oversight

Older Americans Act: Administration on Aging Does Not Approve Intrastate Funding Formulas

Published by the Government Accountability Office on 1990-06-08.

Below is a raw (and likely hideous) rendition of the original report. (PDF)

_-..   “..I._   I”_   ,._,   *.   .I   I   “_.l--....-----.-----




                                                                   OLDER AMERICANS
                                                                   ACT
                                                                   Administration on
                                                                   Aging Does Not
                                                                   Approve Intrastate
                                                                   Funding Formulas


                                                                                   141736
   a
                   United States
GAO                General Accounting  Office
                   Washington, D.C. 20648

                   Human Resources    Division

                   B-237081

                   June 8,199O

                   The Honorable Augustus F. Hawkins
                   Chairman, Committee on Education and Labor
                   House of Representatives

                   The Honorable Dale E. Kildee
                   Chairman, Subcommittee on Human Resources
                   Committee on Education and Labor
                   House of Representatives

                   In 1987, the US. District Court for the Southern District of Florida ruled
                   that Florida’s formula for distributing federal grant funds provided
                   under Title III of the Older Americans Act for supportive and nutrition
                   services was invalid. The court found that the formula not only failed to
                   consider the needs of low-income minorities, as required by the act and
                   implementing regulations, but also contained factors that discriminated
                   against minorities. In an October 3 1, 1988, letter, you expressed concern
                   that other state formulas may not be considering the needs of elderly
                   minorities when distributing Title III funds or may be using the same
                   factors that were found to discriminate in the Florida case.

                   In response to your letter and later discussions with Subcommittee staff,
                   we agreed to review each state’s Title III intrastate funding formula to
                   identify the (1) factors used to distribute funds within the state,
                   (2) number of formulas that contain a specific factor that directs funds
                   to where minorities are located, (3) number of formulas that contain the
                   same factors that were found to be discriminatory in Florida, and
                   (4) recent state revisions to funding formulas and the reasons for them.
                   We also agreed to determine the extent to which the Administration on
                   Aging (AOA), the component of the Department of Health and Human
                   Services that administers the act, is involved in developing and approv-
                   ing intrastate formulas. As further agreed with your staff, we did not
                   attempt to determine whether individual state formulas comply with the
                   decision in the Florida case.


                   Forty-five states use intrastate funding formulas to distribute Title III
Results in Brief   funds. While AOA'S regulations state that formulas must target those eld-
                   erly in greatest economic or social need,, with particular attention to low-
              */   income minorities, they do not identify the factors to be used for such
                   targeting. States’ formulas include as many as nine factors. For example,
                   44 formulas contain an economic need factor. Thirty-one include a
                   minority factor, five have a low-income minority factor, and two have a


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             B287081                                                                                         ,




             minority and a low-income minority factor. Twenty state formulas con-
             tain a factor that was found to discriminate against minorities in the
             Florida case. Since the beginning of 1986, 18 states have revised their
             formulas to, among other things, give preference to targeted categories
             of the elderly.

             While AOA reviews and comments on states’ funding formulas, the
             agency believes the act does not authorize it to approve or disapprove
             formulas. Although the act leaves room for different interpretations, we
             believe it does authorize ADA to disapprove formulas that do not comply
             with its guidelines. However, given AOA’S position on this issue, the Con-
             gress should consider clarifying its intent as to whether AQA should dis-
             approve formulas the agency believes do not meet the intent of the act
             and its regulations.


Background   enacted to ensure the well-being of the elderly (aged 60 or older) by pro-
             viding services to help them live independently in their own homes and
             communities. Under Title III of the act, the federal government distrib-
             utes funds through formula grants to state agencies to develop or
             expand community-based social service programs. Title III funds are dis-
             tributed to states based on each state’s proportion of the total elderly
             population in the United States. In fiscal year 1988 about $689 million
             was available for Title III supportive services’ and nutrition services.

             The act is implemented through a national aging network consisting of
             AOA,  69 state agencies on aging,2 over 670 area agencies on aging, and
             more than 26,000 organizations providing supportive and nutrition ser-
             vices in the community. The state agency must develop a 2- to 4-year
             plan for providing services. AM must approve the plan before the state
             can receive a federal grant. The state agency distributes the grant to an
             area agency in each planning and service area within the state. The area
             agencies award subgrants or contract with local providers that deliver
             the services to the elderly. Most state agencies have several area agen-
             cies, but 16 have designated their entire state or territory as a single


             ‘Supportive services include (1) access services, such as transportation, outreach, and information
             and referral, (2) in-home services, such as housekeeping and home health aides; and (3) other commu-
             nity and neighborhood services, such as legal, escort, physical fitness, and second career counseling.

