Nutrition Requirements 

of the Older Americans 

Act (OAA)

What are the basic requirements of the OAA Title III C?

The OAA Title III C [Subpart C1, Congregate Nutrition Services (Section 331) and Subpart 

C2, Home- Delivered Nutrition Services (Section 336)] authorizes nutrition services for 

older adults. Section 330 states that its purposes are to:

• Reduce hunger, food insecurity and malnutrition of older adults;

• Promote socialization of older individuals;

• Promote health and well-being of older people 

◊	By assisting them in gaining access to nutrition and other disease prevention 

and health promotion services

◊	To delay the onset of adverse health conditions resulting from poor nutritional 

health or sedentary behavior

The OAA contains provisions about the responsibilities of the State Units on Aging 

(SUAs) and Area Agencies on Aging (AAAs). The OAA provides specific standards and

requirements for the OAA Nutrition Program.

What are the nutrition requirements of the OAA?

OAA Section 339 lists the basic nutrition requirements of the OAA:

• Meals are to comply with the most recent Dietary Guidelines for 

Americans;

• Meals are to provide nutrients to meet the Dietary Reference Intakes

as follows;

◊	A minimum of 33 1/3 percent of the DRIs for one meal per day. 

◊	A minimum of 66 2/3 percent of the DRIs for two meals per day. 

◊	A minimum of 100 percent of the DRIs for three meals per day.

• Meal service is to meet state and local public health code for safe 

and sanitary foodservice. Most state public health departments use 

the Model Code from the Food and Drug Administration; and

• Meals are to be appealing to older adults.

Why are the nutrition requirements of the OAA important?

It is important that the OAA Nutrition Program provides food and meals 

that are adequate, nutritious, safe, appetizing, help older adults remain 

healthy, and help older adults manage chronic health conditions. 

?
What are the Dietary Guidelines for Americans (DGAs)?

The 2020-2025 DGAs are federal policy developed jointly by the U.S. Department of 

Health and Human Services (HHS) and the U.S. Department of Agriculture (USDA) that 

makes recommendations to promote health and prevent chronic disease. The USDA 

does not provide any requirements for the OAA.

• Follow a healthy dietary pattern at every stage of life

• Customize and enjoy food and beverage choices to reflect personal preferences,

cultural traditions, and budgetary considerations

• Focus on meeting food group needs with nutrient-dense foods and beverages, 

and stay within calorie limits

• Limit foods and beverages higher in added sugars, saturated fat and sodium, and 

limit alcoholic beverages

The 2020-2025 DGA recommendations include:

Every five years, the DGAs are revised. The DGAs target specific groups of foods that

Americans need to consume to be healthy (whole grains, fruits, vegetables, dairy and 

dairy alternatives, low-fat protein foods, and oils). The DGAs also focus on some foods 

and nutrients that Americans do not consume enough of, such as dark leafy greens 

and orange vegetables, or nutrients such as potassium, vitamin D, calcium, and fiber.

The DGAs provide lists of common food sources of such nutrients.

The DGAs also target foods and nutrients that Americans consume too much of 

and that are not healthy, such as too many calories, added sugars, and alcoholic 

beverages and too much sodium and saturated fat which need to be limited, 

especially for individuals with specific chronic health conditions.

The DGAs recommend different amounts of food for individuals of different ages, 

sex (assigned male or female at birth), and activity levels. For example, an active 

25-year-old male needs more calories and different nutrients and amounts of food 

than a 70-year-old, sedentary female. Information on the nutrient needs of individuals 

of different ages and sex is found in Appendix 2. Chapter 6 of the 2020-2025 DGAs 

specifically addresses the nutrition needs of older adults.

The eating patterns found in Appendix 3 can be used for menu planning as well as 

program monitoring.

What are the Dietary Reference Intakes (DRIs)?

The DRIs are developed and published by the Food and Nutrition Board of the National Academies of 

Sciences, Engineering, and Medicine. The DRIs represent the most current scientific knowledge on nutrient

needs of healthy populations.

