Older Americans Act: COVID-19 Response

Older Americans Act: COVID-19 Response

Older Americans Act: COVID-19 Response
June 22, 2023
Compared with younger people, older adults have been at higher risk of severe illness due to
Coronavirus Disease 2019 (COVID-19), including hospitalization and death. The Older
Kirsten J. Colello
Americans Act (OAA) supports a wide range of social services and programs for older
Specialist in Health and
individuals. In response to the COVID-19 pandemic, additional discretionary and mandatory
Aging Policy
appropriations provided $1.120 billion in FY2020 funding and $1.609 billion in FY2021 funding

for OAA programs and activities to prevent, prepare for, and respond to COVID-19. These
Angela Napili
amounts were in addition to the annual OAA funding levels of $2.145 billion and $2.179 billion,
Senior Research Librarian
for FY2020 and FY2021, respectively.

As part of the federal government’s response to COVID-19, Congress also enacted legislation to

provide new authorities and types of federal assistance to address the pandemic. These provisions
define their applicability by reference to COVID-19 pandemic declarations made by the former Secretary of HHS, Alex M.
Azar, on January 31, 2020. Secretary Azar determined the pandemic to be a public health emergency (PHE) pursuant to
Section 319 of the Public Health Service Act (PHSA). On May 11, 2023, HHS allowed the PHE authority declaration to
expire.
Legislation enacted in FY2020 and FY2021 provided additional appropriations, as well as certain policy changes to facilitate
administration of OAA services and activities through the Aging Network, which is composed of federal, state, and local
entities and service providers. This report summarizes provisions from four COVID-19 response measures:
• the Families First Coronavirus Response Act (FFCRA; P.L. 116-127);
• the Coronavirus Aid, Relief, and Economic Security Act (CARES; P.L. 116-136);
• the Additional Coronavirus Response and Relief, Division N of the Consolidated Appropriations Act, 2021
(P.L. 116-260); and
• the American Rescue Plan Act of 2021 (ARPA; P.L. 117-2).
During the first months of the COVID-19 pandemic, the Aging Network was faced with closures of congregate nutrition
sites, where meals are served in group settings, and the need to rapidly expand home-delivered nutrition services to older
individuals. COVID-19 relief legislation provided additional funding and OAA statutory flexibilities that allowed the Aging
Network to quickly expand delivery of home-delivered nutrition services, as well as to address food shortages through the
use of frozen meals, shelf-stable meals, and grocery delivery, among other activities.
In addition to summarizing provisions from the four COVID-19 response measures listed above, this report also summarizes
selected Administration for Community Living (ACL) administrative activities regarding implementation of COVID-19
relief legislation and public health emergency and disaster response to COVID-19. The report further describes the Aging
Network’s response to COVID-19 with respect to administration and implementation of OAA programs and activities.
When the public health emergency for COVID-19 expired on May 11, 2023, the specific OAA legislative flexibilities also
expired. Furthermore, with the publication of notice in the Federal Register announcing the closure of the incident periods
for major disaster declarations under the Stafford Act for COVID-19, state units on aging (SUAs) must begin unwinding
disaster relief flexibilities used under the OAA. In March 2020, at the beginning of the COVID-19 pandemic, Congress
passed and the President signed legislation to reauthorize the OAA for a five-year period through FY2024. Congress may
continue to assess the Aging Network’s response to the COVID-19 pandemic and unwinding activities to determine what, if
any, OAA program modifications or innovations might be considered with future OAA reauthorizations.
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Contents
Families First Coronavirus Response Act ....................................................................................... 5
Coronavirus Aid, Relief, and Economic Security (CARES) Act .................................................... 5
Consolidated Appropriations Act, 2021 .......................................................................................... 7
American Rescue Plan Act of 2021 ................................................................................................. 8
Administration for Community Living (ACL) Activities ................................................................ 9
COVID-19 Relief Funding Allocations..................................................................................... 9
Disaster Relief ........................................................................................................................... 9
COVID-19 Response Guidance .............................................................................................. 10
Program Reporting Requirements ........................................................................................... 10
Other Activities ........................................................................................................................ 11
Aging Network Activities ............................................................................................................... 11
Concluding Observations .............................................................................................................. 13

Figures
Figure 1. Actions that Area Agencies on Aging (AAAs) Have Taken in Response to
COVID-19 .................................................................................................................................. 12

Tables

Table A-1. COVID-19 Additional Funding for Older Americans Act Programs, FY2020-
FY2021 ....................................................................................................................................... 16

Appendixes
Appendix. COVID-19 Response Funding for Older Americans Act Programs ............................ 15

Contacts
Author Information ........................................................................................................................ 17

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Older Americans Act: COVID-19 Response

