship activities , and to discuss potential approaches for future efforts. As 

result, parcipants agree that in addition to reinstituting the monitoring of individual States 

there was a nee to provide the Commissioner with an overview of how States are 

implementing key components of Title II -- Grants for State and Community Programs on 

Aging. Accordingly, OIG staf would assist AoA in developing national, stadardized 

compliance review instrments for key components of Title II and in writing a report 

summaring States ' compliance with the Act. It was also agree the compliance reviews 

would be conducted on a saple of States to conserve trvel dollars. 

Designing the compliance review took a number of steps. The first step was a meetig 

between OIG and selected AoA regional staff to branstorm approaches and issues. This took 

place durig a three-day session in Washington, D. , where specific Federal reportng and 

operational requirements for SUAs and Area Agencies on Aging (AAAs) and potential 

monitorig strtegies were discussed. 

The second step was to drat the instrments which would contan the compliance review 

questions and criteria, and would serve as the one place to record al data. Two writing tes, composed of OIG and AoA staf, shared ideas and approaches initially, and then 

created ealy versions of the instrments. These were shared with AoA Headquarers staff 

and each regional office for comments, and then revised to reflect comments. 

During the third step, OIG and AoA staf pre-tested the instruments and data collection 

methodology. Ths necssitated conducting actual compliance reviews for each of the five 

instrments in three different regions. We found , durig the pre-test, that a great dea of 

time was lost explaiing criteria (interpreting law and regulation) and seaching for 

documentation. Based on these reviews, we modified each of the instruments and changed 

the data collection methodology. The most significant change to the methodology requires 
sharng copies of the review instrments with the States prior to the site visit. We believe 

that if States are aware of and understad the review criteria being used during the 

compliance review, they wil be better prepared to provide required documentation and to 

discuss speific compliance issues. 
SAME STATES


Strtu 1 Strtu 2 Strtu 3 Stratwn -4 

Caiforna 

Penylvana 

Michigan 

Indiana 

Wiscnsin 

Colorado 

New Hampshire 

North Dakota 

New York Massachusetts Oklahoma Nevada 

Texas Georgia Maie District of Columbia 

Florida Nort Carolina Oregon Montaa 

We wil also employ sampling techniques during our visits to the States for our reviews of 

AAA area plans and assessments. In some States, the number of AAAs could excee 30 

which would ta the limited resources available to the reviews. Therefore, prior to our visit 

to each State, we wil select a simple, random sample of 10 AAAs to review on-site. 

DATA COLLECTION 

The actual data collection wil be conducted in two phases -- a desk review and an on-site 

review at the SUA. Durig the desk review phase, AoA Regional Program Directors (RD) wil send a letter to each SUA selected in the sample announcing the compliance review 

listing compliance review criteria, and requesting selected documents. The documents 

requested wil include area plan guidance and program instructions for each of the review 

area, as well as a copy of the State s assessment instrments for AAAs. The AoA staff wil 

review these prior to the site visit to determine if they are consistent with Federal law and 

regulations. The desk review wil also include an assessment of priority services waivers and 

a review of tageted populations parcipation data from the State Program Report. 

Following the desk review, the RPD wil send a second letter to each SUA in the sample. It 

wil provide a proposed agenda for the site visit, a listing of the ten AAAs whose area plans 

and assessment reports wil be reviewed, copies of the compliance review instrments 

(Appendices A-E), and findings from the desk review to be discussed during the site visit. 

The instrments share a common approach to data collection. Initially, the instrments focus 

on the guidance SUAs issued to AAAs on key requirements of Title II, and on the 

instrments and proceures they use to assess AAA compliance with those requirements. A 

review of area plans wil determine whether, and to what extent, they reflect OAA 

requirements. The review of area-specific assessment reports wil determine compliance. 

The instrments also focus on the issues of SUA operating procedures , and on training and 

technica assistace activities. The Ombudsman instrument is an exception since all 

Ombudsman activities are cared out by the SUA and do not require the involvement of 

AAAs. 
During the trng, the procedures for conducting the compliance review wil be discussed 

in deta. Ths wil assure that each review tea functions similarly on-site, that data are 

being collected in the proper sequence, and that all components of the five compliance 

reviews are being covered. With regard to sequencing, certin tasks will be identified for 

completion in a parcular order. 

The AoA staf wil also nee to develop key data collection skills -- interviewing and 

recrding. The interviewing skills wil assure that all questions wil be asked the same way. 

Varance in how questions are asked can affect the integrity of the review findings. 

Recrding conventions wil be reviewed to assure that responses and quantitative data are 

recorded in the same manner by all review teams. Lastly, during the training sessions team 

members wil receive some trning in the analysis of open-ended questions. 

ANALYSIS AN REPORTING 

The analysis of the compliance review data wil be led by AoA and OIG staff in Regions 2 

and 6. In the lead Regions , OIG/ AoA teams wil enter data from the compliance review 

instrments into automated databases. The AoA regions wil be given responsibility for the 

analysis of open- ended questions in different programmatic areas. This wil give all AoA 

regions an opportunity to parcipate in the analysis phase of the report. 

Once the analysis is completed , the lead Regions wil develop one-page briefing papers for 

each of the compliance review areas. These wil serve as the basis for a story conference 

with the Commissioner. At the story conference, the lead teams will brief the Commissioner 

on fmdings , respond to questions, and discuss drafting the reports and recommendations. 

Six compliance review reports wil be written. One report wil be written for each of the 

five compliance review instruments and wil present findings based on a weighted-frequency 

distrbution of key questions. A sixth report wil present a overview or summar of the five 

programmatic reports and wil focus on cross-cutting issues. The reports wil contan , where 

appropriate, recommendations for strengthening SUA operations or AoA stewardship. 
APPENDIX A

,...

