Sec.17a-306-40. Miscellaneous

This section covers those important topics of insurance, release of information and privacy act maintenance not covered elsewhere in the Manual of Fiscal Policies.

(a) Minimum Insurance Requirements

In general, Attachment B of OMB Circulars A-102 and A-110 and specifically Title 45 Code of Federal Regulations Subpart 74.15 provide that "no additional bonding and insurance requirements, including fidelity bonds, shall be imposed by the terms of the grant or subgrant." Separate rules are imposed on projects involving construction and fidelity bond coverage. Thus, while the Connecticut Department on Aging may not impose as policy any additional requirements, the Department may make nonbinding suggestions that its subrecipients might consider in determining the scope and level of their insurance coverage, provided the costs of such insurance coverage are reasonable.

(1) Types and Levels of Insurance

As a guideline, subrecipients of the Connecticut Department on Aging should consider the following types and levels of insurance as minimum, either for themselves and/or their subgrantees or subcontractors, in their risk management programs:

(A)

Comprehensive liability

$1,000,000

(B)

Automobile for employees, volunteers, or escorts

1,000,000

(C)

Fire and water damage

Coverage for all items with acquisition cost of greater than $1,000

(D)

Directors' and officers' liability

$1,000,000 (with an adequate deductible level)

(E)

Theft

Coverage for all items with acquisition cost of greater than $1,000

(F)

Workers' compensation

To the extent required by state law

(G)

Product liability

Adequate coverage for weatherization contractors, nutrition providers and caterers

(2) Keeping Down the Cost of Insurance

Subrecipients of the Connecticut Department on Aging should employ all practical means to keep down the cost of insurance, including, but not limited to, product liability, self insurance of reasonable risks, adequate but not excessive deductible levels for purchased insurance, and clustered insurance programs with other providers in the same or similar risk category.

(b) Federal and State Freedom of Information Act Rules

(1) The Federal Freedom of Information Act applies to agencies of the U.S. Government.

(2) In accordance with the State Freedom of Information Act, upon request area agencies on aging shall make all nonexempt information available within the required deadline.

(c) Safeguards to Protect Certain Confidential Data

For all client and confidential employee data, area agencies on aging and their subgrantees shall exert special safeguards to preclude the unauthorized release of such data. These restrictions shall include (1) access controls, (2) personnel controls and (3) system controls in accord with Sections 4-190 through 4-197 of the Connecticut General Statutes.

(Effective November 8, 1991)