Christina Mills. A Turning Point for California’s Aging Network. Let’s Talk Aging & Disability (Substack), August 12, 2025. Access Article on Substack
A Turning Point for California’s Aging Network
California has been in the midst of a major transformation since the adoption of the Master Plan for Aging (MPA) in 2021. The MPA is a 10-year blueprint to create a California for All Ages by 2030, with bold goals to improve housing, health, caregiving, inclusion, and economic security for older adults and people with disabilities.
Alongside this vision is CA2030, a statewide initiative led by the California Department of Aging to strengthen the structure, funding, and equity of the state’s aging network so it can meet the needs of a rapidly growing and increasingly diverse population. CA 2030 brings together stakeholders from across the state to prepare for the demographic reality that by 2030, one in four Californians will be over the age of 60.
Against this backdrop of ambitious and necessary reform, SB 12499 – an update to the Mello-Granlund Older Californians Act—presents both opportunities and real risks for the very people it is meant to serve. For local Area Agencies on Aging (AAAs), which plan and deliver programs for older adults, these changes could significantly affect how services are provided—and, ultimately, the lives of the older adults who rely on them.
What Are Area Agencies on Aging (AAAs)?
Before diving into SB 1249, it’s important to understand the critical role that Area Agencies on Aging play in California’s aging and disability infrastructure.
AAAs are local government or nonprofit agencies designated by the state to plan, coordinate, and deliver services to older adults, people with disabilities, and caregivers. Every AAA is guided by a local area plan, developed with direct community input and approved by the state.
AAAs deliver essential services such as:
· Home-delivered and congregate meals
· In-home supportive services and case management
· Transportation assistance
· Legal and elder abuse prevention services
· Caregiver support and respite
· Information and referral to long-term services and supports
· Long-Term Care Ombudsman services to protect residents in care facilities
· Health Insurance Counseling and Advocacy Program (HICAP) to help Medicare beneficiaries navigate their benefits
Some AAAs also work in close partnership with their local Independent Living Center (ILC) to thoughtfully carry out Aging and Disability Resource Connection (ADRC) programs—an innovative model that bridges aging and disability services to create a coordinated, no-wrong-door system of support. This is a much-needed navigation program that helps individuals get the services they need, when they need them. This is especially critical given how often we hear people say they need help understanding how the system works and who to turn to for the many different needs that come with aging and living with a disability.
AAAs are local long-term services and supports leaders, uniquely positioned to respond to the diverse needs of California’s communities—urban, rural, coastal, inland, and everything in between. They serve as the frontline of California’s aging network, connecting residents to life-saving and life-enhancing supports that promote independence and dignity.
What SB 1249 Changes
SB 1249 introduces three major policy shifts that will directly affect how AAAs operate:
· Designation of Service Areas – redefining how California’s AAAs are geographically structured.
· Establishment of Statewide Services – aiming to create more consistency in services across all regions.
· Revisions to the Funding Formula – altering how limited resources are distributed among AAAs.
While these reforms aim to increase equity and efficiency, they also risk disrupting the local, community-driven model—potentially altering who delivers critical services, how much of the local area plan can be implemented under the new statewide service requirements, and how funding will be allocated.
Changes to designated service areas could also result in shifts to which subcontractors deliver services locally—meaning that even if a program continues, the organization providing it may change.
For example:
· In a rural county where the AAA partners closely with a local nonprofit to deliver home-delivered meals, a change in service area boundaries could shift that contract to a larger, more distant provider—potentially creating delays or reducing the frequency of meal delivery for isolated older adults.
· In an urban community with a culturally specific caregiver support program shaped by the local area plan, new statewide service requirements could mean that resources are redirected to a uniform model that doesn’t reflect the community’s language needs or caregiving traditions.
The Risk: Undermining Local Voices
Under the Older Americans Act (OAA), AAAs must develop and implement area plans based on input from older adults, caregivers, and community members. These plans are essential to ensuring services meet real, local needs—not just theoretical or statewide averages.
