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Disaster
Assistance
Disaster Preparedness Manual for the Aging Network
VIII. Fiscal Considerations
A. BACKGROUND
It is critical that services to older persons be available as
soon as possible after a major disaster. This is particularly
true of disaster advocacy and outreach services as older persons
need the special assistance that these services provide if
they are to receive the same level of assistance as the general
population. In order to provide these services more readily,
State and Area Agencies on Aging must have a reasonable assurance
that funding is available or will be forthcoming on as close
to a immediate basis as possible.
The first steps in the funding process are the determination
of need and the development of a plan to respond to that need.
Numbers of older persons affected, aging facilities damaged,
and characteristics of the disaster impact are important elements
that must be determined by the AAA and submitted to the State
Agency on Aging, who in turn communicates such information to
the Regional Office and to other state agencies. In this process,
AAA's and State Agencies on Aging receive additional information
about the disaster.
A skeleton plan is then developed with best estimates of the
fiscal resources that will be needed to implement the plan. The
AAA and the State Agency on Aging must develop plans for their
respective levels that will factor in a knowledge of the role
of other Community, State and federal agencies and their funding
potentials. These plans are shared with the State and Federal
Emergency Management Agencies and are forwarded to the Regional
Office. The Regional Office will interact with the State relative
to the needs identified and will make efforts to address the
funding requirements as quickly as possible.
As State and Area Agencies on Aging respond
to the disaster, individuals involved should maintain diaries
of expenditures
and time spent working on the disaster. Receipts and all available
documentation should be maintained so that these expenditures
can be reimbursed at a later time.
It may be necessary for the aging network
to use funds that are already programmed for the existing program.
The Administration
on Aging recognizes that most states have fully committed
available funds and that expenditure of such funds for disaster
response
puts the existing program and therefore the recipients of
services in danger of terminated services. This in turn threatens
those
individuals as surely as the older disaster victims. Maintenance
of good communications between the AAA's involved, the State
Agency on Aging and the Regional Office will help in maintaining
a current awareness of the likelihood of additional funding
and knowledgeable decisions can be made on expenditures.
Any funds a State or Area Agency on Aging has that can be made
available for disaster response without later reimbursement
should immediately be committed.
B. TITLE III, SEC. 310
The Older Americans Act, Title III, Sec. 310, provides for reimbursement
of expenditures made by States to meet the social service needs
(and related supplies) of older victims of disasters declared
by the President. In order to meet these costs, the Administration
on Aging is directed to set aside 2% of the funds appropriated
for Title IV-Training, Research, and Discretionary Projects
and Programs.
In any given year, this is approximately $500,000. In FY 1994,
Title IV was appropriated approximately $26 million, meaning
that $520,000 was available for disaster response.
In any given year, an undetermined number of Presidentially-Declared
disasters will occur. So the Administration on Aging will want
to be in a position to support disaster response in each of these
situations. AoA limits the amount available to $50,000 per state.
In substantially larger disasters, this amount may be increased
depending on the time in the year the disaster occurs and the
amounts used to that time.
The Administration on Aging strongly recommends
the first use of these funds to be for the provision of Disaster
Advocacy and
Outreach Services. Only after these services are adequately funded,
and there is reasonable assurance that the scope of the disaster
will not continue to grow should there be consideration of gap-filling
services. There is unanimous support for this position among
states and area agencies on aging polled who have experienced
major disasters in recent years.
The Administration on Aging will accept an
abbreviated application after declaration and attempt to fund
it within 24 to 48 hours.
This is deemed necessary so that states and area agencies
on aging will have the assurance that initial support is available
and will therefore have adequate financial support to proceed
immediately to implement the disaster advocacy and outreach
program. Every effort should be made to have staff and disaster
advocates ready and available to staff the Disaster Assistance
Centers as they are opened by the Federal Emergency Management
Agency. Simultaneously, outreach to assure that older victims
register must be made. The language in the Older Americans Act indicates that these
funds must be made available on a reimbursement basis. The Administration
on Aging has found that a slow response to the funding needs
of States and Area Agencies on Aging will sometimes mean a slow
response to disasters. Consequently, the Administration on Aging
has determined that an obligation of funds by a State Unit on
Aging will constitute an expenditure and therefore will meet
the intent of the legislation. A copy of the award document should
be included in the abbreviated application submitted to the Administration
on Aging in order to meet the requirements of the Older Americans
Act.
