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Using Groceries and Other Nutritional Services to MeettheNeeds of 

Senior Nutrition Program Participants

Revised 10/27/2020

The Senior Nutrition Program (SNP) of the Older Americans Act (OAA) is a unique federal 

program for older adults that offers nutritious meals, social opportunities of friendship, 

companionship, volunteerism, civic engagement, health promotion/disease prevention 

activities, and access to community services that allow older adults to remain healthy and 

independent at home in their community. 

Senior Nutrition Program (SNP) Purpose

OAA Title III-C Section 330 states the purposes of the SNP, which are to promote nutritional 

status, general health and well-being of older individuals. The services are intended to:

• Reduce hunger, malnutrition, and food insecurity,

• Promote socialization, and

• Delay the onset of adverse health conditions through access to nutrition and health 

promotion/disease prevention services.1

1 OAA, Section 330

OAA Sections 305, 601 and 614 respectively place responsibility to administer OAA services on 

the State Unit on Aging (SUA) or the Tribal Organization. The SUA is to determine policies and 

procedures for SNP implementation2

2 OAA, Section 305(a)(1)(C)

. The Tribal Organization is to deliver nutrition services to 

older Indians that are “substantially in compliance with the provisions of part C of title III..”3

3 OAA, Section 601, 614(a)(8)

Congress places significant emphasis in the OAA on the provision of meals to older adults. 

Sections 331 and 336 state specifically that meals are the primary nutrition service. Section 339 

details the nutrient content of the meals. Title VI Sections 601 and 614 authorize the provision 

of nutrition services for Native Americans that are comparable to those provided by Title III. 

However, the SNP is not limited to meals or to food alone. To meet the nutrition needs of a 

diverse community of older adults and to assist older adults to remain healthy in the 

community, OAA Sections 331 and 336 allow for “. . . nutrition education, nutrition counseling, 

and other nutrition services, as appropriate, based on the needs of meal recipients.” 4

4 OAA Sections 331(3) and 336(2)

 As a 

result, limited other nutrition services are available. Other nutrition services can be things like 

liquid nutritional supplements (e.g., Ensure, Boost, etc.), weighed utensils, or groceries.
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As stated OAA Title III-C Section 330 and supported by numerous studies, the SNP is more than 

food provision. The Administration for Community Living (ACL), Administration on Aging’s (AoA)

nutrition evaluation reports 5

5 Mathematica Policy Research. 2015. Process Evaluation of Older Americans Act Title III-C Nutrition Services 

Program.

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6 Mathematica Policy Research. 2017. Evaluation of the Effect of the Older Americans Act Title III-C Nutrition 

Services Program on Participants’ Food Security, Socialization, and Diet Quality.

7

7 Mathematica Policy Research. 2018. Evaluation of the Effect of the Older Americans Act Title III-C Nutrition 

Services Program on Participants’ Health Care Utilization

and budget justifications

. 

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8 Department of Health and Human Services Fiscal Year 2021 Administration for Community Living Justification of 

Estimates for Appropriations Committees.

demonstrate how the congregate and 

home delivered nutrition services programs, including meals, meet the OAA’s intent of 

addressing nutrition, health and socialization needs. In addition, SUA/Area Agency on Aging 

(AAA)/Local Service Provider (LSP) and Tribal Organization policies and procedures should 

clearly reflect how the purposes of the SNP will be implemented and monitored to assure 

adherence to the OAA requirements.

Allowable Title III-C Other Nutrition Services

As indicated in the section above, in addition to meals, other nutritional services may be 

provided to meal recipients. In general, limited resources often result in SNP network 

organizations being able to provide few, if any other nutritional services. This is important to 

consider, as at the time of publication, funding levels have expanded through September 30, 

2021 (related to a national pandemic), but these increases are unlikely to continue into future

years. Because of the limited funding, coupled with existing plus new increases in food 

insecurity, malnutrition and hunger, and the fact that SNP meals alone may not meet all needs, 

Congress allows flexibility based on the needs of meal recipients. 

The SUA/AAA/LSP and/or Tribal Organization should establish policies and procedures to 

determine availability and eligibility of Title III-C and Title VI nutrition services as well as access 

to other nutrition services in alignment with the OAA intent (see SNP Purpose section). 

