OLDER AMERICANS 

ACT

Options to Better 

Target Need and 

Improve Equity

Report to the Ranking Member, Special 

Committee on Aging, U.S. Senate

November 2012

GAO-13-74

United States Government Accountability Office

GAO
Page i GAO-13-74 Older Americans Act

Letter 1 

Agency Comments and Our Evaluation 5

Appendix I Briefing Slides 7

Appendix II Objectives, Scope, and Methodology 28

Appendix III Application of the Partial Beneficiary Equity Option to Fiscal Year 

2012 Titles III and VII Allotments 39

Appendix IV Transition Measures for Moderating Impact of Formula Modifications 44

Appendix V Comments from the Department of Health and Human Services 54

Appendix VI GAO Contact and Staff Acknowledgments 56

Tables

Table 1: Disability Questions from the American Community 

Survey, 2008-2010 30

Table 2: Comparison of States’ Share of Population Age 60 and 

Over with at Least One ADL Limitation 31

Table 3: Percentage of Older Adults Age 60 and Older with Various 

Indicators of Need with One or More Activities of Daily 

Living Limitations 33

Table 4: Comparison of Fiscal Year 2012 Title III Allotments to 

Simulated Partial Beneficiary Equity Allotments 39

Table 5: Comparison of 2012 Title VII Allotments to Simulated 

Partial Beneficiary Equity Allotments 41

Table 6: Transition Combining the FY 2012 Current Formula 

Allotments and Partial Beneficiary Equity Formula Option, 

Comparison of Allotments 46

Contents
Page ii GAO-13-74 Older Americans Act

Table 7: Transition Using a Hold Harmless, Comparison of FY 2012 

Allotments to Allotments for the Partial Beneficiary Equity 

Formula Option 50

Abbreviations

AAA Area Agency on Aging 

ADL activities of daily living 

ACS American Community Survey 

AOA Administration on Aging 

BLS Bureau of Labor Statistics 

FMR Fair Market Rents 

HHS Department of Health and Human Services 

OAA Older Americans Act of 1965 

Treasury Department of the Treasury 

TTR Total Taxable Resources 

This is a work of the U.S. government and is not subject to copyright protection in the 

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Page 1 GAO-13-74 Older Americans Act

United States Government Accountability Office

Washington, DC 20548

November 30, 2012 

The Honorable Bob Corker 

Ranking Member 

Special Committee on Aging

United States Senate 

The Older Americans Act of 1965 (OAA)1 was enacted to help older 

individuals remain in their homes and communities as long as possible.

Based on formulas specified in law,2 the Department of Health and

Human Services’ (HHS) Administration on Aging (AOA) awards grants to

fund services for older individuals. State and local agencies are 

responsible for planning, developing, and coordinating services within 

each state, as well as distributing OAA grant funds to local Area Agencies 

on Aging (AAA) through intrastate funding formulas developed by each 

state in accordance with OAA requirements. Services funded by titles III

and VII OAA grants, as well as by other sources, provide a broad range of

vital assistance to older adults and include congregate and homedelivered meals, home-based care, transportation services, and elder

abuse, neglect, and exploitation prevention programs. In fiscal year 2012 

approximately $1.4 billion and $22 million, respectively, was provided for

services and programs under title III and title VII of the OAA. In fiscal year 

2010—the most recent year for which data are available—these funds 

were used to serve nearly 11 million older Americans and their 

caregivers. While all adults age 60 and over are eligible for services, the 

OAA title III requires programs to target or prioritize service to older

individuals with the greatest economic and social need.3

 

1 Pub. L. No. 89-73, 79 Stat. 218 (codified as amended at 42 U.S.C. §§ 3001 and 3058ff). 

The OAA defines

such need as (1) living below the poverty threshold; (2) having physical or

mental disabilities that pose risk for institutional placement; or (3) cultural,

2 42 U.S.C. §§ 3024, 3030s-1(f), and 3058b. Under the current OAA authorization, for 

titles III and VII, the formula considers each state’s proportion of elderly U.S. residents—

60 years of age and over or 70 years of age and over depending on the program—but the 

statute also provides that each state will receive at least as much funding as it received in 

a specified prior fiscal year and that no state receive less than one-half percent of the 

funds appropriated. 

3 42 U.S.C. § 3025(a)(2)(E).

 
 

Page 2 GAO-13-74 Older Americans Act

social, or geographic isolation, including isolation caused by language,

race, or ethnic status.4

Given current fiscal pressures, it is increasingly important to ensure that 

program funds align with greatest economic and social need, especially 

considering that demographic studies show that older Americans will 

make up an increasing proportion of the country’s population in the next 

few decades. Specifically, U.S. census projections estimate the number

of Americans age 65 and over will increase from 40 million in 2010 to 72

million in 2030.

 

5 Accordingly, the number of those eligible and in need of

services like those provided under OAA title III and VII programs will

increase as well. In 2011, we issued a report examining unmet need for 

OAA title III services showing that many older adults who may be in need 

of meals or home-based care may not receive assistance from title III 

programs or from other sources.6 Despite the growing need for these 

services as the population ages, it is anticipated that the funding level for 

these programs at the federal level will remain relatively flat in fiscal year 

2013—as it has for at least the last 9 years.7

In light of concerns about the growing demand for these vital OAA

services combined with current federal fiscal constraints, you asked us to

assess the current formula used to allot OAA funds to the states and

explore options to better ensure that the needs of the growing older adult

population are met. Specifically, our study examined (1) how intrastate

funding formulas take into account older adults with greatest economic 

and social need as defined by OAA, (2) options for modifying OAA title III

and VII statutory funding formulas to better target older adults with the 

greatest economic and social need under generally accepted equity 

standards, and (3) what effect, if any, might these formula modifications

 

 

4 42 U.S.C. § 3002(23) and (24).

5

 U.S. Census Bureau, Population Division, “Table 2. Projections of the Population by

Selected Age Groups and Sex for the United States: 2010 to 2050 (NP2008-T2),” 

released August 14, 2008. Note our analysis is of people age 60 and over. 

6 GAO, Older Americans Act: More Should Be Done to Measure the Extent of Unmet 

Need for Services, GAO-11-237 (Washington, D.C.: February 28, 2011).

7 Title III funding has fluctuated between a little over $1.2 billion and a little over $1.4 

billion from fiscal years 2004 to 2012. For the same period, title VII funding has fluctuated 

between a little over $19 million and just under $22 million. 
 

Page 3 GAO-13-74 Older Americans Act

have on states’ program allotments and what transition measures could 

be used to ease the implementation of modifications.

We used several methodologies to develop our findings. To assess how 

intrastate funding formulas account for older individuals in greatest 

economic and social need, we reviewed the state plans for all 50 states 

and the District of Columbia—45 of which had intrastate funding 

formulas.8

We conducted this performance audit from March 2012 through 

November 2012 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

To develop formula modification options and estimate the 

effects on states’ program allotments, we analyzed data from a number of 

sources, including AOA’s data on state OAA titles III and VII allotments, 

American Community Survey (ACS) data on elderly populations, 

Department of the Treasury’s (Treasury) data on state taxable resources, 

Bureau of Labor Statistics (BLS) data on wages, and the Department of 

Housing and Urban Development data on rents. For all of the objectives, 

we reviewed literature on OAA services and elder abuse and we 

interviewed advocacy groups, state and local aging officials in Illinois and 

Wisconsin, experts on aging, and officials at AOA. Appendix II provides a 

detailed description of our methodology.

On July 23, 2012, we briefed your staff on the results of our analysis. This 

report formally conveys the information provided during that briefing (see 

app. I for the briefing slides). In summary, we found that that states used 

a variety of demographic factors to account for greatest economic and 

social need in their intrastate funding formulas. We also presented three 

options for revising the statutory funding formula to more equitably 

account for differences among states with respect to needs, cost, and 

capacity using generally accepted equity standards. The first option 

 

8 Eight states and the District of Columbia are single planning and service areas and are 

not required to use an intrastate funding formula to distribute title III funds; nevertheless, 

three of these states use an intrastate funding formula. We did not review intrastate 

funding formulas in the U.S. territories. 
 

Page 4 GAO-13-74 Older Americans Act

allots9 funds based on states’ elderly population with limitations in their 

activities of daily living (ADL); the second option adds an additional factor 

to account for costs of providing services, and the third option further 

accounts for state resource capacity.10

More specifically, we found that:

Lastly, we found that such 

modification to the formula would redistribute funds among states, and 

presented a number of transition measures that could moderate such 

effects.

• States use a variety of factors to distribute OAA intrastate funding to 

AAAs and local service providers. All states that use intrastate funding 

formulas11

• The current statutory funding formula could better meet generally 

accepted equity standards

—which help determine the distribution of funds within a 

given state—use one or more demographic measures of need to 

target funding for OAA titles III and VII services. Factors included age, 

income, rural residence, disability impairment status, and minority 

status to indicate need for OAA services.

12

 

9 In the briefing slides, we summarized the statutory funding formula and federal and state 

actions in using the funds for authorized purposes, generally using the terms “allotment” 

and “allocation.” In accordance with the statutory framework, we have now updated the 

terminology in this letter to use the term “allotment” when referring to the manner in which 

the federal agency provides funding to the states See 42 U.S.C. §§ 3024, 3030s-1(f) and 

3058b. We now use the term “distribution” when referring to the states’ actions in 

providing funds to local areas. See 42 U.S.C. § 3025(a)(2)(C). Thus, references to 

allotment or allocation in the briefing slides should be interpreted according to the federal 

action or the state actions as described here. 

in targeting greatest economic and social 

10 In the briefing slides, we sometimes referred to the availability of state resources, in 

which case we are referring to states’ fiscal capacity (see app. I). 

11 States that designated a single planning and service area covering all older individuals 

in the state on or before October 1, 1980, may continue to operate in that manner. 42 

U.S.C. § 3025(a)(1)(E) and (b)(5).

12 There are two standards concerning the concept of equity that have commonly been 

used to design and evaluate funding formulas. The first—known as beneficiary equity—

stipulates that funds should be distributed to states according to the needs of their 

respective populations and adjusted for the cost of providing services. Partial beneficiary 

equity is achieved when funds are distributed based on the size of a state’s population 

potentially needing services, without adjusting for differences across states in terms of the 

cost of providing services. The second standard—known as taxpayer equity—applies to 

programs, such as OAA title III, in which states also contribute funds. This standard, like 

the first, seeks to provide individuals in need with the same level of services, but it also 

considers a state’s ability to finance a given program from its own resources.
 

