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Partnerships with Foodbanks and Other United States Department of 

Agriculture (USDA) Programs 

Basics

Food security/insecurity is a basic social determinant of health. Access to safe, adequate, nutritious, 

quality food and fluid is essential for life, health, disease risk reduction, and management of chronic 

disease and conditions. Titles III and VI of the Older Americans Act (OAA) indicate that a primary 

purpose of the OAA Nutrition Program is to reduce hunger and food insecurity.

The OAA Nutrition Program administered by the Administration for Community Living (ACL) is not alone 

in addressing the issue of food insecurity and older adults. The United States Department of Agriculture

(USDA) Food and Nutrition Services (FNS) funds programs that target vulnerable older adults as well. 

Most OAA Nutrition Programs provide one meal per day about five days per week. OAA Nutrition 

Programs are not designed to supply a complete daily diet. However, it is important to note that the 

OAA does not prohibit nutrition programs from serving more than one meal per day or more than five 

days per week if program resources permit it. The Process Evaluation of the OAA Title III-C Nutrition 

Services Program found that about six percent of congregate and twelve percent of home-delivered 

nutrition programs provided weekend meals. About eleven percent of congregate programs offered 

either breakfast or dinner in addition to lunch. Four percent of home-delivered programs offered 

breakfast and about fifteen percent offered dinner in addition to lunch. 

Similar to OAA Nutrition Programs, USDA programs are designed to supplement the diets of individuals, 

not provide enough food to meet their entire needs. The two agencies administer complementary 

programs that can build on each other to meet the food security needs of older adults.

Similarities and Differences between OAA Nutrition Programs and USDA (FNS) Programs

Although both ACL and FNS programs address hunger and food insecurity, understanding the similarities 

and differences between their programs may help the aging services networks and the food assistance 

networks work more collaboratively. 
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The table below provides a quick overview of programs administered by ACL and FNS. The FNS 

programs are discussed in more detail later in the document with links to each program’s websites. 

Category OAA Nutrition Program USDA Programs

Address food insecurity X X

Participation/Eligibility Criteria

Age X (Age 60+ required, with 

limited exceptions)

X (depends on program)

Means-testing or incomedetermination requiredX

Means-testing prohibited, 

targeting required

X

Administration (Specified in 

the federal legislation, receives 

federal funding, distributes 

federal funding, selects 

grantees)

State agency X X

State flexibility depends on 

federal regulation, some 

programs are more flexible than

others

X

Implementation significantly 

federally regulated

X

State flexibility inherent in law X

Implementation not 

significantly federally regulated

X

Service Provision Networks

Food assistance networks such 

as food banks, food pantries, 

governmental & private nonprofit organizations

X

Aging services networks, area 

agencies on aging, local 

nutrition service providers, 

governmental & private nonprofit organizations

X

The Federal Nutrition Programs and Emergency Food Referral Chart for Older Adults from the Food 

Research and Action Center (FRAC) provides detail about food and nutrition programs that benefit older 

adults. In addition, various membership and advocacy groups also provide details on available food and 

nutrition programs for older adults.
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To learn more about these programs, please review the following resources:

• FNS programs

• Food Research and Action Center (FRAC), older adult resources

• National Council on Aging (NCOA), nutrition and hunger resources

• National Resource Center on Nutrition and Aging

• Feeding America, older adult resources

• AARP, resources from the AARP Foundation, additional hunger resources

Questions and Answers about Working with USDA Programs

Supplemental Nutrition Assistance Program (SNAP)

How can the aging services network partner with entities administering SNAP?

Because the aging services and food assistance networks are usually different systems, with different 

state agencies, different mandates, different services, and different reporting, the aging services 

network needs to establish collaboration to maximize assistance to older adults. SNAP is administered 

by governmental agencies only. Less than half (48 percent) of eligible older adults participate in SNAP. 

Because of this, hunger advocacy groups such as Feeding America, and FRAC (see link above to their 

website) have developed technical assistance materials about SNAP for programs and for consumers. 

The National Council on Aging developed tools to increase enrollment, and BenefitsCheckUp on-line 

resources assist older adults in accessing SNAP benefits.

Can older adults use their SNAP benefits as a contribution for congregate or home-delivered meals?