ompared with younger people, older adults have been at higher risk of severe illness due
to Coronavirus Disease 2019 (COVID-19), including hospitalization and death.1 In
C response to the COVID-19 pandemic, additional discretionary and mandatory
appropriations provided $1.120 billion in FY2020 funding and $1.609 billion in FY2021 funding
for Older Americans Act (OAA) programs and activities to prevent, prepare for, and respond to
COVID-19 (see the text box below). These amounts were in addition to the annual OAA funding
levels of $2.145 billion and $2.179 billion, for FY2020 and FY2021, respectively.2
Older Americans Act: Overview of Current Law
The Older Americans Act (OAA) supports a wide range of social services and programs for older
individuals, defined as those aged 60 years or older. These include supportive services, congregate nutrition
services (i.e., meals served at group sites such as senior centers, community centers, schools, churches, and
senior housing complexes), home-delivered nutrition services, family caregiver support, the long-term care
ombudsman program, and services to prevent the abuse, neglect, and exploitation of older persons. The
OAA also provides part-time opportunities in community service activities for unemployed low-income
individuals aged 55 and older. Except for Title V, Community Service Employment for Older Americans
(CSEOA), all programs are administered by the Administration on Aging (AOA) in the Administration for
Community Living (ACL) within the Department of Health and Human Services (HHS). Title V is
administered by the Department of Labor’s (DOL’s) Employment and Training Administration. The OAA
statutory language contains the fol owing seven titles, which authorize various programs and activities:
•
Title I sets policy objectives and defines terms.
•
Title II establishes administrative functions for the executive branch under the AOA.
•
Title III authorizes grants to states and U.S. territories that in turn fund local entities that provide
supportive services, nutrition services (home-delivered and congregate nutrition), disease prevention,
and family caregiver services and supports for individuals aged 60 and older.
•
Title IV authorizes grants for training, research, and demonstration projects in the field of aging.
•
Title V authorizes grants to states, U.S. territories, and national organizations to promote part-time
opportunities in community service activities for unemployed low-income older individuals aged 55
and older.
•
Title VI authorizes grants to tribal organizations for supportive and nutrition services to older Native
Americans.
•
Title VII authorizes grants to states and U.S. territories for vulnerable elder rights protection
activities, including the long-term care ombudsman program.
For more information, see CRS Report R43414, Older Americans Act: Overview and Funding.
As part of the federal government’s response to COVID-19, legislation was enacted to provide
new authorities and types of federal assistance to address the pandemic. With respect to new
authorities under the OAA, these provisions define their applicability by reference to COVID-19
pandemic declarations made by the former Secretary of HHS, Alex M. Azar, on January 31, 2020.
Secretary Azar determined the pandemic to be a public health emergency (PHE) pursuant to
Section 319 of the Public Health Service Act (PHSA). Since that initial issuance, Secretary Azar,
and subsequently Secretary Xavier Becerra, renewed this PHE declaration every 90 days.3 On
May 11, 2023, HHS allowed the PHE authority declaration to expire.4

1 Centers for Disease Control and Prevention, Risk for COVID-19 Infection, Hospitalization, and Death By Age Group,
https://www.cdc.gov/coronavirus/2019-ncov/covid-data/investigations-discovery/hospitalization-death-by-age.html.
2 For more information, see CRS Report R43414, Older Americans Act: Overview and Funding.
3 See HHS Secretary, Xavier Becerra, Renewal of Determination That a Public Health Emergency Exists (January 11,
2023), https://aspr.hhs.gov/legal/PHE/Pages/covid19-11Jan23.aspx.
4 HHS, COVID-19 Public Health Emergency, https://www.hhs.gov/coronavirus/covid-19-public-health-emergency/
index.html.
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The following sections summarize legislation enacted in FY2020 and FY2021 that provided
additional appropriations, as well as certain policy changes to facilitate administration of OAA
services and activities through the Aging Network. The Aging Network is composed of the
Administration for Community Living (ACL) at the federal level; state agencies, referred to as
state units on aging (SUAs); local area agencies on aging (AAAs); and thousands of service
providers that receive federal funding under the OAA. Provisions from four COVID-19 response
measures are summarized below, as follows:
• the Families First Coronavirus Response Act (FFCRA; P.L. 116-127);
• the Coronavirus Aid, Relief, and Economic Security Act (CARES; P.L. 116-
136,);
• the Additional Coronavirus Response and Relief, Division N of the Consolidated
Appropriations Act, 2021 (P.L. 116-260); and
• the American Rescue Plan Act of 2021 (ARPA; P.L. 117-2).
For a summary of these additional OAA appropriations for COVID-19 response, according to law
and appropriation year, see Table A-1.
Families First Coronavirus Response Act
On March 18, 2020, the President signed the Families First Coronavirus Response Act (FFCRA;
P.L. 116-127), which provided a total of $250.0 million in discretionary supplemental funding for
expanded food assistance for OAA nutrition services to states, U.S. territories, and tribal
organizations, among other activities. Funding was provided to the Administration for
Community Living (ACL) Aging and Disability Services Programs, to remain available until
September 30, 2021. Specifically, the FFCRA provided the following amounts:
• $80.0 million for congregate nutrition services to states and U.S. territories,
• $160.0 million for home-delivered nutrition services to states and U.S. territories,
and
• $10.0 million for nutrition services to Native Americans.5
For these funds, the FFCRA eliminated the 15% state matching requirements that apply to OAA
Title III formula grants for supportive services and nutrition services (OAA Sections 304(d)(1)(D)
and 309(b)(2)).
Coronavirus Aid, Relief, and Economic Security
(CARES) Act
On March 27, 2020, the President signed the Coronavirus Aid, Relief, and Economic Security Act
(CARES; P.L. 116-136), which provided a total of $870.0 million in discretionary supplemental
funding to states, U.S. territories, and tribal organizations for OAA nutrition services, supportive
services, family caregiver services, Aging and Disability Resource Centers (ADRCs), and elder
rights protection activities. Funding was provided to the Administration for Community Living

