1.5     Grantees are required to target services to low-income, minority, rural and frail seniors (including Native Americans). Low-income is defined as having an income that is at or below 100% of the current Federal Poverty Guidelines. The Division will provide guidance to programs in developing a Targeting Plan during the grant application process. The Targeting Plan contained in the approved grant application must be implemented.

1.5.a   Documentation of the Targeting Plan activities and any other targeting activities provided during the grant year shall include:  

1.6     Proof of U.S. citizenship is not required to receive services from this funding source.

2.       Documentation and Reporting Requirements: 

2.1     Grantees are required to meet the program reporting requirements established by the Administration on Aging under the National Aging Program Information System (NAPIS).  

2.1.a   Grantees are required to submit all applicable reports and/or complete data entry per the Division’s Grantee Reporting Schedule. 

2.2     Programs funded with Older Americans Act, State Volunteer and/or State Transportation monies shall: 

2.2.a   Update registration forms for all active clients in the first quarter of the fiscal year and complete registration forms on new clients as they enter the program. Any deviation from this schedule must be approved by the Division. Clients must sign and date the registration form indicating that the information provided is correct.

2.2.b   Enter client information into the Social Assistance Management System (SAMS) as it is made available to the program on the client registration form. The information entered into SAMS must be accurate and kept up-to-date.

2.2.c   Provide each client with the Notice of Privacy Practices made available by the Aging and Disability Services Division, unless the client has received the Notice from another Division-funded program, as noted in SAMS.

2.2.d   Develop and maintain a system for recording the units of service provided to each client daily, e.g. daily sign-in sheets, time sheets, logs or client files. 

2.2.e   Enter units of service provided by the program into the SAMS database by the 15th day of the following month.  

3.       Operating Procedures - Grantees are required to submit a written copy of the following operating policies/procedures to ADSD as requested, or when a revision has been made:

3.1     Client Cost Sharing and Donation Procedures: 

3.1.a   The opportunity to make confidential, voluntary, non-coercive contributions is required. Means testing and denial of service based on non-contribution are prohibited. 

3.1.b   Establish procedures to protect the privacy of individuals regarding their contributions. 

3.1.c   A suggested donation amount shall be established for services provided through the grant(s).

3.1.d   A consumer may be encouraged to share the cost of services based on a specific program's sliding-fee schedule. Sliding-fee schedules must be submitted to the Aging and Disability Services Division for review and approval prior to implementation. (PIN 30) 

3.2      Advocacy, Information and Referral Procedures: 

3.2.a   Grantees are required to establish, acquire or develop, and utilize a comprehensive list of resources available to seniors within their service area. 

3.2.b   Grantees are required to maintain current program information on the Aging and Disability Resource Center (ADRC) website, www.nevadaadrc.com, and include ADRC program and contact information in their Advocacy, Information and Referral policy.  

3.2.c   Any client who needs or requests assistance in completing a referral shall be provided an appropriate level of assistance. 

3.3     Client Grievance Procedure: 

3.3.a   A formal grievance procedure must be established for occasions when the client is not satisfied with efforts made by the program to resolve  concerns. The formal procedure must clearly define the steps that the program will take to resolve formal complaints. The procedures must: 

(1)      specify that complaints are to be submitted in writing;

(2)      provide for an impartial review;

(3)      ensure that complaints are acted on in an expeditious manner; and

(4)      stipulate that assistance will be available to clients who require help in preparing a written complaint. 

3.3.b   Grantees who contract with other agencies for the provision of services must establish a procedure to ensure that client complaints are directed to the grantee agency. A complaint tracking system must be maintained to include: 

(1)      date of complaint;

(2)      client’s name, address and telephone number;

(3)      client’s perception of the problem;

(4)      date of follow-up with the contractor; and

(5)      action taken to resolve the complaint. 

3.4     Procedure for Suspension or Termination of Clients from Service: 

3.4.a   Grantees are required to establish a written procedure that defines the steps that will be taken to suspend or terminate clients from service. Grantees are advised to note that the suspension/termination of a client from a federally-funded program without just cause represents a violation of the client’s civil rights. A suspension or termination is to be undertaken only after all other reasonable measures for resolving the concern have been exhausted. The procedure must contain the following provisions: 

(1)      description of behaviors that are considered grounds for suspension or termination, if circumstances allow;

(2)      documentation of the incident;

(3)      procedure for warning the client prior to suspension;

(4)      written notification of suspension/termination provided to the client; and

(5)      client appeal process. Whenever feasible, clients are to be placed on temporary suspension. 

3.5      Emergency Procedures: 

3.5.a   Grantees are required to develop written procedures for staff to follow in addressing client medical emergencies. The procedures must address the basic steps staff members need to take in responding to an actual or potential emergency. Programs providing services in the homes of clients should also develop procedures when clients do not answer the door or cannot be located during a scheduled visit. 

