From mo To: Mullinslam; Will Cc: mm; Subject: Documentation to Support Targeted Group Eligibility for Contracts_DW.doo< Date: Friday, October 30, 2015 1:51:34 PM Attachments: Documentation to Targeted Group Eligibility for Controgg Dwoog Janre and Sheryl, The attached document has the changes we discussed. Janre please proof one more time If this passes Janre?s review ?this is the version that we are going to circulate to BOB as back-up for the financial order. Thanks! Dave DHHS Use of TANF Transfer to SSBG Table of Contents: Section I: Background and Summary Section II: Allowable Categories of Expenditures under SSBG Section Target Group Eligibility Section IV: Contract Language Enhancements for FFY ?16 Section V: OADS Population Study Section I: Background and Summary Background: The 60 month TANF eligibility restriction has produced the opportunity for the State to leverage TANF dollars in priority areas in the Department of Health and Human Services. In the spring of 2015, PCG, an independent consultant, completed an assessment for the Department on potential uses of TANF, SSBG, and CCDF that includes the ability to transfer funds from TANF to SSBG and/or CCDF and related uses. The Department then spent summer of 2015 assessing priority uses and the related mechanics of changes. This document summarizes the intended uses of TANF transfer funding to SSBG and the related eligibility criteria associated with how those funds are spent. Summary of Intended Uses Related of TANF Transfer to SSBG: Maine DHHS has the authority to transfer 10% of its Temporary Assistance to Needy Families (TANF) funding to the Social Services Block Grant (SSBG). It can do so under the following conditions: 1. Under federal law, the transferred funds are subject to the rules of the program to which they are transferred; in this case, TANF transfer dollars become subject to the rules of SSBG expenditure.1 2. The services funded with the transferred dollars are within the allowable categories of expenditure in SSBG (See Section II). a. in this case, DHHS is using TANF transfer dollars to SSBG for Elderly and Adults Home Based Care (vendor is Seniors Plus) and Independent Support (Homemaker) Services (vendor is Catholic Charities). b. These services meet the broader goal of maintaining self-sufficiency and reducing institutional care and qualify under independent] transitional living. 3. Welfare reform established an income limit of 200% of poverty for recipients of services funded specifically from TANF allotments that are transferred to the SSBG and benefit children or their families.2 guidepdf 2 PRWOR ACT, 1996. a. The Department is using the SSBG definition of families defined in the SSBG Annual Grant Application as the following (consistent across SSBG annual applications since 2009): i. ?For purposes of determining financial eligibility, a family is defined as: A group of related or non-related individuals, who are not residents of an institution or boarding house, but who are living as one economic unit. An economic unit consists of all individuals who share a dwelling unit and either pool income or share expenses in common.?3 ii. This method, also known as ?target group eligibility? is used by other States (see Section for supporting documentation). b. For purposes of meeting eligible income limits the Department is using the following approaches: i. Prior to FFY ?16: The Department is citing OADS population studies that peg the population that meets the 200% FPL restriction at 82% of the population served (See Section V). The proportion of revenue from the TANF transfer to SSBG in the contracts involved is well below the eligible population percentage that is eligible as evidenced by the OADS study. ii. For FFY ?16 and beyond: The Department is using the prior population study as a benchmark and making contract amendments that specifically require the vendors (Seniors Plus and Catholic Charities) to meet criterion #3 in order to leverage TANF transfer funding (see Section for further details). Section II: Allowable Categories of Expenditures under SSBG Allowable Expenditures Goals of SSBG: Under SSBG law, states can furnish social services best suited to the needs of the individuals residing in the State. Federal block grant funds may be used to provide services directed toward one of the following five goals specified in the law: 1) To prevent, reduce. or eliminate dependency; (2) to achieve or maintain self-sufficiency; (3) to prevent neglect, abug, or exploitation of children and adults; (4) to prevent or reduce inappropriate institutional 033; and (5) to secure admission or referral for institutional care