TO : STATES ADMINISTERING PLANS UNDER TITLE
III OF THE OLDER AMERICANS ACT OF 1965, AS AMENDED
SUBJECT : Procedures for Reporting the Transfer
of Title III Formula Grant Funds
LEGAL AND RELATED REFERENCES : Older Americans
Act, as Amended - Sections 308(b)(4)(A), 308(b)(4)(B), 308(b)(5)(A),
and 308 (b)(4)(C)
This Program Instruction (PI) provides procedures for reporting
the transfer of funds within certain Title III allotments. This
PI also explains how the Administration on Aging will reflect
these reported transfers on grant award amendments.
The Older Americans Act (OAA) provides authority for states to
transfer funds, within statutory limits, among their allotments
for Supportive Services and Senior Centers (III-B), Congregate
Meals (III-C1), and Home-Delivered Meals (III-C2). There is, however,
no authority for states to transfer funds in or out of the allotments
for Preventive Health Services/Disease Prevention, Ombudsman Program
or the National Family Caregiver Support Program.
Transfers between Congregate Meals (Title III-C1) and Home-Delivered
Meals (Title III-C2): States may transfer up to 40% of their allotment
for Title III-C1 to Title III-C2, or vice versa. By statute, the
election to transfer funds is a state decision that may be disapproved
by the Assistant Secretary, AoA, only if she determines that the
transfer is not consistent with the objectives of the OAA. A state
may effect such a transfer at any point during the fiscal year.
AoA encourages states to notify it whenever they transfer funds
so that any potential issues may be resolved timely. However,
AoA policy is to require states to notify it of transfers at the
end of the year.
The OAA provides that the Assistant Secretary may grant a waiver
to permit a state to transfer an additional 10%, i.e., up to a
total of 50%, of funds between Titles III-C1 and III-C2. The granting
of such a waiver is contingent upon the state’s demonstrating
to the satisfaction of the Assistant Secretary that the funds
available under Titles III-C1 or III-C2, including transfers,
are insufficient to satisfy needs. The contents of the waiver
request are specified in section 308(B)(4)(C).
Transfers between Title III-B and the Nutrition Programs under
Title III-C: The OAA permits a state to transfer up to 30% of
an allotment between Titles III-B and the Nutrition Programs under
Title III-C. This transfer may be made at the discretion of the
state and requires only that the state notify AoA.
Section 316(b)(4) permits the Assistant Secretary to grant a
waiver of the 30% transfer limit. However, in order to receive
such a waiver, a state must comply with all the requirements in
section 316. The section 316 waiver provision is more involved
than the waiver provision in section 308(relating to transfers
between Titles III-C1 and III-C2). States are cautioned not to
wait until the end of the fiscal year to request a waiver under
section 316. If needed, a section 316 waiver should be initiated
as early as possible in the fiscal year.
Instructions for Reflecting a Transfer on the SF-269: Whenever
a state makes a transfer during the fiscal year, the state should
reflect that transfer on its next SF-269. The state should reflect
the transfer on the supplemental sheet to the Financial Status
Report(SF-269), detailing how the funds in line 10.o are allocated.
Funds taken from any part of Title III for use as State Plan
Administration do not constitute a transfer in the context of
this Program Instruction, and therefore should not be reported
as a transfer.
When submitting its transfer information, a state should follow
1. transfers are made only from the last grant award for FY 2001
for Title III;
2. show only the total transfer effected during the fiscal year,
in III-B, III-C1 and/or III-C2 (not the series of individual transfers
that might have been made during the fiscal year); and,
3. show the state’s computation of its final allotment
in each affected Title, as shown in the state’s records,
so that AoA can verify the transfer grant award against the state’s
Notification of amounts transferred this fiscal year, as well
as requests for a waiver must be received on or before September
28, 2001. AoA will issue a revised grant award reflecting the
transfer. This will ensure that states may draw down funds from
the appropriate allotment.
State agencies will be notified by letter of the Assistant Secretary
for Aging’s approval or disapproval of requests for waiver
of the limits on the amount of funds that a state may transfer.
Any transfers reflected on the SF-269 after the close of the
fiscal year must be supported by documentation which indicates
that the transfers were approved or made prior to the close of
the fiscal year.
AoA will not accept requests for waivers submitted after the
end of the fiscal year.
DUE DATE: September 28, 2001 for submission
to Regional Administrators on Aging.
INQUIRIES: Inquiries should be addressed to
the appropriate Regional Administrator on Aging.
Josefina G. Carbonell
Assistant Secretary for Aging