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Oral Nutrition Supplements 

Considerations for Senior Nutrition Programs

This tip sheet explains how oral nutrition supplements (ONS) can be offered, funded, 

and documented in your senior nutrition program. ONS are typically ready-to-drink 

beverages that provide nutrients like carbohydrates, protein, fat, vitamins, and 

minerals. They may be recommended by a registered dietitian or other health 

professional to help participants enhance their nutrient intake. Please refer to your 

state and local policies to ensure proper procedures are followed.

Planning 

ONS are not a necessity within the senior nutrition program but can be a tool to meet 

the nutritional needs of your participants. If you are deciding whether to add these 

supplements to your program, consider the following.

• Whether state and local policies allow these supplements, and if so, what 

procedures must be followed. 

• The need for and interest in ONS within your program. Participant surveys and 

client intake forms may help make this determination. 

• ONS are not one size fits all; some supplements may interact with chronic 

conditions or medications. Consider medical recommendations for 

participants to receive ONS.

• How your program will pay for ONS. They may increase your food costs, but 

there are different ways to pay for them – this document outlines several 

ways. 

o The issue brief, Identifying the Total Cost of a Meal, can help you 

determine how ONS will impact your program’s costs.
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Incorporating 

There are two ways ONS can be incorporated into senior nutrition programs:

1. Offer them separately or in addition to congregate and home-delivered meal 

services. 

ONS can be consumed with the meal or at another time. When served in addition 

to meals or offered to eligible persons who do not actively participate in the meal 

program, these supplements can be helpful for people who:

• Are at high nutritional risk. 

• Have increased protein and calorie needs.

• Have unmet nutritional needs because of a health condition, food 

insecurity, or limited ability to grocery shop or cook meals. 

2. Incorporate them as an option as part of a congregate or home-delivered meal. 

Older Americans Act (OAA) meals must meet the current Dietary Guidelines for 

Americans (DGAs) and provide one-third of the Dietary Reference Intakes (DRIs). 

See Nutrition Requirements of the OAA for a basic summary. 

A provider could offer an OAA meal and include an ONS as an optional choice. For 

example, ONS can be provided as an option instead of milk. 

Funding 

There are different funding streams to consider when purchasing ONS. If you plan to 

use OAA funds, it is essential to understand the proper way to purchase ONS for your 

program. 

OAA Title III-C Nutrition Services

ONS may be funded by OAA Title III-C funds whether 

they are provided as part of a program meal or 

provided separately. 

Remember: OAA meals must 

meet the current DGAs and 

provide one-third of the DRIs.

OAA Nutrition Services Incentive Program (NSIP)

NSIP funds cannot be used to purchase ONS. NSIP funds may only be used to 

purchase domestically produced foods. As these supplements are considered 

processed pharmaceutical products, they do not meet the definition of domestically 

produced food. Find more information in the NSIP FAQ. 
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Other Ways to Fund

Title III-B: ONS can be covered if their use complies with state and local policies and 

funds are available, as ONS are considered “other services as necessary for the 

general welfare”, as indicated in Sec 321(26).

Title III-E: These funds can be used for supplemental services on a limited basis to 

complement the care provided by caregivers under OAA Section 373(b)(5). The care 

recipient must have impairments in two or three activities of daily living (ADL) to be 

considered eligible for supplemental services.

Other sources to help defray costs: Nutrition programs may be able to negotiate a 

discount or join a Group Purchasing Organization or a Purchasing Consortium. 

Donors or partners within the community can be approached to help cover or 

contribute towards the cost of ONS.

Reporting

Ensuring correct documentation of ONS in your program’s reporting is very 

important. ONS alone may not be counted as a meal. ONS purchased with OAA 

funds can be reported in the State Performance Reporting (SPR) systems.

OAA Title III-C

If provided separately from or in addition to a program meal: SPR “other services”

enhance program services in addition to the reported elements of meals, nutrition 

education, and nutrition counseling. If offered separately from a meal, ONS would be 

counted under “other services” within the SPR. ONS may be provided to appropriate 

meal participants as well as non-participants if these individuals meet Title III-C 

eligibility.

If offered as part of the meal: Report the meal per usual as a C1 or C2 meal. The ONS 

should be considered part of the food cost and included in reporting meal 

expenditures.

OAA Nutrition Services Incentive Program (NSIP)

If an ONS is offered within an OAA meal that meets all NSIP meal requirements, the 

meal may be counted as an NSIP meal in the SPR.
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Reporting for Other Ways to Fund

Title III-B: ONS would be reported as “other services.” The state should be able to 

document why Title III-C cannot cover the cost so the program can justify using 

other limited OAA funds for their purchase.

Title III E: Eligible ONS should be reported as “supplemental services.”

Other Considerations

Participants may always choose to eat only certain items from a meal. If served as 

part of a meal, a participant may select only the ONS or any combination of items 

offered. However, if a participant consistently chooses to consume the ONS and not 

the meal, the program should consider engaging the participant, for example, by:

• Offering a referral for nutrition counseling to assess their nutritional needs, 

provide individualized guidance, and assist with identifying dietary 

interventions that meet the participant’s needs. 

• Offering a referral to a primary care physician, a case manager, or additional 

meal providers to determine if additional services might be appropriate to 

support the participant’s nutrition, health, socialization, and well-being.

• Reviewing existing policies and procedures, including training activities, 

monitoring practices, and funding approaches, to identify cost-effective ways 

to best meet the needs of program participants.

Last updated: Apr. 2023