STEWARSHIP COMPLIACE REVIEW


HHS/AOA - 03/20/92 

State Date 

Prary Respondent Telephone 

Review Tea Leder Telephone 

Prir to the on-sie visi, obtain a copy of the Area Plan fomzat provided to Area Agencies 

on Aging (AAs) from the State Agency on Aging (State Agency). Review and detemzine 

whether or not the Area Plan fomzat addresses the crieri identified in the following 

table. Indicate your responses with an 
 in the approprie column reflecting these codes: 

Y (Yes) Total Compliance with Crieri


P (Partl) = Partl Compliance with Crieri


N (No) = Not in Compliance with Crieri 

CRIRI COMMNTS 

Sec. 306(a)(2) 

contain an assurace that an adequate proportion of


Title m-B win be expended for acces, in-home


and legal assistace


spify anualy, amounts expended in previous


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


Sec. 306(a)(3) & 1321.3 

designate communty focal points for selVices; 

Sec. 306(a)(4) 

establish and maintain informtion and referrl


service;


Sec. 306(a)(5) 

assure that preference is given to selVing those of


greatest economic or social nees (particularly lowincome miorities)... 

have proposed methods to selVe those of greatest 

ecnomic or social nees... 

Stewardship - Final 
CRIERI 

assure each service provider agreement wil spify how the service provider will serve low-income 

miorities...in at leat the sae proporton.. 

identify numbers of and desribe method us 

serve low-income miorities in previous fiscl 

year... 

asre use of outreach methods... with special 

emphasis on rura elderly, greatest economic or 

soial nee (with paricular attention to low-income 

miorities), and severe disabilities; 

Se. 306(a)(6) 

conduct periodic (at leat anually) evaluations 

conduct public hearigs on Ar Plan activities... 

conduct an anual evaluation on outreach... 

provide tehnca assistace to service providers... 

consider views of reipients of service in the 

development and admistration of Area Plan... 

monitor, evaluate, and comment on policies, 

actions... affecting elderly... 

provide volunteer opportties for older individuas 

in day care services for children and adults and 

resite for famiies... 

establish an Area Agency advisory council.. 

develop and publish methods for determng 

priority of services. .. 

elD establish proceure for cordinating Title 

progrms with other Federal programs as spified 

in Sec. 2D3(b)... 

ell faciltate cordination with communty-bas, longterm ca services... 

el2 identify agencies and organizations workig in area 

of abus, neglect, and exploitation of older people... 

e13 determe unet service nees of abuse, neglected 

and exploited older individuals.. 

el4 facilitate involvement of long-term care providers in 

cordinating community-based long-term care 

service... 

elS cordinate priority service with Alzheimer s disea 

organizations... 

COMMNTS


Stewardship - Final 
(If additnal space is required, use the back of the previous page. 

Beyond that required by Sec. 306 of OAA, what significant items have you added to area 

plan formats?


Don t Know
 (Check if applicable) 

A-4 Stewardship - Final 
Doe the State Agency have any criteria for approving the direct provision of supportve 

servce, nutrtion services , or in-home services'? 

Yes (If yes) 
 , What are they'?

(2) 

(3) Don t Know
 (Check if applicable) 

10.	 Are any AAAs approved by the State Agency to directly provide supportive services 

nutrtion services or in-home services'? 

Yes 

No (If No, sldp to queston 12)


Don t Know 
 (Check if applicable)


11.	 What are the number of AAAs providing each'? 

Number of AAAs directly providing supportive services 

Number of AAAs directly providing nutrition services 

Number of AAAs directly providing in-home services 

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

or combinatn): 

12.	 State Agencies have the ability to waive the adequate proportion requirement for Title IIfor accss services. How many AAAs have been grated waivers for: (Fill-in with a-c and record response) 

Access services'?


In-home services'?


Legal assistace services'?


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


or combinatn): 

(NOTE: A1TACHMENT B PERTAINS TO IN-HOUSE DESK REVIEW OF AM WAIVERS 

- IF ANY INFORMATION 	 IS MISSING OR INDICATES DISCREPANCIES, ASK 

ABOUT THESE DURING THE ON-SITE VISIT AT THIS POINT) 

A-6	 Stewardship - Fina 
CRIRI 

identify numbers of and desribe methods us 

serve low-income miorities in previous fiscl 

yea... 

as us of outrh methods... with special 

emphasis on rural etderIy, great ecnomic or

-sial nee (with particular attention to low-income 

miorities), and severe disabilties; 

Se 306(a)(6) 

conduct periodic (at leat anualIy) evaluations


conduct public hearigs on Area Plan activities... 

conduct an anual evaluation on outreach... 

provide technca assistace to service providers... 

consider views of recipients of service in the 

devetopment and admistration of Area Plan... 

monitor, evaluate, and comment on policies, 

actions.. .affecting elderly... 

provide volunteer opportties for older individuas 

in day care service for children and adults and


reite for families... 

establish an Ar Agency advisory council.. 

develop and publish methods for determg 

priority of service... 

e10	 establish proure for cordinating Title m 

programs with other Federat programs as specified 

in Sec. 203(b)... 

ell	 faciltate coordination with communty-based , longterm care services... 

e12	 identify agencies and organizations workig in area 

of abus, neglect, and exploitation of older peple... 

e13	 determe unet service nees of abus, neglected, 

and exploite older individuals... 

e14	 facilitate involvement of tong-term care providers in 

cordinating communty-bas long-term 

service... 

e15	 cordinate priority services with Alzheimer s disea 

organzations... 

e16	 cordinate Title moB mental health service with the 

services of other mental health agencies and 

organzations... 

COMMNTS


Stewardship - Final 
(If additnal space is required, use the back of the previous page. 

15.	 Beyond that required by Federa law or regulation , what significant items have you added to 

your assessment instrument for assessing AAAs? 

- Don t Know
 (Check if applicable) 

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

Annualy 

Biannually


Quarerly


Other (Specif time period)


- Don t Know 
 (Check if applicable)

17.	 What were the beginning and ending dates of the last complete cycle of assessments of all 

AAAs? 

Beginning Date ­


Ending Date ­


Stewardship - Final 
20.	 Provide a brief description of how each procss is used to monitor the performance of 

AAs. (Descriptin should be provied for each applicable response provided in questn 

19) 

21.	 What were the most common deficiencies reveaed in the last cycle of assessments of the 

Area Agencies?


Don t Know 
 (Check if applicable)

Stewardship - Final 
26.	 Have you analyze the: (Fill-in the remainder of the question with a, b, and c. Indicate 

response for each) 

a. evaluation of activities? 

(1) Yes (If Yes), What are your primar observations based on the analysis? 