Yes, federal regulations (7 Code of Federal Regulations Parts 271 and 274) for SNAP allow congregate or 

home-delivered nutrition programs to accept SNAP benefits as a contribution. Whether a program 

chooses to do so is a state and local program decision. If a program accepts these benefits, it may 

expand its funding sources. If a program decides to accept SNAP benefits as a contribution, it will need 

capacity to redeem those contributions via the electronic benefit transfer (EBT) technology. Both the 

New York and Wisconsin SUAs have developed processes to allow local nutrition service providers to 

become authorized vendors and thus have helped to expand their funding through SNAP contributions.

Can older adults and other SNAP beneficiaries use their benefits for on-line purchasing?

The FNS has authorized a pilot project using on-line purchasing. This program is authorized in the 

following 16 states: Alabama, Arizona, California, District of Columbia, Florida, Iowa, Idaho, Kentucky, 

Missouri, Nebraska, New York, North Carolina, Oregon, Texas, Vermont, Washington, and West Virginia. 

Although authorized in 16 states, not all state agencies have implemented a functional project yet. FNS 
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is continuing to expand this program based on state agency interest, third party processors, and 

retailers.

How can older adults access their SNAP benefits and how can the aging network help them?

The aging services network can assist older adults in using SNAP benefits safely through regular checkup calls, case management, or written or online materials. 

For some older adults, especially those with multiple impairments, grocery delivery or curbside pickup is 

preferable to making purchases in stores. There are several options that would allow for a retailer to get 

food to its SNAP clients. These may include, but are not limited to:

• The SNAP client places their order online or over the phone and picks it up at the store. If the 

store has a wireless point-of-sale device (POS), then the customer would be able to complete 

the transaction without having to leave their car (i.e., curbside pickup). For example, the aging 

network might help an older adult navigate the on-line ordering system, arrange transportation 

to the store and/or help them by picking up the groceries and taking the older adult’s home.

• The SNAP client places their order online or over the phone and the order is delivered to their 

designated delivery address. The transaction can then be completed using a wireless POS (i.e., 

home delivery). For example, the aging network might help them navigate the on-line system.

• The SNAP client places their order online or over the phone and designates a person to pick the 

order at the store using the clients EBT card. The transaction can be completed, using the SNAP 

clients EBT card, in the store or by using a mobile POS device outside of the store. 

If the SNAP client is unable to use these methods or is homebound with limited assistance, the aging 

services network, as a last resort and under extreme circumstances, may assist the SNAP client in the 

completion of a manual voucher. The SNAP customer would need to sign in person at the point the 

voucher is authorized. Procedures for manual vouchers are detailed by FNS. 

FNS cautions retailers to never accept payment by obtaining a client’s EBT card number and PIN over the 

phone. Manual vouchers must be completed when the client is present to sign it. A retailer is not 

allowed to obtain the EBT card number remotely (e.g. call or email) and complete the voucher without 

the client present. 

Delivery fees cannot be paid for with SNAP benefits. It is up to retailers to decide how to handle these 

delivery fees (e.g., waive delivery fees, allow for another form of electronic payment to be used for 

delivery fees). 

The Emergency Food Assistance Program (TEFAP)

How does TEFAP work?

USDA purchases a variety of nutritious, high-quality USDA Foods, and makes those foods available to 

State Distributing Agencies. State Distributing Agencies provide the food to local agencies that they have 

selected, usually food banks, which in turn distribute the food to local organizations. These local 
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organizations distribute USDA Foods to eligible recipients for household consumption or distribute them 

to organizations to use in meal preparation.

Food banks are a warehouse of food that is distributed to community organizations for use. Food 

pantries directly interact with individuals in the community and receive food from a food bank. In some 

cases, food banks serve as a food pantry in their location as well. Many food banks obtain most of their 

food through resources other than USDA. These include donations from the food industry as well as 

fund raising, community food drives, and volunteer and financial assistance from faith communities.

Can OAA Nutrition Programs access food from food banks for use in preparing meals for the OAA 

Nutrition Program?

This is a state and local decision and use of such foods is subject to audit and interpretation by State and 

local USDA representatives. In some states, there is extensive collaboration. In others, there is none. 