These funds do not require a non-federal match share.
The Legislation directs that the funds held in reserve for disaster
response be released after the third quarter of each year so
that it may used to meet the objectives of Title IV. It is therefore
critical that any perceived needs for such disaster funding be
communicated as soon as possible so that a situation does not
develop in which there are no funds available at some point in
the fourth quarter of the year. Early notification will permit
the Administration on Aging to reserve these funds for use in
the fourth quarter.
States have the authority to set aside a portion of their Title
III allotment for disaster assistance. The setting aside of these
funds must be included in the process for developing the state's
Intrastate Funding Formula, and any unused funds must revert
back to AAAs using the Intrastate Funding Formula.
C. Federal Emergency Management Agency
During the 1970's, a National agreement
between AoA and the Federal Disaster Assistance Administration
(FDAA, now FEMA) to reflect
an understanding by the two agencies that a commitment of
$40,000 of AoA discretionary funds would meet a requirement that
the
Administration on Aging contribute funds to meet the disaster
needs of older persons before requests for funding be submitted
to FDAA. Following this commitment, AoA was encouraged to
submit a proposal to FDAA representing additional financial needs
so that funding could be provided through a mechanism call
a mission assignment. This understanding was reflected in
AoA-PI-76-44
and the AoA/FDAA agreement attached to that memorandum. This
understanding was also reflected in a manual prepared for
the Aging Network and disseminated widely in 1980. In 1979, AoA-PI-79-25 was issued to the Aging network which
indicated the Agreement previously negotiated was still in effect.
Pursuant to that instruction and the FEMA/AoA agreement, mission
assignments were made in Region VII on May 1, 1979 and January
14, 1983.
In the 1980's, this agreement lapsed and an interpretation developed
by FEMA which precludes funding of the aging network in disasters
at either the State or Federal levels. The basis of this interpretation
is that authorizing language already exists in the Older Americans
Act (Sec. 310) and that increases in funding should be made in
the legislation, if necessary.
From time to time, area agencies on aging have developed positive
relationships with FEMA representatives in responding to disasters
and have received funding based on the submittal of appropriated
documentation of expenditure. Maintenance of good financial and
performance records will facilitate potential reimbursement from
FEMA.
At this time, the Administration on Aging and State Units on
Aging are not receiving funds directly from FEMA. In some disasters,
it has been required by the Office of Management and Budget that
FEMA provide denials of funding requests at the state level and
that those denials be submitted as part of any request for supplemental
funding. Such requests are submitted from the State Agency on
Aging, through the State Emergency Management Office, to FEMA.
For this reason, and for reasons described elsewhere, it is important
that strong cooperative relationships be maintained between the
State Agency on Aging and the State Emergency Management Agency
during the course of the disaster.
D. Supplemental Appropriations
In very large or in catastrophic level disasters, such as the
Midwest Flood and the Northridge Earthquake in Los Angeles, the
Executive Branch of the Federal Government has prepared a request
which is submitted to Congress for a supplemental appropriation
to finance activities that go beyond the scope of conventional
disaster capabilities. In the Department of Health and Human
Services, funds have been requested and become available to finance
health and social services needed.
The process used in such instances by the Administration on
Aging correspond with the normal planning functions which must
be completed regardless of whether supplemental appropriations
are requested. Area Agencies on Aging identify the services needed
and the costs of providing those services. Factored into these
considerations are the other resources available. These plans
and budgets are forwarded to the State Office on Aging and are
updated on an on-going basis. These plans and budgets are unified
and communicated to the Administration on Aging. It is important
that this information be communicated quickly and updated as
when the determination is made that a supplemental appropriation
request will be made, decisions must be made quickly and supporting
documentation developed.
