concurring in part and dissenting in part.
I agree that Lake County Equal Opportunities Council (LCEOC) is a political subdivision for purposes of the Indiana Tort Claims Act and that tort claims notice to LCEOC was inadequate. However, I believe that the nature of the relationship between LCEOC and Greater Hammond Community Services (GHCS) is such that GHCS is also entitled to Tort Claims Act immunity.
Unlike the parent and subsidiary corporations in McQuade v. Draw Tite, Inc., 659 N.E.2d 1016 (Ind.1995), LCEOC and GHCS are integrated, not-for-profit entities as a result of federal laws and regulations that encouraged local community control of service provision and decision-making regarding federal social service grant funds.6 In particular, LCEOC serves as the Area Agency on Aging under *211the federal Older Americans Act. The Older Americans Act requires a comprehensive, coordinated social services delivery system that includes an identified service focal point in target communities. 42 U.S.C. § 3026(a)(3)(A) (“Each area agency on aging ... shall ... prepare and develop an area plan [that] ... designate^], where feasible, a focal point for comprehensive service delivery in each community.... ”).
The record shows that LCEOC provides services to the poor and elderly in six counties of Northwest Indiana through an organized network of service providers. The six-county area includes both highly industrialized urban areas and sparsely populated rural communities. Because of the diversity of the area and the requirements of the Older Americans Act, LCEOC divided the region into ten subareas and designated in each area a nonprofit organization (including GHCS) to provide most of the services contained in its six basic programs. There is a single funding stream from LCEOC to its ten service providers; the services GHCS provides are determined solely by LCEOC; GHCS budgets and budget amendments are submitted to and approved by LCEOC; GHCS must obtain prior written approval of LCEOC prior to entering into any subcontract and all GHCS subcontractors must comply with the provisions of the agreement between LCEOC and GHCS; and LCEOC has full access to and the right to examine or audit all GHCS papers, documents, books, and records.
The record presents a picture of LCEOC serving as the headquarters or home office and GHCS and its sister organizations actually delivering the early childhood, nutrition, transportation, and other social services. I find this administrative structure highly analogous to that of a civil city where the mayor’s office is “headquarters” but the actual municipal services are delivered by the police department, fire department, street department, etc. Just as those departments are covered by a city’s Tort Claims Act immunity, so should GHCS and its sister organizations be covered by LCEOC’s.
Because I believe that GHCS is a governmental entity for purposes of the Tort Claims Act, I would hold that Greer’s claim against GHCS is also barred for failure to comply with the Tort Claims Act notice requirements.
. See, e.g., Economic Opportunity Act Amendments of 1967, Pub.L. No. 90-222, § 210(a), 81 Slat. 672, 691 (1967) (repealed 1981 and recodified at 42 U.S.C. § 9901-9912 (2000)) (defining community action agency as a “State or political subdivision of a State ... or a combination of such political subdivisions (amending the Economic Opportunity Act of 1964); id. § 211(c), 81 Stat. at 693 (repealed 1981 and recodified at 42 U.S.C. § 9901-9912 (2000)) (“Where a community action agency places responsibility for major policy determinations with respect to the character, funding, extent and administration of and budgeting for programs to be carried on in a particular geographic area within the community in a subsidiary board, council, or similar agency, such board, council, or agency shall be broadly representative of such area, subject to regulations of the director which assure adequate opportunity for membership.... Each community action agency shall be encouraged to make use of neighborhood-based organizations composed of residents of the area, or members of the groups served to assist such agency in the planning, conduct, and evaluation of components of the community action program.'') (amending same).