Administration on Aging
Policy Clarification Response
PCR - 94 - 10
February 4, 1994
Subject:
Inclusion of Title VII Funds in Calculation for State Plan
Administrative Costs
Inquiry Source: AoA
Regional Offices, Several States
Stat. & Reg.
Basis:
OAA Section 308(b)
Key Words:
State Administrative Costs, Calculation, Title VII Funds
ADDRIS Code:
Questions: Is
the amount allocated under the new Title VII included in the calculation
of funds available for State plan administration?
Response:
States may include Title VII allocations in the calculation of funds
available for State plan administration through fiscal year 1994; but
beginning on October 1, 1994, States may not include any Title VII
funding in their calculation of funds available for State plan
administration.
Discussion:
There is absent any reference in the Act to Title VII allotments in
calculating funding for administration of State plans. On the other
hand, it is quite clear that the Act authorizes States to allocate five
percent, or $500,000, whichever is greater, of their cumulative total
Title III allotments for meeting administrative costs.
When abuse prevention funding was under Part G of Title III and there
was an ombudsman allotment under Title III, States were authorized to
include these funds in computing the amount allowable to the State for
State agency administration. (See AoA PI-91-02, issued December 13,
1990.) AoA believes it is reasonable to permit Title VII funds to
continue to be calculated in the base for State plan administration
funding through FY 1994, in order to ensure continuity and a smooth
transition for the affected programs from Title III into Title VII.
The programs under Title VII, unlike most of the programs under Title
III, are established and operated as direct advocacy services by the
State agency on aging and/or agencies with which the State agency
contracts or provides grants to operate the programs. Thus, at least
some, if not all, of the Title VII funds are used to pay direct costs
for such administrative costs as staff, offices expenses, travel, etc.
Therefore, a major funding principle to which States need to adhere with
regard to Title VII is that all funding allotted for a particular Title
VII chapter must be used to carry out the requirements and activities
specified for that chapter in the Act. Funds allotted for FY 1995 and in
subsequent years for any chapter under Title VII should not be included
in the calculation for State plan administration funding.
Fernando M. Torres-Gil, Assistant Secretary for Aging