Page 5 GAO-13-74 Older Americans Act

need for services by addressing differences among states with 

respect to the (1) needs of the elderly population, (2) cost of services 

to address those needs, and (3) capacity of individual states to 

finance needed services. Funds are currently allotted to states 

according to the relative proportion of older individuals, and states 

with similar populations are treated the same, irrespective of need. 

We presented three options for revising the formula using generally 

accepted equity standards to illustrate a range of possibilities. The 

first, the partial beneficiary equity option, distributes funds based on 

the state’s population in need of services by measuring older adults 

with limitations in their ability to maintain an independent lifestyle; the 

second, the full beneficiary equity option, accounts for differences in 

the costs of key inputs for providing services, such as wages, food, 

and office space; and the third, the taxpayer equity option, further 

accounts for state resource capacity. 

• Modifying the formula under a partial beneficiary option using ADL 

limitations as a need measure could result in a number of states 

seeing changes in their allotments and we presented several 

transition measures for moderating the impact of such changes. 

Under the partial beneficiary equity option, states with 

disproportionately high elderly populations with ADL limitations—as 

well as low-income states—would receive larger increases in their 

allotments. At the same time, states currently receiving the small state 

minimum13 could see larger decreases in their allotments. However, if 

transition measures such as a phase-in or hold harmless provision,

14

minimum allotment, or funding floors and ceilings are implemented, 

the effect on states can be tempered.

We provided HHS with the opportunity to comment on a draft of this 

report (HHS’ written comments appear in appendix V). In its comments, 

HHS generally agreed with our findings. In particular, HHS acknowledged 

the importance of moderating the effects of any formula changes in the 

current fiscal environment of relatively flat funding levels. 

 

13 The statute provides that no state receive less than one-half of one percent of the title 

III and VII funds appropriated. 42 U.S.C. §§ 3024(a)(3)(A), 3030s-1(f)(2)(B)(i)and 

3058b(a)(2)(B)(i). 

14 The statute provides, for example, that notwithstanding the current formula no state is 

to receive less funds under title III (other than Part E) than it did in 2006. 42 U.S.C. § 

3024(a)(3)(D)(i). 

Agency Comments 

and Our Evaluation
 

Page 6 GAO-13-74 Older Americans Act

HHS also called attention to a few issues that reinforced our findings. 

While not specifically raising these issues on its own, HHS noted that 

questions could be raised regarding the impact of formula changes on 

very rural states. Such an adverse effect was a key reason why the report 

discusses the importance of formula changes with transitions measures, 

such as a minimum allotment for small states that could mitigate such 

effects. Further, HHS highlighted the wide variation in the frequency, 

collection, and weighting of cost data among states and communities, 

which highlights the importance of creating a cost index that relies on 

federal data sources that capture the geographic variation in the costs of 

key inputs for providing services. HHS also agreed that, should Congress 

implement a different funding formula under the reauthorization of the 

OAA, the agency would work with Congress to ensure that any such 

formula involved appropriate available data.

As agreed with your office, unless you publicly announce its contents 

earlier, we plan no further distribution of this report until 30 days from its 

issue date. At that time, we will send copies of this report to the Secretary 

of Health and Human Services, relevant congressional committees, and 

other interested parties. In addition, this report will be available at no 

charge on GAO’s website at www.gao.gov . 

If you or your staff have any questions about this report, please contact 

me at (202) 512-7215 or jeszeckc@gao.gov. Contact points for our 

Offices of Congressional Relations and Public Affairs may be found on 

the last page of this report. GAO staff members who made key 

contributions to this report are listed in appendix VI. 

Sincerely yours,

Charles Jeszeck, Director

Education, Workforce, and Income Security Issues
Appendix I: Briefing Slides

Page 7 GAO-13-74 Older Americans Act

Appendix I: Briefing Slides 

Older Americans Act:

Options to Better Target Need 

and Improve Equity 

Briefing for Congressional Requesters on 

Preliminary Findings

July 23, 2012

Page 1

Appendix I: Briefing Slides
Appendix I: Briefing Slides

Page 8 GAO-13-74 Older Americans Act

Introduction

• The Older Americans Act of 1965 (OAA) was enacted to provide 

services to older adults and help them remain in their homes and 

communities. OAA funds are allocated primarily based on states’ 

relative proportion of older adults and states develop formulas to target 

those funds within the state consistent with the act.

• Programs funded by Titles III and VII OAA grants provide a broad range 

of vital services to older adults, including:

• In FY 2012, approximately $1.36 billion was provided for Title III 

services, and $21.8 million was provided for Title VII services. 

Page 2

Title and Part Service

III B Support services, such as transportation

III C Congregate and home-delivered meals 

III E Caregiver support

VII Vulnerable elder rights protection activities
Appendix I: Briefing Slides

Page 9 GAO-13-74 Older Americans Act

Current OAA Formula Allocates Funds 

Primarily Based on Age

• The OAA funding formula generally allocates federal funds to states 

based on the proportion of elderly residents in each state. For example: 

• The Act also provides a minimum level of funding to each state. No 

state receives less than one-half percent of the total appropriation. The 

FY 2012 minimums for Titles III and VII were about $5.9 million and 

$108,000, respectively. 

• A “hold harmless” provision also guarantees that each state will receive 

at least as much funding as it received in a specified prior fiscal year.

Page 3

Background

Title and part Formula 

III B and C

Share of population age 60 and older

VII

III E Share of population age 70 and older
Appendix I: Briefing Slides

Page 10 GAO-13-74 Older Americans Act

OAA Requires States to Target Greatest 

Economic and Social Need

• While the federal formula is generally based on age, OAA 

requires state programs to target or prioritize service to older 

adults with the greatest economic and social need, including 

those

• living at or below the poverty threshold, 

• having physical or mental disabilities that pose risks for 

institutional placement, or

• impacted cultural, social, or geographic isolation, including 

isolation caused by language, race, or ethnic status.

• States are required to consider such factors when developing the 

intrastate formulas they use to allocate funds among their local 

agencies.*

Page 4

Background

*42 U.S.C. § 3025(a)(2)(ii)(C).
Appendix I: Briefing Slides

Page 11 GAO-13-74 Older Americans Act

General Distribution of OAA Funds

Page 5

U.S. Department of Health and Human Services, Administration on 

Community Living, Administration on Aging

Allocates funds to states based on proportion of elderly population, generally 

those over age 60 or 70.

Area aging agencies or local service 

providers 

Use funds to deliver services in the community. 

State Units on Aging

Distribute funds using intrastate funding formulas, 

which must be approved by AOA*, that target 

elderly with greatest economic and social need 

using factors reflecting individual state 

characteristics, such as age, minority status, and 

income level. 

Background

*42 U.S.C. § 3024(a)(2)(D).
Appendix I: Briefing Slides

Page 12 GAO-13-74 Older Americans Act

Activities of Daily Living Capture Many 

Need Factors 

• A 2011 GAO study* found that the very old, minorities, and poor 

experienced greater disabilities in terms of being able to perform 

activities necessary to maintain an independent lifestyle or 

activities of daily living (ADL). ADLs measure a person’s ability to 

perform “basic” daily activities such as eating, bathing, dressing, 

and toileting. 

• These are many of the same population groups that OAA 

identifies as having greatest social and economic need and 

instructs states to use similar factors in allocating federal funding 

among local agencies. 

• The U.S. Census Bureau’s American Community Survey (ACS) 

refined its questions related to ADLs in 2008.

Page 6 * GAO, Older Americans Act: More Should Be Done to Measure the Extent of Unmet Need for Services, GAO-11-237 (Washington, 

D.C.: February 28 , 2011).

Background
Appendix I: Briefing Slides

Page 13 GAO-13-74 Older Americans Act

Research Objectives

1. How do intrastate funding formulas take into account older adults 

with greatest economic and social need as defined by OAA?

2. What are options for modifying OAA Title III and VII statutory 

funding formulas to better target older adults with the greatest 

economic and social need under generally accepted equity 

standards?

3. What effect, if any, might these formula modifications have on 

states’ program allotments and what transition measures could 

be used to ease the implementation of modifications?

Page 7
Appendix I: Briefing Slides

Page 14 GAO-13-74 Older Americans Act

Methodology

• Reviewed intrastate funding formulas for all 50 states.*

• Reviewed literature on OAA services and elder abuse.

• Interviewed advocacy groups, state and local aging officials in 

Illinois and Wisconsin, experts on aging, and officials at the 

Department of Health and Human Services, Administration on 

Aging.

• Analyzed data from the American Community Survey (ACS), 

Treasury's Total Taxable Resources (TTR) databases, Bureau of 

Labor Statistics data from the Occupational Employment 

Statistics, and U.S. Department of Housing and Urban 

Development’s Fair Market Rents (FMR) data to develop formula 

options.

Page 8 * Some states are single service-area states and are not required to use an intrastate funding formula to distribute Title III funds. 42 U.S.C. 

§ 3025(b)(5). We did not review intrastate funding formulas in the U.S. territories.
Appendix I: Briefing Slides

Page 15 GAO-13-74 Older Americans Act

States Use a Variety of Factors to Allocate 

OAA Funding

• All states with intrastate funding formulas use one or more 

measures of need to target funding for OAA services. 

• States use a variety of factors to indicate need, including

• age,

• income,

• rural residence, 

• disability or impairment status, and 

• minority status.

Page 9

Objective One
Appendix I: Briefing Slides

Page 16 GAO-13-74 Older Americans Act

Equity Standards for Designing and 

Evaluating Funding Formulas*

• Improved targeting for greatest social and economic need could 

be accomplished by adhering to commonly used equity standards. 

• Beneficiary Equity – federal allotments are based on need and 

adjusted for differences in the cost of providing services:

• Partial Beneficiary Equity – distributes funds based on size 

of state’s population potentially needing services, and 

• Full Beneficiary Equity – also adjusts for differences in the 

cost of providing services in each state. 

• Taxpayer Equity – allotments are adjusted to account for each 

state’s ability to finance a given program from its own resources.