             21ncludesthe 60 states, the District of Columbia, American Samoa, the Commonwealth of the North-
             em Mariana Islands, the Federated States of Micronesia, Guam, Puerto Rico, the Republic of the Mar-
             shall Islands, the Republic of Palau, and the Virgin Islands.



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                         service area with the state agency performing the area agency
                         functions.


Title III Targeting      Specified categories of elderly persons are targeted to receive preference
                         for Title III services. Under the act, all individuals 60 years old and
Prov,isions              older are eligible for services. However, the act has been amended over
                         the last several years to identify categories of individuals to receive
                         preference for services. The act currently states that “preference will be
                         given to providing services to older individuals with the greatest eco-
                         nomic or social needs, with particular attention to low-income minority
                         individuals.“” The emphasis on serving low-income minorities was added
                         by 1984 amendments to the act. In developing the state plan, each state
                         agency must assure that these preferences will be given and include in
                         the plan the proposed methods for doing so.


How Intrastate Funding   To be eligible for grants, states with more than one service area must
Formulas Work            develop a Title III intrastate funding formula in addition to the state
                         plan4 The formula determines how federal funds will be distributed to
                         service areas within the state. Under the act, state agencies must
                         develop the formula according to AoA guidelines, taking into account the
                         best available statistics on the location of persons 60 years old and
                         older. The state must publish the formula for review and comment and
                         include a statement of the formula’s goals and the application of the
                         definitions of greatest economic or social need.

                         Under AOA’S regulations (45 C.F.R. 1321.37), the formula must reflect
                         the proportion among service areas of persons aged 60 years old and
                         older “in greatest economic or social need with particular attention to
                         low-income minority individuals.” The formula must be published for
                         review and comment within the state by older persons, appropriate
                         agencies and organizations, and the general public. Although the act and
                         regulations require each state agency to submit its formula to AOA for
                         review, and comment, the formula is not part of the state plan and AQA
                         does not approve or disapprove it.

                         “As defined in the act, “greatest economic need” means the need resulting from an income at or below
                         poverty levels established by the Office of Management and Budget. “Greatest social need” means the
                         need caused by noneconomic factors-disabilities, language barriers, and isolation, including that
                         caused by racial or ethnic status- that restrict the ability to perform normal daily tasks or threaten
                         the capacity to live independently.
                         “Though not required, single-service-area states may also use formulas to distribute funds to counties
                         or other identified areas in the state.



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                   B287081                                                                          #




                   State formulas usually distribute funds based on a combination of
                   weighted economic, social, and other factors. The weights determine the
                   emphasis placed on factors in distributing Title III funds. For example,
                   some states place a large weight on “persons 60 years old and older at or
                   below the poverty level,” which directs more funds to service areas with
                   larger concentrations of the elderly in greatest economic need. In con-
                   trast, other states place a large weight on “persons 60 years old and
                   older,” which addresses neither economic nor social need but more
                   evenly distributes Title III funds to the elderly throughout the state. The
                   act and regulations do not provide guidance on specific factors to use or
                   how heavily to weight them; therefore, states make this determination.

                   States may also provide for a percentage of the total funds to be set
                   aside for administrative purposes. Further, if the state begins the distri-
                   bution process by providing a fixed amount to each area agency, only
                   the remaining grant funds will be distributed through the formula fac-
                   tors and weights.


Meek v. Martinez   Meek v. Martinez,” the case that challenged Florida’s Title III formula,
                   marked the first time a federal court interpreted the targeting provi-
                   sions of the act and regulations. The complaint contended that Florida’s
                   formula was illegal because it failed to target funds specifically to low-
                   income minority elderly and that factors in the formula discriminated
                   against elderly minorities.

