Guide to SUA Sodium Policies and Guidance

Table of Contents

Purpose.................................................................................................................................... 2

Toolkit Data Collection ......................................................................................................... 2

OAA Nutrition Requirement Flexibilities .............................................................................1

Sodium Reduction Efforts in the Food Supply ....................................................................1

State Unit on Aging Policies and Procedures on Sodium Requirements ......................1

Common Themes in State Policies ......................................................................................1

Section I: Sodium Related Policy Examples....................................................................... 3

California........................................................................................................................................................................3

Colorado.........................................................................................................................................................................4

Georgia............................................................................................................................................................................4

Iowa....................................................................................................................................................................................4

New Jersey ....................................................................................................................................................................5

Maryland.........................................................................................................................................................................5

Texas...................................................................................................................................................................................7

Vermont............................................................................................................................................................................7

Virginia..............................................................................................................................................................................7

Wisconsin.......................................................................................................................................................................8

Section II: Sodium Related Information for Menu Patterns ............................................ 9

Texas..................................................................................................................................................................................9

Vermont...........................................................................................................................................................................9

Wisconsin......................................................................................................................................................................10

Additional Resources............................................................................................................11
Purpose

This toolkit provides a sample of state unit on aging (SUA) policies related to sodium 

requirements, as well as regulations related to demonstrating compliance through 

nutrient analysis or meal patterns. The toolkit is designed to help senior nutrition 

programs develop or refine policies and guidance that address the Older American 

Act (OAA) Title III-C nutrient standards related to sodium. The toolkit also includes 

key information pertaining to the Food and Drug Administration’s (FDA) “Guidance 

for Industry: Voluntary Sodium Reduction Goals.”

Toolkit Data Collection 

From March 2022 to October 2022, the Administration for Community Living (ACL) 

and the FDA collaborated to consider incorporating aspects of the FDA’s “Guidance 

for Industry: Voluntary Sodium Reduction Goals” into SUA, area agency on aging 

(AAA), and local service provider policies and procedures. As part of the initiative, a 

focus group was created between FDA, ACL, SUA dietitians, and the Nutrition and 

Aging Resource Center. The group reviewed guidance and identified key information 

that may be included in policies and contracts. The needs of the aging network were

evaluated related to the FDA’s Voluntary Sodium Reduction Goals. During this 

process, state policies were collected for review. Tufts University dietetic intern Alicia 

Lee reviewed SUA sodium-related policies and guidance. The review process took 

geographic differences into account, collecting policies from states across the 

country. SUAs and AAAs can use the toolkit to educate about the FDA’s Voluntary 

Sodium Reduction Goals and to develop or refine policies and practices that assist 

local nutrition service providers in preparing meals that are consistent with OAA 

nutrition requirements and support the FDA initiative.

Thank you to the FDA for your partnership in this project.

Thank you to SUA nutrition program staff from the following states for assisting us 

with this project:

● California

● Colorado

● Georgia

● Iowa

● New Jersey

● Maryland

● Texas

● Vermont

● Virginia

● Wisconsin
OAA Nutrition Requirement Flexibilities 

Section 339 of the OAA provides SUAs the flexibility to establish regulations on how 

Title III-C meals comply with the Dietary Reference Intakes (DRIs) and the Dietary 

Guidelines for Americans (DGAs). The sodium DRI for adults is ≤ 2,300 mg daily. OAA 

funded meals must provide: 

● A minimum of 33.3% of the DRIs for one meal per day.

● A minimum of 66.6% of the DRIs for two meals per day.

● A minimum of 100% of the DRIs for three meals per day.

Nutrition Requirements of the Older Americans Act provides further information on 

DRI requirements.

Sodium Reduction Efforts in the Food Supply 

Due to the prevalence of sodium in the food supply, the DGAs encourage a multilevel approach to help reduce sodium intake. In 2021, the FDA released “Guidance for 

Industry: Voluntary Sodium Reduction Goals.” This guidance encourages food 

manufacturers and food service operators to reduce sodium levels in the overall 

food supply by 2024. These efforts will support OAA Title III-C nutrition programs in 

meeting sodium requirements on menus.