Page 10 * These standards are commonly used in social science research to evaluate and design funding formulas. See, for example, National Research 

Council, Statistical Issues in Allocating Funds by Formula, Panel on Formula Allocations, Committee on National Statistics (Washington, D.C.: 2003).

Objective Two
Appendix I: Briefing Slides

Page 17 GAO-13-74 Older Americans Act

Current Federal Formula Could Better 

Meet Equity Standards

• Current federal formula primarily allocates funds to states according to the relative 

proportion of older adults, with adjustments for minimum funding levels for each state 

and “hold harmless” provisions.

• The current federal formula does not address differences among states with respect to

• needs of their elderly population,

• cost of services to address need, and

• capacity of states to finance services.

• Under the current federal formula states with similar populations are treated alike 

irrespective of need. For example:

Page 11

Objective Two

Louisiana has approximately 83,000

more people age 60 and older with at 

least one ADL limitation than Colorado, 

but Louisiana receives less funding 

because their total population age 60 and 

older is less than in Colorado.

Colorado Louisiana

Population age 60 and 

older

793,144 785,877

Population 60 and 

older with at least one 

ADL limitation (share)

234,714 

(30 percent)

317,913

(40 percent)

Source: GAO analysis of 2008-2010 3-year average American Community Survey 

data. Note: For purposes of this analysis, our measure includes people who 

reported at least one ADL limitation or a severe vision or hearing impairment.
Appendix I: Briefing Slides

Page 18 GAO-13-74 Older Americans Act

ADLs Better Capture Need and Achieve 

Partial Beneficiary Equity

• Need for OAA services can be better estimated using data on 

ADL limitations.

• Our analysis found the incidence of ADL limitations is higher 

among some of the demographic groups captured in need factors 

used by states.

Source: GAO analysis of 2008-2010 3-year average American Community Survey data.

* For purposes of this table, lower income is defined as 100 percent of the federal poverty level or less and higher income is defined as more than 100 percent of 

the federal poverty level.

Page 12

Objective Two

Those age 60 and over reporting at least one ADL limitation

Lower

income*

Higher

income*

Limited 

English

speaking

English 

speaking Minority Nonminority

Minority 

and lowincome

Percent of 

population 49% 31% 42% 33% 37% 33% 51%
Appendix I: Briefing Slides

Page 19 GAO-13-74 Older Americans Act

Prevalence of Having at Least One ADL 

Limitation Increases with Age 

Page 13

Objective Two
Appendix I: Briefing Slides

Page 20 GAO-13-74 Older Americans Act

Concentration of Elderly with ADL 

Limitations Varies across States 

Page 14

Objective Two

Across all states, the 

share of the 

population age 60 

and older with at least 

one ADL limitation is 

34 percent. States 

with an index value 

greater than 1 are 

above the national 

average.
Appendix I: Briefing Slides

Page 21 GAO-13-74 Older Americans Act

Adjusting for Cost Differences Could 

Achieve Full Beneficiary Equity 

• In addition to need, allotments can be adjusted for differences 

in the cost of key inputs for providing services, including

• wages,

• food, and

• office space (rent).

Page 15

Objective Two
Appendix I: Briefing Slides

Page 22 GAO-13-74 Older Americans Act

Adjusting for State Taxable Resources 

Could Achieve Taxpayer Equity 

• Allotments can be adjusted to achieve taxpayer equity by 

basing allotments on a state’s need population—adjusted for 

the cost of providing services—and its ability to fund program 

services.

• A state with fewer taxable resources compared to other states 

would have a larger allotment percentage and, therefore, a 

larger final allotment (all else being equal).

• Adjustments are based on Treasury’s Total Taxable Resources 

data, which provide a comprehensive measure of the economic 

activities that underlie a state’s sources of revenues—personal 

and corporate income.

Page 16

Objective Two
Appendix I: Briefing Slides

Page 23 GAO-13-74 Older Americans Act

Potential Effects of Partial Equity Formula 

Modifications on States’ Allocations*

• Under a Partial Beneficiary Equity option using ADL limitations, a 

number of states could see changes in their allocations. 

Note: Last two columns only capture those states with increases or decreases of 20 percent or more. 

• States with disproportionately high elderly populations with ADL 

limitations, as well as low-income states, could see higher 

increases in their allocations (e.g., Alabama, Arkansas, and 

Kentucky).

• States currently receiving the small state minimum could see 

larger decreases in their allocations (e.g., Alaska, Delaware, and 

Wyoming).

Page 17

Objective Three

Decrease in 

funding

Increase in

funding 

Decrease over 

20 percent 

Increase over 

20 percent

Number of 

states

29 22 10 7

* Analysis of allocations for the 50 states and the District of Columbia for Title III funding only. Does not include analysis of Title VII 

funding.
Appendix I: Briefing Slides

Page 24 GAO-13-74 Older Americans Act

Options for Moderating Impact of Formula 

Changes

• Phase-in provision combining the old and new formulas, with a gradual 

increase in the portion of funding distributed through the new formula, until the 

phase-in period is complete. For example:

• Funding floors and ceilings limiting the amount of funding that a state could lose 

or gain under a new formula from year to year.

• Hold harmless provision limiting the increase or decrease in funding that states 

could receive under a new formula, until funding for the program increases.

• Maintaining a minimum allocation for small states. 

Page 18

Year Old formula New formula

1 50 percent 50 percent

2 40 percent 60 percent

3 30 percent 70 percent

4 20 percent 80 percent

5 10 percent 90 percent 

6 (complete) 0 percent 100 percent 

Objective Three
Appendix I: Briefing Slides

Page 25 GAO-13-74 Older Americans Act

Concluding Observations 

• Given the growing need for OAA services in a constrained fiscal 

environment, it is increasingly important to ensure that program funds 

are aligned with the greatest economic and social need consistent with 

some measure of a state’s resources.

• In deciding whether to revise the current federal formula, policymakers 

should consider how to strike a balance among all important equity 

factors:

• need, 

• cost of providing services, and 

• availability of state resources.

• While revising the formula poses challenges, there are options that 

could ease the transition and minimize disruption in OAA services. For 

example, features from different formulas could be combined.

Page 19
Appendix I: Briefing Slides

Page 26 GAO-13-74 Older Americans Act

Appendix I: OAA Funding Formula 

Options to Improve Allocation Equity*

*The options presented here are simplified to focus on the various factors used in each formula and do not represent the actual equations.

Page 20
Appendix I: Briefing Slides

Page 27 GAO-13-74 Older Americans Act

Page 21

GAO on the Web

Web site: http://www.gao.gov/

Contact

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(202) 512-4800, U.S. Government Accountability Office

441 G Street NW, Room 7149, Washington, D.C. 20548

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Appendix II: Objectives, Scope, and 

Methodology

Page 28 GAO-13-74 Older Americans Act

Our objectives were to examine (1) how intrastate funding formulas take

into account older adults with greatest economic and social need as 

defined by the Older Americans Act of 1965 (OAA), (2) options for 

modifying OAA title III and VII statutory funding formulas to better target

older adults with the greatest economic and social need under generally 

accepted equity standards, and (3) what effect, if any, might these

formula modifications have on states’ program allotments and what 

transition measures might ease the implementation of modifications. To 

address the first objective, we reviewed the state plans for all 50 states 

and the District of Columbia—45 of which had intrastate funding 

formulas.1 To address the second objective, we used two generally 

accepted formula design standards intended to achieve equity for 

beneficiaries and taxpayers.2

We conducted this performance audit from March 2012 through 

November 2012 in accordance with generally accepted government 

auditing standards. Those standards require that we plan and perform the 

To meet both equity standards, a formula 

should use reliable and appropriate measures of the need population in 

each state and the cost of providing services in each state. A taxpayer 

equity formula additionally requires a reliable measure of a state’s ability 

to finance a program from its own resources. In the following sections, we 

describe how we measured the need population, cost of providing 

services, and financing capacity in each state, and how we developed 

various formula options to incorporate these equity standards. For the 

third objective, we analyzed the Administration on Aging’s (AOA) data on 

state OAA titles III and VII allotments and the American Community 

Survey (ACS) data on elderly populations. Finally, to address all three 

objectives, we reviewed literature on OAA services and elder abuse; 

interviewed advocacy groups, state and local aging officials in Illinois and 

Wisconsin, experts on aging, and officials at AOA; and we reviewed 

relevant laws, regulations, and guidance. 

 

1 Some states are single service-area states and are not required to use an intrastate

funding formula to distribute title III funds. 42 U.S.C. § 3025(b)(5)(A). We did not review 

intrastate funding formulas in the U.S. territories.

2 Beneficiary equity stipulates that funds should be distributed to states according to the 

needs of their respective populations, so that each state, with its federal allotment, can 

provide the same level of services to each person in need. Taxpayer equity stipulates that 

funds are distributed so that states can provide individuals comparable services using 

both state and federal funds, while each state contributes about the same proportion of its 

resources to a given federal program.

Appendix II: Objectives, Scope, and 

Methodology 
Appendix II: Objectives, Scope, and 

Methodology

Page 29 GAO-13-74 Older Americans Act

audit to obtain sufficient, appropriate evidence to provide a reasonable 

basis for our findings and conclusions based on our audit objectives. We 

believe that the evidence obtained provides a reasonable basis for our 

findings and conclusions based on our audit objectives.

To assess how intrastate funding formulas take into account, as required 

by the OAA, older adults with greatest economic and social need as 

defined by the OAA, we reviewed the most recently available state plans 

for all 50 states. As a starting point for our analysis, we obtained an 

electronic listing of state agency on aging intrastate funding formulas 

updated by AOA staff in May 2012. This list categorized factors in each 

state’s funding formula to target and indicate need, as well as the weights 

applied to each factor. To assess the reliability of the data, we also 

obtained electronic copies of state plans from the National Association of 

States United for Aging and Disabilities website or officials or an AOA 

official. In a few cases, we also obtained electronic copies of the state 

plan directly from the state unit on aging website or an agency official. For 

the 45 states with intrastate funding formulas, we independently reviewed 

the intrastate formulas detailed in the state plan noting the factors used to 

indicate need and the assigned weights, and revised and updated the 

AOA listing provided to us. To ensure the data collected were accurate 

and complete, two analysts independently reviewed and analyzed the 

formulas.