                   Florida’s formula included three factors-the number of persons in each
                   service area who were (1) 60 years old and older below the poverty
                   level, (2) 66 years old and older living alone, and (3) 75 years old and
                   older. The state intended for these factors to result in the distribution of
                   funds on the basis of economic need, social isolation, and frailty, respec-
                   tively. In its December 1987 decision, the court found that none of Flor-
                   ida’s factors targeted low-income minorities. The court also found that
                   the second and third factors did not correlate with social or economic
                   need and were discriminatory under Title VI of the Civil Rights Act of
                    1964.

                   The court held that the Florida formula did not meet the requirements
                   of the Older Americans Act, as amended, and its regulations, that it tar-
                   get the elderly population in the greatest economic or social need and
                   “give particular attention” to low-income minorities. The court ordered

                   “No. 87-1233 slip op. (SD. Fla., Dec. 11, 1987).



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              B-237081




              Florida to adopt a new formula incorporating a minority factor that ade-
              quately addresses the mandate to give “particular attention” to low-
              income minorities and eliminating the two factors that were found to
              discriminate against minorities.

              An AW official said that the agency has not taken the position that the
              Meek v. Martinez decision applies to other states. However, effective
              November 21, 1989, AOA issued a program instruction to state agencies
              in which it discussed an increased commitment to target services, espe-
              cially to low-income minorities. AOA indicated that because of recent
              legal developments, states may need to change their formulas, and it ini-
              tiated a review of all state formulas.


              To respond to your request, we reviewed the Older Americans Act and
Methodology   its implementing regulations -focusing on Title III program require-
              ments and responsibilities; reports and statistics on services provided
              through Title III programs; and court documents in the Meek v. Martinez
              case. We met with the Acting Commissioner (now Commissioner) and
              other AOA officials to discuss the federal government’s role in providing
              services to the elderly, distributing Title III grant funds to the states,
              assuring that the needs of minorities are met, and approving funding
              formulas.

              Forty-five states use intrastate funding formulas” to distribute Title III
               funds.7 We analyzed these formulas to identify the factors used to dis-
              tribute funds and the number of formulas that contain specific minority
               factors and factors that were found to be discriminatory in Meek v. Mar-
              tinez. We developed an interview guide to (1) verify our categorization
              of the factors, (2) discuss each state’s formula and revisions to it, and
              ,(3) determine how states without formulas distribute funds. Using this
               guide, we conducted telephone interviews with officials in the agency on
               aging in each of the 50 states and the District of Columbia.

              Our work was done from January to October 1989 in accordance with
              generally accepted government auditing standards.


              “The 46 states include 3 single-service-area states-Alaska, Nevada, and New Hampshire-that use
              formulas even though they are not required to do so. We did not review distribution methods in the
              eight territories.

              7Five single-service-area states-Delaware, North Dakota, Rhode Island, South Dakota, and Wyo-
              ming-and the District of Columbia do not use an intrastate funding formula to distribute Title III
              funds. They use different methods, including directly awarding grants to service providers.



              Page 5                                                       GAO/HRD90-86 Older Americans Act
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                           The 46 formulas used from one to nine factors to distribute Title III
Most Formulas              funds.8 While there are differences in the factors contained in formulas,
Address Minorities,        there are also similarities. For example, 44 formulas have one or more
but Many Contain a         economic need factors, 41 contain a factor to direct funds to where per-
                           sons 60 years old and older are located, and 38 include one or more
Fat ‘tar Found to          minority factors. Seven of the 38 contain a specific factor addressing
Discriminate               low-income minorities. Twenty formulas contain one of the factors that
                           was found to discriminate in Meek v. Martinez-persons       76 years old
                           and older, Eight use a factor similar to the other factor found to discrim-
                           inate-persons 66 years old and older living alone. Since the beginning
                           of 1986,18 states have revised formulas to, among other things, direct
                           funds to categories of individuals who are to receive preference for
                           services.


Most Formulas Contain      Forty-four of 46 state formulas contain one or more economic need fac-
Economic and Social Need   tors-which    focus primarily on persons 60 years old and older who are
                           at or below the poverty level. Appendix I shows the various economic
Factors                    need factors found in funding formulas. Most state formulas also con-
                           tain social and other factors to direct funds to categories of elderly indi-
                           viduals. Forty-one of 46 formulas contain at least one factor that
                           allocates funds according to the distribution of the 60 year old and older
                           population, similar to the way AOA distributes federal funds to the
                           states.” Populations targeted as being in greatest social need include per-
                           sons who are 76 years old and older, are living alone, or are minorities.
                           Appendix II shows the various social and other factors found in funding
                           formulas.