5 State and tribal organization allocation tables for the Families First Coronavirus Response Act (P.L. 116-127) and
CARES Act (P.L. 116-136) are at ACL, Older Americans Act (OAA), https://acl.gov/about-acl/older-americans-act-oaa.
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(ACL) Aging and Disability Services Programs, to remain available until September 30, 2021.
Specifically, the CARES Act provided the following amounts:
• $480.0 million for nutrition services to states and U.S. territories,6
• $20.0 million for nutrition services to Native Americans,
• $200.0 million for supportive services,
• $100.0 million for family caregiver services,
• $50.0 million for ADRCs, and
• $20.0 million for elder rights protection activities, including the long-term care
ombudsman program.7
With respect to the CARES Act supplemental funding, the act provided an SUA the authority to
transfer up to 100% of its CARES Act Title III nutrition services funds between the congregate
and home-delivered nutrition services programs. For these CARES Act funds, the 15% state
matching requirements for OAA Title III formula grants for supportive services and nutrition
services did not apply.
In addition to supplemental funding provided under the CARES Act, certain provisions under the
act made policy changes to various OAA programs during any portion of the COVID-19 public
health emergency declared under Section 319 of the Public Health Service Act (PHSA). These
changes were similar to those applied to the CARES Act supplemental funding. However, these
provisions also applied to other appropriations measures for the duration of the public health
emergency and allowed for additional flexibilities.
Specifically, Section 3222 of the CARES Act provided an SUA or AAA, without prior approval,
the authority to transfer up to 100% of its OAA Title III nutrition services funds between the
congregate and home-delivered nutrition programs. This 100% transfer authority applied to Title
III nutrition services funding regardless of whether the funds were from COVID-19 supplemental
acts or from regular annual appropriations acts and extended until the PHE declared by the HHS
Secretary ended. Under current law, only SUAs have the authority to establish a process for
transferring funding between nutrition programs and are prohibited from delegating transfer
authority to AAAs or other entities. Specifically, the OAA authorizes SUAs to transfer up to 40%
of allocations between congregate and home-delivered nutrition programs, with approval from the
Assistant Secretary for Aging. SUAs may request a waiver from the Assistant Secretary for Aging
to transfer an additional 10% of funds between these programs.8
Section 3222 of the CARES Act further clarified participant requirements for home-delivered
nutrition services to include those unable to obtain nutrition due to social distancing as a result of
the emergency. Section 3222 also authorized the Assistant Secretary for Aging to waive certain

6 ACL allocated the entire $480.0 million for nutrition services to states and U.S. territories for home-delivered
nutrition. For more information, see “ACL State by State Total for CARES Act Funding,” April 21, 2022,
https://acl.gov/sites/default/files/about-acl/2020-04/
ACL%20State%20by%20State%20Tribe%20and%20CIL%20CARES%20Supplemental%20Awards%20Tables%2004
.21.20.pdf.
7 P.L. 116-136, the Coronavirus Aid, Relief, and Economic Security (CARES) Act, provided $480.0 million in
supplemental funding for OAA Title III nutrition services that ACL allocated to states and territories under their home-
delivered nutrition programs and provided $20.0 million for OAA Title VII services that ACL allocated to the long-
term care ombudsman program. State and tribal organization allocation tables for the CARES Act (P.L. 116-136) are at
ACL, Older Americans Act (OAA), https://acl.gov/about-acl/older-americans-act-oaa.
8 OAA Section 308(b)(4).
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dietary requirements for nutrition services during the COVID-19 public health emergency.9 Under
current law, senior nutrition program meals must meet nutrition requirements established under
Dietary Reference Intakes (DRIs) and Dietary Guidelines for Americans (DGAs).10
Section 3223 of the CARES Act provided additional authority for the Secretary of Labor with
respect to the administration and implementation of OAA Title V, Community Service
Employment for Older Americans (CSEOA), due to the effects of the COVID-19 public health
emergency declared under PHSA Section 319, if determined appropriate.11 This additional
authority included extending individual program participation beyond 48 months in the aggregate,
increasing the average participation cap for eligible individuals that is applied to grantees, and
increasing the limit on administrative expenses to 20% of the grant amount.12
Consolidated Appropriations Act, 2021
On December 27, 2020, the President signed the Consolidated Appropriations Act, 2021 (P.L.
116-260). Division N, the Additional Coronavirus Response and Relief, provided a total of $175.0
million in mandatory supplemental funding for OAA nutrition services to states, U.S. territories,
and tribal organizations. Specifically, Section 731 of Division N provided the following amounts:
• $168.0 million for nutrition services to states and U.S. territories, and
• $7.0 million for nutrition services to tribal organizations.13
Of the $168.0 million to states and U.S. territories for nutrition services, ACL allocated the entire
amount to home-delivered nutrition services.14 This supplemental funding was to remain
available through September 30, 2022.15
For the Division N funds, Section 731 eliminated the 15% state matching requirements that
usually apply to OAA Title III formula grants for supportive services and nutrition services.

