ACL details match rules, maintenance-of-effort, transfer limits and reporting deadlines for OAA grantees

During the webinar, ACL staff provided detailed operational guidance on match requirements, maintenance-of-effort (MOE), fund transfers, program income, and required financial reporting for Older Americans Act grantees.

Stephanie Cole summarized match rules under the Act: state and area plan administration require a 25% non-federal share; supportive services and senior centers (Title 3 Part B) require a 15% match; congregate (C1) and home-delivered (C2) meal services require a 15% match with one-third of that match required to come from state sources. Cole emphasized that state or local funds tied to means testing may not be used to meet match requirements.

Cole explained MOE is calculated as the average of the three prior-year certification amounts and must be maintained (for example, averaging $10M across three years yields a $10M spending floor). She also described the long-term care ombudsman minimum-expenditure requirement and the SUA/ombudsman certification process.

Adam Mosy explained reallotment and transfers: SUAs must annually report whether they will fully use title 3 and 7 funds; reallotments are rare but occur when states cannot use funds and other states request them. Transfers between title 3 parts B and C are permitted up to 30% of final awards; transfers between C1 and C2 are capped at 40% (with a possible additional 10% authorized by an assistant secretary for aging waiver if demonstrated need exists). Transfers may not move funds to/from parts D, E, NSIP or title 7.

On timing and forms, presenters said transfer requests within statutory limits must be submitted by Aug. 1 in the final year of a project period, reallotment statements are due the second Friday in September, MOE and ombudsman minimum-expenditure certifications are due Aug. 1, and the title 3 supplemental form accompanies SF-425 submissions (annual and final reporting windows were noted). ACL indicated it aims to issue amended NOAs reflecting transfers within two weeks of approval and provided contact information for transfer and waiver instructions.

Monitoring and oversight expectations—risk-based monitoring, audits, reconciliations, site visits and corrective action plans—were underscored as responsibilities of SUAs when managing subrecipients. Presenters closed by linking to ACL’s OA implementation web page and providing a grants mailbox for fiscal questions.