Most Formulas Have         Of the 46 state formulas, 38 contain a social need factor to direct Title
Minority Factors           III funds to minoritieslO The other seven states had different rationales
                           for not including a minority factor. For example, state officials reasoned
                           that: (1) by directing funds to elderly persons at or below the poverty
                           level, minorities are automatically included; (2) a separate factor is not
                           needed because high minority participation rates already exist in Title
                           III programs; (3) the number of minorities in the state is too small to

                           “Not all Title III funds are distributed through formulas. For example, one state divides half of its
                           Title III allocation equally among five area agencies and distributes the remainder through a formula
                           containing five factors.
                           “In addition, one state’s formula addresses persons 60 to 74 years old.
                           “‘The seven states without a specific minorlty factor in the formula are Louisiana, Maryland, Missis-
                           sippi, New Hampshire, Pennsylvania, South Carolina, and Vermont.



                           Page 6                                                        GAO/IiRD-9085 Older Americana Act
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                      8287081




                      warrant a factor; and (4) services are to be targeted to minorities at the
                      local level and area agencies must develop minority targeting objectives.

                      Under AOA’S regulations, states are to pay “particular attention” to low-
                      income minorities when developing formulas. The regulations do not
                      explain how states are to do this. An AOA official said that states can do
                      this with one factor or a combination of factors in the formula. All of
                      the 38 states with a minority factor also have an economic need factor
                      in the formula. Seven of the 38, including Florida (which added the fac-
                      tor because of the Meek v. Martinez case), have specific factors address-
                      ing low-income minorities, in addition to a more general economic need
                      factor. As shown in appendix III, 31 formulas target funds to minorities
                      who are 60 or 66 years old and older, 5 target to low-income minorities
                      who are 60 years old and older, and 2 have factors addressing minorities
                      in general as well as low-income minorities.


Twenty States Use a   Twenty states use one of the specific factors found to be discrimina-
Factor Found to       tory,ll and eight use a factor that is similar to one the court found to be
                      discriminatory. In Meek v. Martinez, the court found that the factor in
Discriminate by a     Florida’s formula directing funds to service areas where persons 76
U.S. District Court   years old and older were located-the frailty factor-discriminated
                      against minorities. The court pointed out that minority groups have a
                      shorter life expectancy than nonminorities, which means that they make
                      up a smaller percentage of the over 75 elderly population than they do
                      of the elderly over 60 years of age, In addition, experts testified that
                      funds should not be distributed based on frailty because 77 percent of
                      persons who are 75 years old and older are not frail by gerontological
                      standards. They testified that disability was the relevant concept and
                      evidence showed that minorities experience chronic disability at an
                      earlier age. Because of this, the 75 year old and older factor excluded
                      minorities who suffered disabilities before age 76, and included many
                      nonminorities who suffered no disability and, therefore, was found by
                      the court to be discriminatory. Twenty states distribute Title III funds
                      using this factor. ‘2 In addition, one state (Nevada) directs funds using a
                      factor focusing on persons 80 years old and older.


                      ’ ‘This is not necessarily an indication that any of these states’ formulas would be found invalid even
                      in the district where this district court is located. The validity of a formula depends upon the effect of
                      the formula as a whole. Further, this decision is not binding in other districts.

                      “Arizona California, Colorado, Connecticut, Georgia, Idaho, Illinois, Indiana, Louisiana, Massachu-
                      setts, Missouri, Nebraska, New Hampshire, New Jersey, New York, Ohio, Oregon, Utah, Washington,
                      and West Virginia.



                      Page 7                                                          GAO/HRD-90-86 Older Americans Act
                               E237081




                               The court in Meek v. Martinez also found that persons 65 years old and
                               older living alone were not necessarily socially isolated. Many older per-
                               sons who live alone have higher incomes than those living with families.
                               Living alone has no independent significance as an indicator of loneli-
                               ness or social isolation, the court stated, and must be analyzed along
                               with other factors, such as economic status, availability of a support
                               group, whether the decision to live alone was voluntary, and cultural
                               patterns. In addition, the court found that minority elderly lived more
                               frequently with members of their family than nonminorities. The court,
                               therefore, ruled that this factor in Florida’s formula discriminated
                               against minorities.