Often organizations that operate the food bank network have an advisory board which includes a variety 

of social and health service providers representing specific populations. Serving on the board or 

attending them as an observer will help programs understand how the program operates in each state 

and provide opportunities for collaboration.

In some states, there appears to be debate regarding the OAA language of voluntary and non-coercive 

solicitation of contributions. For many years, USDA and some local food banks have viewed the OAA 

language as a requirement for “payment” for the food and the meal, rather than as a voluntary 

contribution for nutrition services. USDA has indicated in its memorandum that individuals may not be 

charged for foods from the TEFAP nor may voluntary contributions be solicited. 

However, current USDA regulations list organizations and charitable organizations that can receive USDA 

donated food for use in their programs including nutrition projects under the OAA. USDA regulations

state that entities that administer programs such as TEFAP are prohibited from requiring or soliciting 

payments from program participants for USDA-donated food. Similarly, the OAA prohibits programs 

from requiring participants to pay for meals or food.

Rather, the OAA allows for the voluntary and non-coercive solicitation of contributions from older 

adults. Programs are to establish mechanisms to ensure that contributions are confidential, that older 

adults understand that they are not required to contribute and cannot be denied service if they choose 

not to contribute. In addition, programs are required to safeguard contributions. The OAA does not 

specify that these contributions are to be used for food or for food only. It states that these 

contributions are to be used to expand nutrition services. Therefore, the local program may choose to 

use these donations for items such as nutrition staff salaries, transportation, or supplies, etc. in an 

attempt meet both OAA and TEFAP requirements.

Regulations from USDA indicate that activities unrelated to the distribution of TEFAP foods or meal 

service may be conducted if it is clear that:

• The person(s) conducting the activity is unrelated to TEFAP

• Contributions are not a condition for receiving a meal prepared with TEFAP commodities
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• The activity is not conducted in a way that disrupts meal service.

If these conditions are met, the solicitation of donations are allowable. In fact, some food banks use a 

voluntary donation box separated from the food distribution area.

Therefore, local providers that choose to use these foods need to account and document how the 

voluntary contributions to the OAA Nutrition Program are being used. The local program needs to 

ensure that monies received for donations does not “pay for” food obtained from TEFAP and that 

signage and participants are aware that no money is to be given towards the cost of the food. 

Establishing a policy which states that client donations will be used to pay for program costs other than 

food is one way to assure that this is clear. The burden of accounting for and auditing by FNS of 

programs using TEFAP foods is between FNS and the state and local entities administering TEFAP. 

Auditors from FNS would determine what is allowed or not allowed based on accounting methods.

As a result, ACL cannot offer recommendations for or against using TEFAP USDA foods in OAA meal 

preparation. Foods from the food bank that are not USDA foods might be allowable depending on 

discussions with the local food bank. In acquiring foods from the local food bank, OAA Nutrition 

Programs might be required by a food bank to pay for logistical services such as the storage and 

transportation of food to the OAA Nutrition Program. This is allowable and not considered “buying 

food” from the food bank. Any participation or assistance which the OAA Nutrition program can offer 

the food bank (developing nutrition education materials, recipes for use of commodities, volunteer 

recruitment for food banks, and collaborative purchasing of foodstuffs using shared contracts, etc.) will 

help assure that the programs can work well together and utilize one another’s strengths to support 

both missions. 

Can an Area Agency on Aging (AAA) or local nutrition service provider completely replace a meal for 

congregate and home-delivered meals funded by the OAA with TEFAP foods and not allow for 

contributions from participants?

Under most circumstances, no. The OAA requires that meals be served five days per week within their 

service area unless the AAA or nutrition service provider receives a waiver from the State Unit on Aging 

(SUA). The SUA has the authority to develop policies and procedures about implementation and less 

frequent service. 

The OAA indicates that voluntary and non-coercive solicitation of contributions from older adults are to 

be allowed. These contributions are to be used to expand nutrition services. The ACL has no authority 

to waive this requirement.

In the few occasions that it may be possible to eliminate an OAA funded meal and replace it with a meal 

funded by TEFAP, the SUA needs to consult with ACL for technical assistance to assure that the meal is 

being replaced and no additional costs (direct or indirect from OAA funding) are being used to support 

the meal. If the intent in replacing the meal, is to feed people not eligible under the Act or provide 

additional meals to an eligible participant, you may want to consider adding a meal using TEFAP food. 

