These August 22, 2016 comments, signed by the ACLU, respond to the Administration for Community Living’s (ACL) request for comments on its proposed guidance regarding the obligation of State Units on Aging to target resources to older adult populations that have the “greatest economic and social need.” The comments commend the proposal for expressly recognizing that sexual orientation and gender identity “can limit the degree to which older adults experience full inclusion in society and are able to access available services and supports.” However, the comments express concern that the proposal does not unambiguously require the States to assess the need of LGBT older adults. The comments urge ACL to modify the proposed guidance to expressly require States to describe the actions taken to assess the needs of LGBT older individuals.