Delivering high quality food and nutrition services is a paramount concern as our network has a 

newly expanded base of participants and a growing number of eligible persons, based on 

population estimates. The network should utilize tools and develop relationships with key 

stakeholders to meet the growing and changing needs of their clientele.

When Groceries Might be Appropriate

The following examples list situations when, under usual OAA authority, offering groceries may 

be appropriate to purchase and provide as Title III-C other nutrition service:

1. Groceries might be offered to an individual who has severe dietary restrictions and 

cannot consume the congregate or home delivered prepared meals, but who 
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participates in OAA-funded nutrition education programs or is otherwise eligible for 

OAA services. 

2. Liquid nutrition supplements (eg, Ensure, Boost, etc.) may be offered in addition to a 

meal for a person with, or at high risk for, malnutrition, in order to enhance the protein, 

vitamins and minerals provided by the SNP meal.

3. Specialized one-on-one or group nutrition education might be offered to caregivers to 

assist them in meeting the specialized nutrition needs of individuals with dementia who 

may no longer feed themselves or who may suffer additional health complications. 

4. Addressing local, state or national emergencies – when meals may not be available, 

staffing shortages, seniors capable of cooking, groceries may be a viable, but limited, 

option.

Please note: Items such as groceries or liquid nutrition supplements provided as other 

nutrition services are not counted as a meal and cannot be counted toward meal counts or 

NSIP meals for reporting purposes.

Addressing Food Insecurity

Some older adults may need more than one meal daily to meet food basic needs. The OAA does 

not prohibit SNP ability to serve multiple meals per day, or providing combinations of frozen, 

shelf-stable and fresh foods, and/or sending more than one meal for a day (eg, breakfast and 

lunch). Prioritizing systems and food/nutrition screening tools can assist in determining which 

clients require higher levels or types of meals and related nutrition services. Please see the 

Senior Nutrition Program Meal Services Elements for Sustainability: Guide to Prioritizing Clients

for further information.

Furthermore, in alignment with the basic purposes of the SNP, one of which is to reduce food 

insecurity, SNPs should consider appropriate referrals, application assistance and/or 

partnerships to ensure prudent use of limited OAA funds. Several federal programs target food 

insecurity by providing food or supplemental assistance.9

9 Federal Nutrition Programs and Emergency Food Referral Chart for Older Adults. Food Research and Action 

Center. 2021.

 Other resources including SNAP 

benefits, Food Distribution on Indian Reservations or food banks/pantries can be leveraged to 

meet food needs. SUAs/AAAs/LSPs or Tribal Organizations can develop and/or continue new 

partnerships that provide access to groceries/shopping assistance via referrals to food pantries, 

hospital food prescriptions, Senior Farmers Market Programs, faith-based organizations etc.

Other federal programs such as United States Department of Agriculture (USDA) programs 

[such as the Supplemental Food Assistance Program (SNAP)or the Commodity Supplemental 

Food Program (CSFP)] offer food assistance designed supplement the diets of older adults only 

and are not designed to help decrease social isolation or keep older adults independent at 

home. As a result, the SNP addresses social determinants of health (SDOH) in a more 
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comprehensive way than does USDA programs that provide food alone. SDOH include access to 

affordable, healthy food; availability of community resources; transportation; and social 

support10

10 Social Determinants of Health. Healthy People 2020.

—all of which are available through the Senior Nutrition Program. Studies indicate 

that addressing SDOH are related to improved health outcomes.11

11https://www.who.int/social_determinants/themes/en/

Provision of Groceries During Emergencies

Periodic Emergencies

During, or in preparation for, emergent weather, natural disasters or localized events (eg, loss 

of power to an individual meal site), in order to assist with providing nutritious meals when 

home deliveries or group meal service is not feasible or safe groceries may be an option.

Major Disaster Declaration

During COVID-19 Major Disaster Declaration (MDD), groceries and other services have been 

widespread and assisted with meeting the nutritional and other basic household supply needs 

of older adults who were encouraged to shelter in place. Significant and unprecedented 

additional funding and transfer flexibility between OAA Title III Parts B, C1 and C2 and service 

flexibility in Title VI has enabled the aging services network to address the escalating food 

insecurity, socialization and health needs of eligible populations resulting from physical 

distancing requirements.