Data that directly measure the number of people in a state who potentially 

need OAA services do not exist. Although AOA collects data on the 

number of clients who receive certain types of OAA services, these data 

are not appropriate for use in a funding formula for two reasons. First, 

caseloads may be influenced by state funding levels. For example, an 

agency’s caseload may be relatively small because of limited funds, not 

because of limited demand for services. Second, data that can be 

controlled by state agency officials should not be used in a funding 

formula because they could introduce some undesirable incentives into 

the program. For instance, if a state’s allotment were determined by the

size of its caseload, a state agency might be rewarded for taking 

inappropriate actions, such as enrolling individuals into an OAA program 

who do not require these services.

There are, however, several national surveys that provide estimates of 

the number of people that may need OAA services by state using several 

need indicators. Measures of need for OAA services may be based on 

Analyzing Intrastate 

Funding Formulas

Measuring State Need 

Populations 
Appendix II: Objectives, Scope, and 

Methodology

Page 30 GAO-13-74 Older Americans Act

low income or minority status, impairments, limited English proficiency, 

race, and living in rural area. Several surveys include some of these 

measures and are conducted by statistical agencies such as the U.S. 

Census Bureau, the National Institute on Aging, and the Social Security 

Administration. 

For this study we used the Census Bureau’s ACS to use as a measure of 

state populations potentially in need of OAA services for several reasons. 

First, the ACS provides data on states’ populations age 60 and over. 

Second, the ACS has a large sample size (with about 3 million housing 

units surveyed across all 50 states, the District of Columbia, and Puerto 

Rico), which would allow for accurate estimates of populations in each 

state.

3

Table 1: Disability Questions from the American Community Survey, 2008-2010

Third, the ACS surveys people in group quarters such as those 

living in nursing care facilities. This is significant because the title VII 

Long-term Care Ombudsman program focuses on advocating on behalf 

of older residents of long-term care facilities, including nursing homes, 

assisted living, and other residential settings. Fourth, the ACS asks 

questions that are designed to capture a wide range of potential 

economic and social need for populations 60 and older who are targeted 

for OAA services, including a person’s ability to perform basic activities of 

daily living (ADL), and these questions are asked consistently across all 

states (see table 1). 

Question

1. Is this person deaf or does he/she have serious difficulty hearing?

2. Is this person blind or does he/she have serious difficulty seeing even when wearing 

glasses?

3. Because of a physical, mental, or emotional condition, does this person have 

serious difficulty concentrating, remembering, or making decisions?

4. Does this person have serious difficulty walking or climbing stairs?

5. Does this person have difficulty dressing or bathing?

6. Because of a physical, mental, or emotional condition, does this person have 

difficulty doing errands alone such as visiting a doctor’s office or shopping?

Source: U.S. Census Bureau, American Community Survey (2008-2010). 

 

3

One limitation of the ACS for purposes of allotting OAA funds, however, is that the data 

are not available for the other U.S. territories. 
Appendix II: Objectives, Scope, and 

Methodology

Page 31 GAO-13-74 Older Americans Act

From the ACS data averaged for 2008 to 2010, the number of elderly 

people age 60 and over that had at least one ADL limitation is listed in 

table 2. Nationwide, about 34 percent of all adults over 60 are limited by 

at least one of the six items indicated in table 2. The state’s share of 

elderly population compared with the national 34 percent is used to 

calculate a state index. If the state’s index value is greater than 1 then the 

percentage share of their elderly population with at least one ADL 

limitation is higher compared to the national average. For example, West 

Virginia has a higher percent of elderly with at least one ADL limitation 

(42 percent) compared to the national average (34 percent) and an index 

greater than 1. Mississippi ranks the highest in percentage of elderly with 

at least one ADL limitation. Mississippi’s state index is 1.28. At the other 

end Colorado has the least percent of elderly with at least one ADL 

limitation. Colorado’s state’s index is 0.87.

Table 2: Comparison of States’ Share of Population Age 60 and Over with at Least One ADL Limitation 

State 

Number of elderly 

age 60 and over

Number with at 

least one ADL 

limitation

Percentage with

at least one ADL 

limitation

State to national 

average index

Totals 55,871,230 18,941,108 33.90% 1.00

Alabama 914,807 373,662 40.85% 1.20

Alaska 85,953 30,429 35.40% 1.04

Arizona 1,201,071 367,907 30.63% 0.90

Arkansas 577,965 240,338 41.58% 1.23

California 5,930,094 1,938,535 32.69% 0.96

Colorado 793,347 234,714 29.59% 0.87

Connecticut 701,564 212,704 30.32% 0.89

Delaware 178,423 57,323 32.13% 0.95

District of Columbia 96,949 31,186 32.17% 0.95

Florida 4,312,979 1,362,336 31.59% 0.93

Georgia 1,480,443 526,517 35.56% 1.05

Hawaii 273,399 81,791 29.92% 0.88

Idaho 269,969 94,680 35.07% 1.03

Illinois 2,229,960 725,069 32.51% 0.96

Indiana 1,168,207 407,755 34.90% 1.03

Iowa 613,051 200,908 32.77% 0.97

Kansas 518,052 183,550 35.43% 1.05

Kentucky 810,708 332,533 41.02% 1.21

Louisiana 785,851 317,913 40.45% 1.19
Appendix II: Objectives, Scope, and 

Methodology

Page 32 GAO-13-74 Older Americans Act

State 

Number of elderly 

age 60 and over

Number with at 

least one ADL 

limitation

Percentage with

at least one ADL 

limitation

State to national 

average index

Maine 294,439 104,568 35.51% 1.05

Maryland 999,733 301,054 30.11% 0.89

Massachusetts 1,252,829 389,813 31.11% 0.92

Michigan 1,888,120 643,100 34.06% 1.00

Minnesota 942,976 279,820 29.67% 0.88

Mississippi 532,428 231,384 43.46% 1.28

Missouri 1,153,175 424,288 36.79% 1.09

Montana 205,106 68,692 33.49% 0.99

Nebraska 337,579 113,036 33.48% 0.99

Nevada 463,287 139,035 30.01% 0.89

New Hampshire 254,488 75,798 29.78% 0.88

New Jersey 1,640,212 489,437 29.84% 0.88

New Mexico 383,604 140,072 36.51% 1.08

New York 3,627,253 1,173,610 32.36% 0.95

North Carolina 1,727,139 618,971 35.84% 1.06

North Dakota 131,650 45,966 34.92% 1.03

Ohio 2,249,710 769,349 34.20% 1.01

Oklahoma 697,580 285,232 40.89% 1.21

Oregon 751,860 254,812 33.89% 1.00

Pennsylvania 2,662,996 900,008 33.80% 1.00

Rhode Island 208,204 70,042 33.64% 0.99

South Carolina 884,234 317,300 35.88% 1.06

South Dakota 156,676 54,118 34.54% 1.02

Tennessee 1,198,644 460,380 38.41% 1.13

Texas 3,673,715 1,361,585 37.06% 1.09

Utah 345,934 109,120 31.54% 0.93

Vermont 129,647 42,075 32.45% 0.96

Virginia 1,386,861 436,196 31.45% 0.93

Washington 1,171,854 389,577 33.24% 0.98

West Virginia 415,102 174,949 42.15% 1.24

Wisconsin 1,063,026 324,361 30.51% 0.90

Wyoming 98,377 33,510 34.06% 1.00 

Source: GAO analysis of U.S. Census Bureau, American Community Survey 3-year average data (2008-2010).
Appendix II: Objectives, Scope, and 

Methodology

Page 33 GAO-13-74 Older Americans Act

Prior GAO work has shown that indicators of the ability of a person to 

perform basic activities of daily living (ADL) are highly correlative with 

other need indicators used by states, such as age, income, and minority 

status. For example, in another report, we found that food insecurity 

among the elderly was associated with being low-income and having ADL 

limitations.4

Table 3 presents the estimated proportion of adults age 60 and over 

within various demographic groups reporting one or more ADL limitation. 

It shows that many of the demographic groups associated with greatest 

economic and social need for title III and VII services (based on lowincome or minority status, impairments, and limited English proficiency) 

have a higher percent chance of having one or more ADL limitation 

compared to those not within the above-mentioned groups. 

 

Table 3: Percentage of Older Adults Age 60 and Older with Various Indicators of Need with One or More Activities of Daily 

Living Limitations

Indicator of need Category

Percent age 60 and 

older

Percent age 60 and older reporting 

one or more ADL limitations

Age 60 -64 29.1% 21%

65-69 21.5% 24%

70-74 16.4% 30%

75-99 13.1% 40%

80 -84 10.2% 52%

85 and above 9.6% 73%

Race Minority 21% 37%

Non-minority 84% 33%

Family Poverty Status At or below poverty threshold 9% 49%

English Proficiency Limited English Speaking 14% 42% 

Source: GAO analysis of U.S. Census Bureau, American Community Survey 3-year average data (2008-2010).

To assess the reliability of the ACS, we reviewed the technical 

documentation for these data files, including the coding and definition of 

variables of interest, the procedures for handling missing data, coding 

checks, and imputation procedures for missing data. Because the ACS 

 

4 GAO, Older Americans Act: More Should Be Done to Measure the Extent of Unmet 

Need for Services, GAO-11-237 (Washington, D.C.: February 28, 2011).

Activities of Daily Living and 

Different Need Measures 
Appendix II: Objectives, Scope, and 

Methodology

Page 34 GAO-13-74 Older Americans Act

had a very high response rate, a low allocation rate, and narrow 

confidence intervals, we found the ACS data to be sufficiently reliable for 

our study objectives.

Beneficiary equity-based allotment formulas distribute funds so that states 

are able to provide the same levels of services to each person in need. 