(2)

(3) Don t Know 
 (Check if applicable)

b. results of public heangs? 

(1) 	 Yes (If Yes), 
 What are your primar observations based on the analysis?

(2)

(3) Don t Know 
 (Check if applicable)

c. evaluation of outreach?


(1) Yes (If Yes), What are your primar observations based on the analysis?

(2)

(3) Don t Know 
 (Check if applicable)

Stewardship - Final 
:!!

29.	 Doe the State Agency have any unmet training or tehnical assistace nees related to 

stewardship activities? 

a. 	 Yes Pleae describe: (lfyes), 

Don t Know
 (Check if applicable) 

30.	 The preselected sample of 10 Area Agencies on Aging were identified prior to the on-sie 

visi. This sample is to be used throughout the compliance review process for all five 

areas, the firs compliance review being Stewardship. 

For the sample AAs, obtain the most current Area Plan. Review each Area Plan and 

detennine the extent to which the plan addresses the statutory and regulaory crieri 

identified in Atachment A. Record your responses on the following table using these 

codes: 

Y (Yes) = Total Compliance with Crieri 

P (Part) = Part Compliance with Crieri 

N (No) = Not in Compliance with Crieri NSC No Stae Crieri (State Agency does not assess this 

Fedeml crieri 
 identified through in-house review of 

State Agency s assessment tool and relaed materis) 

Other Finding (provide explanaton and indicate by 

reporl number and crieri number in the Comments 

section following the table) 

Criteri 

Stewardship - Final 
el2 

e13 

el4 

elS 

el6 

el7 

el8 

COMMS: 

Stewardship - Final 
elO 

el2 

e13 

el4 

elS 

Stewardship - Final 
,...

IT ACHM 

STEWARSHIP CRIER 

Sec. 306(a)(2) 

contan an assurace that an adequate proporton of Title II-B wil be expended for 

acCss , in-home, and legal assistace 

specify annually, amounts expended in previous fiscal yea for access , in-home and 

legal assistace; 

Sec. 306(a)(3) & 1321.3 

designate community foca points for services; 

Sec. 306(a)(4) 

establish and maintan information and referr services; 

Sec. 306(a)(S) 

assure that preference is given to serving those of greatest economic or social nees 

(parcularly low-income minorities)...


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


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


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


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


previous fiscal yea...


assure use of outreach methods... with speial emphasis on rural elderly, greatest 

economic or social nees (with parcular attention to low-income minorities), and 

severe disabilties; 

Sec. 306(a)(6) 

conduct periodic (at least annually) evaluations 

conduct public heangs on Area Plan activities... 

conduct an annual evaluation on outreach... 

provide technical assistace to service providers... 

consider views of recipients of services in the development and administration of Area 

Plan.. .


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


Stewardship - Final 
ATIACHMNT B


AOA IN-HOUSE DESK REVIW OF AAA WAIVERS 

Identi from in-house documents those AA which have received an approved waiver. On the 

following table list each. Review the in-house documentaton and determine whether each 

addresses questns a-e. Record your responses on the table using these codes: 

Yes 

No (provide explanaton and indicate by AA)


Discrepancy (provie explanaton and indicate by AA what the discrepancy is in
 the Comment sectin) 


Missing informaton (provide explanaton and indicate by AA what the 

discrepancy is in the Comment section) 

Prior to the submission of the waiver, did the Area Agency conduct a public hearing? 

1/ the answer to question a was yes, was the reord of the hearing submitted with the waiver request to the State 

Agency? 

Prior to the grating of the waiver, did the State Agency publish the intention to grant such a waiver with the 

justification at leat 30 days prior to the effective date of the decision to grant the waiver? 

Were any hearigs convened by the State Agency durig the 30-dy period in response to requests from individuals 

or service providers from the area?


Did the State Agency provide to the U.S. Commssioner on Aging, through the appropriate AoA Regional Offce, a 

report regarding the waiver along with a copy of the notice of public hearing and minutes of the hearings conducted 

by the Area Agency and the State Agency (if appropriate)? 

STATE 

HEARNG STATE STATE PROVIDED AOA 

REORD PUBLISHED HEARING REPORT ON PUBLIC 

HEARNG	 SUMITTD INTENT 30 DURNG 30 WAIVER WITH 

WITH DAYS PRIOR DAYS IN COPY OF HELD AAA WI WAIVR	 WAIR RESPONSE NOTICE OF BEFORE 

SUBMISSON REQUE, IF EFFCTIVE HEARNG AN 

HEARNG DATE OF REQUES MINUES OF OF WAIVER 


(0) HELD DECISION (IF AN AN HEARINGS 

(b) (e) (d) (e) 

Stewardship - Final 
HEAG 

REORD PUBLIC 

HEARNG SUMITID

WITH HELD AA WI WAIVR WAIVER BEFORE REQUE. IF SUBMISSION 

OF WAIR HEARNG 

HELD (a) 

(b) 

SIATE 

PUBLISHED 

INTENT 30 

DAYS PRIOR 

EFFCTIVE 

DATE OF 

DECISION 

(c) 

SIATE 

HEARING 

DURNG 30 

DAYS IN 

RESPONSE 

REQUESS 

(IF ANY 

(d) 

SIATE 

PROVIDED AOA 

REPORT ON 

WAIVER WITH 

COpy OF 

NOTICE OF 

HEARING AN 

MINU OF


AN HEARNGS


(e) 

COMMNTS:


(If additonal space is required, use the back of the previous page. 

Stewardship - Final 
APPENDIX B

TARGETIG COMPLIACE REVIEW


HHS/AOA - 03/20/92 

State Date 

Prary Respondent Telephone 

Review Tea Leder Telephone 

In our ealier interview on stewardship, we discussed how your assessment instrument 

addresses tageting. What other procedures do you use to review and evaluate each Area 

Agency on Aging s (AAAs) performance in tageting? (eg. on-site/desk review)? 

- Don t Know 
 (Check if applicable)

Did the State Agency underte speific activities in support of tageting during the last two Federa fisca yeas? 

No 

Yes (If Yes, go to questn 3)

(If No, go to queston 4) Don t Know (If Don t Know, go to queston 4) 

Targeting - Final 
Describe and give examples of the following activities underten by the State Agency in 

support of tageting durig the last two fisca yeas? (Read list and check those with 

offirmve responses. For each affinnatve response, identify examples of that activit, 

where applicable. 

