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sharing, it specifically prohibits it to determine eligibility for certain Title III services for which voluntary contributions are allowed. These include essential services, such as: legal assistance or other consumer protection services, benefits counseling; ombudsman, abuse prevention, congregate and home delivered meals; and any services delivered through tribal organizations.14 It is in the discussion of voluntary contributions that the Act itself now addresses means testing. Voluntary contributions are only allowed provided there is no coercion 15 or means test used.l6 Further, if a provider accepts voluntary contributions for legal services, these contributions must be used to augment legal services, and should not be used for other services or purposes.17 Asking About Financial Circumstances as Part of Service Delivery Legal assistance providers often include questions about income and assets as part of their intake process so that they can appropriately address a client's legal circumstances or identify benefits for which they could qualify. So long as this information is not used up front to deny or limit services to the individual, this is appropriate under the OAA, as OAA regulations specifically state: "A legal assistance provider may ask about a person's financial circumstances as part of the process of providing legal advice, counseling, and representation, or for the purpose of identifying additional resources and benefits for which an older person may be eligible."" Many legal problems cannot be resolved without understanding the client's income and assets. Further, many programs ask these questions as part of a "public benefits check-up" with clients to identify whether the client is eligible for SNAP, Supplemental Security Income (SSI), public housing, Medicaid, and Medicare Savings Programs." Guiding Principles for Targeting Services Without Means Testing As clarified in the OAA, the goal for all entities in the aging network should be to provide legal services to those individuals with the greatest social and economic need. However, because of the natural tension between targeting services to those with greatest need while adhering to the means testing prohibition, legal services programs can effectively target by following these principles: 1. Identify the target population; 2. Establish the legal issue/case priority; 3. Provide legal services with cultural sensitivity and effective communications; 4. Develop strategic outreach and education materials; 5. Coordinate with other entities in the legal services and aging network; and 6. Make legal services accessible and user friendly. More information on each of these components is below. 1. Identify the target population Providers have several tools available to help ensure clients in the greatest need of legal services are targeted for assistance. First, providers, Legal Assistance Developers (LADS), and area agencies on aging (AAAs) can 14 42 U.S.C. §3030c -2(a)(2) and (3) 2016. 15 42 U.S.C. §3030c -2(b)(1), (2016). 16 42 U.S.C. §3030c -2(b)(3) (2016). 17 Specifically, the OAA states: "The area agency on aging shall ensure that each service provider will... use all collected contributions to expand the service for which the contributions were given and to supplement (not supplant) funds received under this chapter). 42 U.S.C. §3030c-2(b)(4)(E)(2016). 18 45 C.F.R. §1321.71(e)(2012). 19 The National Council on Aging's (NCOA) website, located at betiefitscheck" or,, provides an easy way to identify benefits for clients. Issue Brief 4