Such formulas can include an index that takes into account differences in 

the costs of key inputs used to provide services in addition to other 

formula factors. Developing a cost index including such key inputs could 

serve as a reasonable proxy to reflect general differences across states in 

the cost of providing OAA services. A cost of services index is used in the 

funding formulas for the Community Mental Health Services and the 

Substance Abuse Prevention and Treatment block grants. Development 

of a cost of services index for the OAA titles III and VII allotment formulas 

can draw on a methodology employed in prior GAO reports.5

There are a variety of measures for the costs of resources or inputs that 

go into providing OAA title III services, which are generally beyond the 

direct control of state agencies, and that are captured in various available 

data sets. These key inputs include wages, food, office space, and 

transportation. These data sets can be used to construct an OAA title III 

cost index as described above. For example, AOA compiles annual 

reports on state expenditures for 14 categories of OAA services ranging 

from home delivered meals to adult day care, which could be used to

identify the shares of program national average expenditures for broad 

categories of OAA services. Also, there are available data sets that 

capture the costs of such inputs. For example, a 1996 Mathematica 

Construction 

of such an index requires estimates of (1) the shares of program national 

average expenditures for broad categories of OAA title III funded 

services; (2) the mix of inputs required to provide those services; and (3) 

geographic variation in the cost of those inputs. This yields a broad based 

index that reflects cost of a typical or national average mix of services 

rather than actual services costs for each state. This approach in effect 

encourages efficiency by rewarding states that are more efficient in 

delivering OAA-funded services.

 

5 GAO, Older Americans Act: Funding Formula Could Better Reflect State Needs,

GAO/HEHS-94-41 (Washington, D.C.: May 12, 1994) and Vocational Rehabilitations 

Funding Formula: Options for Improving Equity in State Grants and Considerations for 

Performance Incentives, GAO-09-798 (Washington, D.C.: September 30, 2009).

Measuring State Cost 

Differences
Appendix II: Objectives, Scope, and 

Methodology

Page 35 GAO-13-74 Older Americans Act

Policy Research, Inc. report provides detailed estimates of input costs for 

providing nutritional services that in fiscal year 2010 represented about 60 

percent of title III services, including congregate and home delivered 

meals. There are also a number of other federal data sources that may 

capture geographic variations in the costs of key inputs such as labor, 

food, and rents—namely, data from the Bureau of Labor Statistics, the 

United States Department of Agriculture, and the Department of Housing 

and Urban Development. 

A taxpayer equity standard stipulates that funds are distributed so that 

states can provide individuals comparable services using both state and 

federal funds, while each state contributes about the same proportion of 

their resources to a given federal program. This equity standard requires 

a formula to include an indicator of each state’s ability to finance its share 

of the costs of a given program from its own sources. In a funding 

formula, a good indicator of a state’s financing ability would measure all 

types of taxable resources and would not be affected by an individual 

state’s actual fiscal decisions. The Department of the Treasury’s 

(Treasury) Total Taxable Resources (TTR) estimate is such a measure. A 

number of prior GAO reports have found that TTR is a comprehensive 

measure of a jurisdiction’s fiscal capacity, and two specifically found that 

it is not affected by jurisdictions’ fiscal choices.6

 

6 For example, GAO, School Finance: Options for Improving Measures of Effort and 

Equity in Title I, 

Incorporating TTR 

estimates into OAA title III and VII formulas could achieve taxpayer equity 

by capturing states’ ability to fund program services through a measure of 

the economic activities that underlie states’ revenue sources—personal 

and corporate income. Specifically, according to Treasury, the objective 

of TTR is to capture the unduplicated sum of per capita Income and gross 

state product (GSP) that is susceptible to taxation by a jurisdiction’s 

government. By this means, the entirety of income potentially exposed to 

GAO/HEHS-96-142 (Washington, D.C.: August 30, 1996); Ryan White 

Care Act of 1990: Opportunities to Enhance Funding Equity, GAO/HEHS-96-26 

(Washington, D.C.: November 13, 1995); Older Americans Act: Funding Formula Could 

Better Reflect State Needs, GAO/HEHS-94-41 (Washington, D.C: May 12,1994); and 

Medicaid Formula: Fairness Could Be Improved, GAO/T-HRD-91-5 (Washington, D.C.: 

December 7, 1990). See also, GAO, Federal Disaster Relief: Improved Criteria Needed to 

Assess a Jurisdiction’s Capability to Respond and Recover on Its Own, GAO-12-838 

(Washington, D.C.: September 12, 2012) and Vocational Rehabilitation Funding Formula: 

Options for Improving Equity in State Grants and Considerations for Performance 

Incentives, GAO-09-798 (Washington, D.C.: September 30, 2009), which found that TTR 

is not affected by jurisdictions’ fiscal choices. 

Measuring State Financing 

Capacity
Appendix II: Objectives, Scope, and 

Methodology 

Page 36 GAO-13-74 Older Americans Act 

taxation is measured. In practice, the calculation is relatively simple. A 

jurisdiction’s GSP is supplemented with income received by jurisdiction 

residents that originated in other jurisdictions. This would include the 

labor earnings of residents who commute to jobs in other jurisdictions, 

and the capital income (mainly interest, dividends, rent, and capital gains) 

of all jurisdiction residents due to asset holdings in other jurisdictions. It 

excludes indirect business taxes paid to the federal government (such as 

the payroll tax and federal excises). TTR is used in allotment formulas for 

HHS’s Services’ Substance Abuse and Mental Health Services 

Administration’s Community Mental Health Service and the Substance 

Abuse Prevention and Treatment block grant programs. 

For our second objective, we developed three prototype formula options 

based upon equity standards commonly used to design and evaluate 

funding formulas. We also estimated the grant allotments that each state 

would receive under the partial beneficiary equity option, using data from 

the ACS on states’ elder populations with one or more ADL limitations. 

See appendix III for a table of our estimates of the grant allotments. 

Specifically, for states’ need populations we used the ACS 2008-2010, 3-

year average state data to limit the effects of any year-to-year 

fluctuations. As described above, we used the six questions from the ACS 

related to the ability to live independently. 

The three prototype formula options we developed for revising the OAA 

title III and VII allotment formulas are (1) a partial beneficiary equity 

formula option that distributes funds based only on the size of a state’s 

population potentially in need of services, (2) a full beneficiary equity 

formula option with an adjustment for the cost of services, and (3) a 

taxpayer equity formula option with the addition of a measure of state 

fiscal capacity to account for the relative ability of a state to finance its 

share of service costs. 

State Allotment ൌ Appropriation x State Need Population

∑ State Need Population

where: state need population = number of elderly in a state reporting 

limitation in one or more activities of daily living, ADLs. 

This formula would allot funds based on each state’s share of the total 

population in need nationally. It would only partially achieve beneficiary 

Analysis of Formula 

Options 

Description of Formula Options 

Partial Beneficiary Equity 

Formula Option 
Appendix II: Objectives, Scope, and 

Methodology 

Page 37 GAO-13-74 Older Americans Act 

equity because it does not account for differences among states in the 

cost of providing services. 

State Allotment ൌ Appropriation x S୲ୟ୲ୣ C୭ୱ୲ Aୢ୨୳ୱ୲ୣୢ Nୣୣୢ P୭୮୳୪ୟ୲୧୭୬

∑ S୲ୟ୲ୣ C୭ୱ୲ Aୢ୨୳ୱ୲ୣୢ Nୣୣୢ P୭୮୳୪ୟ୲୧୭୬ 

where: Cost Adjusted Need Popululation ൌ Need Population x Cost Index 

The cost index in the formula estimates for each state the relative cost of 

providing OAA-funded services. This formula option thus achieves full 

beneficiary equity by accounting for both a state’s need population and its 

costs of providing OAA-funded services. 

Taxpayer Equity Option 

State Allotment

ൌ Appropriation x State Cost Adjusted Need Population x Allotment Percentage

∑ State Cost Adjusted Need Population x Allotment Percentage

 where: Allotment Percentage ൌ 1 െ 0.15 ቂTTR/C୭ୱ୲ Aୢ୨୳ୱ୲ୣୢ Nୣୣୢ P୭୮୳୪୳୪ୟ୲୧୭୬

∑ TTR/ ∑ S୲ୟ୲ୣ Nୣୣୢ P୭୮୳୪ୟ୲୧୭୬ ቃ 

This formula option would achieve taxpayer equity by basing allotments 

on a state’s need population, adjusted for its cost of providing services, 

and its ability to fund the state’s share OAA-funded services. In this 

option, the formula includes an “allotment percentage” to account for a 

relative state’s ability to finance OAA-funded services from its own fiscal 

resources. As we described earlier, a number or prior GAO reports have 

found TTR data to provide a comprehensive measure of a state’s fiscal 

resources.7

 TTR provides a comprehensive indicator of a state’s relative 

ability to finance services. A state with fewer fiscal resources compared to 

other states would have a larger allotment percentage and, therefore, a 

larger final allotment (all else being equal). The allotment percentage 

equation indicates each state’s required contribution in terms of a 

matching rate to finance the OAA-funded services. Nationally, this rate is 

 

7

 See GAO-12-838, GAO-09-798, GAO/HEHS-96-142, GAO/HEHS-96-26, 

GAO/HEHS-94-41, and GAO/T-HRD-91-5. 

Full Beneficiary Equity 

Formula Option 
Appendix II: Objectives, Scope, and 

Methodology

Page 38 GAO-13-74 Older Americans Act

assumed for illustrative purposes to be 15 percent, with each state’s rate 

to varying according to its share of national TTR.8

 

To gain perspectives on intrastate funding formulas and options for 

modifying the statutory funding formulas for titles III and VII, we first 

reviewed relevant literature and spoke with AOA officials. In addition, we 

interviewed experts on aging, key national organizations to understand 

the perspectives of program participants, aging network practitioners, and 

service providers. Key national organizations included representatives 

from organizations that represent aging network practitioners and service 

providers, such as Meals On Wheels Association of America, National 

Association of States United for Aging and Disability, and National 

Association of State Long-Term Care Ombudsman Programs. We also 

interviewed representatives from AARP, a key national organization that 

represents program participants. In addition, we interviewed other 

national experts in the aging network. We also conducted site visits in two 

states, Illinois and Wisconsin, for which we held on-site, semi-structured 

interviews with regional, state, and local aging officials. These interviews 

included open-ended questions addressing topics related to our research 

objectives, including characteristics of program participants, factors that 

best account for greatest economic and social need, the equity of the 

distribution of funds under the existing funding formulas, and access to

research or data on OAA funding formulas and services. States were 

selected for geographic efficiency for field office staff conducting the work 

and are not a representative sample of state units on aging. 

 

8 States are required to provide a matching share of 15 percent in order to receive funds 

for OAA title III supportive services and congregate and home-delivered nutrition 

programs. 42 U.S.C. § 3024(d)(1)(D). Similarly, a matching share of 25 percent is required 

for the title III National Family Caregiver Support Program. However, no match is required 

for title III disease prevention and health promotion services or for any title VII programs. 