                               Eight states distribute funds using a factor focusing on persons living
                               alone. Formulas of seven states-Alabama, California, Idaho, Illinois,
                               Massachusetts, Ohio, and Washington- direct funds to persons 60 years
                               old and older living alone, while Wisconsin’s formula directs funds to
                               persons 76 years old and older living alone.


States Have Been Active   in   Thirty-six states have revised their original Title III funding formulas.
Revising Funding               Eighteen of the states with revised formulas made changes that became
                               effective after 1985.1” The changes in eight of these states became effec-
Formulas                       tive in 1989.

                               States changed the formulas for various reasons, but primarily to
                               attempt to address changes to the act and regulations. Fifteen changed
                               the formulas to give preference to required categories of individuals,
                               while officials in four states said the formulas were revised because of
                               Meek v, Martinez. Although few states changed their funding formulas
                               because of Meek v. Martinez, all but three of the officials we spoke with
                               were aware of the case.
                                                                                                             .
                               No federal agency approves funding formulas. Section 305 of the act
No Federal Approval            requires the state agency to submit its formula to the Commissioner of
of Funding Formulas            AOA for review and comment. The implementing regulations provide
                               more guidance. The regulations require the state agency to review and
                               update the formula as often as it submits its state plan for approval.
                               Although the regulations require the state agency to submit the formula
                               to AOA for review and comment, they specify that the formula be submit-
                               ted separately from the plan.

                               “‘Includes one state that estimates the changes will become effective in July 1990.



                               Page 8                                                       GAO/HRD-90-85 Older Americans Act
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    B-237081




    Officials in 44 of the 45 states with formulas told us they submit the
    formulas to AOA for review and commentI The Acting Commissioner
    (now Commissioner) said that AOA follows a standardized guide in
    reviewing formulas to determine whether they meet the act’s
    requirements.

    Although AOA suggests changes to state funding formulas, the states are
    not required to make such changes. Fourteen state officials told us that
    when providing comments, AOA requested or encouraged that they con-
    sider changing the formula. For example, one official said AOA suggested
    that the state review the formula as a result of the Meek v. Martinez
    case, while another said AOA strongly encouraged the state to change
    formula factors. Both of these states revised their formulas in 1989 by,
    among other things,‘adding a minority factor. However, although AOA
    has encouraged,another state to consider adding a minority factor, a
    state official told us the state did not plan to do so.

    With the issuance of the program instruction in November 1989 (See
    p. 5.), AOA initiated a review of all state formulas to determine whether
    funds are targeted for services to low-income minorities, That review
    will result in comments or suggestions to the states, not the approval or
    disapproval of their formulas.

    Although AOA approves the service plan developed by the state agency,
    it does not consider the funding formula to be part of the plan and,
    therefore, does not approve the formula. AOA believes that because the
    act discusses the formula in section 305 (42 USC. 3025)-which
    addresses state agency duties- rather than in section 307 (42 U.S.C.
    3027)-which      deals with the approval by AOA of state plans-the act
    does not authorize AOA to approve intrastate funding formulas. AOA'S
    position is that the statutory language authorizing it to “review and
    comment” on formulas prohibits it, by implication, from disapproving
    formulas.

    We believe AOA'S authority to “review and comment” on formulas does
    not preclude it from disapproving formulas that fail to comply with its
    guidelines. A condition of grant eligibility is that a state must have a
    funding formula that conforms to AOA'S guidelines. An agency has
    authority to enforce grant conditions. Since a funding formula that com-
    plies with the guidelines is a grant condition, it follows that the agency
    has authority to enforce them.

    140nestate did not provide this information.



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                R-237081




                We believe the act gives AQA two chances to consider the formula. First,
                AOA   can review and comment on the formula as it is being developed by
                the state agency. This puts the state on notice of potential problems,
                although AOA lacks the authority to prevent the state from adopting the
                formula. Second, once the state has adopted the formula, AOA can deter-
                mine whether it meets the agency’s guidelines and, if it does not, can
                initiate the procedure to declare the state ineligible to receive funds.

                Although we disagree with AOA'S position, we recognize that the law
                leaves room for different interpretations. The act does not clearly state
                that formulas are to be included as part of the plan or are to be submit-
                ted to AOA for approval; it states only that ADA must “review and com-
                ment” on them. This language arguably limits, by implication, AQA'S
                authority. Without clearer statutory authority, and in view of its cur-
                rent position that it lacks authority, AQA might be in a vulnerable legal
                position if it disapproved formulas and withheld funds from the states.