The DRIs establish nutrient values or levels of needed nutrients by age and sex with Recommended Dietary 

Allowances (RDAs). The RDAs represent the average intake level for a specific nutrient necessary to meet

the needs of nearly all healthy individuals within a specific Age-Sex group. For example, the amount of

vitamin C that an older adult needs daily is 90 milligrams (mg) of vitamin C or 30 mg of vitamin C per meal. 

Vitamin C is found in fruits such as citrus fruits, strawberries, as well as vegetables such as broccoli, spinach, 

peppers, tomatoes, or vegetable juice. The amount of calcium needed is 1200 mg per day or the amount of 

calcium found in one quart (32 fl oz) of milk. Most programs provide one container or 8 fl oz of milk, which

provides calcium and vitamin D to help meet this need. Appendix 1 of the 2020-2025 DGAs provides tables 

of Nutritional Goals for Age-Sex groups across the lifespan.

Although the DRIs contain information on food sources of nutrients, they do not recommend foods to eat nor 

provide advice that is easily translated to menu planning for programs.

Because nutrient needs vary by age and sex, meals that meet the DRIs for a 25-year-old male, for example, 

may not meet the DRIs for a 70-year-old female. 
What do the DGAs say about older adults?

The 2020-2025 DGAs include special dietary considerations for older adults. Most 

older adults do not consume enough protein, vitamin B-12, and fluids which can

lead to muscle loss, anemia, and dehydration. Overconsumption of alcohol is also a 

special consideration since it can lead to an increased risk of falls and other adverse 

health effects. The tip sheets below provide more information about special nutrient 

considerations: 

Protein Tip Sheet (NRCNA)

Using the Nutrition Facts Label: For Older Adults (FDA) 

Vitamin D and Vitamin B-12 Tip Sheet (NRCNA)

Calcium and Potassium Tip Sheet (NRCNA)

How do the DRI and DGA requirements differ?

The DGAs focus on eating patterns and food choices to support health by 

emphasizing foods such as vegetables, fruits, grain products, dairy/dairy alternate 

foods, protein sources, and oils. The U.S. Departments of Health and Human Services 

and Agriculture issue the DGAs every five years. The DGAs are food-focused.

The DRIs focus on the nutrients found in food that are necessary for health and for 

decreasing the risk of chronic disease. The DRIs provide the amount of a nutrient 

needed to maintain health or function such as the milligrams of calcium a person 

needs to consume to maintain bone health. The DRIs are published periodically.

In planning menus, nutrition professionals select quality foods that contain nutrients 

needed for health in combinations that are appealing to older adults and that are 

cost effective.

Can State Units on Aging (SUAs), Area 

Agencies on Aging (AAAs) or local nutrition 

service providers use the Nutrition Facts label 

on food packages instead of the DGAs and 

the DRIs?

No. The Nutrition Facts label on a food package is not 

the same as the DGAs and the DRIs.

The nutrient values listed on the label are called the 

daily value (DV). The DV is not the same as the DGAs or 

the DRIs, which are required by the OAA, and cannot be 

used as a basis for planning meals nor assuring quality 

of menus for the OAA Nutrition Program.

The Food and Drug Administration (FDA) is responsible 

for enforcing the Food, Drug, and Cosmetic Act, which 

requires the food industry to label prepared foods such 

as breads, cereals, canned and frozen foods, snacks, 

desserts, drinks, etc. with food ingredients and a limited 

list of nutrients. The nutrients listed on a food label do 

not comprise all the nutrients needed to stay healthy. 

Rather, the nutrients listed on the Nutrition Facts of 

packaged foods reflects scientific information about

the link between the nutrient content of packaged 

foods and chronic disease. Nutrition labeling is not 

required for some foods such as raw produce (fruits 

and vegetables) and fish. As a result, many food items

do not have the Nutrition Facts label.
Who is responsible for implementing the nutrition requirements of the 

OAA?

The State Unit on Aging (SUA) is responsible for developing and implementing policy, 

procedures, guidance and technical assistance to implement the requirements of 

the OAA. The OAA does not prescribe how SUAs, Area Agencies on Aging (AAA)s, or 

local nutrition service providers are to implement these requirements. This is the 

responsibility of the SUA. SUAs have flexibility in developing policy and procedures to

demonstrate adherence to the standards and requirements.