42 U.S.C. § 3029(b)(1).

. 

Literature Review and 

Interviews and Site Visits
Appendix III: Application of the Partial 

Beneficiary Equity Option to Fiscal Year 2012 

Titles III and VII Allotments

Page 39 GAO-13-74 Older Americans Act

The following tables show the application of the partial beneficiary equity 

option—distributing funding based on elderly eligible population with at 

least one limitation in ADL—to the fiscal year 2012 titles III and VII 

allotments. Title III and title VII allotments could also be modified to allow 

for full beneficiary equity by additionally adjusting for differences in the

cost of providing services in each state, and for taxpayer equity by 

additionally adjusting for differences in each state’s ability to finance 

these programs from its own resources. 

Table 4 shows the partial beneficiary equity title III allotment for each 

state and the percentage change from their fiscal year 2012 allotment

under the partial beneficiary equity option, which is described in appendix 

II, and compares populations age 60 and over to population age 60 and 

older with at least one ADL limitation. In this table, we exclude the hold 

harmless provision and the minimum allotment provided under the current 

formula, one-half of one percent of the total federal funds appropriated to 

the OAA program, or about $5.9 million for fiscal year 2012. 

Table 4: Comparison of Fiscal Year 2012 Title III Allotments to Simulated Partial Beneficiary Equity Allotments

50 states and DC 

2012 title III 

allotment amount

Formula based on the elderly having an at least one ADL limitation

Simulated amount 

 Difference

Amount Percent

Alabama $18,218,136 $22,939,239 $4,721,103 25.91%

Alaska $5,928,086 $1,868,047 -$4,060,039 -68.49%

Arizona $24,054,835 $22,585,938 -$1,468,897 -6.11%

Arkansas $11,499,761 $14,754,433 $3,254,672 28.30%

California $118,678,094 $119,007,334 $329,241 0.28%

Colorado $15,803,697 $14,409,174 -$1,394,523 -8.82%

Connecticut $14,327,416 $13,057,972 -$1,269,444 -8.86%

Delaware $5,928,086 $3,519,079 -$2,409,007 -40.64%

District of Columbia $5,928,086 $1,914,519 -$4,013,567 -67.70%

Florida $86,721,589 $83,634,278 -$3,087,311 -3.56%

Georgia $29,451,447 $32,323,061 $2,871,614 9.75%

Hawaii $5,928,086 $5,021,178 -$906,908 -15.30%

Idaho $5,928,086 $5,812,438 -$115,648 -1.95%

Illinois $46,709,183 $44,512,237 -$2,196,947 -4.70%

Indiana $23,302,596 $25,032,221 $1,729,624 7.42%

Appendix III: Application of the Partial 

Beneficiary Equity Option to Fiscal Year 2012 

Titles III and VII Allotments
Appendix III: Application of the Partial 

Beneficiary Equity Option to Fiscal Year 2012 

Titles III and VII Allotments

Page 40 GAO-13-74 Older Americans Act

50 states and DC 

2012 title III 

allotment amount

Formula based on the elderly having an at least one ADL limitation

Simulated amount 

 Difference

Amount Percent

Iowa $13,526,086 $12,333,812 -$1,192,274 -8.81%

Kansas $11,004,841 $11,268,198 $263,358 2.39%

Kentucky $16,143,866 $20,414,316 $4,270,450 26.45%

Louisiana $15,655,237 $19,516,789 $3,861,552 24.67%

Maine $5,940,070 $6,419,466 $479,396 8.07%

Maryland $19,940,856 $18,481,809 -$1,459,047 -7.32%

Massachusetts $26,370,317 $23,930,755 -$2,439,563 -9.25%

Michigan $37,747,646 $39,480,132 $1,732,486 4.59%

Minnesota $18,875,651 $17,178,247 -$1,697,404 -8.99%

Mississippi $10,664,774 $14,204,744 $3,539,970 33.19%

Missouri $23,260,470 $26,047,187 $2,786,717 11.98%

Montana $5,928,086 $4,217,026 -$1,711,060 -28.86%

Nebraska $7,318,818 $6,939,319 -$379,499 -5.19%

Nevada $9,153,288 $8,535,407 -$617,881 -6.75%

New Hampshire $5,928,086 $4,653,265 -$1,274,821 -21.50%

New Jersey $33,432,655 $30,046,707 -$3,385,949 -10.13%

New Mexico $7,619,473 $8,599,069 $979,595 12.86%

New York $77,516,307 $72,048,324 -$5,467,983 -7.05%

North Carolina $34,413,733 $37,998,844 $3,585,110 10.42%

North Dakota $5,928,086 $2,821,869 -$3,106,217 -52.40%

Ohio $45,248,374 $47,230,601 $1,982,227 4.38%

Oklahoma $13,989,820 $17,510,491 $3,520,671 25.17%

Oregon $14,965,075 $15,642,997 $677,922 4.53%

Pennsylvania $57,248,700 $55,251,803 -$1,996,897 -3.49%

Rhode Island $5,928,086 $4,299,903 -$1,628,183 -27.47%

South Carolina $17,656,443 $19,479,157 $1,822,714 10.32%

South Dakota $5,928,086 $3,322,323 -$2,605,763 -43.96%

Tennessee $23,784,711 $28,262,888 $4,478,177 18.83%

Texas $73,246,322 $83,588,174 $10,341,852 14.12%

Utah $6,937,554 $6,698,915 -$238,639 -3.44%

Vermont $5,928,086 $2,582,999 -$3,345,087 -56.43%

Virginia $27,537,616 $26,778,223 -$759,393 -2.76%

Washington $23,443,456 $23,916,267 $472,811 2.02%

West Virginia $8,828,503 $10,740,180 $1,911,676 21.65%

Wisconsin $21,426,723 $19,912,634 -$1,514,089 -7.07%
Appendix III: Application of the Partial 

Beneficiary Equity Option to Fiscal Year 2012 

Titles III and VII Allotments

Page 41 GAO-13-74 Older Americans Act

50 states and DC 

2012 title III 

allotment amount

Formula based on the elderly having an at least one ADL limitation

Simulated amount 

 Difference

Amount Percent

Wyoming $5,928,086 $2,057,190 -$3,870,896 -65.30%

Total $1,162,801,174 $1,162,801,174 $0 0.00%

Source: GAO analysis of AOA data on OAA title III state allotments (2012) and U.S. Census Bureau, American Community Survey 3-

year average data (2008-2010).

Table 5 shows the partial beneficiary equity title VII allotments for each 

state and the percentage change from their fiscal year 2012 allotments

under the partial beneficiary equity option, which is described in appendix 

II, and compares populations age 60 and over to population age 60 and 

older with at least one ADL limitation. In this table, our simulation 

excludes the hold harmless provision and the minimum allotment that the 

current formula provides, of one-half of one percent of the total federal 

funds appropriated to the OAA program, or about $108,000 for fiscal year 

2012. 

Table 5: Comparison of 2012 Title VII Allotments to Simulated Partial Beneficiary Equity Allotments 

50 states and DC

2012 title VII 

allotment amount

Formula based on the elderly having at least one ADL limitation

Simulated amount

Difference

Amount Percent

Alabama $336,116 $417,659 $81,543 24.26%

Alaska $107,898 $34,012 -$73,886 -68.48%

Arizona $446,777 $411,226 -$35,551 -7.96%

Arkansas $211,423 $268,637 $57,214 27.06%

California $2,187,718 $2,166,787 -$20,931 -0.96%

Colorado $294,722 $262,350 -$32,372 -10.98%

Connecticut $257,340 $237,749 -$19,591 -7.61%

Delaware $107,898 $64,072 -$43,826 -40.62%

District of Columbia $107,898 $34,858 -$73,040 -67.69%

Florida $1,581,700 $1,522,744 -$58,956 -3.73%

Georgia $549,939 $588,512 $38,573 7.01%

Hawaii $107,898 $91,421 -$16,477 -15.27%

Idaho $107,898 $105,828 -$2,070 -1.92%

Illinois $830,033 $810,442 -$19,591 -2.36%

Indiana $429,683 $455,766 $26,083 6.07%

Iowa $228,715 $224,564 -$4,151 -1.81%
Appendix III: Application of the Partial 

Beneficiary Equity Option to Fiscal Year 2012 

Titles III and VII Allotments

Page 42 GAO-13-74 Older Americans Act

50 states and DC

2012 title VII 

allotment amount

Formula based on the elderly having at least one ADL limitation

Simulated amount

Difference

Amount Percent

Kansas $191,820 $205,162 $13,342 6.96%

Kentucky $298,426 $371,687 $73,261 24.55%

Louisiana $291,260 $355,346 $64,086 22.00%

Maine $108,575 $116,880 $8,305 7.65%

Maryland $369,048 $336,502 -$32,546 -8.82%

Massachusetts $463,743 $435,711 -$28,032 -6.04%

Michigan $697,750 $718,822 $21,072 3.02%

Minnesota $346,545 $312,767 -$33,778 -9.75%

Mississippi $195,712 $258,628 $62,916 32.15%

Missouri $423,498 $474,246 $50,748 11.98%

Montana $107,898 $76,780 -$31,118 -28.84%

Nebraska $124,937 $126,345 $1,408 1.13%

Nevada $171,053 $155,406 -$15,647 -9.15%

New Hampshire $107,898 $84,723 -$23,175 -21.48%

New Jersey $607,466 $547,066 -$60,400 -9.94%

New Mexico $138,638 $156,565 $17,927 12.93%

New York $1,342,758 $1,311,796 -$30,962 -2.31%

North Carolina $637,783 $691,852 $54,069 8.48%

North Dakota $107,898 $51,378 -$56,520 -52.38%

Ohio $833,389 $859,936 $26,547 3.19%

Oklahoma $258,023 $318,817 $60,794 23.56%

Oregon $277,005 $284,815 $7,810 2.82%

Pennsylvania $994,623 $1,005,979 $11,356 1.14%

Rhode Island $107,898 $78,289 -$29,609 -27.44%

South Carolina $328,382 $354,660 $26,278 8.00%

South Dakota $107,898 $60,490 -$47,408 -43.94%

Tennessee $440,583 $514,587 $74,004 16.80%

Texas $1,359,212 $1,521,904 $162,692 11.97%

Utah $127,819 $121,968 -$5,851 -4.58%

Vermont $107,898 $47,029 -$60,869 -56.41%

Virginia $510,806 $487,556 -$23,250 -4.55%

Washington $435,392 $435,448 $56 0.01%

West Virginia $154,347 $195,548 $41,201 26.69%

Wisconsin $393,789 $362,553 -$31,236 -7.93%

Wyoming $107,898 $37,456 -$70,442 -65.29%
Appendix III: Application of the Partial 

