On Monday, August 22^nd, ADvancing States submitted comments to ACL regarding proposed changes to ACL’s Program Instruction on Guidance for the Development and Submission of State Plans on Aging, State Plan Amendments and the Intrastate Funding Formula.  In the initial proposal, ACL requests comment on a template that would expand the populations designated as “greatest social need.” In the template, there is an emphasis on individuals who are lesbian, gay, bisexual and transgender (LGBT), American Indian (regardless of membership in a Federal or state-recognized tribe); being a Holocaust survivor; status as a refugee; or discrimination and/or persecution (past or present) based on religious/social/political beliefs.  ADvancing States’s comment letter expresses support for increased activities to ensure that these populations are able to access Older Americans Act services, but raises concerns regarding potential unintended consequences of expanding the definition of greatest social need.

Click here to read comment letter.