Section 339 of the OAA requires SUAs to utilize the expertise of a registered dietitian 

in planning nutrition services or, if a dietitian is not available, an individual with 

education and training that is comparable to a dietitian. In addition, the OAA requires 

that local nutrition service providers solicit the advice of a dietitian or individual of 

comparable expertise. If the AAA is also the direct nutrition service provider, the AAA 

would need to meet this requirement. Dietitians can assist in developing practice and 

science-informed policies, procedures, guidance and technical assistance.

At a minimum, a registered dietitian nutritionist or qualified individual of comparable

expertise can provide advice on:

• How to implement the nutrition standards and requirements and how to ensure 

adherence to the standards and requirements;

• How to develop food service contracts, contracts with food suppliers, and 

contracts with food service management companies;

• How to assist in food service and food safety management and in both quality and 

quantity meal production;

• How to plan to meet nutrition needs of older adults both in non-emergency and 

emergency situations;

• How to address issues of hunger, food insecurity, malnutrition, health promotion 

and chronic disease management among older adults.

• How to meet other requirements within the Older Americans Act Title III to include 

the nutrition education, nutrition counseling requirements, or both.

How do State Units on Aging (SUAs) ensure adherence to the nutrition 

requirements of the OAA?

Many SUAs establish an eating pattern based on the eating patterns found in 

Appendix 3 of the 2020-2025 DGAs to assure adherence to the standards. It is 

assumed that if an individual eats a meal that matches this eating pattern, the person 

will consume a diet that meets the DGAs and the DRIs. For example, if the eating 

pattern contains two vegetables and one fruit, it is assumed that the menu provides 

adequate fiber, vitamins A and C, and potassium.

In addition, some states may not require that all nutrient recommendations be met 

in every meal and may use the DRIs to establish target nutrients, ranges (acceptable 

upper and lower levels of specific nutrients), or a minimum level for a specific number

of these target nutrients.

These are the nutrients, as established by the DRIs, that are commonly used by several 

SUAs in their program policies, procedures, guidance and technical assistance: 

calories; protein; carbohydrate; fat, including saturated fat; fiber; calcium; zinc;

sodium; potassium; vitamin A; vitamins B6 and B12; vitamin C; and vitamin D.

States may establish different levels of nutrients for special circumstances such as 

nutrients needed for short-term or long-term emergencies, medically tailored meals, 

etc. States policies and procedures should address these special circumstances and 

have a solid plan of action for them.

The Nutrition and Aging Resource Center has a Dietary Guidelines for Americans and 

Older Adults: Toolkit for Senior Nutrition Programs. This toolkit includes resources such 

as tip sheets, menu creation tools, and recorded webinars.
What is a common eating pattern that is assumed to provide 

adequate nutrition and meet the requirements of the DGAs and DRIs?

A common eating pattern used for a lunch or dinner funded by the OAA and used by 

many SUAs, AAAs, and local providers (with a sample menu) could be:

Food Group Portion Size (see 

Choose MyPlate 

portions) Examples

Monday Tuesday Wednesday

Protein 3 oz meat/fish/poultry;