9 National Resource Center on Nutrition and Aging, Understanding Nutrition Requirements During COVID-19 for
Senior Nutrition Programs, updated June 2021, https://acl.gov/sites/default/files/2021-06/
Understanding%20Nutrition%20Requirements%20During%20COVID-19_FINAL.docx; ACL, COVID-19 Response:
Funding Flexibilities for Senior Nutrition Programs, updated October 2021, https://acl.gov/sites/default/files/nutrition/
SNP_FundingFlexibilities_2021OCT.pdf.
10 For further information, see National Academies, Summary Report of the Dietary Reference Intakes,
https://www.nationalacademies.org/our-work/summary-report-of-the-dietary-reference-intakes, and Dietary Guidelines
for Americans, https://www.dietaryguidelines.gov.
11 For information on the CSEOA program, see CRS Report R45626, Older Americans Act: Senior Community Service
Employment Program.
12 For more information on OAA Title V, CSEOA programs, see CRS Report R45626, Older Americans Act: Senior
Community Service Employment Program; U.S. Department of Labor, Employment and Training Administration,
COVID-19 Frequently Asked Questions, https://www.dol.gov/agencies/eta/coronavirus#SCSEP; U.S. Department of
Labor, Employment and Training Administration, Training and Employment Guidance Letter No. 22-19: Program
Year (PY) 2020 Planning Instructions and Allotments for Senior Community Service Employment Program (SCSEP)
State, Territory, and National Grantees; and Implementation of SCSEP Provisions of the Coronavirus Aid, Relief, and
Economic Security Act (CARES Act), May 28, 2020, https://www.dol.gov/agencies/eta/advisories/training-and-
employment-guidance-letter-no-22-19 (this guidance letter is no longer active).
13 State and tribal organization allocation tables for Consolidated Appropriations Act, 2021, Division N, are at
https://acl.gov/sites/default/files/about-acl/2021-02/Supp%205%20-
%20Title%20III%20and%20Title%20VI_01292021_CM%20Table%20of%20States-Territories-Tribes.pdf.
14 Email communication with ACL Budget Director, January 7, 2021.
15 ACL issued further guidance on OAA funding under P.L. 116-260 on January 28, 2021; see https://acl.gov/sites/
default/files/common/AoA%20-%20Fiscal%20FAQs%20Supplement%205.pdf.
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Section 732 of Division N (P.L. 116-260) further provided that of the Title III-C home-delivered
and congregate nutrition services program funds that they received in FY2021, SUAs and AAAs
could transfer up to 100% of the funds between the two programs without prior approval.16
Similar to the CARES Act, Section 732 further clarified participant requirements for home-
delivered nutrition services to include those unable to obtain nutrition due to social distancing as
a result of the public health emergency and authorized the Assistant Secretary to waive certain
dietary requirements for nutrition services.
American Rescue Plan Act of 2021
On March 12, 2021, the President signed the American Rescue Plan Act of 2021 (ARPA; P.L.
117-2). Title II, Subtitle L, provided a total of $1.434 billion in mandatory funding for OAA
programs, to remain available until expended. Specifically, Section 2921, Supporting Older
Americans and their Families, provided the following amounts:
• $750.0 million to states and U.S. territories for nutrition services;
• $460.0 million for supportive services, to include COVID-19 vaccination
outreach (including transportation) and activities to prevent and mitigate social
isolation related to COVID-19;
• $145.0 million for family caregiver services;
• $44.0 million for disease prevention;
• $25.0 million to tribal organizations for nutrition services, supportive services,
and family caregiver services; and
• $10.0 million for the long-term care ombudsman program.17
Of the $750.0 million to states for nutrition services, ACL allocated $450.0 million to home-
delivered nutrition services and $300.0 million to congregate nutrition services.18 Of the $25.0
million to tribal organizations, ACL allocated $16.7 million to supportive and nutrition services
and $8.3 million to family caregiver services.19 In contrast to supplemental funding provided
under earlier relief acts, ARPA did not eliminate the 15% state matching requirements that apply
to OAA Title III formula grants for supportive services and nutrition services.

16 Ibid.
17 State allocation tables for ARPA are at https://acl.gov/sites/default/files/about-acl/2021-05/
FY%202021%20ARP%206%20Programs%204-30-21%20Values%20Only%20version%202.pdf. USAspending.gov, a
database of federal awards, lists ACL’s tribal ARPA awards at https://www.usaspending.gov/search/?hash=
e85c2f6388842115b24dbe2f99f5d07c. For background on USAspending.gov, see CRS Report R46491, Resources for
Tracking Federal COVID-19 Spending.
18 Email communication with ACL Budget Director, March 15, 2021.
19 Ibid. Of the Title III-C home-delivered and congregate nutrition services program funds that they received in
FY2021, SUAs and AAAs may transfer up to 100% of the funds between the two programs without prior approval, per
P.L. 116-260, Division N, Section 732.
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Administration for Community Living (ACL)
Activities
The following sections summarize selected ACL administrative activities regarding
implementation of COVID-19 relief legislation and public health emergency and disaster
response to COVID-19 under OAA programs and activities.20
COVID-19 Relief Funding Allocations
ACL provided additional OAA funding appropriated through COVID-19 relief legislation to
states, U.S. territories, and tribal organizations based on the statutory formulas authorized under
the OAA. These allocations were based on each state or territory’s relative share of the total U.S.
population aged 60 years and older (with the exception of the National Family Caregiver Support
Program, which was based on the relative share aged 70 years and older). To be eligible for OAA
funding, tribal organizations must include at least 50 Native American elders aged 60 or older.21
States and U.S. territories were required to distribute this additional funding based on each state’s
or territory’s intrastate funding formula, approved by the Assistant Secretary for Aging. This
funding formula (1) takes into account the geographical distribution of older individuals in the
state or territory; and (2) the distribution among planning and service areas of older individuals
with greatest economic need and older individuals with greatest social need, with particular
attention to low-income minority older individuals.22
Disaster Relief
In addition to the COVID-19 relief legislation that provided new OAA authorities and expanded
administrative flexibilities, as previously described, the OAA also contains authority for disaster
relief reimbursement pursuant to an emergency determination under Section 501(b) of the Robert
T. Stafford Disaster Relief and Emergency Assistance Act (“Stafford Act”; 42 U.S.C. §§5121-
5207). On March 13, 2020, the President declared that the COVID-19 pandemic was of sufficient
severity and magnitude to warrant an emergency determination under the Stafford Act, effective
nationwide. Under the declaration, states, U.S. territories, and tribes were authorized to consider
requests for a declaration of a “major disaster” under Section 401(a) of the Stafford Act. A major
disaster declaration under the Stafford Act triggers the disaster relief authority in the OAA,
should a state (including a U.S. territory) or tribe (OAA Title VI grantee) request and receive such
declaration. Subsequently, President Trump, and later President Biden, issued major disaster

