Older Americans Act Nutrition 

Programs & Services:

Understanding Title III-C Flexibilities

This information is to help the aging 

nutrition network better understand 

what flexibilities already exist within the 

Older Americans Act while delivering 

congregate and home-delivered meals 

in regards to nutrition guidelines and 

service delivery methods. In some cases, 

state and/or local regulations may have 

more strict regulations. It is best to be 

aware of those rules and regulations and 

to follow state and local mandates.

For specific questions or concerns, 

please consult with the appropriate 

entity (local providers can consult with 

the area agency on aging (AAA), AAA 

can consult with the state unit on aging 

(SUA), SUA can consult with ACL regional 

administrator (RA)).

How Do We 

Incorporate 

Nutrition 

Guidelines - 

Dietary Guidelines 

for Americans 

(DGA) & Daily 

Reference Intakes 

(DRI)?

Providing nutritious meals and utilizing the DGA/DRI is necessary for the 

aging nutrition network. Making that happen can be a challenge. These 

resources can aid in managing DGA and DRI for congregate and homedelivered meals.

• The Nutrition Requirements of the Older Americans Act (OAA) covers frequently asked 

questions regarding OAA and nutrition requirements.

• The Senior Nutrition Program Webinar provides an overview of the Dietary Guidelines for 

Americans and Dietary Reference Intakes, what they are, how much flexibility they offer, 

and how states and Area Agencies on Aging share ultimate discretion on establishing 

their own specific nutrition and menu policies to best meet their community’s needs. 

(slide deck)

• ACL’s Senior Nutrition Program invited aging services network members from three 

states to share their experiences with the Dietary Guidelines for Americans and Dietary 

Reference Intakes. Through the panel discussion the network members share lessons 

learned, advice for peers, and more. (takeaways sheet)
Can we provide Grab & Go/ 

dine-in/ food truck meals?

Congregate and home-delivered meals can be 

served in innovative and creative ways. These varied 

delivery methods can make it a challenge to know 

what funding sources can be and should be utilized. 

The decision tree can help determine if the meals 

being served are reported as Title III-C 1 (congregate 

nutrition) funds or Title III-C 2 (home-delivered 

nutrition) funds.

Individuals receiving carry-out meals do not need 

to be homebound per the Older Americans Act. 

However, some states may include homebound as 

a requirement to receive III-C 2 meals.

What about groceries?

In some instances, providing groceries for participants may be appropriate and is allowable per 

the Older Americans Act. Groceries are foods that are ingredients for a meal and typically are not 

ready to consume as is and need further preparation. This would include ingredients in a meal box 

intended for the recipient to make the meal in their home. These groceries could be offered with a 

variety of funding sources as “other nutrition services.” This means that they would not be counted 

as a meal or toward meal count for Nutrition Services Incentive Program (NSIP). Instead, groceries 

are considered “material aid: consumable supplies” in regard to the State Program Report (SPR). 

OAA funding sources Title III-B and/or III-C (III-E funds when provided to caregivers) may be used 

in addition to other non-federal funding sources. States may have additional guidance on what is 

allowable. 

The Using Groceries and Other Nutrition Services to Meet Senior Needs document provides guidance 

for when groceries may be appropriate, the provision of groceries during an emergency, and 

groceries in regard to NSIP.

Does a participant need food or do they need meals? This Food vs. Meals guide can help decide.

The COVID-19 Triage Guidelines for Food and Meal Needs, Older Adults is intended to help senior nutrition 

programs triage requests for service.

This step-by-step guide provides guidance for working with restaurants and grocery stores for meals.

How can we utilize our nutrition funds to increase 

attendance?

As states move toward reopening congregate meal programs and other aging network 

activities, this reopening considerations guide offers considerations to help programs adapt 

once again.

The senior nutrition program spending idea brief offers a range of ideas that may help programs 

to brainstorm new and/or expanded ways to meet older adults’ nutrition, socialization, and 

wellness needs with Older Americans Act (OAA) funds.

Consider establishing a restaurant program by reviewing No Reservations Establishing 

Restaurant Partnerships in the Age of COVID-19 or restaurant and Café appraches to providing 

congregate meals as demonstrated by Innovations in Nutrition grantees.

The funding flexibilities for senior nutrition programs offers an overview of flexibilities allowed 

by both standard operating statute and emergency authorities.

This project was supported in part by grant number 90PPNU0002-01-00 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.