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National Resource Center on Nutrition and Aging

FAQ: Managing Older Americans Act (OAA) Funded Senior 

Nutrition Programs (Title III C-1, C-2, and NSIP) 

During Emergencies Updated: August 2021

During an emergency, senior nutrition programs will need to adapt their services, activities, and events 

to continue safely supporting their communities. This FAQ provides information to help programs plan 

for, and adapt to, some of the most common emergencies that they may face. The strategies and 

suggestions in this guide are not exhaustive and should be adapted and modified to meet your situation. 

In addition, a prudent program administrator will develop emergency plans, policies, and procedures well 

in advance and review the plans annually.

Topics 

• Plans, Protocols, & Practices

• Meals & Nutrition Requirements

• Logistics

• Safety

• Communication

• Staff & Volunteers

• Funding & Reporting

Plans, Protocols, & Practices 

In an emergency, what protocols or practices should be in place for senior 

nutrition services?

All senior nutrition services should have emergency protocols and Continuity of Operations Plans 

(COOP) in place. If your community mandates a shutdown or shelter-in-place (e.g., due to natural or 

human-caused disasters, pandemic) it is critical that policies and practices should be in place to address 

issues such as providing meals, ensuring client health and safety, etc.

It is also important to have established community partnerships that can assist you during emergencies.

Examples of trusted partnerships include police and fire departments, and other entities such as the 

American Red Cross that have the capability, community trust factor, and authority to enter homes and 

deliver meals. You should partner with state and local emergency management agencies and/or public 

health agencies, depending on the situation.

In addition, preplanning for the emergency should include talking to local authorities to determine if 

your staff can be deemed essential. If so, you should decide in advance who is considered an essential 

worker and communicate that information to your staff and ensure staff are cross trained. Consider 

reassigning job responsibilities during an emergency so you can continue to perform mission-critical 

duties. A priority should be ensuring the safety of their employees.
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For the most accurate, up-to-date information, we recommend you follow communications from your 

state and local health departments and emergency management agencies. 

Can you share examples of emergency preparedness plans?

We recommend that you work with your state and local health departments and emergency 

management agencies to develop and practice emergency plans. These plans should prioritize services 

for seniors most in need and address how and when to use shelf-stable, frozen, and other meal delivery 

options.

The Federal Emergency Management Agency (FEMA) has a number of helpful resources, including 

information on emergency preparedness for community-based organizations, as well as, Ready, FEMA’s 

national public service campaign, which has information on developing emergency plans and how to 

create an emergency kit. In addition, the National Association of County & City Health Officials and 

Association of State and Territorial Health Officials have developed a toolkit on how to build capacity for 

including aging and disability networks in emergency planning. These are just a few examples of 

available resources, and you are encouraged to search for other resources specific to the population you 

serve as needed.

Also, program experiences and approaches from other states can be found on the Nutrition Listserv, 

which is available to State Unit on Aging (SUA) nutrition directors and professionals. For more 

information, please contact your SUA nutrition professional.

Meals & Nutrition Requirements 

What are some ways to provide emergency food assistance to older adults 

during an emergency?

The decision about how to provide emergency food assistance to older adults during an emergency is a 

local and state decision. Some examples include partnering with local food banks/pantries and working 

with U.S. Department of Agriculture (USDA) programs, like the Senior Nutrition Assistance Program 

(SNAP). For examples of other partnerships, visit the Nutrition and Aging Resource Center. 

Is it important to maintain senior nutrition requirements during an emergency? 

The OAA requires that the Dietary Reference Intakes (DRIs) and the Dietary Guidelines for Americans 

(DGAs) be adhered to by Title III-C senior nutrition programs. While flexibility may be helpful when food 

supplies may be scarce, in order to ensure older adults have food in their homes, maintaining nutrition 

requirements for seniors, even during an emergency, is extremely important to ensure seniors stay 

healthy. Meeting dietary requirements may be easier than you think. See Understanding Nutrition 

Requirements During COVID-19: DRIs and DGAs (Jun 2021) for guidance regarding the importance of 

meeting nutritional needs and also for meal planning ideas that meet the DRIs/DGAs.

Can ACL waive nutrition requirements?

Since it is in the OAA statute, ACL does not have the authority to waive nutritional requirements for 

meals funded through Title III C-1, C-2, or the Nutrition Services Incentive Program (NSIP). In cases 

where an emergency is raised to the level of a Presidential major disaster declaration (i.e., COVID-19 
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crisis), Congressional authority may choose to waive requirements. When a decision is made to do so, 

ACL will provide further guidance to the network. 

If you are having difficulty meeting DRIs/DGAs, the Nutrition Resource Center on Nutrition and Aging 

highlights success stories from the network on how this can be done. You can also contact your local 

SUA or ACL Regional Administrator (RA) for guidance.