State Unit on Aging Policies and Procedures on Sodium 

Requirements 

This compilation of policies and procedures shows how SUAs use inherent OAA 

federal flexibilities regarding sodium content of meals and menus to meet the needs 

in their state. Maximum sodium levels ranged between 760 mg and 1,200 mg per 

meal. Some SUA policies require a specific sodium target value, while others provide 

a target range . The SUAs permitting nutrient averaging used weekly or monthly 

ranges. 

Common Themes in State Policies

● Setting specific target values or acceptable ranges of sodium content per 

meal based on a weekly or monthly average.

● Providing tips on lowering sodium in menus when purchasing foods or 

preparing meals.
● Noting canned foods may be high in sodium. Providing tips on how to reduce 

sodium content for canned foods. 

● Outlining strategies to reduce sodium by food group.

● Setting requirements to identify high-sodium meals on their menus (e.g., using 

an image such as a heart for low-sodium or saltshaker for high-sodium 

items). 

● Providing low-sodium options alongside high-sodium items on menus to offer

consumers choice in meal options.

● Indicating the use of certain low-sodium seasonings on their menu (e.g., 

herbal seasonings, etc.). 

● Requiring a specific menu pattern to ensure nutritional adequacy of meals 

when nutrient analysis is not available. More information is available in the 

DGA Toolkit. 

● Listing examples of high-sodium foods with sodium content (e.g., sodium 

levels in protein foods) to help meet sodium targets when nutrient analysis is 

not utilized. 
Section I: Sodium Related Policy Examples

California

Although the established adequate intake (AI) for sodium is 1,500 mg per day, the 

Chronic Disease Risk Reduction (CDRR) recommendation is to reduce sodium intakes 

if above 2,300 mg per day. This recommendation is the basis for the Older 

Californian’s Nutrition Program target of 760 mg sodium per meal.

When planning menus, the target for sodium content is less than or equal to 760 mg 

sodium per meal, averaged over the number of meals provided in one week.

Meals containing equal to or greater than 1,000 mg of sodium should be avoided. 

High sodium meals, containing equal or greater than 1,000 mg, must not exceed 

more than one meal per week. They also must be identified on the nutrient analysis 

and on the participant menu as containing greater than 1,000 mg sodium. 

Meal analysis is conducted using either nutrient analysis or a meal component 

pattern and is approved by a Registered Dietitian (RD) to ensure compliance with 

DGAs and DRIs. The table below is adapted from “Older Californians Nutrition 

Program Menu Guidance,” Figure 2.

Table 1: Reducing the Sodium Content in Meals

Instead of: Try:

Flavoring foods with salt, high sodium 

seasonings, soy sauce

Onions, garlic, fresh or dried herbs, spices, vinegars, 

citrus juices, diluted soy sauce

High sodium soup bases and canned foods Low sodium, reduced sodium* or no salt added 

soup bases and canned goods

High sodium canned foods (vegetables, 

legumes)

Drain and rinse canned foods like vegetables and 

legumes with water

Canned vegetables with salt, frozen 

vegetables with sauce

Fresh, canned without salt, or frozen vegetables 

without sauce

Processed meats, poultry, and seafood (deli 

meat, sausage, pepperoni, sardines)

Fresh meat, poultry, and seafood 

Instant products like flavored rice and readymade pastaRegular rice and pasta with low sodium seasonings 

and sauces

High sodium condiments like ketchup, 

mustard, pickles, olives, salad dressings

Low or reduced sodium* condiments and salad 

dressings

Purchasing products without comparing 

nutrition labels

Reading the Nutrition Facts labels to compare 

products and choose lower sodium foods

✱ Foods labeled “reduced sodium” may still be high in sodium. Read the Nutrition Facts label to 

determine sodium content. 
Colorado

The sodium limit is set at <1,200 mg per meal for all meal types, including shelfstable, congregate, and home-delivered. The total sodium content of the meal is 

required to be provided and/or listed on the menus for clients. Some programs list 

the sodium amount per menu item, while others simply provide the total.