when other forms of care are not appropriate. Authorized Uses: funds 29 categories of initiatives for children and adults including but not limited to the following: . Daycare Protective services . Special services to persons with disabilities 3 Maine 2014 Social Services Block Grant (SSBG) Application Adoption Case management Health related services Transportation Foster care Substance abuse Housing Home-delivered meals Independent/transitional living Employment services4 Section Target Group Eligibility Documentation to Support Target Group Eligibility for Contracts 1. For vulnerable populations, the Department has authority to encourage greater coordination of resources, advise regarding funding, and develop rules for this population as stated in Title 22, ?5106. Other states use target group eligibility Arizona?s State Plan for SSBG submitted and approved by the federal government clearly shows their intention to spend nearly double their SSBG allocation (thru TANF Transfer to SSBG) on populations that are not "family designated" by virtue of ?group" eligibility. Target Group Eligibility is differentiated from Status Eligibility, which is the financial category of eligibility qualification. New Jersey included in its SSBG report to the federal DHHS that TANF transfer to SSBG is used for Case Management, Day Care-Adults, Home Based Services, Home-Delivered Meals, Protective Services ?Adult. These fall under the target group eligibility. Texas outlines use of TANF Transfer for Adult Mental Health Services, particularly case management, and education or training to improve knowledge or daily living skills. Section IV: Section IV: Contract Language Enhancements for FFY ?16 As noted in the Congressional Research Service document on SSBG prepared for Congress in 2012, there are no federal eligibility criteria for SSBG participants. The exception is that welfare reform established an income limit of 200% of poverty for recipients of services funded by TANF allotments that are transferred to the SSBG. To that end, Maine DHHS proposes language that ensures the following: 4 3 Draft Contract Amendment Language Block Grant Funding - The Provider will agree to comply with the requirements applicable to the federal TANF program; including the audit requirements of OMB Circular A-133 (the circular is available online at This agreement shall be extended to and communicated in writing to subcontractors and sub- recipients implementing the programs. Contractor compliance with and notification to subcontractors and sub-recipients in writing shall include the following: . Providers maintain records on their clients that contain income information that ensures that expenses billed fall in one of two categories: the first are those that meet the SSBG definition of "a children or their families? and the 200% FPL requirement and secondly, those that do not. All reimbursements from the State will be based on this criteria. . Providers will maintain necessary data and documentation required for auditing to ensure integrity in the collection and reporting of this data. Section V: OADS Population Study Program Income/Assets Limits Program Caps Copay Calculation Elderly and Adults Home Based Care OADS Policy Section 63 Current Contractor: Seniors Plus No income limit Assets less for 1, <$75,000 for 2 Level I: $968 Level 1,183 Level 1,838 Level NF ($3682) 4% of income 3% of assets $15,000 Independent Support Services (Homemaker) OADS Policy Section 69 Current Contractor: Catholic Charities No income limit Assets less <$50,000 for 1, <$75,000 for 2 Maximum ten hours per month 20% of cost of services Functional assessment is not conducted if individual?s assets exceed allowable program limit. Assessing Services Agency refers individual to Office of Family Independence if person appears to meet MaineCare financial eligibility. The current contractors conduct financial assessment of participants to determine copay obligation. Home Based Care Quantity and percentage of . . . consumers served under Profile Distinct Average age . Home Based Care whose SFY2014 Client Count of consumers . (?1501) income is 200% or less of the Federal Poverty Level COUNTY Quantity Percent ANDROSCOGGIN 78 71 71 91% AROOSTOOK 268 78 227 85% CUMBERLAND 208 77 155 75% FRANKLIN 27 79 21 78% HANCOCK 43 75 31 72% KENNEBEC 194 77 164 85% KNOX 19 77 16 84% LINCOLN 25 73 22 88% OXFORD 75 77 66 88% PENOBSCOT 151 75 121 80% PISCATAQUIS 25 77 16 64% SAGADAHOC 20 75 11 55% SOMERSET 122 75 101 83% WALDO 29 76 25 86% WASHINGTON 45 76 38 84% YORK 172 76 139 81% 76 82% Statewide Statewide Percent Average Age below 200% FPL Data Source: MeCare MED Assessment Data