The Administration on Aging, based on information submitted
by the State or States involved in the disaster, develops a request
reflecting the information which has been developed from the
States and other sources in the Department and elsewhere, such
as FEMA, and submits the request to the Office of Emergency Preparedness
located within the Public Health Service. All requests are combined
at that point, recommendations made, and forwarded to the Secretary.
With approval of the Secretary, these requests then go the Office
of Management and Budget and finally to the President. These
requests will then be transmitted to the Congress.
At all levels, the appropriateness of the
requests will be evaluated and recommendations developed. It
is in the interest of the aging
network to make reasonable and well documented requests in such
circumstances, not inflated requests, as a competitive situation
exists where the best documented proposals have the best chance
of funding. It is possible that complete funding of a request
may be made or, more commonly, a percentage of the request is
funded.
The time factors involved in this process
also become important considerations. Typically, it has taken
four to six months
for funds under a supplemental appropriation to become available
in a given disaster. In that period of time, the situation
of the elderly my change significantly. Instead of being
in the response stage, older persons are in the recovery stage
and many different kinds of service gain in importance. For
example, abuse and exploitation has become more important
now
than it was initially. The Administration on Aging attempts
to maintain flexibility in the funds that are received through
this process because it recognizes that the needs change
through the passage of time. Nonetheless, the Administration
on Aging
does recognize that the more immediate the assistance provided
older victims, the more impact on that persons ability to recover. Supplemental appropriations are another instance where the maintenance
of good records are critical. Whereas funds may not be available
for four to six months under this process, they may be used to
pay back costs accrued from the time of the disaster. State and
Area Agencies on Aging are forced into a situation where severe
risk-taking has taken place under this set of circumstances.
The difficult decisions often faced is how much of the regular
service funding should be used to respond to the disaster, what
are the time frames involved, and how likely is it that funds
will become available? The network will provide the best intelligence
possible to assist in these most difficult decisions by State
and Area Agencies on Aging. The Administration on Aging is making
an effort to address this very difficult set of circumstances.
E. Reallotted Appropriations
At the end of each fiscal year, the Administration on Aging
asks states to determine whether all the funds made available
for that year are needed. Funds which are not needed for Title
III and Title VII are then returned to the Administration on
Aging and are reallotted nationally to states which have submitted
a request for such funds. Added to these amounts are any funds
the Administration on Aging has held for evaluation per the legislation
and not used.
When very large or catastrophic disasters
occur, and the disaster has occurred in the proximity to the
end of the Fiscal Year,
the Administration on Aging may determine that the most appropriate
use of such funds are to reallot them to the states impacted
by the disaster. The amount may vary from very small amounts
to several million dollars.
When such funds are reallotted to states
for use in responding to disasters, the same rules apply as if
they were available
under ordinary circumstances. They must be used in conformance
with the governing legislation. For example, Title III (C)
(1), Congregate Meals Program, must be used for those purposes
unless transferred. These funds must be matched as usual.
They may be obligated at any time in the year following the reallotment
as usual. If Area Agencies on Aging are designated in the
disaster
areas, they must be obligated to the Area Agencies on Aging,
a circumstance which may not always prevail with the use
of the supplemental or Title IV funds obligated under Title III,
Sec. 310. The major differences between these funds and ordinary
use of reallotted funds is that they should be used for disaster
response and they do not have to be obligated in accordance
with the intrastate formula. They may be spent where they
are
needed.
F. Additional Fiscal Considerations
State and Area Agencies on Aging should be alert to the other
opportunities that may be available for funding. In disasters,
funds have become available to the aging network from the Community
Development Act (CDA), the Social Services Block Grant (SSBG),
the Community Services Block Grant (CSBG), the Economic Development
Act (EDA) and other sources. Relationships and credibility
have much influence on the opportunities which may develop.
Early in the disaster, the State(s) and Area Agencies on Aging
should identify a potential recipient of donated funds. Substantial
amounts of funds are donated in larger disasters, often directly
to the aging network. A name, address and phone number for such
donations should be available as soon as possible. These should
not be established unilaterally, but in cooperation with other
aging organizations in the community or state.
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