Nutritional adequacy of menus is documented through computer analysis and 

approved by the program RD, dietetic technician, registered, or nutritionist.

Source: Colorado Rule Manual Volume 10

Georgia

Nutrient content of meals is determined by the application of the DRIs and the DGAs.

To allow for regional preferences, the nutrient content of meals must:

● The nutrition analysis will show these targets are met over an average of one 

menu cycle (minimum of twenty days), within +/-10%. 

● Target for sodium: 766 mg

Source: Georgia Division of Aging Nutrition Service Program Guidelines & 

Requirements 2019. For assistance accessing the document, contact 

https://aging.georgia.gov or (404) 657-5258.

Iowa

Iowa issued Operational Guidance in 2016 which provided information on the DGA 

recommendation to reduce daily sodium intake to 2,300 mg and established the 

target value for sodium at less than 1,000 mg per meal based on a weekly average. 

Other guidance includes:

● The DGA recommendation for persons who have pre-hypertension, 

hypertension, diabetes, or chronic kidney disease is to reduce sodium to 1,500 

mg.

● Potassium: A potassium rich diet can blunt the effect of sodium on blood 

pressure.

● Use a salt-shaker icon to identify a high sodium meal (more than 800 mg) on 

the menu. High sodium meals are to be limited to twice a month.

● Nutrition Programs should establish purchasing policies and procedures for 

healthful foods that incorporate the sodium recommendations of the DGAs. 
Sodium reduction in ethnic meals: Iowa Nutrition Programs are encouraged to 

provide culturally appropriate meals for an ethnically diverse population. Programs 

that provide culturally appropriate meals that may be higher in sodium are to place 

a statement on each menu. 

● Explore ways to reduce sodium content of meals. 

● Use low sodium soy sauce or dilute soy sauce with water to reduce sodium 

levels.

● Provide low sodium or dilute soy sauce as a condiment at meals, instead of 

adding to meals during preparation. 

● Encourage vendors to provide low sodium alternatives at a reasonable cost. 

● Place potassium rich foods on the menu consistently. 

● Provide nutrition education on the health impacts of high sodium intake on 

older adults.

Source: 2016 Iowa Aging Operational Guidance

New Jersey

Compliance Range (weekly averages): 900 mg. Limit processed smoked or cured 

meats to no more than twice per month. (smoked ham, sausage, cold cuts, hot dogs, 

etc.)

Source: 2018 New Jersey Menu Guidelines. For assistance accessing the document, 

contact https://www.state.nj.us/humanservices/doas/contact/

Maryland

The DGAs recommend moderate sodium (e.g., salt) intake, and therefore the 

Maryland Department of Aging Menu Policies have established a maximum sodium 

content per meal (1,400 mg), averaged over a month. To assist SNPs in determining if 

food products meet the sodium limits, please refer to Table 2, below. 

Table 2: Food and Drug Administration Regulations for Low Sodium Labeling Terminology

What the Label Says What the Term Means

Sodium Free Less than 5 mg of sodium per serving

Very Low Sodium 35 mg of sodium or less per serving

Low Sodium 140 mg of sodium or less per serving

Reduced Sodium At least 25% less sodium than the regular product

Light in Sodium or Lightly Salted At least 50% less sodium than the regular product

No Salt Added or Unsalted No salt is added during processing, but these products may not 

be salt/sodium free

Source: Sodium in Your Diet, FDA
Typically, the entrée contributes the majority of sodium in a meal and can also be 

the most variable in sodium content, depending on the protein food selected as well 

as any sauces, gravies, and other seasonings which may be added.

The sodium in the Protein Food should not exceed 1,000 mg per serving. High sodium 

foods (e.g., processed cheese, hot dogs, sausage, bacon, ham, cold cuts, etc.) are 

not recommended, unless replaced with a low-sodium version, more than:

● Twice per week for 1 meal per day

● Four times per week for 2 meals per day

● Six times per week for 3 meals per day

Use of canned vegetables is discouraged due to added sodium in these products.