ACTIVY 

Altered fuding formula


Monitored/assessed AAs 

Conducted traing conferences, meetings 

workshops 

Dissemiated techncal assistace/informtion 

Conducted data analysis 

Formed State-level tak force or advisory 

commttee 

Implemented specific objectives in the State 

Plan 

EXAMPLES OF ACTIVY 

Not Applicable


(1) 

(2) 

(1) 

(2) 

(I) 

(2) 

Not Applicable


(I) 

(2) 

(1) 

(2) 

Targeting - Final 
ACTIVY EXAMPLES OF ACTIVY 

Established paricipation targets (1) 

(2) 

Other, (Identi): 01(1) 

n1. 

01(2) 

02. 

02(1) 

02(2) 

Describe and give examples of activities implemented by AAAs to increase the parcipation 

of tageted populations. 
 (Probe for infonnaton on: outreach, specializaon of services 

designed for specifc target groups, staffing, provider and site selection) 

TARGET ACTIVIE EXAMPLES OF TARGET ACTIVIES 

Outreach (1) 

(2) 

Speialization of Services Designed for (1)


Speific Target Group


(2) 

B-4 Targeting - Final 
Prior to this visit, we sent you a table entitled "Target Population Parcipation. " The data 

come from your State Program Reports for the last three yeas. What factors affect your 

trends? 

The next few questions focus on the service nees of low-income-minorities. Does the 

State Agency have diffculty in obtaning the required low income-minority data? 

- Yes, Please explain the diffculties being encountered by the State Agency: 

Don t Know (Check if applicable) 

8. Do the AAAs have difficulty in obtaning the required low income-minority data? 

- Yes, Please explain: 

Don t Know (Check if applicable) 

What are examples of the " succssful" methods used by service providers to satisfy the 

servce nees of low-income minority individuals (as contained in the service plan of 

proviers complying with OAA Sec. 306(a)(5)(A)(ii) and Regulaon 1321. 65(b)) 

- Don t Know 
 (Check if applicable)

B-6 Targeting - Final 
13.	 What are some examples ' of successful outreach techniques used by AAAs in reaching 

tagete populations? 

- Don t Know 
 (Check if applicable)

14.	 If identified, how does the State Agency address outreach deficiencies of the AAAs? 

- Don t Know
 (Check if applicable) 

IS.	 Did the State Agency conduct an annual evaluation last year of its effectiveness in outreach 

to tagete populations, as stipulated in Section 307(a)(8)? 

Yes (If Yes) 
 What outreach activities were found to be most effective?

(1) 

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

Don t Know 
 (Check if applicable)

Targeting - Final 
19. What do you see as the major success of the State Agency s tageting effort? 

- Don t Know 
 (Check if applicable)

20.	 What are the major obstacles to effective tageting that stil must be addressed (at either the 

State or AA level)? 

- Don t Know 
 (Check if applicable)

21.	 What speific activities should AoA underte to assist State Agencies' and AAAs' tageting 

efforts? 

- Don t Know 
 (Check if applicable)

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

(INTERVIEW COMPLETED)


Targeting - Final 
For each tageted population , identify the source of the data and the yea that the data was 

avaiable. (For example, a source could be identified as the Bureau of Census, 1990). 

TARGETED POPULATIONS DATA SOURCE DATA AVAILABLE 

a. 60 + population


b. Minority population


c. Fral/Disabled


d. Rur 

e. Low-income non-miority 

f. Low-income miority


g. Other, 
 Specif:

(1) 

(2) 

(3) 

Targeting - Final 
I. FraDisabled


J. Rura


K. Low-Income 

Non Minority 

L. Low-Income 

Minority 

Targeting - Final 
APPENDIX C

FIANCIA MAAGEM COMPLIACE REVIEW 

HHS/AOA - 03/20/92 

State Date 

Prary Respondent Telephone 

Review Tea Leder Telephone 

---..-_-_a__--__---

Prir to the on-sie visi, obtain copies of policies, procedures, and other guidance to Area 

Agencies on Aging (AAs) on financial management from the State Agency on Aging 

(State Agency). Review and detennine whether or not these issuances address the crieri 

identified in the following table. Indicate your responses with an X in the approprie 

column reflecting these codes: 

Y (Yes) Total Compliance with Crieri


P (Parl) = Partl Compliance with Crieri


N (No) = Not in Compliance with Crieri 

During the desk review, if the policy materils do 
 not include those items necessary to

make a detenninatn of compliance (Y, P, or N), mark NA (Not Available) in the 

Comments sectin of the table. 

CRIRI COMMNTS 

Stale Agency approves all AA contracts with 

profitmag gratee 

OM Sec. 212 

Title II expenditures in rural area equal or 

exce 105 % of specified expenditures in FY 1978 

OAA Sec. 307(a)(3)(B) 

AA admistrative expenditures statewide do not 

exce the 10% limitation 

OAA Sec. 304(d)(1)(A) 

There is no fuding at the 85- 15 match for 

progra development and coordinated activities 

until the specified percentage is expended 

statewide for AA admistration 

45 CFR 1321.7(f)(14) 

Financial Management - Final 
CRIRI COMMNTS 

Eah AA reta recrds for 3 yrs aftr the date 

tht the AA submits its fial expenditure report 

or the date on which resolution of audit 

excetions, litigation, etc. ocur (whichever date 

is later)


45 CPR 92.42 & 74 Subpart D 

Paricipants are given an opportty to mae 

volunta contributions 

45 CPR 1321.67(a)(I) 

Limitations on trfers betwee congregat and 

home-delivered meat allotments 

45 CPR 1321.45 

Privacy of contributions 

45 CPR 1321.67(a)(2) 

Safegurds and accounting for contributions 

45 CPR 1321.67(a)(3) 

Support service contributions are used to expand 

support service 

45 CPR 1321.67 

In applying program income, the deduction 

alternative is not used 

45 CPR 1321.73 

AA admistration is fuded from Title II B 

and/or Title II C, only 

OAA Sec. 303(c) 

Statewide trafers between Title II B & C do not 

exce 30 

OAA Sec. 308(b)(5)(B) 

Retention of Federal governent fiancial interet 

in senior centers 

OAA Sec. 312 

AAs spnd State Agency prescribed percentages 

on spified categories of service 

OAA Sec. 307(a)(22) and 306(a)(2) 

Audits for governental and non-governmental 

AAs 

OMB Circular A-128 , A-133 

Nutrition services contributions are us 

incre meals, for acces, or for authorize 

service. 

