and Lincoln, Nebraska with a population of 100,000+ that are functioning as area agencies on aging.)

As far back as 1972-73, I urged that cities of 100,000 should be designated as area agencies on aging in order to provide the maximum strength to the proposed aging network. Many of the current problems and obstacles to successful development of comprehensive, coordinated service delivery systems could have been avoided.

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One example to reinforce our recommendation is the recognition by HUD and the DOL that cities have the capability, authority, and responsibility to plan and allocate funds for all of their citizens Atlanta, for instance, receives little or no monies from the AAA for elderly services but through its Community Development and CETA funds has allocated several hundred thousand dollars for relevant services to the elderly.

including the elderly. The City of

Designation of cities of at least 250,000 population and more will allow for a significant increase in political power, public accountability, skilled staff, and resource

base of the nation's area agencies on aging and will increase their potential for success.

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We recognize the unique characteristics of each area agency planning

and service area; however, we also believe that certain principles should

serve as guidelines in the operation of these agencies. We offer the following:

1) Well staffed and authoritative State and area agencies
on aging should be the preferred instruments for develop-
ing and implementing a coherent national policy on aging.
This, of course, argues for, and seems to us to mandate,
inclusion of major cities and urban areas as area agencies
on aging. Development and implementation of a national
policy on anything is impossible without their significant

2)

involvement.

The mandate should continue for State and area agencies

to plan and develop comprehensive and coordinated serv-
ice delivery systems as their primary mission,

3) Area Agencies should be responsible for ensuring the
development of critical access services to include at

least information and referral, practical assistance,

outreach, client advocacy and case management, trans

portation, consumer information, and follow-up.

4) Area agencies should be encouraged to use Older Americans

Act and other pooled resources to fill locally identified

priority services gaps. These might include, but not be

limited to, preventive health services, home health ser-. wvices, nutrition services, minor home repair, winteriza

tion services, legal services, older worker employment

services, crime prevention and victim assistance services,

reassurance services and recreational, cultural and educa

tional services.

We propose several modifications in the existing Older Americans Act. As noted earlier, Title I should mandate advocacy by the Administration on Aging and State and area agencies on aging to achieve its goals. Title II should raise the Administration on Aging to the level of an independent agency in HEW, headed by an Assistant Secretary for Aging. We recommend that Title III provide grants for the administration of State and community programs. Title III funds are now utilized primarily for services. Administrative funds for program operation are subsumed in service funds. A specific appropriation and allocation formula for administrative costs and the planning and operation of State and area agencies would greatly simplify matters and potential abuses of Older Americans Act funds would be avoided.

Title IV or new sections of Title II should encompass all programs reserved for direct administration by the Administration on Aging, such as Training, Research and Development, Multidisciplinary Centers of Gerontology, and Model Projects. That part of present Title IV-A funds reserved for

States should be increased to 50% and be made a formula grant program with funds allocated to the States and area agencies for locally identified training needs. State units and area agencies should have review, comment and coordination authority for training grants funded directly from AoA within their jurisdictions. To ensure that the research and model project programs administered by the Administration on Aging are responsive to grass roots needs, we recommend that the aging network, and that means inclusion of the city and urban representatives, be part of the strengthened and more effective peer review process, and that this network have input into the development of AoA's annual research and model project strategy along with review, comment and coordination authority over projects funded within their jurisdiction.

Under Title V, Part A, Sections 506 and 507 (Mortgage Insurance and Annual Interest Grants) should be implemented in order that this additional option of financial support is available at the local level. A provision should be included to authorize limited construction of multi-purpose senior centers when the cost of acquisition, alteration, or renovation of existing facilities is prohibitive or otherwise not feasible. Part B, Section 511, Staffing of Multi-purpose Senior Centers should be reauthorized and amended to provide for staffing and operation costs, but not to replace such costs which were in place prior to Title V funding. The potential of the senior center to serve a broad spectrum of service needs may currently be under-utilized. Amending Title V as proposed will mobilize the senior centers in more effective support of the needed continuum of services for the elderly.

Currently, there is legislation before Congress to provide home delivered meals to the elderly and handicapped. We would recommend that when this legislation is passed that it be made a separate section of Title VII with a separate authorization to be administered by the Administration on Aging and distributed on a formula grant basis to the state and area agencies. The recent GAO study, Home Health The Need for a National Policy to Better Provide For the Elderly, cited meal preparation as a critical service for the moderately and generally impaired elderly. Supportive services of this nature can help other persons with some impairment to remain in their own homes for an extended period. This not only minimizes the cost of service for the older person and the family, but also allows the older person to maintain independent living for as long as it is practical.

Title IX should be renamed "Community Services Roles for Older Americans", with Part A providing community service employment for all older people, with emphasis on the low income elderly. Jurisdiction for this Part should be transferred from the Secretary of Labor to the proposed Assistant Secretary for Aging. The employment section of the Act should be restructured to allow flexibility in determining participant eligibility by using a State-by-State cost of living index, rather than

a national income level. Part B should include those services currently under the Domestic Volunteer Service Act of 1973