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O4A urges delay on Ohio rule for area-agency commercial contracts; Department of Aging defends safeguards

Joint Committee on Agency Rule Review · January 20, 2026
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Summary

The Ohio Association of Area Agencies on Aging told JCAR that proposed OAC 170:3-28 would add burdens and discourage private partnerships; the Department of Aging said CSI found no prong violation and emphasized exemptions and safeguards, and members agreed to continue working with a tentative April 1 implementation date.

Kelsey Birkfeld, chief policy officer of the Ohio Association of Area Agencies on Aging (O4A), told the Joint Committee on Agency Rule Review on Feb. 9 that the Department of Aging’s proposed rule OAC 170:3-28 on commercial relationships would expand bureaucracy, delay partnerships and be more stringent than federal guidance.

“As written, the rule will expand bureaucracy, delay partnerships, and discourage innovation that helps older Ohioans access critical services,” Birkfeld said, urging JCAR and the department to delay the rule’s effective date to allow technical assistance and full implementation planning. She said the Department had offered an April 1 effective date and…

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