OAA 307(a)(13)(C)(ii) & 45 CPR 1321.67 

Financial Management - Final 
(If aditna space is required, use the back of the previous page) 

Note: Under the Single Audit concept, the tenn "grantee " refers to the AA, when the AA is 

an independent agency or organizaon. Otherwise, the tenn "grantee " refers to the 

multpurpose agency or organizan, when the AA is a separae organizaonal unit within 

such multpurpose agency or organizaon.


How does the State Agency ensure that audits of its gratees wil be conducted in 

accordace with the law and the regulations? (i. e., through which methods) 

AAAs must budget funds for audits 

gratees are directed to have audits conducted in accordance with specified 

OMB Circulares 

Other (Identify the specifc procedure and explain) 

What was the last fisca yea during which audits were made of the State Agency


gratee?


Beginning date ­


Ending date ­


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


Prir to the on-sie visi, list the sample grantees below. In preparaon for the onsie visi, ask the State Agency to have available for each sample AA: 

the type of audit conducted (A-128 or A-I33) for the last fiscal year (identified 

at questn 
 a and b) and 

the name of the audit agency conducting that audit. 

For each of the sample AAs, fill-in the approprie infonnaton on the following 

table. 

C-4 Financial Management - Final 
Prr to the on-sie visi, list the sample grantees below. In preparan for the on-sie 

visi, ask the Stae Agency to have availale audit findings for the most recently 

completed A-128 or A-133 audit of each sample AA. For each of the sample AAs, 

each approprie column to designate any deficiencylies that were 

specifed in tha AA' s audit findings. 

place a check mark in 


AUDIT FIINGS (Check all applicable) 

Inte Non-compliance GRAE Control with Law or Questioned Other 

Weaes Regulations Costs (Identify) 

(1) 

(2) 

(3) 

(4) 

(5) 

(6) 

(7) 

(8) 

(9) 

(10) 

C-6 Financial Management - Final 
The Final SF-269 Report shows that $ (fll-in amount prior to on-site visi) in Title 

il funds was allocted for State Agency administrtion. What was the actual amount expended? 

(Indicate amount) 

I nee to review documentation confirming this information. Check as approprie:


Documentan is by provided is unavailable
 or will be mae available

on (date) 

Don t Know (Check if applicable) 

documented expenditures 

indicate tha more than $300, 000, or more than percent of the Tile III allotments 

(whichever is greater) was lient on State Agency administraon. This may require your 

calculang the percent figure. 

Indicate your finding: a. More than $300, 000 or more than percent was 

spent 

$300, 000 or less than 5% was spent 

If received, review the documentaton and detennine whether the 


- Don t Know (Check if applicable) 

Only if the documented expenditures are more than $300 000 or more than percent, ask 

questn 9. OthelWise, skip to queston 10. 

What is the reaon(s) for the additional expenditures? (More funds could have been spent if an 

aditna 75 percent was approved by AoA (OAA 308(b). 

Not Applicable


was 

alocted for the State ombudsman program from Title III-B resources. What was the actual 

10. The Final SF-269 Report shows that $ (fll-in amount prior to on-sie visi) 

amount expended?


(Indicate amount) 

I nee to review documentation confirming this information. Check as approprie:


Documentaton is provided is unavailable or wil be made available
 by on (date)

Don t Know 
 (Check if applicable)

C-8 Financial Management - Final 
Prir to the on-sie visi, detennine if the State Agency reported any transfers among allotments 

during the la Federa fiscal year. lf none were reported, go to queston 16. lf transfers were 

reported, ask the following approprie questions (pre-marked prior to the on-sie visi), depending 

upon the type of transfer(s) which occurred. 

14.	 Prior to our visit, we reviewed fisca data to determine if any trasfers occurred among 

alotment durig the last Federal fisca yea. Tbe State Agency reported (Fill-in with a, b, or 

both a and be as review indicated): 

Trnsfers between Title il-B and Title il-C in the amount of : 


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


Not Applicable


(If applicable) 
 I nee to review documentation confirming this information. Check as

approprie: Documentaton is provided 	 is unavailable 
 or wil be made available by on (date) 

Review the documentaton and indicate below whether or not documented transfers 

between Tile lIl-B and Tile Ill-C exceed 30 percent of either of these allotments. 

Yes 

Don t Know 

Transfers between Title il- ! and Title il- 2 in the amount of: 


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


Not Applicable


I nee to review documentation confirming this information. Check as (If applicable) 


approprie: Documentaton is provided 	 is unavailable 
 or will be made

available by on (date) 

Review the documentatn and indicate below whether or not documented transfers 

between Tile Ill- l and Tile Ill- 2 exceed 30 percent of either of these allotments. 

Yes (If YES, ask queston 15)


No (If NO, go to question 16)


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


Financial Management - Final 
Revew and detennine whether or not the assessment instruments address the financia 

management crieri identied in the following table. Indicate your responses with an X in 

the approprie column reflecting these codes: 

Y (Yes) Total Compliance with Crieri 

P (Partl) = Partl Compliance with Crieri 

N (No) Not in Compliance with Crieri 

During the desk review, if the assessment instrument and relaed materils do not include 

those items necessary to make a detenninatn of compliance (Y, P, or N), mark NA (Not

Availe) in the Comments section of the table. 