1 egg = 1 oz

Roast chicken Mixed bean 

soup, 1.5 cups

Baked salmon

Grain #1 1 slice bread, 1- 6” tortilla; 1⁄2 

cup rice/pasta, 5 crackers

Whole wheat 

roll

Baked cheese 

quesadilla with 

whole wheat 

tortilla

Wild/brown 

rice pilaf

Grain #2 1 slice bread, 1- 6” tortilla; 1⁄2 

cup rice/pasta, 5 crackers

Oatmeal 

topping on 

apple-raisin 

crisp dessert

Large tortilla, 

12 “

Sour dough 

bread

Vegetable #1 1⁄2 cup cooked, 1 cup leafy 

greens, 1 small whole 

vegetable

Small baked 

sweet potato

Pepper, tomato 

corn salsa

Low-fat 

creamed 

spinach

Vegetable #2 1⁄2 cup cooked, 1 cup leafy 

greens, 1 small whole

vegetable

Broccoli with 

diced red 

pepper

5 carrot sticks 

or 1⁄2 cup 

cooked carrots

Low-sodium 

vegetable juice

Fruit 1⁄2 cup canned/frozen; 1

small raw, 1⁄4 cup dried

Apples/raisins 

in dessert

Strawberries or 

blueberries

Pineapple 

canned in its 

own juices

Dairy/ 

Alternative

1 cup low-fat fluid

(reconstituted dry or 

evaporated milk); 1.5 to 

2 oz cheese; 2 cups lowfat cottage cheese; 1 cup 

yogurt

1% milk Cheese in 

quesadilla; 1.5 

oz

Low-fat 

cottage cheese

Dessert 

(optional)

1⁄2 cup of dessert options, 2 

small cookies

Apple-raisin 

crisp

Oil/ Margarine 1 Tablespoon oil,

1 Tablespoon soft

margarine, 2 Tablespoons 

salad dressing

1 tablespoon 

soft margarine

1 tablespoon 

soft margarine

Beverages 8 oz. Coffee, tea, 

water

Coffee, tea, 

water

Coffee, tea, 

water
Can the Administration for Community Living (ACL) waive the OAA 

nutrition requirements for meals funded with Title III C and Nutrition 

Services Incentive Program (NSIP)?

No. ACL does not have the authority to waive the nutrition requirements for meals 

funded with Title III C or NSIP. 

Can SUAs, AAAs, and local nutrition service providers use restaurants 

to provide meals?

Yes. The OAA does not address how SUAs, AAAs or local nutrition service providers are 

to select meal caterers, vendors or food suppliers. This is a provider’s decision.

The meals produced by alternative sources still need to comply with the state’s 

standards or guidelines for implementing the nutrition requirements of the OAA for 

meals (DGAs and DRIs), including consultation with a registered dietitian nutritionist 

or nutrition professional, and meet all state and local health standards. Dietitians 

with the AAAs or local nutrition service providers will need to work with a restaurant to 

develop appropriate menus, and they will need to work with the agency or provider’s 

financial or contracts person to negotiate appropriate food service contracts.

Many states have used restaurants to not only produce the meal but also provide the 

service location. In this case, the community restaurant functions just like any other 

congregate site. In other cases, the local restaurant has functioned as the caterer or 

vendor. This food service method has often been used in rural areas or to produce 

meals for people of color and under-represented people with different cultural food 

needs and preferences.

ACL has funded many nutrition innovators who are working in this space. The Nutrition 

and Aging Resource Center, has a wealth of information on this topic including the 

guide for Senior Nutrition Programs Seeking to Work with Food Retailers as well as 

a quick guide to lead programs through the process. Also find replication toolkits

for restaurant-based meal innovations. Erie County (New York) Department of 

Senior Services Modernizing the Congregate Dining Program project modernized its 

congregate dining program by partnering with local restaurants to give participants 

more flexibility in how and where they dine. Adults 60 or older could eat at any

participating restaurant at a time of their choice. The study had a number of positive 

outcomes, including decreasing feelings of social isolation in older adults. In other 

states, SUAs, AAAs, or local nutrition service providers have used restaurant voucher 

programs for restaurants, grocery store food facilities or hospital food facilities to 

expand service options. For example, the CHAMPSS (Choosing Healthy Appetizing 

Meal Plan Solutions for Seniors) is a successful partnership between the Johnson 

County AAA Nutrition Program in Kansas and the Hy-Vee grocery chain. The Ohio SUA 

established state administrative code regarding alternative meal providers, including 

voucher programs to address consumer direction. 

Find additional resources from the Nutrition and Aging Resource Center in the Dietary 

Guidelines for Americans and Older Adults: Toolkit for SNPs

This project was supported in part by grant number 90PPNU0002 from the U.S. Administration for Community Living, Department of 

Health and Human Services, Washington, D.C. 20201. Grantees undertaking projects with government sponsorship are encouraged to 

express freely their findings and conclusions. Points of view or opinions do not, therefore, necessarily represent official ACL policy.