On Monday, June 6, 2022 ADvancing States submitted comments on the Administration for Community Living’s (ACL) Request for Information (RFI) regarding potential changes to the Older Americans Act (OAA) regulations. In the letter, we offer a wide range of recommendations to update antiquated language; remove or modernize obsolete rules; and strengthen the regulatory framework governing the OAA. Some examples of our recommendations include:
- Creating a regulatory structure for the Administration for Community Living, including the new research center created by the 2020 reauthorization;
- Aligning the definition of “Older Indian” across Titles III and VI’;
- Updating the language regarding transfers between congregate and home delivered meals to reflect current statute, and providing presumptive approval for all transfers up to the statutory maximum;
- Create a new subsection in the rules that provides structure and oversight regarding private-pay contracts that leverage OAA resources;
- Clarify the populations “who were the focus of resource centers funded under Title IV in fiscal year 2019” as well as the state and area responsibilities for compiling and reporting that data;
- Establish conflict of interest safeguards to ensure OAA resources are appropriately used and targeted to individuals with the greatest social/economic need; and
- Clarify that III-B funding can be used in Aging and Disability Resource Centers to support all populations included in the ADRC statutory definition, including individuals with disabilities under the age of 60.
Click here to access the full letter.