If SB 1249 is implemented without strong protections for local input, the shift toward statewide service models and new funding formulas could undermine this local responsiveness. Uniform programs may not reflect cultural, geographic, or economic differences across California’s diverse regions—and local voices may be left out of the conversation entirely.
It’s also important for those currently receiving services to understand that the organization they rely on today could change. Such transitions in providers can affect trust, continuity, and quality of care—but they could also lead to better programs and services. The reality is, we don’t yet know how these changes will play out, which makes it even more important for individuals to be aware of what may impact them. That’s why it is critical to include service recipients in any discussions that will lead to changes in service delivery. In the disability community, there is a long-standing motto that applies here as well: “Nothing About Us Without Us.” This principle must guide SB 1249’s implementation to ensure that the voices of those most impacted remain at the center of decision-making.
The Context: Growing Demand, Limited Resources
The demographic shift driving both the MPA and CA 2030 is no longer on the horizon—it’s here. By 2030, one in four Californians will be over the age of 60, and we cannot ignore that one in four people is also disabled. This means not only a growing need for services, but also the urgent necessity for those services to be both programmatically and physically accessible. The demand for aging and disability services is increasing rapidly—and yet AAAs are being asked to do more with less. The risk of budget cuts, staffing shortages, and rising costs is real.
The timing of SB 1249 adds pressure to an already strained system. Major structural changes—especially those affecting service areas, funding, and flexibility—require time, resources, and collaboration. Without those, we risk destabilizing the very infrastructure California is counting on to deliver its Master Plan for Aging and CA 2030 goals.
California Association of Area Agencies on Aging (C4A) Role and Recommendations
As the statewide membership association representing 31 of California’s 33 AAAs, C4A has been actively engaged in the SB 1249 implementation process. We’ve recently adopted a set of recommendations, provided them to the California Department of Aging, and are now sharing them with partner and ally organizations that care deeply about strengthening the system that supports older adults. The full list of C4A’s recommendations is provided at the end of this blog post.
C4A’s key recommendations include:
· Ensure service area redesigns preserve community integrity and functionality, rather than fragmenting successful networks.
· Allow flexibility in statewide service models, so local AAAs can tailor services to their communities.
· Revise the funding formula using equity-focused data, such as rural access barriers, intensity of need, and cost of living.
· Protect the local area planning process, ensuring that SB 1249 implementation strengthens—not overrides—community input.
The Path Forward
SB 1249 has the potential to enhance California’s aging network—but only if it is implemented with care, equity, and transparency. We must not lose sight of the foundational principle that has made AAAs effective for more than 50 years: local communities know best how to serve their own people.
California is rapidly aging. The policy choices we make today will determine whether our communities can age independently in the community with support tomorrow. C4A remains committed to ensuring SB 1249 becomes a tool for empowerment—not displacement—and that California’s aging network continues to serve as a national model for equity, responsiveness, and innovation. The choices we make today will determine how well our communities can truly support those who wish to live out their lives in the Golden State.
We encourage individuals and organizations who care about this issue to share their perspectives directly with the California Department of Aging by submitting public comments to CA2030@aging.ca.gov. Your voice can help ensure that SB 1249 is implemented in a way that strengthens—not weakens—the services older adults and people with disabilities depend on.
C4A SB 1249 Implementation Recommendations
STATEWIDE SERVICES
Alignment with ADRC Model
We recommend aligning Information & Assistance (I&A) services with the Aging and Disability Resource Connection (ADRC) model where applicable. Recognizing that not all AAAs currently operate as ADRCs, we encourage CDA to provide funding so that all AAAs can participate in the program.
Optional Statewide Services Approach
Suggest allowing AAAs flexibility or an opt-out option if they cannot feasibly provide a particular statewide service due to lack of provider capacity or failed RFPs.
Service Definitions and Integration
We request that CDA update and modernize service definitions to reflect current best practices and delivery models. This includes clarifying how care management is distinct from or integrated with enhanced I&A. Updated definitions will help ensure consistency and relevance across all PSAs.
Funding Considerations for Statewide Services
We recommend that CDA ensure statewide services identified under SB 1249 are adequately resourced and not implemented as unfunded mandates. PSAs should be supported with sufficient funding and implementation flexibility to account for local capacity, existing contracts, and provider availability.