Under MDD authorities, all OAA Title III funding was permitted to be allocated to any of the 

OAA Title III Parts. States were allowed to use regular OAA funding, as well as Families First and 

CARES Act funds -- including those given under Title III-C -- for delivery, pick up, or other 

services necessary to grocery assistance. The CARES Act also included Title III-B funding which 

may be used for such services. 

As common practice to help with meal shortages, staffing shortages, and to assist seniors who 

were encouraged to shelter in place who were capable of making their own meals, groceries 

were used to address these critical needs. This increase in funding will not be forever and thus 

the use of groceries should be evaluated.

Under disaster and non-disaster scenarios, the Title III-C funds cannot be used for grocery pickup and delivery, but Title III-B funds could be used for that purpose. 

Provision of Groceries and Nutrition Services Incentive Program (NSIP) Funding

Under regular OAA authorities, Title III-B funds 12

12 Research Triangle International. 2007. Draft Final Report for the Evaluation of Select Consumer, Program, and 

System Characteristics under the Supportive Services Program (Title III-B) of the Older Americans Act. 

can be used for groceries and grocery delivery

services. In considering whether to continue offering groceries and grocery assistance, a 

SUA/AAA/LSP needs to consider how the purposes of the SNP found in Section 330 will be met, 
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the engagement of program participants, and the continued funding of the variety of services 

available through both congregate and home-delivered meals.

Groceries, as distinguished from shelf-stable meals, cannot be structured in a way to count as a 

meal. In addition, groceries alone cannot be counted towards the Nutrition Services Incentive 

Program (NSIP) funding allocation. Use of Title III-C funding to purchase groceries may reduce

NSIP meal counts and thus the amount of the NSIP allocation that a SUA receives. 

When considering providing groceries via Title III-C funding as other nutrition services, the 

SUA/AAA/LSP may want to consider these factors in performing a cost-benefit analysis:

• Title III-C funding is not sufficient to provide services to all eligible individuals. Therefore, 

funding must be prioritized across all authorized services (eg, meals, nutrition 

education, nutrition counseling, other nutrition services)

• Groceries are not meals and not available to count as an NSIP meal:

o NSIP meal counts are directly related to NSIP funding (payments based on NSIP 

meal counts will resume in federal fiscal year 2022; during FY20 and FY21 SUAs 

will be held harmless). 

o Spending Title III-C funds to support other nutrition services reduces the funding 

available for meals, potentially reducing the number of NSIP meals served. 

Therefore, funds devoted to groceries and other nutrition services may decrease 

the number of meals and/or persons who can receive meals. 

o Reductions in subsequent NSIP funds may result in serving fewer individuals with

greatest need during a time when more seniors are facing food insecurity and

malnutrition at higher rates than many populations. 

Summary

The COVID-19 pandemic called for flexible service provision to ensure access to nutritious, 

adequate, safe food for older adults served by the OAA SNP. Congress appropriated significant 

funding to allow this flexible service to occur.

As service provision returns to the “new normal”, this additional funding will not be available. 

SUAs/AAAs/LSPs should carefully consider the benefits of offering groceries to a limited 

number of persons who may benefit from food provision versus serving a meal. 

SUAs/AAAs/LSPs and Tribal Organizations should prepare to meet this new challenge by:

• continuing to provide quality meal service, 

• developing and/or enhancing partnerships with food assistance organizations, and

• determining which flexible, innovative services to embed within their service structure 

to best capture the practices adopted and new audiences gained during the COVID-19 

crisis. 

A nutrition provider that is considering offering groceries should tread carefully. Providing food 

such as groceries might be considered duplicative of other federal food assistance programs, 
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which provide only food and be considered unnecessary by the Government Accountability 

Office. Policies and procedures should address how the other parts of the Act (ie. socialization 

and health and well-being are addressed). Because the OAA nutrition program provides more 

than food and it offers significant other benefits, Congress continues to value and fund this 

unique program.