3.5.b   When services are provided in a facility, grantees are required to develop written emergency procedures for fire, flood, earthquake, bomb threat, physical assault/threat and other natural and technological disasters that might require emergency response and/or evacuation of the facility. 

3.5.c   Grantees are required to work with governmental agencies during emergencies to ensure the safety of clients and others in the community.

3.6      SAMS Procedures: 

3.6.a   Grantees must develop written, internal procedures for staff on entering required data elements into SAMS. The basic purpose of these procedures is to create continuity of program operation.

4.       Training: 

4.1      Elder Abuse Awareness: 

4.1.a   Persons providing direct service to seniors shall be provided with an annual training on recognizing the signs of elder abuse and the Nevada Elder Abuse Law (NRS 200.5092 - 200.5099). The Division-approved Elder Abuse PowerPoint, located at www.nvaging.net/epstraining.htm, is to be used, unless Division staff, or a pre-approved representative, is able to provide an in-service training.

(1)        Date of training;
(2)        Signatures of staff and/or volunteers in attendance; and
(3)        Method of training (PowerPoint vs. In-Service).
             a.     In-service documentation must also include the  
                    name and title of the trainer.    

5.       Quality Improvement: 

5.1     Sub-Contractor Performance Review: 

5.1.a   Grantees who contract with other agencies for the delivery of service must develop standardized criteria to evaluate the performance of the contractor. Performance evaluations must be conducted and documented annually. 

5.2     Grantee Performance Review: 

5.2.a   Programs will develop and implement pre and post performance indicator surveys to assess the impact of the services provided to the client and/or caregiver. New clients will be asked to complete a pre-survey upon entering the program, with the post-survey given as a follow-up within six (6) months of the first survey. Survey questions are subject to the approval of the Aging and Disability Services Division.  

5.2.b   The program shall establish an annual method to determine consumer satisfaction with service through questionnaires or some other means. The results of the quality improvement review must document the process, instruments used and individuals involved.  Program deficiencies found must be documented and a plan of correction must be developed.  

6.       Special Compliance Requirements: 

6.1     Confidentiality: 

6.1.a   In accordance with OAA Regulations, grantees must obtain a client’s informed consent prior to disclosing information about the client to other agencies. In compliance with the Aging and Disability Services Division’s Program Instructions – Nevada, PIN 2: The Division’s ability to evaluate the grant will not be denied or hindered. This includes access to any document or record that is pertinent to administering the program. This also includes the right to interview participants/clients, grantee personnel and program staff, in accordance with confidentiality regulations.   

Providers of legal assistance are not required to reveal any information to ADSD that is protected by attorney-client privilege. 

6.1.b   Grantees must establish procedures to limit access to client records to appropriate staff and ensure that client records are stored in a secure manner. 

6.2     Waiting Lists: 

A waiting list is to be established only after all other measures for improving the efficiency of the service delivery system have been examined and, when feasible, implemented. Grantees are required to establish a waiting list policy that will be activated in the event that demand for service exceeds the program’s capacity. Waiting list documentation must include, at a minimum: 

6.2.a   The client’s name, address, and telephone number; 

6.2.b   the date the client was placed on the waiting list; and 

6.2.c    the description of each client’s need for service. 

Services are targeted to those clients with the greatest social and economic needs, with particular attention to low-income individuals, minority individuals, those in rural communities, those with limited-English proficiency and those at the greatest risk of institutional care. Those at risk of institutional care are to receive highest priority consideration. The program must establish a procedure for updating the continued service needs of clients placed on the waiting list. 

6.3     Service Prohibitions: 

6.3.a   Staff shall not accept tips, gifts, loans or fees from clients.

6.3.b   Staff shall not smoke in clients’ homes or while transporting clients. 

6.3.c    Staff shall not purchase alcohol or illegal substances for clients. 

6.3.d   Staff shall not borrow the client’s car or other personal belongings. 

6.3.e   Staff shall not bring family members, other people or pets to the client’s home without the client’s permission and supervisory approval. 

6.3.f    Staff shall not eat the client’s food. 

6.4.    Safety: 

6.4.a   The grantee cannot assign staff, volunteers or contractors to work in conditions that jeopardize their safety.

6.4.b   A qualified professional will supervise volunteers, if applicable.

6.4.c   Prior to providing services, staff, professionals and volunteers who have direct contact, enter a client’s home or provide transportation for clients are required to have a fingerprint-based background check. If the person can present a valid fingerprint clearance card or credible documentation that the person’s application for a fingerprint clearance card is pending, he/she is not required to submit another application for a fingerprint clearance card. Federal Bureau of Investigation (FBI) background checks are recommended for further protection, but not required at this time.