Beneficiary Equity Option to Fiscal Year 2012 

Titles III and VII Allotments

Page 43 GAO-13-74 Older Americans Act

50 states and DC

2012 title VII 

allotment amount

Formula based on the elderly having at least one ADL limitation

Simulated amount

Difference

Amount Percent

Total $21,171,324 $21,171,324 $0 0.00%

Source: GAO analysis of AOA data on OAA title VII state allotments (2012) and U.S. Census Bureau, American Community Survey 3-

year average data (2008-2010).
Appendix IV: Transition Measures for 

Moderating Impact of Formula Modifications

Page 44 GAO-13-74 Older Americans Act

To moderate the decrease in allotments presented in appendix III, we 

present two transition measures. As illustrated in appendix III, 

implementing a partial beneficiary equity formula option using a measure 

of the elderly with at least one ADL limitation will result in allotment 

changes as large as 20 percent. The changes are due in part to a change 

in how the formula measures the need population, as well the exclusion 

of two significant provisions under current law. Specifically, our analysis in 

appendix III did not include the hold harmless provision and the one-half 

of one percent minimum allotment. The following two transition measures 

moderate significant allotment changes by gradually introducing the new 

formula over a number of years or limiting the yearly allotment changes 

using a hold harmless provision, as well by including the one-half of one 

percent minimum allotment. To illustrate the moderating effect of these 

transition options, we have simulated two transitions for the partial equity 

formula. In the first transition, the new formula is phased-in over 6 years 

and lessens the year-to-year changes. In the second transition, the 

changes in allotments are limited annually, and the number of years to 

complete transition may vary. In the two transitions presented, the 

allotments under the partial beneficiary equity formula include the onehalf of one percent minimum allotment, approximately $5.9 million for 

fiscal year 2012. The comparisons are made for fiscal 2012 title III 

allotments using the same funding amount.

Phase-In Transition 

In the first example, a 6 year transition is demonstrated, which 

incrementally phases in the new formula. In the first year, the allotments 

are based on a 50-50 split between the current formula and the partial 

beneficiary equity formula option. In a 50-50 split, half of the allotment is 

based on the current formula and half from the partial beneficiary equity 

formula option. In the second year, the split is 40-60 between the current 

formula and the partial beneficiary equity formula option. The split in the 

succeeding years are 30-70, 20-80, 10-90, and 0-100. By the sixth year 

the entire allotment is based on the partial beneficiary equity formula 

option. Table 6 shows the first, second, and fifth year allotments under a 

6-year phase-in. This transition could be made faster or more gradually 

by changing the splits between the current and alternative formulas and 

number of years. Other split combinations could be used for the initial and 

subsequent years, such as 80-20, 60-40, 40-60, 20-80, and 0-100.

Table 6 shows the allotments under the partial beneficiary equity formula 

option using this transition method and compares the changes to the 

current allotments. For example, the allotment to Alabama rises by 12 

Appendix IV: Transition Measures for 

Moderating Impact of Formula Modifications
Appendix IV: Transition Measures for 

Moderating Impact of Formula Modifications

Page 45 GAO-13-74 Older Americans Act

percent in the first year of transition (using the 50-50 split). In comparison, 

if no transition was provided its allotment would have risen by 27 percent. 

By the fifth year, the allotment to Alabama rises to over 20 percent. In 

contrast, the allotment to New Jersey in the first year falls by 6 percent, 

and without the transition its allotment falls by 10 percent. By the fifth 

year, the allotment falls by over 11 percent.
Appendix IV: Transition Measures for Moderating Impact of Formula Modifications

Page 46 GAO-13-74 Older Americans Act

Table 6: Transition Combining the FY 2012 Current Formula Allotments and Partial Beneficiary Equity Formula Option, Comparison of Allotments

States and the 

District of Columbia

Actual 2012

title III

Year 1: 50:50 Allotments Year 2: 40:60 Allotments Year 5: 10:90 Allotments

Partial 

equity

Difference Partial 

equity

Difference Partial 

equity

Difference

Amount Percent Amount Percent Amount Percent

Alabama $18,218 $20,458 $2,240 12.29% $20,835 $2,617 14.37% $21,967 $3,749 20.58%

Alaska $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Arizona $24,055 $23,189 -$866 -3.60% $22,951 -$1,104 -4.59% $22,238 -$1,817 -7.55%

Arkansas $11,500 $13,053 $1,553 13.50% $13,317 $1,817 15.80% $14,108 $2,608 22.68%

California $118,678 $118,144 -$534 -0.45% $117,700 -$979 -0.82% $116,367 -$2,311 -1.95%

Colorado $15,804 $15,069 -$735 -4.65% $14,862 -$942 -5.96% $14,242 -$1,561 -9.88%

Connecticut $14,327 $13,479 -$848 -5.92% $13,327 -$1,000 -6.98% $12,871 -$1,456 -10.16%

Delaware $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

District of Columbia $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Florida $86,722 $84,503 -$2,218 -2.56% $83,896 -$2,826 -3.26% $82,074 -$4,648 -5.36%

Georgia $29,451 $30,768 $1,317 4.47% $30,911 $1,460 4.96% $31,342 $1,890 6.42%

Hawaii $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Idaho $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Illinois $46,709 $44,310 -$2,399 -5.14% $44,120 -$2,589 -5.54% $43,549 -$3,160 -6.77%

Indiana $23,303 $24,048 $745 3.20% $24,115 $812 3.49% $24,316 $1,014 4.35%

Iowa $13,526 $12,229 -$1,297 -9.59% $12,186 -$1,340 -9.91% $12,057 -$1,469 -10.86%

Kansas $11,005 $10,746 -$259 -2.35% $10,792 -$213 -1.93% $10,930 -$75 -0.68%

Kentucky $16,144 $18,171 $2,028 12.56% $18,514 $2,371 14.68% $19,543 $3,399 21.05%

Louisiana $15,655 $17,482 $1,827 11.67% $17,788 $2,133 13.62% $18,705 $3,050 19.48%

Maine $5,940 $6,115 $175 2.94% $6,143 $202 3.41% $6,225 $285 4.80%

Maryland $19,941 $19,147 -$794 -3.98% $18,918 -$1,023 -5.13% $18,231 -$1,709 -8.57%

Massachusetts $26,370 $24,369 -$2,001 -7.59% $24,158 -$2,213 -8.39% $23,522 -$2,848 -10.80%

Appendix IV: Transition Measures for 

Moderating Impact of Formula Modifications 
Appendix IV: Transition Measures for Moderating Impact of Formula Modifications

Page 47 GAO-13-74 Older Americans Act

Michigan $37,748 $38,391 $643 1.70% $38,404 $656 1.74% $38,444 $696 1.84%

Minnesota $18,876 $17,936 -$940 -4.98% $17,695 -$1,180 -6.25% $16,973 -$1,902 -10.08%

Mississippi $10,665 $12,323 $1,658 15.55% $12,626 $1,961 18.39% $13,534 $2,869 26.90%

Missouri $23,260 $24,390 $1,130 4.86% $24,587 $1,326 5.70% $25,176 $1,915 8.23%

Montana $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Nebraska $7,319 $6,806 -$513 -7.01% $6,796 -$522 -7.14% $6,769 -$550 -7.52%

Nevada $9,153 $8,859 -$295 -3.22% $8,750 -$404 -4.41% $8,423 -$730 -7.98%

New Hampshire $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

New Jersey $33,433 $31,279 -$2,154 -6.44% $30,877 -$2,556 -7.65% $29,670 -$3,763 -11.25%

New Mexico $7,619 $8,081 $462 6.06% $8,140 $521 6.84% $8,317 $698 9.16%

New York $77,516 $71,902 -$5,614 -7.24% $71,558 -$5,959 -7.69% $70,525 -$6,991 -9.02%

North Carolina $34,414 $36,036 $1,622 4.71% $36,232 $1,818 5.28% $36,819 $2,405 6.99%

North Dakota $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Ohio $45,248 $45,835 $587 1.30% $45,870 $621 1.37% $45,972 $724 1.60%

Oklahoma $13,990 $15,609 $1,619 11.57% $15,899 $1,909 13.64% $16,767 $2,777 19.85%

Oregon $14,965 $15,249 $284 1.90% $15,247 $282 1.88% $15,240 $275 1.84%

Pennsylvania $57,249 $53,936 -$3,312 -5.79% $53,913 -$3,336 -5.83% $53,843 -$3,406 -5.95%

Rhode Island $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

South Carolina $17,656 $18,461 $805 4.56% $18,564 $908 5.14% $18,872 $1,215 6.88%

South Dakota $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Tennessee $23,785 $25,931 $2,146 9.02% $26,251 $2,466 10.37% $27,211 $3,426 14.40%

Texas $73,246 $77,997 $4,751 6.49% $78,682 $5,436 7.42% $80,737 $7,491 10.23%

Utah $6,938 $6,773 -$164 -2.37% $6,724 -$214 -3.08% $6,575 -$363 -5.23%

Vermont $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Virginia $27,538 $27,117 -$421 -1.53% $26,910 -$628 -2.28% $26,291 -$1,247 -4.53%

Washington $23,443 $23,541 $98 0.42% $23,492 $49 0.21% $23,345 -$98 -0.42%

West Virginia $8,829 $9,444 $616 6.98% $9,648 $819 9.28% $10,258 $1,430 16.20%
Appendix IV: Transition Measures for Moderating Impact of Formula Modifications

Page 48 GAO-13-74 Older Americans Act

Wisconsin $21,427 $20,486 -$941 -4.39% $20,268 -$1,159 -5.41% $19,614 -$1,812 -8.46%

Wyoming $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Total $1,162,801 $1,162,801 $0 0.00% $1,162,801 $0 0.00% $1,162,801 $0 0.00%

Source: GAO analysis of AOA data on OAA Titles III and VII state allotments (2012) and U.S. Census Bureau, American Community Survey 

3-year average data (2008-2010).
Appendix IV: Transition Measures for 

Moderating Impact of Formula Modifications

Page 49 GAO-13-74 Older Americans Act

Hold Harmless Transition 

The second transition method utilizes a hold harmless provision. The hold 

harmless provision works by constraining the losses of states that could 

lose funding under an alternative formula. The additional funding needed 

to raise the allotments to the states losing more than a certain percentage 

is obtained by proportionally lowering the allotments to the states not 

affected by the hold harmless provision. In the example presented in table

7, the hold harmless losses are 2 percent in the first year, 4 percent in the 

second year, 6 percent in the third year, 8 percent in the fourth year, and, 

10 percent in the fifth year.

