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National Resource Center on Nutrition and Aging

Use of Incentives for Older Americans Act Grantees

FOR TITLE III-C SENIOR NUTRITION PROGRAMS

July 2021

Businesses, non-profit organizations, and research entities have long used incentives to raise awareness 

and encourage participation in their programs and services. Incentives such as gift cards, vouchers, 

giveaways, or prize items can motivate an individual to take action when they may not have otherwise. 

In fact, studies have shown that for projects that involve evaluation and/or research activities, even 

small incentives – of as little as $2 in value – can increase participation and survey response rates.1

The purpose of this resource is to provide Older Americans Act (OAA) grantees with a basic 

understanding of the most common types of incentives and how to use them effectively within their 

senior nutrition programs. 

Please note that this guidance is not intended to supersede local and state policies. Although this 

resource is focused on the use of incentives in the senior nutrition program, this information may be 

useful to other ACL grant programs that currently use or are considering the use of incentives.

General Guidance

As a general rule, incentives to participants or volunteers in ACL grant-supported projects or programs

are allowable. Incentives that motivate individuals to participate in grant-supported services, programs, 

healthcare, or other services are allowable if they are within the scope of an approved project. 

Mandatory/Formula grantees (e.g., State Units on Aging, Area Agencies on Aging, and local service 

providers receiving Title III-C 1 and C2 funds) may use incentives if their use meets the intents and 

requirements of the OAA nutrition program which include: reducing hunger, food insecurity and 

malnutrition; promoting socialization; and promoting health and well-being. Additionally, they must 

comply with the current Dietary Guidelines for Americans (DGAs) and the Dietary Reference Intakes

(DRIs). 

Within the aging network, incentives are a useful tool. When used thoughtfully, they can increase the

success of programs, including senior nutrition programs. Senior nutrition programs may use incentives 

to:

• Promote awareness of programs and services within the community.

• Increase participation in programs and services (e.g., congregate meals, physical activity classes, 

nutrition education workshops, caregiver support groups, and evidence-based disease 

prevention and health promotion programs).

• Show appreciation to volunteers and staff.

• Increase participation in research or evaluation projects that show the value of the SUA, AAA, or 

tribal organization’s work.

1 https://bmcmedresmethodol.biomedcentral.com/articles/10.1186/s12874-019-0868-8
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While there is no specific dollar amount limit for an incentive, the amount must remain allocable and 

reasonable. Policies and procedures should be developed to ensure adherence to 45 CFR 75 and other 

applicable laws and regulations. A policy related to the maximum amount of an incentive should be 

included in the policies and procedures developed.

Furthermore, all incentive handling requires policies and procedures which may be very similar to 

policies that nutrition programs should have in place for money handling. A prudent program

administrator would seek legal and/or financial counsel when developing incentive-handling policies and 

procedures. 

Types of Incentives

There are many types of incentives, all with their own strengths and limitations. The following sections

describe three types of incentives most commonly used by senior nutrition programs.

Gift cards and gift certificates

Definition: A card or electronic or paper certificate with a set cash value that can be exchanged for 

goods or services from a specific business. Examples include a $5 gift card for a chain grocery store or a 

$10 gift certificate for a local yoga studio.

Considerations: While gift cards are a popular incentive for many organizations, they can present a 

number of challenges in security and accounting. Gift cards are not recommended for senior nutrition 

programs when they are provided to older adults for the purpose of buying food or other meal items

(e.g., liquid nutrition supplements). Instead of purchasing individual gift cards, senior nutrition programs 

should use funds to purchase groceries directly2, distribute nutritious food boxes, or provide restaurant 

vouchers.

If a program decides to purchase gift cards, extreme caution should be used. Remember senior nutrition 

programs are meal programs. There are other federal programs to help seniors purchase groceries, and 

we do not want to duplicate their work.

In addition, such incentives are not and should not be portrayed as an endorsement by HHS or ACL of 

any company (or its goods, services, or policies) associated or affiliated with the incentive. For example, 

if an incentive is funded by grant funds, a general purpose pre-paid gift card (e.g., one issued by a credit 

card network brand) would more clearly separate the incentive from appearing to be an endorsement 

versus a card to be used only at a specific store or with a specific company. To the extent practicable 

given the proposed incentive, such non-endorsement should be clearly articulated.

Senior nutrition programs that decide to use gift cards should develop policies and procedures for their 

use including how they plan to:

• Determine quantity and frequency of gift card distribution.

• Identify and assess individuals who will receive gift cards.

• Track and document gift card use (i.e., was it used to purchase healthy food as intended, 

redemption rate).

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Food or groceries purchases are allowable if they align with program goals under the OAA, do not involve federal 

staff, and are ancillary to the program. Food purchases should not endorse or favor a specific product, brand, or 

producer.
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• Ensure equitable distribution (e.g., avoid means testing, open to all eligible applicants, avoid 

favoritism).

Note: Cash in itself cannot be used as an incentive. 

Vouchers

Definition: A payment mechanism (card, paper, or electronic notice) for a service. A voucher is a 

document that shows a service has been bought or rendered, and authorizes payment (discounted, free, 

and/or at no additional charge). Examples include a coupon for a 10% discount on any item purchased at 

a local farmers market or a meal voucher for a free meal at a participating restaurant.