                We believe AQA has the authority to disapprove funding formulas that
Conclusions     do not comply with its guidelines. Because ADA does not believe it has
                the authority to approve or disapprove formulas, states distribute Title
                III funds according to formulas that receive no federal approval. In
                Meek v. Martinez, a U.S. district court determined that Florida was dis-
                tributing federal funds through its formula in a manner that discrimi-
                nated against minorities. We recognize that the Meek v. Martinez
                decision is not applicable to other states; however, other state formulas
                that contain the same, similar, or other untested factors may also be
                distributing funds contrary to the intent of the act and its regulations.


                If the Congress wants AOA to (1) approve or disapprove the factors and
Matter for      weights contained in intrastate funding formulas to better ensure that
Consideration   each state’s formula meets the intent of the act and AOA regulations and
                (2) withhold funds for disapproved formulas, it should consider amend-
                ing Title III of the Older Americans Act to clarify this intent.


                As agreed with your offices, we did not request written comments from
                ADA, but we discussed the matters in this report with AOA officials and
          Y     incorporated their comments where appropriate. Unless its contents are
                announced earlier, we plan no further distribution of this report until 30
                days from its issue date. At that time, we will send copies to interested
                parties and will make copies available to others on request.


                Page10                                       GAO/HRD-90-86 OlderAmericansAct
Please call me on (202) 276-1656 if you or your staffs have any ques-
tions about this report. Other major contributors are included in appen-
dix IV.




Linda G. Morra
Director, Intergovernmental
   and Management Issues




Page 11                                     GAO/HRD-99-95 Older Americans Act
_.--.~.------..--..~

Contents


Letter
Appendix I
Economic Need
Factors Found in
Intrastate Funding
Formulas
Appendix II
Social and Other
Factors Found in
Intrastate Funding
Formulas
Appendix III
Minority Factors
Found in Intrastate
Funding Formulas
Appendix IV
Major Contributors to
This Report




                        Abbreviation

                        AOA       Administration   on Aging


                        Page 12                               GAO/HRD-90-85 Older Americans Act
Y




    Page 13   GAO/HRD-90-86 Older Americans Act
Appendix I

EconomicNeedFactors Found in Intrastate                                                                             ’M
Funding Formulas

                 FactoP                                                                               Number of states
                 Persons 60 years old and older who are
                   At or below the poverty level                                                                            14
                   Below the poverty level                                                                                  11
                   Low income                                                                                               6
                   In poverty                                                                                               4
                   Below 125 percent of poverty                                                                             2
                   At or below 125 oercent of povertv                                                                       1
                   At the poverty level                                                                                     1
                   Poor                                                                                                     1
                 Persons 65 vears old and older who are
                   Receivin Supplemental Security Income/
                      State 8 upplementary Payment                                                                           1
                   Poor                                                                                                      1
                 Persons 60 to 74 years old who are
                   In poverty                                                                                                lb
                 Persons 75 years old and older who are
                   In poverty
                 Persons 60 to 74 years old who are
                   At or below 125 percent of poverty                                                                        lC
                 Persons 75 years old and older who are
                   At or below 125 oercent of oovertv
                 Y&en   states also include one or more low-income minority factors in their intrastate funding formulas.

                 bOne state has two economic need factors in its formula: (1) persons 60 to 74 years old-in    poverty and
                 (2) persons 75 years old and older-in poverty.

                 =One state has two economic need factors in its formula: (1) persons 60 to 74 years old-at or below
                 125 percent of poverty and (2) persons 75 years old and older-at or below 125 percent of poverty.




