Public Comment

Older Americans Act: Public Comment

August 2023

In June 2023, the Administration for Community Living (ACL) issued a request for comments regarding proposed changes to regulations of the Older Americans Act of 1965.

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 (about 794,000 adults) in the U.S. are age 65 or older, including approximately 172,000 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 provide research on disparities and discrimination that support ACL’s new designation of LGBTQI+ people as a population of greatest social need. In addition, they support collection and reporting of data on OAA program participants’ sexual orientation and gender identity (SOGI). The comment requests ACL provide states and area agencies with guidance on collecting SOGI data in accordance with the 2022 report from the National Academies of Science, Engineering, and Medicine. And scholars request that ACL reconsider the removal of regulations that clarify relevant nondiscrimination protections.

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Download the 2022 comment

Older Americans Act: Public Comment