20 Additional COVID-19 funding was provided to state Long-Term Care Ombudsman Programs and Adult Protective
Services Programs under statutory authority for grants authorized under Section 2043(a) of Title XX of the Social
Security Act, referred to as the Elder Justice Act. Funding for these programs and activities is outside the scope of this
report. Additional information can be found at ACL, COVID-19 Response: Long-Term Care Ombudsman Programs,
Coronavirus Response and Relief Supplemental Appropriations Act of 2021, February 1, 2021, https://acl.gov/sites/
default/files/common/LTCOP%20Coronavirus%20RR%20Sup%20Aprop%20Act%202-1-21-%20Final.pdf, and ACL,
COVID-19 Response: Coronavirus Response and Relief Supplemental Appropriations Act of 2021: Grants to Enhance
Adult Protective Services to Respond to COVID-19, Frequently Asked Questions, Updated February 12, 2021,
https://acl.gov/sites/default/files/common/ACL_APS_Grants_FAQ_02.11.21.Final_.pdf.
21 Tribal organization allocation tables are at ACL, Older Americans Act (OAA), https://acl.gov/about-acl/older-
americans-act-oaa.
22 OAA Section 305(a)(2)(C); [42 U.S.C. §3025(a)(2)(C)]; ACL, COVID-19 Response, Fiscal FAQ COVID-19
Emergency, https://acl.gov/sites/default/files/common/AoA%20-%20Fiscal%20FAQs%20Supplement%205%201-28-
2021.pdf; ACL, COVID-19 FAQ, American Rescue Plan (Fiscal Questions and Answers), https://acl.gov/sites/default/
files/2021-05/ARP%20Fiscal%20FAQ_4_30_2021.pdf.
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declarations for every state, five territories, the District of Columbia, and three tribes with respect
to the pandemic under the Stafford Act.23
Specifically, the disaster relief authority under OAA Section 310 (42 U.S.C. §3030) allows states
to use any portion of funding made available under any and all sections of the OAA for disaster
relief for the delivery of supportive services provided to older individuals.24 It also provides a
very limited ability for states and tribal organizations to receive reimbursements for the delivery
of supportive services (and related supplies) during a major disaster declaration, with total
payments to all entities not to exceed 2% of the total amount appropriated and available for OAA
Title IV (an estimated $80.7 million in FY2020).
COVID-19 Response Guidance
According to a review by GAO and interviews with ACL officials, ACL provided guidance, on-
line information, and technical assistance to states regarding the use of the COVID-19 funds and
approaches to modify services.25 For example, ACL posted COVID-19 related guidance for OAA
grantees and service providers online at ACL, Coronavirus disease 2019 (COVID-19).26 In
addition, ACL held regular calls with states on how to use and report COVID-19 relief funds,
provided written responses to frequently asked questions, and served as a forum for information
sharing among stakeholders in the form of webinars and other on-line resource sharing.
Program Reporting Requirements
The OAA requires states to report data annually to the Assistant Secretary about services provided
under the act. These reporting requirements are set forth by ACL in annual State Program Reports
(SPR). SPRs require states to enter program data in a uniform template that captures specific data
fields associated with outcome measures such as the number of clients served, service units
provided (e.g., meals or service hours), and expenditures by certain services (e.g., case
management or homemaker expenditures). For FY2020, ACL maintained these SPR requirements
but asked states to report on their use of the additional COVID-19 funds by including an open-
ended “narrative” with their annual SPR.27
ACL stated that these additional reporting requirements allowed the agency and states to adopt a
simple and flexible reporting method.28According to a review of four selected state reports, GAO
found inconsistent details provided in the narratives, which made it difficult to compare spending
across states.29 GAO also noted that, after receiving these initial reports for FY2020, ACL took