Table 7 shows the allotments under the partial equity formula using this 

hold harmless transition method and compares the changes to the current 

allotments. The allotment to Alabama rises by 13 percent in the first year 

of transition. In comparison, if no transition was provided for its allotment 

would have risen by 26 percent. By the fifth year, the allotment to 

Alabama rises to 22 percent. In contrast, the allotment to New Jersey in 

first year falls by 2 percent, the maximum permissible loss. Without the 

transition, New Jersey’s allotment falls by 10 percent. By the fifth year, 

the allotment to New Jersey falls by 10 percent.
Appendix IV: Transition Measures for Moderating Impact of Formula Modifications

Page 50 GAO-13-74 Older Americans Act

Table 7: Transition Using a Hold Harmless, Comparison of FY 2012 Allotments to Allotments for the Partial Beneficiary Equity Formula Option

States and the

District of Columbia

Year 1: Allotments Include 2% HH Year 2: Allotments Include 4% HH Year 5: Allotments Include 10% HH

Actual 2012

title III

Partial 

equity

Difference Partial 

equity

Difference Partial 

 equity

Difference

Amount Percent Amount Percent Amount Percent

Alabama $18,218 $20,602 $2,384 13.09% $21,435 $3,217 17.66% $22,299 $4,081 22.40%

Alaska $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Arizona $24,055 $23,574 -$481 -2.00% $23,093 -$962 -4.00% $21,955 -$2,100 -8.73%

Arkansas $11,500 $13,251 $1,751 15.23% $13,787 $2,287 19.89% $14,342 $2,843 24.72%

California $118,678 $116,305 -$2,374 -2.00% $113,931 -$4,747 -4.00% $115,685 -$2,993 -2.52%

Colorado $15,804 $15,488 -$316 -2.00% $15,172 -$632 -4.00% $14,223 -$1,580 -10.00%

Connecticut $14,327 $14,041 -$287 -2.00% $13,754 -$573 -4.00% $12,895 -$1,433 -10.00%

Delaware $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

District of Columbia $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Florida $86,722 $84,987 -$1,734 -2.00% $83,253 -$3,469 -4.00% $81,299 -$5,422 -6.25%

Georgia $29,451 $29,030 -$421 -1.43% $30,203 $752 2.55% $31,421 $1,969 6.69%

Hawaii $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Idaho $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Illinois $46,709 $45,775 -$934 -2.00% $44,841 -$1,868 -4.00% $43,269 -$3,440 -7.36%

Indiana $23,303 $22,837 -$466 -2.00% $23,391 $88 0.38% $24,333 $1,031 4.42%

Iowa $13,526 $13,256 -$271 -2.00% $12,985 -$541 -4.00% $12,173 -$1,353 -10.00%

Kansas $11,005 $10,785 -$220 -2.00% $10,565 -$440 -4.00% $10,954 -$51 -0.47%

Kentucky $16,144 $18,334 $2,191 13.57% $19,076 $2,932 18.16% $19,844 $3,700 22.92%

Louisiana $15,655 $17,528 $1,873 11.97% $18,237 $2,582 16.49% $18,972 $3,317 21.19%

Maine $5,940 $5,928 -$12 -0.20% $5,998 $58 0.98% $6,240 $300 5.05%

Maryland $19,941 $19,542 -$399 -2.00% $19,143 -$798 -4.00% $17,966 -$1,975 -9.90%

Massachusetts $26,370 $25,843 -$527 -2.00% $25,316 -$1,055 -4.00% $23,733 -$2,637 -10.00%

Michigan $37,748 $36,993 -$755 -2.00% $36,891 -$857 -2.27% $38,378 $630 1.67%
Appendix IV: Transition Measures for Moderating Impact of Formula Modifications

Page 51 GAO-13-74 Older Americans Act

States and the

District of Columbia

Year 1: Allotments Include 2% HH Year 2: Allotments Include 4% HH Year 5: Allotments Include 10% HH

Actual 2012

title III

Partial 

equity

Difference Partial 

equity

Difference Partial 

 equity

Difference

Amount Percent Amount Percent Amount Percent

Minnesota $18,876 $18,498 -$378 -2.00% $18,121 -$755 -4.00% $16,988 -$1,888 -10.00%

Mississippi $10,665 $12,758 $2,093 19.62% $13,273 $2,608 24.46% $13,808 $3,143 29.47%

Missouri $23,260 $23,393 $133 0.57% $24,339 $1,079 4.64% $25,320 $2,059 8.85%

Montana $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Nebraska $7,319 $7,172 -$146 -2.00% $7,026 -$293 -4.00% $6,746 -$573 -7.83%

Nevada $9,153 $8,970 -$183 -2.00% $8,787 -$366 -4.00% $8,297 -$856 -9.35%

New Hampshire $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

New Jersey $33,433 $32,764 -$669 -2.00% $32,095 -$1,337 -4.00% $30,089 -$3,343 -10.00%

New Mexico $7,619 $7,723 $104 1.36% $8,035 $416 5.46% $8,359 $740 9.71%

New York $77,516 $75,966 -$1,550 -2.00% $74,416 -$3,101 -4.00% $70,037 -$7,480 -9.65%

North Carolina $34,414 $34,127 -$286 -0.83% $35,507 $1,093 3.18% $36,938 $2,524 7.33%

North Dakota $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Ohio $45,248 $44,343 -$905 -2.00% $44,133 -$1,115 -2.46% $45,912 $664 1.47%

Oklahoma $13,990 $15,727 $1,737 12.41% $16,362 $2,372 16.96% $17,022 $3,032 21.67%

Oregon $14,965 $14,666 -$299 -2.00% $14,617 -$348 -2.33% $15,206 $241 1.61%

Pennsylvania $57,249 $56,104 -$1,145 -2.00% $54,959 -$2,290 -4.00% $53,709 -$3,540 -6.18%

Rhode Island $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

South Carolina $17,656 $17,495 -$162 -0.92% $18,202 $545 3.09% $18,935 $1,279 7.24%

South Dakota $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Tennessee $23,785 $25,383 $1,599 6.72% $26,409 $2,625 11.04% $27,474 $3,689 15.51%

Texas $73,246 $75,072 $1,826 2.49% $78,106 $4,860 6.64% $81,254 $8,008 10.93%

Utah $6,938 $6,799 -$139 -2.00% $6,660 -$278 -4.00% $6,512 -$426 -6.14%

Vermont $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Virginia $27,538 $26,987 -$551 -2.00% $26,436 -$1,102 -4.00% $26,031 -$1,507 -5.47%
Appendix IV: Transition Measures for Moderating Impact of Formula Modifications

Page 52 GAO-13-74 Older Americans Act

States and the

District of Columbia

Year 1: Allotments Include 2% HH Year 2: Allotments Include 4% HH Year 5: Allotments Include 10% HH

Actual 2012

title III

Partial 

equity

Difference Partial 

equity

Difference Partial 

 equity

Difference

Amount Percent Amount Percent Amount Percent

Washington $23,443 $22,975 -$469 -2.00% $22,506 -$938 -4.00% $23,249 -$195 -0.83%

West Virginia $8,829 $9,646 $817 9.26% $10,036 $1,207 13.68% $10,440 $1,612 18.26%

Wisconsin $21,427 $20,998 -$429 -2.00% $20,570 -$857 -4.00% $19,357 -$2,070 -9.66%

Wyoming $5,928 $5,928 $0 0.00% $5,928 $0 0.00% $5,928 $0 0.00%

Total $1,162,801 $1,162,801 $0 0.00% $1,162,801 $0 0.00% $1,162,801 $0 0.00%

Source: GAO analysis of AOA data on OAA Titles III and VII state allotments (2012) and U.S. Census Bureau, American Community

Survey 3-year average data (2008-2010).
Appendix IV: Transition Measures for 

Moderating Impact of Formula Modifications

Page 53 GAO-13-74 Older Americans Act

While the preceding illustrations show the application of transition options 

to the OAA title III formula allotments, these options for moderating 

formula changes could also be applied to title VII. These transition options 

could also be used to moderate the impact of the application of the full 

beneficiary equity option by additionally adjusting for differences in cost of 

providing services in each state, and the taxpayer equity option by 

additionally adjusting for differences in each state’s ability to finance 

these programs from its own resources. Finally, the change in formula 

allotments could also be moderated if additional program funding were 

available.
Appendix V: Comments from the Department 

of Health and Human Services

Page 54 GAO-13-74 Older Americans Act

Appendix V: Comments from the Department 

of Health and Human Services 
Appendix V: Comments from the Department 

of Health and Human Services

Page 55 GAO-13-74 Older Americans Act
Appendix VI: GAO Contact and Staff 

Acknowledgments

Page 56 GAO-13-74 Older Americans Act

Charles A. Jeszeck, Director, (202) 512-7215, or jeszeckc@gao.gov 

In addition to the contact named above, David Lehrer, Assistant Director; 

Amber Yancey-Carroll, Analyst-in-Charge; Gregory Dybalski, Jessica 

Gray, Sharon Hermes, DuEwa Kamara, Luann Moy, and Michael 

Springer made significant contributions to the engagement. Also 

contributing to this report were Jessica Botsford, David Chrisinger, Holly 

Dye, Monika Gomez, Kathy Leslie, Ashley McCall, Sheila McCoy, Mimi 

Nguyen, Lorin Obler, Anna Maria Ortiz, Max Sawicky, Sal Sorbello, and 

Craig Winslow. 

Appendix VI: GAO Contact and Staff 

Acknowledgments 

GAO Contact 

Staff 

Acknowledgments 

(131163)
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