Shaping the Future, Part II — Aging Policy, OAA Reauthorization, and Grant-Making Shifts
In Part I of this series, I explored how the One Big Beautiful Bill Act (OBBB/OB3) rewrites major parts of Medicaid policy, from a new HCBS waiver option to rural health transformation. But federal policy doesn’t stop at Medicaid. At the ADvancing States HCBS Conference in Baltimore (August 2025), presenters Abby Cox and Rachel Neely (ADvancing States) also unpacked changes that directly impact the aging network, ACL, and federal grant-making authority.
If OBBB represents Medicaid’s future, these developments point to the shifting landscape for aging programs, older Americans, and the organizations that serve them.
Aging Policy in Flux: The OAA Question
The Older Americans Act (OAA) is the backbone of the aging network, authorizing nutrition programs, caregiver support, senior centers, and much more. But right now, OAA is caught between reauthorization and regulation.
Reauthorization vs. Regulation — What’s the Difference?
Reauthorization is when Congress renews the OAA law itself, setting authorization levels that inform appropriations. It’s the big-picture vote of confidence.
Regulation comes from the Administration for Community Living (ACL), which issues requirements and guidance on how OAA programs operate day to day.
Where Things Stand
Reauthorization: The HELP Committee reintroduced OAA reauthorization on June 18, 2025, but no hearing has been scheduled yet. Stakeholders are divided — some want it passed quickly, others fear that “opening up the Act” could backfire.
Regulation: ACL has issued new OAA guidance, requiring states to submit updated plans or amendments. About half of states are preparing corrective action plans, but many view the process as punitive.
Takeaway: OAA is operating in a gray zone — technically authorized, but under new regulatory expectations that stretch state capacity.
Reauthorization vs. Regulation
Reauthorization is an Act of Congress responsible for the renewal of the Older Americans Act (OAA) law while the Regulation of the OAA, rules and guidance to implement the law, is the responsibility of the Administration for Community Living (ACL). Congress has not yet reauthorized the OAA and the ACL has undergone a significant reduction in force (RIF).
ACL Restructuring and Capacity Concerns
In July 2025, ACL experienced a significant reduction in force (RIF), eliminating:
The Budget and Grants team
The Policy and Evaluation teams
All Regional Administrators
Most of the Communications team
States are now directed to funnel questions through a single contact: AoA.OAA@acl.hhs.gov.
This restructuring has triggered deep concern about how funding will be distributed in a timely manner. Without regional administrators and grants staff, states worry about slower approvals, delayed technical assistance, and reduced capacity for evaluation and oversight.
MIPPA: Delays and Reauthorization
The Medicare Improvements for Patients and Providers Act of 2008 (MIPPA) continues to fund programs like SHIP, AAA outreach, and tribal assistance. But implementation is shaky:
FY25 state MIPPA awards (Sept 2025–Aug 2026) are still pending, though expected to be made retroactive.
S.2466, a 5-year MIPPA reauthorization bill, is under consideration.
In the meantime, programs must carry over last year’s funds while waiting for new awards.
This delay is not unusual in federal grant cycles — but combined with ACL’s restructuring, it creates uncertainty for states and local providers who rely on MIPPA for low-income Medicare outreach and enrollment support.
Federal Grant-Making Changes: A New Layer of Risk
A new directive now requires all federal agencies to submit discretionary grant solicitations for review by a political appointee before release.
Key changes:
All discretionary grants must include a “termination for convenience” clause, allowing cancellation at any time.
ACL and other agencies may face delays in posting NOFOs while awaiting political review.
Providers and states could experience more funding delays, shortened application windows, or abrupt cancellations.
In practical terms, this risks slowing innovation in HCBS and aging programs. Shorter timelines also disadvantage smaller providers and CBOs with less grant-writing capacity.
New Funding Opportunities — Short Timelines, Big Potential
Despite the challenges, several Notice of Funding Opportunities (NOFOs) were announced in summer 2025 with aggressive turnaround times:
Behavioral health in senior nutrition programs (released July 29, due Aug 20)
Chronic disease self-management education (released July 30, due Aug 15)
Falls prevention strategies (released July 29, due Aug 15)
National lifespan respite care (released July 30, due Aug 15)
Each is designed to expand evidence-based interventions in areas that directly impact older adults’ independence and quality of life. But the three-week windows illustrate the capacity crunch providers now face.
Emerging Issues to Watch
1. Assisted Living in Medicaid
Pressure is mounting on states to clarify how assisted living fits into Medicaid HCBS. CMS reiterated: Medicaid cannot pay for room and board. But the gray zone of service coverage in assisted living remains unsettled.
2. Case Management Quality
States vary widely in how they structure case management:
Caseload ratios differ dramatically.
Some states centralize across waivers; others segment by program.
Payment structures are inconsistent.
CMS’s Final Rule makes case management quality a focal point — meaning states must invest in monitoring, training, and data systems to demonstrate outcomes.
3. Oversight of the Aging Network
If OAA is reauthorized, it may come with new monitoring expectations for AAAs and providers. This could alter contract terms, performance metrics, and reporting requirements.
The Power — and Limits — of the OAA
One slide from the session captured it perfectly: the OAA is enormous in scope but tiny in funding. It touches millions of lives, yet the federal dollars pale in comparison to Medicaid.
The implication? States and providers must leverage OAA strategically while recognizing its limits:
Nutrition and caregiver programs are vital supports.
But without stronger appropriations, OAA cannot offset workforce shortages or rising demand on its own.
My Reflection
In Medicaid (Part I), OBBB creates bold new pathways with big lifts. In aging (Part II), we see something different: fragility.
The OAA reauthorization debate reflects both the importance and the vulnerability of this law.
The ACL restructuring exposes gaps in capacity that could slow funding and oversight.
The new grant-making rules inject political risk into what should be stable, evidence-driven programs.
And yet, there are bright spots: short-turnaround NOFOs in falls prevention, respite care, and behavioral health signal a federal willingness to invest in innovation — if states and providers can mobilize fast enough.
For providers, states, and vendors, the message is clear:
Diversify funding streams (don’t rely solely on OAA or MIPPA).
Invest in grant-writing capacity to meet tighter deadlines.
Engage early with states on case management quality and assisted living coverage debates.
Further Reading
Administration for Community Living (ACL)
Older Americans Act Overview – ACL
MIPPA Program – ACL
