Public Comment

Older Americans Act: Public Comment

June 2022

In May 2022, the Administration for Community Living (ACL) issued a request for information to inform an anticipated update of its Older Americans Act (OAA) regulations, including challenges to receiving and administering services and feedback on how the Act’s programs can advance equity.

  • Luis A. Vasquez
    Staff Attorney, Former
Public Comment


The OAA was enacted in 1965 to fund state and tribal programs and services that support the health and well-being of older adults and was last reauthorized in 2020. Current regulations for programs authorized under the OAA have not been substantively revised since 1988. The absence of valid and current regulations creates a potential for significant variation in the interpretation and implementation of the OAA across states.


Approximately 7% of LGBT adults in the U.S. are age 65 or older, including approximately 217,000 transgender older adults. LGBT older adults face unique challenges within the context of aging compared to their cisgender, heterosexual peers, including reporting worse mental and physical health outcomes, barriers to receiving formal and informal health care and social support, and experiences of discrimination based on their sexual orientation and gender identity. Poorer health outcomes may result partly from high rates of poverty and food insecurity among all LGBT people, with particular vulnerabilities for LGBT older adults.


Scholars recommend that the ACL modify the regulations to collect data on OAA program participants’ sexual orientation and gender identity (SOGI). While existing research provides valuable insight into the lives and experiences of LGBT older adults, there is a continued need for quality, representative data on this population across a range of contexts. Scholars also suggest that ACL require that participating entities provide assurances related to non-discrimination and confidentiality of information that will foster SOGI data collection and participation by LGBT people in funded programs. In addition, the comment provides support for collecting SOGI data in accordance with 2022 recommendations from an ad hoc panel of the National Academies of Science, Engineering, and Medicine.

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Older Americans Act: Public Comment