Source: 2017 Maryland Senior Nutrition Meal Policies

Table 3: Sodium and Saturated Fat Content of Select Protein Foods

Protein Food Portion for 7 

grams protein or 

1 oz serving

Sodium in 1 oz 

(mg)

Sodium in 3 oz 

serving (mg)

Beans, baked 1⁄2 cup 576 1,728

Beans, canned 1⁄2 cup 200 600

Beef, fresh 1 oz 30 90

Cheese, processed 1 1⁄2 oz 530 1,350

Cheese, natural 1 1⁄2 oz 264 792

Cheese, cottage 1⁄4 cup 229 687

Egg 1 140 420

Fish, breaded, 

baked

1 oz 150 450

Fish, canned 1 oz 116 348

Fish, frozen 1 oz 111 333

Hog Dogs, beef 1 oz 319 957

Nuts, unsalted 1/3 cup 12 36

Peanut butter 2 Tablespoons 147 440

Pork, fresh 1 oz 62 186

Pork, ham 1 oz 340 1,020

Pork, sausage 1 oz 210 630

Poultry, baked 1 oz 90 270

Poultry, deli meat 1 oz 288 864

Poultry salad 1 oz 85 340

Tofu, firm 1⁄4 cup 9 27

Source: 2017 Maryland Senior Nutrition Meal Policies, Appendix D Sodium and 

Saturated Fat Content of Select Foods compiled from the 2015 - 2020 DGA.
Texas

The nutrition program guidelines align with the most recent Dietary Guidelines for 

Americans (DGAs) and Dietary Reference Intakes (DRIs) to support more fruit, 

vegetable, and whole grains consumption, reduce the sodium content of the meals 

substantially over time, and control fat and calorie levels. The established guidelines 

specifically address prevalent disease conditions for the aging population.

The compliance range for one meal is 1,200 mg or less of sodium. 

The DRI target value per meal is 800 mg to 1,000 mg of sodium. 

Source: Texas Area Agency on Aging Policies and Procedures Manual, Chapter F, Title 

II-C, Nutrition Services

Vermont

High sodium meals are to be limited to no more than once a week. When a high 

sodium meal is served, a low sodium option must be available. Meals that contain 

over 1,200 mg must be noted as a high sodium meal on the menu. Any single item 

with greater than 500 mg of sodium must also be marked on the menu. A meal 

should contain between 750 mg – 1,200 mg of sodium.

Menus may be reviewed and approved using either a meal pattern method or 

nutrition analysis method. 

Source: 2019 Vermont Older Americans Act Policy and Operations Manual

Virginia

Sodium target values are based on a per meal basis.

● Target value per meal: 800 mg 

● Compliance Range: <1,200 mg (acceptable maximum value)

Canned vegetables are usually high in sodium; low sodium varieties are available 

but may be higher in cost. If it is necessary to use canned vegetables, they may be 

rinsed thoroughly to remove up to 40% of the sodium*. However, rinsing may also 

remove other nutrients. 

Source: 2016 Virginia Menu Planning Guidelines

*Source: How to Reduce Sodium | American Heart Association
Wisconsin

Sodium standards are set to an upper limit average of 1,200 mg for one meal daily, 

2,400 mg for two meals, or 3,600 for 3 meals per day.

Weekly average of nutrient content of meals may be used to evaluate compliance 

with nutrient standards. Nutrient analysis and meal patterns are allowed with 

nutrient analysis of menus being recommended. See Food Service Chapters E 

through H of the Wisconsin Aging Policy Manual for more information. 

Source: 2021 Wisconsin Aging Policy Manual Nutrition Program Operations, P-03062-

38
Section II: Sodium Related Information for Menu Patterns

Below are examples of state policy guidance to address sodium content using meal 

patterns.

Texas

The Texas Model for Menu Planning chart must be used to identify the types and 

amounts of foods recommended to meet specific nutritional requirements when 

Computer Analysis of Nutrients software is not used.

Limit foods high in sodium and include foods high in potassium, vitamin C, and fiber 

daily. 