Food and nutrition assistance funded via other OAA sources, such as Title III-B or Title III-E (for family 

caregivers) are not required to meet DRI/DGA requirements; however, we encourage that these 

requirements are met to the greatest extent possible. 

Can ACL waive the 5 days-a-week meal requirement?

During an emergency, you do not need a waiver from ACL for this adjustment. Your SUA has the ability 

to approve a lesser frequency for meals, including if your program is in a rural area where such 

frequency is not feasible.

For more information regarding this requirement, contact your RA for guidance.

In an emergency, is there flexibility in how meals are distributed (e.g., send a 

meal home with a congregate meal participant, offer grab and go, drive-up)?

Yes. Even in non-emergency situations, you have flexibility in how meals are distributed. How you report 

it depends on whether they are eating a meal in a congregate or home setting. Refer to the SPR 

definition to determine if it is a Title III C-1 or C-2 meal.

NSIP funds may also be used to pay for these meals as long as program participants and meals meet

NSIP requirements (e.g., domestically produced).

A prudent program administrator should collect information for all congregate participants in advance in 

case those participants request a home-delivered meal during an emergency, enhance protocols for 

making referrals between congregate and home delivered meal providers, and may want to include 

flexible language in their grants/contracts on sources of funding they may use in event of emergency. In 

addition, we understand local and state procurement requirements may limit flexible approaches; we 

will continue to monitor any expressed concerns, in order to address this in the future. Please reach out 

to your RA should you have issues where we can provide technical assistance.

To accommodate additional logistics that may arise because of an emergency, 

can a Title III funded meal be served outside of the lunch hour?

Yes. The OAA does not address specific implementation issues. States, territories, and tribes are 

responsible for developing policies, procedures, and technical assistance for program administration. 

The OAA requires you to consult with your participants to decide the best time to serve breakfast, lunch, 

and dinner based on their needs and preferences. This requirement is true in both emergency and nonemergency situations.
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To prepare for an emergency or potential food shortage, should we purchase

large quantities of shelf-stable food?

Your program will need to make this decision based on the local guidance for your area. However, it is 

important not to buy more food than can be used effectively, keeping in mind expiration dates and 

storage. Remember to rotate stock as needed and consider donating food that has not been used before 

it expires so that it does not go to waste if no emergency occurs.

It is also important to educate your participants about having their own stock of emergency food, water, 

and other supplies. The American Red Cross recommends that each person has two weeks of supplies 

on hand during an emergency. The University of Minnesota offers guidance on how to prepare for a 

two-week emergency food supply. Additionally, Ready, FEMA’s national public service campaign, has 

information about how individuals can plan for different types of emergencies.

Remember that community partners may also be able to provide food assistance during an emergency, 

and a prudent program administrator should develop these partnerships in advance.

When are providers allowed to distribute emergency meals to program 

participants for planned weather-related emergencies?

The OAA does not address this. Policies and procedures should be at the SUA and AAA level regarding 

the distribution of emergency meals for planned weather-related emergencies, such as winter storms 

and hurricanes. A prudent program administrator should review these policies and procedures at least 

annually. It is generally good practice to have meals in a participant’s home before any anticipated 

service interruptions and a check in with participants to identify if meals need to be replenished. 

Program participants should be informed about the use of emergency meals, and meals should be 

consumed within one year or by the expiration date. Note that all meals should be labeled with an 

expiration date. You should ensure that the program participant has the equipment, such as a 

microwave, and capability to heat meals.

If we provide emergency meals (e.g., shelf stable, frozen, grab and go) to people 

who usually attend a congregate meal site, is it considered a congregate (Title 

IIIC-1) or home-delivered (Title IIIC-2) meal?

Meals that are intended to be consumed in an eligible participant’s home are reported as homedelivered (Title IIIC-2). Meals may be provided via home delivery, pick-up, carry-out or drive-through.

Congregate meals (Title IIIC-1) are meals provided in a congregate or group setting to include meals

eaten with another person (in-person or virtually), such as virtual buddy systems or congregate sites (via 

Zoom, FaceTime, GoToMeeting, etc.) where people dine together. 
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Logistics 

What happens if an emergency causes major disruptions to program logistics 

(i.e., kitchen staff, driver, and volunteer shortage; mandated shutdowns or stayat-home orders; facility safety shutdowns such as for a gas leak; surge in 

demand from participants; or disruption to supply chains, etc.)?