23 For specific presidential declarations for COVID-19, see COVID-19 Disaster Declarations, FEMA,
https://web.archive.org/web/20230511110621/https://www.fema.gov/disaster/coronavirus/disaster-declarations, and
Disasters, FEMA, https://www.fema.gov/disasters.
24 For further information, see ACL guidance issued March 16, 2020 at https://acl.gov/sites/default/files/common/
OAA%20DISASTER%20RELIEF%20REIMBURSEMENTS-310%203-16-2020.docx, and ACL guidance issued
April 8,2020, at https://acl.gov/sites/default/files/common/AoA%20-
%20Major%20Disaster%20Declaration%20Fiscal%20FAQ%20FINAL%204-8-2020_0.docx.
25 U.S. Government Accountability Office, COVID-19: Selected States Modified Meal Provision and Other Older
Americans Act Services to Prioritize Safety, GAO-22-104425, December 2021.
26 ACL, For the Aging and Disability Networks: COVID-19 Response, https://acl.gov/covid19/aging-and-disability-
networks (scroll to “Guidance for ACL Programs”: “Older Americans Act programs”).
27 U.S. Government Accountability Office, COVID-19: Selected States Modified Meal Provision and Other Older
Americans Act Services to Prioritize Safety, GAO-22-104425, December 2021.
28 Ibid.
29 Ibid.
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steps to obtain more consistent and reliable data from states. To gain consistency and assist with
funding oversight, ACL developed a template for states to use when reporting additional COVID-
19 funding in their FY2021 SPRs. In addition to the annual SPRs, ACL uses other existing
oversight processes to track COVID-19 funds, such as financial reports and single audits,
according to ACL officials.30
Other Activities
On March 29, 2023, HHS announced a partnership between the Centers for Disease Control and
Prevention (CDC) and ACL to provide $50 million in grants to the Aging Network to assist with
increasing vaccinations among older adults and their caregivers.31 Similar to the additional
COVID-19 funding, ACL awarded funds to SUAs based on the statutory formulas authorized
under the OAA, and the SUAs distributed this funding to AAAs based on each state’s or
territory’s intrastate funding formula.
Aging Network Activities
During the COVID-19 pandemic, SUAs and AAAs adapted to public health and safety concerns
by modifying nutrition services programs and temporarily suspending other OAA services.32 For
example, due to the health risks for older participants, in-person programming was paused at
congregate nutrition sites (i.e., meals served in a group setting), senior centers, adult day health
centers, and other in-person services. SUAs and AAAs expanded options for home-delivered
nutrition services, as well as telephone and virtual programming, among other activities. COVID-
19 relief legislation provided additional funding and OAA statutory flexibilities that allowed the
Aging Network to quickly expand delivery of home-delivered nutrition services and address food
shortages through use of frozen meals, shelf-stable meals, and grocery delivery. According to a
survey of AAAs conducted by USAging in May of 2020, the vast majority of respondents (90%)
transitioned congregate nutrition clients to home-delivered nutrition programs (see Figure 1).33

30 Ibid.
31 ACL, COVID-19 Response: Purpose of Funding, April 9, 2021, https://acl.gov/sites/default/files/about-acl/2021-04/
CDC%20AoA%20Expanding%20Access%20to%20Vaccines%20FAQ-4-8-21.pdf.
32 U.S. Government Accountability Office, COVID-19: Selected States Modified Meal Provision and Other Older
Americans Act Services to Prioritize Safety, GAO-22-104425, December 2021.
33 For specific examples of how local AAAs and tribal organizations adapted existing programs and services, or
established new programs and services, to continue to provide services to older individuals during the COVID-19
pandemic, see USAging, Examples from the Field, at https://www.usaging.org/covid19fieldexamples.
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Figure 1. Actions that Area Agencies on Aging (AAAs) Have Taken in Response to
COVID-19

Source: USAging (formerly N4A, the National Association of Area Agencies on Aging), #AAAsAtWork for Older
Adult: A Snapshot of Area Agency on Aging Responses to COVID-19, July 2020, https://www.usaging.org/Files/
n4a_MemberSurveyReport2020_Web_07July2020.pdf.
According to the same survey, more than two-thirds of AAAs (67%) also reported serving
congregate nutrition clients through a grab-and-go model of food distribution (see Figure 1).
Some sites continued to offer congregate meals by pairing grab-and-go meal delivery with virtual
socialization or in-person socialization in nontraditional congregate settings such as parks and
other outdoor venues. Some service providers expanded their networks by partnering with
restaurants to distribute meals to older adults; others established new partnerships with nonprofit
organizations that provide emergency food assistance or partner with public housing authorities
for service delivery. According to GAO, states reportedly spent more on providing nutrition
services because meal costs increased.34 However, some states and local AAAs were able to use
additional funding to enroll new clients.
With the cancellation of in-person activities and the need for personal protective equipment
(PPE), more than six in 10 AAAs (64%) reported expanding service delivery to include essential
supplies (e.g., medications and hygiene kits) and safety kits with PPE such as masks and
sanitizers. More than three-fourths of AAAs (76%) also reported establishing telephone
reassurance and wellness check-ins and moved to virtual programming to combat social-isolation.
Moreover, the Aging Network was a resource for vaccine education and information to older

34 U.S. Government Accountability Office, COVID-19: Selected States Modified Meal Provision and Other Older
Americans Act Services to Prioritize Safety, GAO-22-104425, December 2021.
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adults, helping them secure vaccine appointments, providing support services and transportation
to vaccine appointments, and hosting clinics at senior centers and other age-friendly locations.35
Concluding Observations
The expiration of the public health emergency for COVID-19, effective May 11, 2023, also ended
the specific legislative flexibilities under the OAA for senior nutrition programs. As described
above, these flexibilities allowed SUAs and AAAs to transfer up to 100% between OAA nutrition
programs, to expand the populations eligible for home-delivered nutrition, and to provide
authority for the Assistant Secretary to waive certain dietary requirements for nutrition services.
Furthermore, with the publication of notice by FEMA in the Federal Register announcing the
closure of the incident periods for major disaster declarations under the Stafford Act for COVID-
19,36 SUAs began unwinding disaster relief flexibilities used under the act. According to ACL,
SUAs are strongly encouraged to unwind all OAA flexibilities for disaster relief by September
30, 2023.37
In March 2020, at the beginning of the COVID-19 pandemic, Congress passed and the President
signed legislation to reauthorize the OAA for a five-year period through FY2024.38 Congress may
continue to assess the Aging Network’s response to the COVID-19 pandemic and unwinding
activities to determine what, if any, OAA program modifications or innovations might be
considered with future OAA reauthorizations. According to GAO, “ACL officials do not believe
that states will continue to need the flexibilities after the pandemic eases due to the inherent
flexibilities within the OAA, but state, local, and national aging association officials had mixed
views on whether the flexibilities would remain helpful in the future.”39
For example, under current law, states determine eligibility for home-delivered nutrition services
and may waive established requirements—a flexibility that states had prior to the COVID-19
pandemic.40 In addition, Congress may consider whether current transfer authority for certain
program funding is sufficient, whether there are existing barriers to current transfer authority, and
whether additional entities should have such authority. Under current law, only SUAs (and not
AAAs, as expanded under certain COVID-19 relief measures) have statutory authority to transfer
funds between certain programs. Congress may also assess increased demand for OAA nutrition
services, particularly home-delivered nutrition services, and whether additional funding may have
allowed some programs to serve clients who were waitlisted for services prior to the pandemic.
Congress may also consider the circumstances under which dietary requirements could or should
be waived, and whether increases in the costs of food may affect service providers’ ability to meet