● Meat Limit: 

o Processed, smoked, cured meat, or a high sodium content meat or 

meat alternate to no more than one three-ounce serving per week.

▪ Examples: cold cuts, ham, hot dogs, canned tuna or salmon and 

sausage.

● Cheese to no more than three ounces per week because of high sodium 

content.

● Vegetables Limit: 

o Canned vegetables with sodium or salt to one serving per meal.

o Canned soups or bouillon with sodium.

● Grains: Limit: 

o Quick breads such as cornbread, biscuits, and muffins to once per week 

due to a higher fat and sodium content.

● Other Foods: Limit: 

o Foods high in sodium.

▪ Examples: canned soup or bouillon, prepared cooking sauces, 

pickles, olives, processed foods, salted foods or soy sauce.

Sources: Texas Area Agency on Aging Policies and Procedures Manual, Chapter F, 

Title II-C, Nutrition Services; Appendix IV, Texas Model for Menu Planning

Vermont

High sodium meals are to be limited to no more than once a week. When a high 

sodium meal is served a low sodium option must be available. Meals that contain 

over - 1,200 mg must be noted as a high sodium meal on the menu. Any single item 

with greater than 500 mg of sodium must also be marked on the menu. A meal 
should contain a between 750 mg – 1,200 mg of sodium. This requirement is waived 

for emergency meals, although inclusion of low sodium items is encouraged. 

Source: 2019 Vermont Older Americans Act Policy and Operations Manual, page 35

Wisconsin

The meal pattern is used as a planning tool to ensure food plate coverage and that 

the required types and amounts of foods are offered. The following meal patterns 

provide specific meal components and serving sizes based on the MyPlate food 

guidance system; however, it does not assure that when meal components are 

combined, the meal pattern will meet 1/3 the DRI and the current dietary guidelines. 

Guidelines for offering grains:

● Reduce sodium by: 

o Choosing not to add salt to cooking water for pasta or rice.

o Choosing lower sodium sandwich breads, rolls, bagels, and buns.

Guidelines for offering vegetables:

● Reduce sodium by: 

o Choosing not to add salt to cooking water for vegetables. 

o Using canned vegetables less often and fresh or frozen vegetables 

without added sauce or sodium more often. 

o Preparing potatoes without added salt.

o Serving lower sodium vegetable juice. 

o Choosing lower sodium canned tomato products.

Guidelines for offering protein foods:

● Reduce sodium by:

o Lessening salt in recipes 

o Make soups or stews from scratch without purchased soup base, use 

reduced sodium soup base for soups and stews, or dilute high sodium 

soup base. 

o Choosing protein foods which are relatively low in sodium. 

o Limit processed meats such as ham, bacon, sausage, frankfurters, and 

luncheon or deli meats that typically have added sodium. 

o Fresh chicken, turkey, and pork that have been enhanced with a salt 

containing solution also have added sodium. Check the product label 

for statements such as “self-basting” or “contains up to __% of __”, 
which mean that a sodium-containing solution has been added to the 

product. 

o Choose unsalted nuts and seeds. 

o Prepare meat, poultry, and fish without breading.

o Choose lower sodium cheeses.

Guidelines for offering fats and oils: 

● Reduce sodium by: 

o Making salad dressings from scratch without added salt. 

o Use “low sodium” or “reduced sodium” salad dressing. 

o Make sauces from scratch without purchased soup base or use 

reduced sodium soup base for sauces. 

o Use olive oil, vegetable oil, and unsalted butter in cooking rather than 

salted butter. 

o Serve salad dressing on the side.

Source: 2021 Wisconsin Aging Policy Manual Nutrition Program Operations, P-03062-

38

Additional Resources

Nutrition Requirements of the OAA: Reviews the basic requirements and provides 

information on flexibilities and responsibilities of the OAA. 

DGA Toolkit: Provides information on general guidelines for nutrient analysis and 

meal patterns. 

Dietary Guidelines and Dietary Reference Intakes Network Discussion (YouTube) and 

takeaway sheet.