The Administration on Community Living is updating the Older Americans Act (OAA) regulations. The Act has been updated a few times, but the regulations have yet to be updated in 35 years! Comments on the rules are due by August 15 and can be submitted online or by mail. (see instructions below)
The Problem
The population of older people experiencing age-related vision problems is growing dramatically. A recent study estimated that 12.5 million Americans over 40 experience blindness or low vision. Of those, 1.02 million were blind (visual acuity of 20/200 or worse), 3.22 million had vision impairment (visual acuity of 20/40 to <20/200), and 8.2 million had uncorrected refractive error. By 2050, the population of people with vision problems is expected to increase by 118%. The greatest increases will be among women, older people, African Americans, and Hispanics (Varma et al., JAMA Ophthalmology, 134(7), pp.802-809).
Further, Older people with blindness and low vision generally have a greater likelihood of reporting other medical conditions (e.g., hearing impairment, diabetes, stroke, heart disease) than older people without vision problems. Overall, the studies indicate that older people with blindness and low vision have poorer health, decreased quality of life, and increased disability, placing them at greater risk for compromised independence and autonomy (VisionServe Alliance (2022). United States’ Page 1 of 2, Older Population and Vision Loss: A Briefing, St. Louis).
Yet the Older Americans Act and its accompanying regulations do not mention vision or hearing impairment.
Action Needed
The VisionServe Alliance Aging and Vision Loss National Coalition (AVLNC) is submitting comments on the regulations and asking others to join by August 15, 2023. Should you wish to reference this document or any part of it in your own response, please refer to Comment Tracking Number ll9-wico-r2lf.
Key Areas to Address
- The Administration has decided to delete the definitions of “frail” and “severe disability.” Therefore, the AVLNC feels it is critically important to add sensory loss to two of the conditions that make up “greatest social need” as spelled out below:
Greatest social need, in this section, means the need caused by noneconomic factors, which include:
(1) Physical and mental disabilities
Recommendation:
Recommendation: Add “sensory loss including deaf, hard of hearing, blind or visually impaired, and deaf-blind” to this category. We would like to see these added
to the final rule. If ACL decides not to include them in the final rule, then we strongly urge ACL to make reference to these in the preamble, notes, or other commentary
accompanying the final rule.
(6) Chronic conditions
Recommendation:
Add “sensory loss including deaf, hard of hearing, blind or visually impaired, and deaf-blind” to the definition of chronic conditions. We would like to see these added to the final rule. If ACL decides not to include them in the final rule, then we strongly urge ACL to make reference to these in the preamble, notes, or other commentary accompanying the final rule.
- Additional Recommendations to the Definitions in the Regulations:
- Add the terms “accessible and accessibility”: The terms accessible and accessibility in connection with delivering services and information to older individuals with sensory loss mean physical and programmatic access, ensuring the full and equal participation of Older Americans.
- Add the term “vision rehabilitation services”: a wide range of professional services that can restore functional independent living after vision changes; such services are provided by a team of specially trained & credentialled professionals, which may include low vision therapists, vision rehabilitation therapists, orientation and mobility specialists, assistive technology instructors and other allied health professionals.
State and Area Plan Recommendations:
The regulations require that the State plan define the greatest economic and social needs. The data from studies referenced earlier indicate that people 65 and older who are blind or have low vision fit both of these categories. They experience social and geographic isolation, live in the southern, southeastern, and southwestern parts of the US, many in poverty, and represent the following races/ethnicities and disabilities:
White non-Hispanic 6.1%
Black non-Hispanic 10.5%
Asian 8.8%
Hispanic 13.9%
American Indian or Alaska Native 14.2%
Thirty-three percent have hearing loss and co-morbidities such as diabetes and heart conditions (VisionServe Alliance (2022). United States’ Page 1 of 2, Older Population and Vision Loss: A Briefing, St. Louis).
Recommendation: Therefore, we recommend that state and area plans specifically address people with sensory disabilities, as stated above.
- Submit comments online at Regulations.gov
- Enter “2023-12829” in the search bar
- Select ACL’s proposed rule; • Click the blue “comment” box at the top left of the page.
- Or by mail to: Administration for Community Living Administration on Aging, Attention: ACL-AA17-P 330 C Street SW Washington, DC 20201
Input needed: Proposed Update to Older Americans Act Regulations | ACL Administration for Community Living
Learn More about the Aging and Vision Loss National Coalition
Aging and Vision Loss National Coalition – VisionServe Alliance