35 USAging (formerly N4A, the National Association of Area Agencies on Aging), Roles of Area Agencies on Aging in
the Vaccination of Older Adults, February 9, 2021, https://www.usaging.org/Files/
AAA%20Roles%20in%20the%20Vaccination%20of%20Older%20Adults%202.9.21%20Final%20to%20Share.pdf.
36 Department of Homeland Security, Federal Emergency Management Agency, “Major Disaster Declarations and
Related Determinations: Expiration of COVID–19-Related Measures,” 88 Federal Register 8884-8886, February 10,
2023.
37 ACL, COVID-19 Relief: Unwinding Guidance to State Units on Aging, Older Americans Act Formula Grants – PHE
for COVID-19 & MDD for COVID-19, March 14, 2023, https://acl.gov/sites/default/files/2023-03/AoA%20-
%20Unwinding%20PHE%20and%20MDD%20for%20COVID-19.pdf.
38 CRS Report R46439, Older Americans Act: 2020 Reauthorization.
39 U.S. Government Accountability Office, COVID-19: Selected States Modified Meal Provision and Other Older
Americans Act Services to Prioritize Safety, GAO-22-104425, December 2021.
40 Administration for Community Living, Older American’s Act COVID-19 Guidance: Comprehensive Guidance
Reference, July 8, 2020, https://acl.gov/sites/default/files/common/Posted%20-%20COVID-
19%20AoA_Guidance%20Collections%20from%20ACL%20website_Final_07082020.pdf#page=21.
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future demand. Such efforts could better inform policymaker’s decisions about program funding
levels and funding adequacy.
During the course of the pandemic, many Aging Network service providers at the state and local
levels expanded partnerships with public health and emergency management entities, as well as
emergency food assistance programs and public housing authorities, among others. Such
partnerships may continue post-pandemic. These partnerships could provide new types of
assistance and service delivery models capable of expanding the reach of services to diverse
senior populations. Several stakeholders have pointed to the need for technology services for
seniors, both for greater access to the internet and for devices such as tablets and other hardware,
as well as one-on-one technology assistance. In addition, issues such as volunteer recruitment and
engagement, combatting social isolation and addressing mental health among seniors, and
provider support to family or informal caregivers will likely remain key issues affecting the
Aging Network and the broader health and well-being of older adults post-pandemic.
Additional discretionary and mandatory appropriations provided through various COVID-19
relief measures provided $1.120 billion and $1.609 billion for OAA programs and activities in
FY2020 and FY2021, respectively. These amounts were in addition to the annual OAA funding
levels of $2.145 billion for FY2020 and $2.179 billion for FY2021, and represent a significant
increase above annual funding levels. Moreover, by 2040, the population aged 65 and older is
projected to increase to 80.8 million (22% of the U.S. population), an increase from 55.6 million
(17% of the U.S. population) in 2020. To the extent that the Aging Network was able to use both
supplemental and annual funding to enroll new clients, expand existing services, and offer new
services, Congress may consider future funding adequacy. For example, federal policymakers
could consider the extent to which funding levels for OAA programs and activities are adequate
or needed to sustain the expansion and innovation necessitated by COVID-19 in a post pandemic
era, as well as the funding implications of keeping up with the potential growth in demand for
OAA services due to the increasing number and proportion of older adults in the near future.
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Appendix. COVID-19 Response Funding for Older
Americans Act Programs
Table A-1 shows discretionary and mandatory funding for OAA programs under the following
laws that were enacted in response to the COVID-19 pandemic:
• Families First Coronavirus Response Act—On March 18, 2020, the President
signed the Families First Coronavirus Response Act (FFCRA; P.L. 116-127),
which provided a total of $250 million in discretionary supplemental funding for
expanded food assistance for OAA nutrition services to states and tribal
organizations, to be made available until September 30, 2021.
• Coronavirus Aid, Relief, and Economic Security Act—On March 27, 2020,
the President signed the Coronavirus Aid, Relief, and Economic Security Act
(CARES; P.L. 116-136), which provided a total of $870 million in discretionary
supplemental funding for OAA nutrition services, supportive services, family
caregiver services, Aging and Disability Resource Centers (ADRCs), and elder
rights protection activities, to be made available until September 30, 2021.
• Consolidated Appropriations Act, 2021—On December 27, 2020, the President
signed the Consolidated Appropriations Act, 2021 (P.L. 116-260). Division N
provides a total of $175 million in additional mandatory funding for OAA
nutrition services to states and tribal organizations. (No funding deadline or
expiration date is specified in the law.)
• American Rescue Plan Act of 2021—On March 12, 2021, the President signed
American Rescue Plan Act of 2021 (ARPA; P.L. 117-2). Title II, Subtitle L,
provides a total of $1.434 billion in mandatory funding for OAA nutrition
services; supportive services, including COVID-19 vaccination outreach (e.g.,
transportation to vaccination sites) and activities to prevent and mitigate social
isolation related to COVID-19; family caregiver services; disease prevention;
grants for tribal organizations; and the long-term care ombudsman program, to be
made available until expended.
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Table A-1. COVID-19 Additional Funding for Older Americans Act Programs,
FY2020-FY2021
($ in millions)