Considerations: Previous voucher or voucher-like programs have been used by senior nutrition programs 

for many years. For example, programs frequently participate in distribution of USDA Senior Farmers’

Market Nutrition Program vouchers, which allow low-income older adults to purchase fresh fruits,

vegetables, and other items at their local farmers markets.

Restaurant meal vouchers that allow an individual to receive a meal at a local, participating restaurant

have also been widely used. Allowing seniors to get a meal from a restaurant has been shown to 

improve menu choice, increase availability of congregate dining site opportunities, foster

intergenerational settings, and increase program donations. 

Senior nutrition programs that decide to use vouchers, including for restaurant meal voucher programs, 

should work with their State Unit on Aging (SUA) and/or Area Agencies on Aging (AAAs) to develop 

regulations, policies, procedures, guidance, and technical assistance. Meal voucher programs must meet

all the requirements of the OAA including:

• Meals adhere to the DGAs and the DRIs, and have been reviewed by a dietitian or individual of 

comparable expertise.

• Meals are served to eligible participants.

• Participants are not charged for the meal and are provided the opportunity to make a voluntary 

and confidential contribution or donation.

• Participants receive the opportunity to participate in nutrition education. 

• Participants receive the opportunity to participate in nutrition counseling where available.

• Data for the state program report is collected.

Gift items, giveaways, and prizes

Definition: A tangible item (sometimes also called a “tchotchke” or “swag”) that is given for free in order 

to motivate or encourage an individual to do something. Sometimes the item is given prior to the 

desired action being taken, such as a community event where free pens are offered to visitors regardless 

of whether they sign up for a nutrition class. Other times the item is given afterwards, such as providing 

a t-shirt to participants who complete all sessions of a physical fitness program. Examples include 

keychains, stress balls, water bottles, or other small items.

In some cases, the incentives are given to all participants (e.g., offering giveaways at an Expo event), and 

in other cases incentives may be done via a raffle or drawing. 

Note: Raffles/drawings may not be allowable in some jurisdictions. 
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Considerations: Gift items, giveaways, and prizes may be used in limited circumstances to meet 

programmatic goals. For example, when offering Bingocize® to meal program participants, the program 

requires the awarding of small prizes as a part of the evidence-based curriculum. Similarly, nutrition 

education workshops may provide giveaways, such as measuring cups and nutrition books, that assist 

participants with cooking and meal preparation.

Food and meal purchases using formula or discretionary funds must align with and support the primary 

goals and activities of the program and serve the intended populations. For example, it has long been an 

acceptable practice for nutrition programs to offer meals to volunteers who assist with home delivered 

or congregate meals. Another permissible example: a nutrition program provides a nutrition education 

class on the benefits of antioxidant foods and supports the class theme by offering blueberry smoothies 

to participating seniors. 

Note: The senior nutrition program is for seniors and spouses (volunteers during meals, 

etc.), therefore meals and snacks using formula or discretionary grant monies need to 

benefit these eligible populations. 

Note: There are clear and long-standing policies prohibiting using federal funds to procure 

food for meetings or trainings. This aligns with HHS policies: HHS Policy on the Use of 

Appropriated Funds for Food.

Key Implementation Question

OAA mandatory/formula and discretionary grantees who are considering the use of incentives, 

regardless of type, should take time to review and consider the following questions before 

implementing an incentive program.

• What do you want to accomplish by using incentives?

o Determine how incentives will help you meet your program’s goals, objectives and/or 

intents.

• What type of incentive will you use?

o Find out what your participants are most likely to be motivated by. If you don’t know, 

ask them.

o Consider the cost of each incentive, including the cost of purchasing, distributing, and 

tracking.

• How will you evaluate the use of incentives by your program?

o Establish metrics up front that will help you understand if your incentives are making a 

difference (e.g., improving participation, increased recognition of your programs and 

services, increased support of local restaurants).

• How does the use of incentives meet the requirements of your OAA grant or other funding 

sources?

o Ensure that all costs of your incentive program meet Federal Cost Principles when 

purchased with OAA funds (i.e., costs are reasonable, allowable, and allocable). A policy 

on the maximum cost of an incentive should be included in your program’s policies and 

procedures.
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o Remember you must adhere to all Uniform Administrative Requirements, Cost 

Principles, and Audit Requirements for HHS Awards found at 45 CFR 75 and other 

applicable federal laws and regulations.

o ACL requires the SUA to report information related to the use of OAA funding in its 

annual programmatic reporting (e.g., State Program Report or SPR). Incentive programs 

may be mentioned in the reporting categories according to the programmatic guidance 

provided regarding expenditures. Financial reporting is also required as outlined in the 

grant’s terms and conditions included in the Notice of Award.

o It is important to note that state and local policies, procedures, and requirements may 

be more restrictive than OAA and other federal laws, regulations, and policies, and 

these state and local restrictions must be adhered to. Local senior nutrition programs 

should check with their SUA for more information.

• Will the use of incentives by your program be sustainable?

o Remember that grant expenditures should be developed with sustainability in mind, so

make sure to plan for this wherever possible.

o Consider partnering with businesses, explore the use of state or local funding, and look 

for other creative means to purchase incentives outside of OAA funds.

For more information on incentives, see ACL’s guidance document on Use of Older Americans Act 

Funding for Incentives.