Performance Measurement Approach
We encourage the use of data-driven performance measurement strategies. When such practices are not available, an age-appropriate and automated performance measurement strategy should be implemented. Simpler, meaningful metrics—such as community impact—should be prioritized over those that are burdensome to track or slow to reflect change (e.g., chronic disease outcomes).
PSA DESIGNATION
Consistency with Federal Regulations
We ask CDA to clarify how SB 1249 implementation aligns with the ACL Final Rule, including regulations related to designation/dedesignation and rural expenditure provisions.
Transition Planning Involvement
We recommend involvement of current AAAs in any designation transitions to promote service continuity and minimize client disruption.
Support During Transitions
We encourage CDA to allow adequate transition time—no less than six months—for impacted AAAs to notify staff, plan financially, and prepare for organizational shifts.
Transition Committee Participation
If AAA transitions are to occur, we would like to see current advisory council members, directors, and consumers represented on a transition committee. Rather than creating a new oversight structure, we recommend the establishment of a general transition committee to provide guidance during designation changes while preserving sustainability and local voice.
Boundary Changes
We recommend that CDA approach boundary changes with intentionality, ensuring alignment with service needs and funding structures. Current AAAs should be given an opportunity to review and provide input before any boundary changes are finalized.
Clarification of Federal Review Requirements
We request clarification from CDA regarding which elements of SB 1249 implementation—such as designation changes, IFF modifications, or statewide services—require review or approval by the federal government. This transparency will support accurate planning and compliance.
Right of First Refusal without Boundary Change
We recommend that CDA clarify how the right of first refusal provision will be applied in cases where an entity seeks AAA designation without requesting a boundary change. This clarity is essential to ensure consistent and equitable implementation of SB 1249 across all PSAs.
Clarity on Local Governance and Structural Realities
Additionally, when boundary changes or transitions affect a Joint Powers Authority (JPA), it is critical that CDA maintain a clear documentation record of being informed about the operational, legal, and financial consequences of dissolving a JPA. The dissolution of a JPA requires full renegotiation among the remaining counties and can lead to significant service and structural disruption. CDA should ensure these scenarios are well understood and planned for, and not treated as incidental or administrative.
INTRASTATE FUNDING FORMULA (IFF)
Key Factors for Consideration
We support CDA’s use of factors such as age 60+, age 75+, 200% of the Federal Poverty Level (FPL), rural geography, general disability, and geographic isolation. We recommend using 200% FPL rather than Medi-Cal eligibility, as it is more inclusive and reflective of actual need.
Hold Harmless Provision
Suggest including a hold harmless clause to prevent PSAs from experiencing dramatic funding reductions. This could help maintain service stability while adjustments are made over time.
Three-Year Rolling Allocation
We support a three-year rolling allocation model (rather than a three-year expenditure average) to improve predictability and support long-term planning. We understand this may require alignment with CDA’s existing fiscal practices.
Per-County Administrative Allocations
We encourage CDA to provide additional administrative funding for multi-county AAAs that manage services across multiple counties. This would account for operational complexity and promote equity without prioritizing structural form over function.
Baseline Funding
We support CDA’s proposal to establish a $250,000 per-PSA baseline allocation and appreciate its efforts to ensure minimum operational capacity for all regions.
Transparency in Category Selection
We ask that CDA clearly communicate how IFF categories are selected and how those selections support statewide equity.
Funding Flexibility
We emphasize the need for flexible funding across all PSAs, especially in geographically large or partially covered areas. This flexibility should not be limited to large counties but should apply universally.
Local Flexibility to Meet Area Plan Needs
We recommend that CDA support maximum local flexibility to respond to the unique needs identified in each PSA’s Area Plan, rather than setting rigid minimum allocations that may not reflect local priorities or service availability.
Transparency on Methodology
We recommend that CDA provide timely and accessible guidance on how service expectations are determined and how PSAs can meet them. Clear and proactive communication will ensure PSAs are prepared to comply with changing standards.
A Turning Point for California’s Aging Network