FY2020 Laws
FY2021 Laws

Total
P.L. 117-2, FY2021
Total
P.L. 116-
P.L. 116-
Total FY2020
P.L. 116-
American COVID
COVID
127,
136,
COVID
260,
Rescue Additional Additional
OAA Programs
FFCRA CARES Act Supplementals Division N Plan Act
Funding
Funding
Title II:
0
$50.000
$50.000
0
0
0
$50.000
Administration on
Aging
Aging and Disability
0
$50.000
$50.000
0
0
0
$50.000
Resource Centers
Title III: Grants
$240.000
$780.000
$1,020.000
$168.000 $1,399.000 $1,567.000 $2,587.000
for State and
Community
Programs on
Aging
Supportive services
0
$200.000
$200.000
0
$460.000
$460.000
$660.000
and centers
Family caregivers
0
$100.000
$100.000
0
$145.000
$145.000
$245.000
Disease
0
0
0
0
$44.000
$44.000
$44.000
prevention/health
promotion
Nutrition services
$240.000
$480.000
$720.000
$168.000
$750.000
$918.000 $1,638.000
Congregate meals
$80.000
0
$80.000
0 $300.000a
$300.000
$380.000
(nonadd)
Home-delivered meals
$160.000
$480.000b
$640.000
$168.000c $450.000a
$618.000 $1,258.000
(nonadd)
Title VI: Grants
$10.000
$20.000
$30.000
$7.000
$25.000
$32.000
$62.000
for Native
Americans
Supportive and
$10.000
$20.000
$30.000
$7.000
$16.670
$23.670
$53.670
nutrition services
Native American
0
0
0
0
$8.330
$8.330
$8.330
family caregivers
Title VII:
0
$20.000
$20.000
0
$10.000
$10.000
$30.000
Vulnerable Elder
Rights Protection
Activities
Long-term care
0
$20.000d
$20.000
0e
$10.000
$10.000
$30.000
ombudsman program
Total Older
$250.000
$870.000
$1,120.000
$175.000 $1,434.000 $1,609.000 $2,729.000
Americans Act
Programs
Source: Statutory language and email communication with ACL Budget Director, March 25, 2020; January 7,
2021; and March 15, 2021.
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a. The American Rescue Plan Act of 2021 (APRA; P.L. 117-2) provided $750.0 mil ion in mandatory additional
funding to OAA nutrition services under Title III-C. ACL allocated $300.0 mil ion to congregate nutrition
and $450.0 mil ion to home-delivered nutrition services programs. However, SUAs and AAAs may transfer
up to 100% of the funds received in FY2021 between the two programs without prior approval, per P.L.
116-260, Consolidated Appropriations Act, 2021, Division N, Section 732 (email communication with ACL
Budget Director, March 15, 2021).
b. The Coronavirus Aid, Relief, and Economic Security Act (CARES Act; P.L. 116-136) provided $480.0 mil ion
for OAA nutrition programs under Title III-C, which includes both home-delivered meals and congregate
meals programs. ACL allocated the entire amount to the home-delivered meals program, but states were
allowed to transfer as much as 100% of the funds they received to the congregate meals program. ACL, ACL
State by State Total for CARES Act Funding, April 1, 2020, https://acl.gov/sites/default/files/about-acl/2020-04/
ACL%20State%20by%20State%20Tribe%20and%20CIL%20CARES%20Supplemental%20Awards%20Tables%2
004.21.20.pdf.
c. The Consolidated Appropriations Act, 2021, P.L. 116-260, Division N, provided $168.0 mil ion to OAA
nutrition services under Title III-C. ACL allocated the entire amount to home-delivered nutrition services.
However, SUAs and AAAs may transfer up to 100% of the funds received in FY2021 between the two
programs without prior approval, per Division N, Section 732 (email communication with ACL Budget
Director, January 7, 2021).
d. The CARES Act (P.L. 116-136) provided $20.0 mil ion “for elder rights protection activities, including the
long-term ombudsman program.” ACL allocated the entire amount to the long-term care ombudsman
program. ACL, ACL State by State Total for CARES Act Funding, April 1, 2020, https://acl.gov/sites/default/files/
about-acl/2020-04/
ACL%20State%20by%20State%20Tribe%20and%20CIL%20CARES%20Supplemental%20Awards%20Tables%2
004.21.20.pdf.
e. In addition to OAA funding, the Consolidated Appropriations Act, 2021 (P.L. 116-260), Division N,
appropriated $100.0 mil ion for activities authorized by the Elder Justice Act to prevent, prepare for, and
respond to coronavirus. ACL announced that $4.0 mil ion of that amount would be available for “Grants to
Enhance Capacity of Long-Term Care Ombudsman Programs to Respond to Complaints of Abuse and
Neglect of Residents in Long-Term Care Facilities During the COVID-19 Public Health Emergency,” 86
Federal Register 7728, February 1, 2021, https://www.federalregister.gov/documents/2021/02/01/2021-02092/
availability-of-program-application-instructions-for-long-term-care-ombudsman-program-funds.

Author Information

Kirsten J. Colello
Angela Napili
Specialist in Health and Aging Policy
Senior Research Librarian

Acknowledgments
Isobel Sorenson, CRS Research Assistant, provided research assistance for this report.
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Congressional Research Service
R47602 · VERSION 1 · NEW
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