             Y




                 Page 14                                                         GAO/HRD-so-85 Older Americans Act
Appendix II

fbcial and Other Factors Found in Intrastate
Funding Formtim

                Factor                                                             Number of states
                Persons 60 years old and older                                                    41
                Persons 60 years old and older who are
                    Minoritv                                                                      298
                    Low-income minority      .~-~~~--. ~~--__.-__   __I___       ___-              3”
                    Minority at or below poverty level                                             2
                    Minoritv UD to 125 oercent of oovertv level                                    1
                    Livina in rural areas                                                         11
                    Living alone
                -__..-__---                ~--
                    Limited in their English-speaking ability
                    Experiencing moderate and severe
                       functional limitations
                    In greatest social
                -..------.-_                need
                                    -.----___                                                      lb
                    Living in counties lying outside Standard
                       Metropolitan Statistical Areas                                              1
                    Residents of Indian reservations                                               lC
                Persons 60 to 74 Years old                                                         1
                Persons 60 to 74 years old who are
                    Minority                                                                       lC
                    Minoritv oovertv                                                               lC
                Persons 65 years old and older who are
                    Minority                                                                       3
                    Experiencing two or more functional
                       limitations of personal care activities                                     I*
                    Transportation disadvantaged                                                   1
                    Living in rural areas                                                          1
                Persons 75 years old and older                                                    20
                Persons 75 years old
                _--_-.------                   and older who are
                                          .._---
                    Minority                                                                       lC
                    Minority
                -_-.-._.-.-_- poverty                                                              lC
                    Living alone                                                                   1
                    Living alone, at or below 100 percent of
                       poverty level                                                               1
                Persons 80 years old and older                                                     1
                Square miles in each planning and service
                    area                                                                           6
                Basic
                   ..~_~.allocation
                              ~-~.-..._ .~~~~_..                                        -          3
                Ruralness at the county level                                                      1
                Inverse population density in each planning
                    and service area                                                               le
                Rate of unemployment at the county level                                           1
                Indicators of the relative cost of doing
                    business among different areas of the state
                    due to higher prices for goods and services                                    1




                Page 15                                             GAO/HRDQO-86 Older Americans Act
Appemllx II
Social and Other Factors Found iu Intrastate
Funding Formulas




‘One state includes both a minority and a low-income minority factor in its formula.

hlncludes individuals requiring assistance with personal care and mobility plus non-English-speaking
persons who might have greater difficulty in obtaining services.

“One state has five minority factors in its formula: (1) persons 60 years old and older-residents    of
Indian reservations; (2) persons 60 to 74 years old-minority;    (3) persons 60 to 74 years old-minority
poverty: (4) persons 75 years old and older-minority;     and (5) persons 75 years old and older-minority
poverty.
*Reflects those in the population with two or more deficits in activities of daily living.

OOne state uses an inverse population density ranking to provide a relationship of geographic size and
population density to the sums needed to provide services equitably to all older individuals residing in
the planning and service areas.




Page 16                                                             GAO/HRD90-86 Older Americans Act




                                                    ,.
      .
Apphdix   III

l%nority Factors Found in Intrast&,e
Funding Formulas

                Minority factors                                                                       Number of states
                Persons 60 vears old and older who are
                   Minority                                                                             28
                Persons 65 years old and older who are
                _--
                   Minority                                                                               3
                Total                                                                                                       31
                Low-income minority factors
                Persons 60 years old and older who are
                  Low-income minoritv                                                                     2
                  Minority at or below poverty level                                                      2
                  Minority up to 125 percent of poverty level                                             1
                Total                                                                                                       5
                Both minority and low-income minority factors
                Persons 60 years old and older who are
                  Minority                                                                                la
                  Low-income minority
                Persons 60 years old and older who are
                  Residents of Indian reservations
                Persons 60 to 74 years old who are
                  Minority                                                                                lb
                  Minority poverty
                Persons 75 years old and older who are
                  Minority
                  Minority povertv
                Total                                                                                                       2
                aOne state includes both a minority and a low-income minority factor in its formula
                bOne state has five minority factors in its formula: (1) persons 60 years old and older-residents     of
                Indian reservations; (2) persons 60 to 74 years old-minority:    (3) persons 60 to 74 years old-minority
                poverty; (4) persons 75 years old and older-minority:     and (5) persons 75 years old and older-minority
                poverty.




                Page 17                                                           GAO/HR.D9O-86 Older Americana Act
Major Contributors to This Report


                        Susan D. Kladiva, Assistant Director, (202) 623-8666
Human Resources         Joseph A. Petko, Evaluator-in-Charge
Division,
Washington, D.C.

Office of the General   Robert G. Crystal, Assistant General Counsel
Counsel,
Washington, D.C.




(llH27H)                 Page 18                                       GAO/HRD-90-85 Older Americans Act