CRIRI COMMNTS 

State Agency approves all AA contracts with


profitmag gratee


OAA Sec. 212


NOT APPLICABLE TO AAA 

AA admistrtive expenditures statewide do not


exce the 10 % limitation


OAA Sec. 304(d)(I)(A) 

There is no fuding at the 85-15 match for 

program development and coordinated activities 

until the specified percentage is expended


statewide for AA admistration


45 CFR 1321.7(f)(14)


Each AA retains rerds for 3 yrs after the date


tht the AA submits its fial expenditure report


or the date on which reslution of audit


exceptions, litigation, etc. occurs (whichever date


is later)


45 CFR 92.42 & 74 Subpart D 

Parcipants are given an opportty to mae


voluntary contributions


45 CFR 1321.67(a)(I) 

Limtations on trafers between congregate and


home-delivered meal allotments 

45 CFR 1321.45 

Privacy of contributions 

45 CFR 1321.67(a)(2) 

Safegurd and accounting for contributions 

45 CFR 1321.67(a)(3) 

Support services contributions are used to expand 

support service 

45 CFR 1321.67 

Financial Management - Final 
(If aditna space is required, use the back of the previous page) 

Financial Management - Final 
23 and 24 apply to the most recent area plan year: Questns 

23.	 How many contrcts did AAAs award to profitmakng firms? 

(Indicate number)


Don t Know 
 (Check if applicable)


None 

24.	 If any contracts were made with profitmakng firms State Agency? 
 , how many firms were approved by the

(Indicate number)


Don t Know (Check if applicable)


25.	 In Fisca Yea 1978, what was the tota amount of the expenditures in rural areas from Title 

, Title V (multipurpose senior centers), and Title VII (nutrtion)? 

Title II Expenditures


Title V Expenditures 

Title VII Expenditures 

Don t Know (Check if applicable) 

26.	 What was the tota amount of the Title II expenditures (only) in rural areas included in the 

most recnt Final SF-269 Report?


Don t Know 
 (Check if applicable)

27.	 The preselected sample of 10 Area Agencies on Aging were identified prior to the on-sie 

visi. This sample is to be used throughout the compliance review process for all five 

areas, the firs compliance review being Stewardship. 

Financial Management - Final 
...... 

. ... .. ... . .. ...

I J


l; 1
 J!ijJMJ 

COMMEJlS: 

ONTERVIEW COMPLETED)


Financial Management - Final 
APPENDIX D

NUON SERVICES COMPLIACE REVIEW


HHS/AOA - 03/20/92


State Date 

Prry Respondent Telephone 

Review Tea Leder Telephone 

Prir to the on-sie visi, obtain copies of policies, procedures, and other guidance to Area 

Agencies on Aging (AA) on nutrin servces from the State Agency on Aging (State 

Agency). Review and detennine whether or not these issuances address the crieri 

identified in the following table. Indicate your responses with an X in the approprie 

column reflecting these codes: 

Y (Yes) Total Compliance with Crieri 

P (Partl) = Partl Compliance with Crieri 

N (No) Not in Compliance with Crieri 

During the desk review, if the policy materis do not include those items necessary to 

make a detenninaton of compliance (Y, P, or N), mark NA (Not Available) in the 

Comments section of the table. 

CRIERI COMMNTS 

I. Eligibility for Congregate Meas 

60+ 

OAA 307(a)(13)(A) 

Handicapped (0: 60) living with 

participant 

OAA 307(a)(13)(1) 

Handicapped (0: 60) living at meal site 

OAA 307(a)(13)(A) 

Spous ( 0: 60) of participant 

OAA 307(a)(13)(A) 

Volunter ( 0: 60) worker 

OAA 307(a)(13)(1) 

2. Eligibilty for Home Delivered Meals 

60+ 

OAA 307(a)(13)(A)(B) 

Nutrition Service - Final 
..

.;;(.;.; :.,::;

CRIRIA	 COMMNTS 

Handicapped (.: 60) living with


participant


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


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


Spous ( .: 60) of paricipant 

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

Volunter ( .: 60) worker 

OAA 307 (a)(13)(I 

I&R for other participant nee 

45 CFR 1321.65(d)(t) 

Provide caed, frozen, or supplemental


meals


OAA Part C- , Section 336


Meals in weather emergency


45 CFR 1321.65(e)


USDA Cash/Commodities 

Use by Title Il-C fuded providers for 

the provision of eligible meals regardless 

of the funding source 

OAA 311(a)(I) & (2) 

Cah purchases only U. grown foo 

OAA 311(b)(2) 

Prompt reporting to USDA 

OAA 311(c)(I)(B), 311(b)(2);


USDA Foo Distribution Regulations,


Par 250.42(C)(5)(i)	 , m

%#AA. 

#WM Food service maagement companes	 tH?4% 

:%1

reciving donated foods have contract :",:-.:x,, 

with the nutrition service provider	 mWi.M 

USDA Regulations, Part 250, Subpart	 fu111


#tlW'
 B(12)(c)	 0:"''''':'; x,.,=:',,: 

:.:"'x"' 

Ony IlC gratee get USDA


reimbursment III


OAA 311(a)(I) ktR


Maita for 3 years records of cah


reived and distribute


USDA Food Distribution Regulations


Par 250.42(c)(iii)	 %WW f.;-r::::; 

Establish proceures for the prompt 

and equitable disbursement of USDA 

cah recived 

OAA 311(b)(2) 

Nutrtion Service


Lotion of nutrition sites


OAA 307(a)(13)(D)


Nutrition Services - Final 
At this point, you should have completed the in-house compliance review of the policies, 

procedures, and other guidance provied to AA on nutrion services. For each crieri IaIgg indicatng an entry of NO, PARTIAL, or NOT AVAIlALE list it in the firs column of questn prir to the on-sie intervew. NOTE: For those items marked NA as a result of the 

desk review, Stae Agency responses may indicate convertng the NA to Y, P, N, or to NA (State 

Agency meets crieri at the State level) or NSC (State Agency does not address this applicable 

Federa crieri). Ask questn


initng the intervew. 

during the on-sie visi following the brief explanaton 

A few weeks ago, AoA requested copies of the policies, proceures, and other guidance provided 

to the Area Agencies on Aging concerning nutrtion services. These were reviewed against 

speific nutrtion criteria contaned in the Older Americas Act and the Title II regulations. 

Durig ths review , we identified issuances which only parally addressed specific criteria, or we 

were unable to identify issuances addressing speific criteria. For these, I nee to understad: 

How the State Agency directs and guides the AAAs to ensure that nutrition services 

requirements are met for those criteria not addressed or parially addressed. 