Emergency protocols and COOP should already be established in case an emergency causes major 

disruptions to program logistics. Staff shortages, for example, may necessitate you to offer other 

delivery options, such as grab and go, drive-up, and drive-through meals; use of emergency staff for 

meal delivery; or use of shelf-stable and frozen meals. Depending on the nature of the emergency, you 

may also want to factor in well-being checks. We recommend you work with your state and local health 

departments and local emergency management agencies to decide how to handle such situations.

If a meal site is shut down, can you offer meals at another location?

Yes, if a site (congregate meal site or meal prep site for home-delivered meals) is shut down due to an 

emergency, you may move to another location provided there is another site available within your 

catchment area that has not been affected and can accommodate additional participants or meal 

preparation there. A prudent program administrator should identify alternative, accessible locations in 

advance. If the meal site is not near the original location, you should provide transportation for seniors.

The SUA and Area Agency on Aging (AAA) should ensure that current policies address procedures for 

moving a nutrition site in case of emergencies. The OAA provides guidance on the types of structures 

permitted as meal sites. For example, a meal site can be moved to a temporary food facility, such as a 

firehouse, religious institution, park, or recreation site. Program providers should work with local health 

authorities to ensure requirements for temporary food facilities are met (e.g., application, inspection). 

The building should also be accessible for older adults who have limited mobility such as using a walker 

or wheelchair.

You should also plan for how you will provide emergency meals for participants who cannot access your 

alternative site, as well as your regular home-delivered meals. Prioritize seniors as needed. If needed, 

set up a temporary food facility or encourage program participants to consume shelf-stable or 

emergency meals that you have delivered.

For reference: OAA SEC. 339. NUTRITION A state that establishes and operates a nutrition project under 

this chapter shall ensure that the project provides meals that comply with applicable provisions of state 

or local laws regarding the safe and sanitary handling of food, equipment, and supplies used in the 

storage, preparation, service, and delivery of meals to an older individual.

What are some suggestions for dealing with vendor shortages during an 

emergency?

We do not have information on the availability of supplies or vendors. However, you can find 

experiences and approaches from other programs on the Nutrition Listserv, which is available to the 

SUA nutrition directors and professionals. For more information, please contact your SUA nutrition 

professional. When dealing with shortages, past history has shown that it is best to work with your local 
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vendors and restaurants. Additionally, a prudent program administrator should create a list of 

alternative vendors to be used as back-up in case of an emergency. 

In an emergency, can agencies do home-delivered meal assessments via phone

or the internet?

OAA does not make provisions for when or how home-delivered meal determinations or assessments 

are done. The SUA has the flexibility to make this decision or pass the decision to the AAA Policies and 

procedures should be in place and this flexibility should be included in emergency plans.

Safety 

What safety recommendations can you provide for participants, staff, and 

volunteers during an emergency?

The National Resource Center on Nutrition and Aging is not the authority on safety protocol, however, 

some basic recommendations include the following:

For emergencies situations, contact 911. We recommend that you follow specific safety guidance from 

your state and local health departments and emergency management agencies. For public health 

emergencies or health-related issues, CDC also may be a resource. State and local health departments 

and emergency management agencies as well as CDC and FEMA may have communications toolkits and 

resources that can be adapted for messaging on safety recommendations.

We also recommend that you have policies and procedures in place for emergencies, such as individual 

office or agency building evacuation plans, and that those policies/plans be availability to, and practiced 

with, staff and volunteers.

What triggers no contact or socially distanced delivery protocols?

There is no specific federal law, such as the OAA, or ACL regulation that determines this. We

recommend that you follow your state and local public health and emergency management agencies’ 

guidance on when such protocols are triggered. CDC may also be a resource.

Communication 

How should we communicate with program participants, families, and 

caregivers during emergencies?

During emergencies, we encourage you to work with your state and local health departments and other 

trusted partners to communicate with program participants, families, and caregivers. For more 

information, contact your local SUA nutrition professional. Your organization should also establish 

backup or alternate communication methods in case your primary communications methods are 

inaccessible or don’t work during an emergency. For example, you may want to ensure contact lists are 

available in non-electronic formats in case of power outages.

To help ensure you reach as many people as possible during an emergency, a prudent program 

administrator should issue communications in a variety of formats, such as letter, email, voicemail 
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message recording, and social media and website posts. Communications should explain the nature of 

the emergency, how it will affect programs and services, contact information for participants who have 

questions, and where to find the latest, up-to-date information (e.g., your website, local media). Ensure 

that communication is accessible to all people and is appropriate for the population you serve (e.g., 

language, trauma, cognitive and physical disabilities). For example, for people with low literacy, use 

plain language and pictograms. For individuals with disabilities, consider accessibility such as using larger 

font, sign language interpreters, and captioning, and using alt text and closed-captioned videos on social 

media posts. 