Criteria # with


, Paral, or


Not Available entry A!!ency Resoonse 

D-4 Nutrition Services - Final 
Review and detennine whether or not the assessment instroments address the nutrin 

semce crieri identfied in the following table. Indicate your responses with an in the 

approprie column reflecting these codes: 

Y (Yes) Total Compliance with Crieri 

P (Part) = Part Compliance with Crieri 

N (No) = Not in Compliance with Crieri 

During the desk review, if the assessment instroment and relaed materils do not include 

those items necessary to make a detenninatn of compliance (Y, P, or N), mark NA (Not 

Available) in the Comments sectin of the table. 

CRIERI COMMNTS 

1. Eligibilty for Congregate Meals


60+


OAA 307(.)(13)(A)


Handicapped ( 0: 60) living witb


participant


OAA 307(a)(13)(I)


Handicapped ( 0: 60) living at mea site


OAA 307(.)(13)(A)


Spouse ( 0: 60) of participant


OAA 307(a)(13)(A)


Volunteer ( 0: 60) worker 

OAA 307(.)(13)(1) 

2. Eligibilty for Home Delivered Meals


60+


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


Handicappe ( 0: 60) living with 

paricipant


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


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


Spouse ( 0: 60) of p.rticipant


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


Volunteer (0:60) worker 

OAA 307 (.)(13)(1) 

I&R for other paricipant nee 

45 CFR 1321.65(d)(f) 

Provide caed, frozen, or supplemental


meals


OAA P.rt C- , Section 336


Meals in weather emergency


45 CFR 1321.65(e)


D-6 Nutrition Services - Final 
gg. 

CRIRI	 COMMNTS 

Other nutrition service 

OAA Par C - Section 331(3) 

List other nutrition servces in State: 

Speial menus


OAA 307(a)(12)(G) 

List special menus in State: 

as.	 Assure competition in provider selection


OAA Sec. 501(b), Comprehensive Older


Americans Act Amendment of 1984;


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


bb. Voluntary Contrbutions


Collect and safegurd cah


OAA 307(a)(13)(C)(i) 

ce.	 Collection of food stamps 

45 CFR 1321.65(c) 

dd.	 Confidentiality 

45 CFR 1321.67(a)(2) 

00.	 6. Health and Safety


State and local licensing requirements


45 CFR 1321.5 

ff.	 Health department inspections


45 CFR 1321.75


Fire department inspections


45 CFR 1321.75


For each crieri 4a-4gg indicatng an entry of NO, PARTIAL, or NOT AVAILABLE, list it in 

the firs column of queston 
 prior to the on-sie interview. NOTE: For those items marked 

NA as a result of the desk review, State Agency responses may indicate convertng the NA to Y 

, N, or to NA (State Agency meets crieri at the State level) or NSC (State Agency does not 

address this applicable Federal crieri). Ask queston during the on-site visit. 

A few weeks ago, AoA also requested a copy of the assessment instrument and any applicable 

tools used by the State Agency to assess compliance and performance of AAAs with nutrition 

service law and regulations. These were reviewed against specific nutrition service criteria 

contaned in the Older Americans Act and the Title II regulations. During this review, we 

identified issuances which only parially addressed specific criteria, or we were unable to identify 

issuances addressing specific criteria. For these , I nee to understad: 

Nutrition Services - Final 
(If aditna space is required, use the back of the previous page) 

What criteria, not required by Federa law or regulation , has the State Agency included in' 

its assessment instrment for nutrtion programs? 

- Don t Know
 (Check if applicable) 

How oftn doe the State Agency assess the Title II-funded nutrition programs? 

Annually 

Every 6 months


Every quarer 

Monthly 

Other (Define) 

What are the sta and end dates for the last completed cycle of on-site assessments? 

a. Sta date 


b. End date ­


Nutrition Services - Fina 
11. Whch of the following activities does the State Agency use to monitor the Title Il-funded 

nutrtion programs? 
 (Read the following list and check responses. 

Review of report (USDA, Progra Performance, or other State reports 

regarding the planned number of meas to be served contrasted with the 

number of meas actuly served). 

Commodity withdrawals


USDA cash disbursements


Other (Explan): 

- Don t Know
 (Check if applicable) 

12. What are the most common deficiencies in the nutrition program in this State? 

Don t Know
 (Check if applicable) 

13. What technica assistace or trning has the State provided to address these deficiencies? 

- Don t Know 
 (Check if applicable)

Nutrition Services - Final 
16. What factors does the State use in determining the cost of meas: 

FACTORS 

CONGREGATE MEALS HOME DELIVERED MEALS 

Uses unit cost per mea 

(Circle if applicable) 

Don t Know


(Circle if applicable)


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

Cash


Commodities


Cash and Commodities 

Don t Know 
 (Check if applicable)

18. Why was this option chosen? 

Don t Know 
 (Check if applicable)

Nutrition Services - Final

!il.ii


Criteria 

Nutrition Service - Final 
y

.gg. 

w1% a.mijprff :-:,:v;.w,.,.;:X,' &1M.-m:'" JI. 1m1myg 

COMMS: 

(INTERVIEW COMPLETED) 

Nutrition Services - Final
gg. 

Ony mc grate get USDA reimbursment 

OAA 311(a)(1) 

Maita for 3 yea recrd of cah reived and distributed 

USDA foo distribution regulations, Part 250.42(c)(iii) 

Establish proceure for the prompt and equitable disbursement of USDA cash recived 

OAA 311(b)(2) 

4. Nutrtion Serice 

Lotion of nutrition sites 

OAA 307(a)(13)(D) 

Outreh to eligible individuas 

OAA 307(a)(l3)(E) 

Eah meal provides a mimum of 1/3 RDA 

OAA Par C - Section 331(1) 

Provide at leat one meal, 5 or more days per week 

OAA Part C - Section 331(1) 

Nutrition education services 

OAA Part C - Section 331(3) 

Other nutrition service 

OAA Par C - Section 331(3) 

Speiat menus 

OAA 307(a)(12)(G) 

aa. Assure competition in provider selection 

OAA Sec. 501(b), Comprehensive Older Americas Act Amendments of 1984; 

45 CFR Par 92, 36(8) "Procurement 

bb. 5. Volunta Contrbutions 

Collect and safegu cah 

OAA 307(a)(13)(C)(i) 

ce. Collection of foo staps 

45 CFR 132\.65(c) 

dd. Confdentiality 

45 CFR 132\.67(a)(2) 

ee. 6. Heath and Safety 

State and tocalicensing requirements 

45 CFR 132\. 75 

ff. Heath department inpetions 

45 CFR 1321.75 

Fire departent intions 

45 CFR 1321.75 

Nutrition Services - Final 
APPENDIX E

OMBUDSMA COMPLIACE REVIEW


HHS/AOA - 03/20/92


State Date 

Ombudsn Telephone 

Review Tea Leder Telephone 

(Al citations refer to the Older Americans Act) 

Is the Office of the Long-Term Care Ombudsman located in the State Agency on Aging? 

(Hereafer the State Agency on Aging wil be referred to as the State Agency) 

Yes (If Yes, go to question 2) No (If No): 

(1) Where is it locted? 

(2) Is there a contrct between this agency and the State Agency? 

(a) Yes (If Yes, get copy) 

(b) 

(c) Don t Know
 (Check if applicable) 

Is the agency that sponsors (houses) the Ombudsman responsible for licensing long-term 

cae (LTC) facilities or an association affiliated with LTC facilties? 

a. Yes (If Yes, discuss): 

Ombudsan - Final 
Is there a State law governing the Ombudsman Program? 

Yes (q Yes, get copy) 

Don t Know 
 (Check if applicable)

Does the Office of the Long-Term Care Ombudsman utilize sub-State ombudsmen? 

Yes (q Yes, go to questn 5)


No (q No, go to queston 7)


Describe the organizational relationship between the sub-State ombudsmen and the State 

Office of the Ombudsman. 

Are there any reportng or operations problems with sub-State ombudsman? (Probe both) 

Ombudsan - Final 
10.	 Of that tota (number provied in questn 9), how many professional and support staff are: 

(Complete queston using a, b, and c) 

PROFESSIONAL SUPORT DON' T KNOW 

(Indcate Number) (Indcate Number) (Check if Applicale) 

Ful-time employees? 

Par-time employees? 

Volunteers? 

11.	 What procures are in place to assure that Ombudsman employees and volunteers are 

qualfied and trained prior to investigating complaints? (Sec. 307(a)(12)(K)) (Probe for 

standrds for both employees and volunteers) 

12.	 Does the Ombudsman program formally certfy volunteers? 

Yes (If Yes, go to questn 13) 

No (If No, go to queston 14) 

13.	 What are the requirements for certfication? 

E-4	 Ombudsman - Final 
Lo laws, regulations , and policies regarding LTC 

facilities (If No): 
 When was the last time traning was

conducted? 

Investigative techniques (If No): 
 When was the last

time trning was conducted?


17.	 Is there a formal (written) in-service trning currculum for employees? 

Yes (If Yes, get copy) 

18.	 What are examples of the tys of training provided in the last year to: (Complete queston 

using a, h, and c) 

a. paid full-time staff 

b. paid par-time staff


c. volunters?


19.	 How do you coordinate activities with the protection and advocacy systems for individuals 

with developmenta disabilities and menta ilness? (Sec. 307(a)(l2)(H)(v)) (Get examples) 

E-6	 Ombudsman - Final 
23. How do you encourage the parcipation by citizen organizations in the Ombudsman

progra? (307(A)(12)(A)(ii)) 

24.	 How does the State Agency identify and resolve any potential conflicts of interest affecting 

the Ombudsman, or any employee or representative of the Offce of the Ombudsman? 

(Sec. 307(a)(12)(F)(i), (ii),(iii)) 

25.	 How does the State ensure that no representative of the Office of the Ombudsman wil be 

held liable for the performance of offcial duties? (Sec. 307(a)(12)(I)) 

E-8	 Ombudsman - Final 
29.	 Have any sactions ever been applied to any individual or entity? 

Yes (If Yes): 

Describe the circumstaces, the saction applied , and the results of the saction. 

CIRCUMSTANCES SANCTION RESULTS OF 

APPLIED SANCTION 

(1) 

(2) 

(3) 

(4) 

(If additonal space is required, use the back of the previous page) 

30.	 How do you ensure residents of LTC facilities, throughout the State, are made aware of the 

Office of the Ombudsman? 

Ombudsman - Final 
36. Do you prioriti complaints? 

Yes (If Yes), How are complaints prioritized? (Probe for process, definitons 

used, etc. 

37. How do you ensure your staffs access to LTC facilities, residents, and residents' records? 

(Sec. 307(a)(12)(B), (K)) 

Ombudsman - Final 
40.	 How do you ensure that the identity of any complainant or resident of a facility wil not be 

disclosed? (Sec. 307(a)(12)(D)) 

41.	 Has your Offce had to identify the complainant or resident of a facility without his or her 

permssion? 

a. 	 Yes (If Yes), 
 Please discuss the circumstaces and under what grounds the

Offce disclosed this information. 

42.	 How is legal counsel made avaiable to the Offce of the Ombudsman? 

Ombudsman - Final 
46.	 What was the date of your last annual report?(Sec. 307(a)(12)(H)) 

(Te "annua report" pertains to Ombudsman report as per Sec. 307(1)(12)(H) 

47.	 Were' policy, regulatory, and legislative recommendations made in this report? 

Yes 

48.	 Was the annual report submitted to the State agency responsible for licensing or certifying 

LTC facilties? 

Yes 

49.	 Was it submitted to the State legislature? 

Yes 

50.	 In genera, who else routinely receives the report? 

Ombudsman - Finat 
ATTACHMT A


OMBUDSMA COMPLIACE CRITERIA 

307(a)(12)(A) Full time ombudsan 

307(a)(12)(A)ii Promote citizen organiztion participation 

307(a)(12)(B) Protect confdentiality of records and fies 

307 (a)(12)( C) Unionn reporting system 

307(a)(12)(D) Non disclosure of identity of complainant 

307 (a)(12) (E) Solicit views of AAAs, providers, & elderly 

307(a)(12)(F Conflct of interes 

307(a)(12)(G)ii Abilty to pursue remedies 

307(a)(12)(1) Representatives not held liable 

307(a) (12)(J)ii Prohibit retaliation 

307(a)(12)(J)il Provide sanction authority 

307(a)(12)OO Invesigative training 

Ombudsman - Fina