Depending on your community, consider issuing communications in multiple languages. You may also 

want to contact your local TV and radio stations, which can quickly disseminate information to the 

community at large. 

For more information, the nonprofit organization SCORE, a resource partner of the U.S. Small Business 

Administration, has information on how to prepare for a crisis, including a downloadable crisis 

communications planning checklist. While this information does not specifically address accessible 

communication, the guidance provides sound advice and should be modified to address accessible 

communication. 

Staff & Volunteers 

In an emergency, what changes to volunteers should we anticipate? 

During an emergency, your pool of volunteers may change. As such, a prudent administrator would have 

a backup plan to volunteers (i.e., looking at reassigning your staff ahead of time, your local partnerships 

such as government and non-profit). If calling for volunteers during an emergency, we recommend that 

you continue to screen your volunteers.

Funding & Reporting 

If frozen, shelf-stable, or “FEMA meals” are used for congregate meal 

participants during an emergency, can those meals be reported as homedelivered meals for the State Program Report (SPR)?

Yes, these meals can be used for a congregate meal participant during an emergency. However, frozen, 

shelf-stable, and FEMA meals must be counted for programmatic reporting purposes under Title III C-2 

(i.e., home-delivered meals). Meals must conform to the DRIs/DGAs. We understand that during an 

emergency, food supplies may be limited and meeting DRIs/DGAs may be challenging. Resources on the 

National Resource Center on Nutrition and Aging are available to assist network organizations during 

emergencies. Please contact your RA if you require additional guidance.

If frozen, shelf-stable, or “FEMA meals” are used for congregate meal 

participants during an emergency, can those meals be reported as homedelivered meals for the NSIP report?

It depends. For NSIP reporting purposes, frozen, shelf-stable, or FEMA meals must meet nutrition 

requirements and program participants must meet NSIP eligibility. Absent Congressional action, such 

meals reported as NSIP meals must meet the DRIs/DGAs. A prudent program administrator would count 
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the meal when it is served. For more information, see guidance for understanding nutrition 

requirements during COVID-19 (DRIs/DGAs) here and NSIP requirements here.

When do we count an emergency meal as delivered to a program participant?

The OAA does not address this issue. However, it is recommended that the meal be counted when it is 

delivered.

When NSIP funding has been affected by disasters (NSIP funding will likely 

decrease next year because of the pandemic), do you provide accommodations 

for states, territories, or tribes?

NSIP funding is distributed to the SUA and Title VI grantees based on the number of eligible meals 

served in the prior year as a proportion to the number of meals served by all states, territories, and 

tribes. It is possible, therefore, that funding could decrease because fewer meals are served. Historically, 

a national emergency such as the COVID-19 pandemic, ACL made accommodations to hold harmless the 

NSIP allocations for reporting purposes. If a disaster of that magnitude occurs again, ACL will inform 

SUAs and local providers of any change in this requirement.

Remember that to limit the impact of serving fewer meals, you may deliver shelf-stable, frozen, grab 

and go, drive-up, drive-through and home-delivered meals, to be consumed on days when service may 

be disrupted. Meals that are given out and taken home to consume are reported as home delivered 

meals (Title IIIC-2). In addition, when Title III-C program participants consume their shelf-stable meals

during an emergency, you may deliver additional meals to replenish those meals. 

To count a meal as NSIP eligible, emergency meals must meet NSIP requirements. Meal kits will need to 

meet nutritional requirements, or include a food component, such as milk or fruit. You may count 

replenished shelf-stabled meals as NSIP meals if the meals and the program participants meet NSIP 

requirements. 

Because it is impossible to know when meals are actually consumed, shelf-stable, frozen, grab and go, 

drive-up, and drive-through meals can be counted when they are delivered. 

If a nutrition provider has a fire at their facility, and they lost food inventory, 

would the U.S. Department of Agriculture (USDA) assist in providing 

reimbursement for commodities that are lost?

The USDA does provide supplemental nutrition assistance in response to numerous types of 

emergencies and disasters, including but not limited to hurricanes, tornadoes, severe storms, and 

flooding so the fire would have to be a result from an emergency event. To qualify, these emergencies 

must be Presidentially declared emergencies, such as a Major Disaster Declaration by the President.

Money to buy and replenish food stocks used in emergencies comes from special funds that are 

available to the Secretary of Agriculture. For more information, contact the USDA Food and Nutrition 

Service Public Information Staff at 703-305-2281, or by mail at 3101 Park Center Drive, Room 819, 

Alexandria, Virginia 22302. USDA’s website also has information on Disaster Assistance Programs.
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Facilities that store food should have insurance for fires, floods, and other unexpected occurrences, so 

you should refer to the facility’s insurance policy to determine if the value of the donated foods is 

covered.