However, please contact the ACL Regional Administrator for additional assistance.
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Can the aging services network, Area Agencies on Aging (AAAs) and local nutrition service providers 

help OAA Nutrition Program participants access foods from TEFAP for household use?

Yes. As a part of collaborative efforts, AAAs and local nutrition service providers may work with a food 

bank to help stock and operate a mobile food pantry. These mobile units may go to senior housing, a 

local on-site pantry at the congregate site that disburses foods for congregate or home-delivered 

participants before a storm or use foods from TEFAP to assemble grocery bags for seniors.

The Commodity Supplemental Food Program (CSFP)

How can the aging services network assist older adults in accessing this program?

The CSFP is available in all states. It is administered by a state agency such as health, social services, 

education, or agriculture. State agencies store and distribute USDA Foods to local agencies who 

determine eligibility and distribution methods to eligible older adults. Although available in all states, 

there is not enough funding to allow for complete coverage throughout the state. 

Eligible older adults (not OAA Nutrition Programs) receive a preselected box of healthy food that 

supplements their diets. The food products are lower sodium canned vegetables, low added sugar fruits, 

canned protein foods and dry beans in consumer sizes.

In many communities, the CSFP is aligned with TEFAP and a food bank. By collaborating with the local 

food bank, the aging services network may increase access to this program for eligible older adults.

What are examples of collaborative efforts between the aging services network and the CSFP?

There are many examples of local interactions between the local CSFP and the aging services network. 

Working with the local CSFP program, home-delivered meal drivers may deliver CSFP food boxes to the 

homebound. In other communities, the local CSFP may deliver food boxes to the congregate site for 

distribution to eligible older adults who take the boxes home. Or local transportation provider such as a 

senior center bus may help deliver the boxes to congregate or home-delivered participants’ homes. This 

is helpful because the boxes are heavy, and many seniors need help in getting the boxes into their 

homes.

Senior Farmers’ Market Nutrition Program (SFMNP)

How is the SFMNP administered?

At a state level, the SFMNP is administered by a variety of different agencies from agriculture to health 

to economic security. The SFMNP is designed to provide low-income seniors with access to locally grown 
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fruits, vegetables, honey, and herbs. Due to limited funding, the SFMNP may not be available in all parts 

of the state. The benefit from the program varies from $20 to $50 per year in coupons distributed to 

eligible older adults who are determined to be at 185 percent of poverty or lower. In some states, the 

SFMNP receives additional state funding.

How is the aging services network coordinating with the SFMNP?

The SUA and/or aging services network often consults with the state agency that administers the SFMNP 

to implement the program. In a few states, the state agency responsible for administering the OAA 

programs is also the agency responsible for working through the aging services network to distribute 

coupons to eligible older adults. There may be multiple methods of distributing coupons to older adults 

such as through senior centers, nutrition programs or by mail. Nutrition education is also provided by 

program partners which could be the local area agency on aging or the cooperative extension service. 

Nutrition education procedures vary by state.

How can the aging services network assist older adults in accessing farmers’ markets?

The aging services network can help older adults access farmers’ markets, just as it helps older adults 

access other services in the community such as pharmacies, grocery stores, etc. which do not receive 

federal funding. Not all farmers’ markets accept SFMNP vouchers nor are they connected with the 

SFMNP. 

The AAA or local nutrition service provider may want to help older adults access farmers’ markets by 

arranging transportation to a local farmers’ market or help them access (if an option) an on-line ordering 

system. The AAAs or local nutrition service providers may want to connect with their State Farmers’ 

Market Association through state websites. Although state and local government sources may be the 

best source of information for farmers’ markets, USDA keeps a data base of farmers’ markets which 

may/may not accept coupons. 

Child and Adult Care Food Program (CACFP)

Can the aging services network access the CACFP?

Yes, if the program is an adult day care program approved by the state. Then, the aging services network 

can use CACFP funding for meals in an approved adult day care program. 

The aging services network needs to be aware of the “how-to’s” when they implement the program. To 

utilize funding from the CACFP, first the local service providers need to understand the CACFP 

implementation requirements. These requirements such as providing information on how to credit food 

components and food combinations that are allowable for USDA reimbursement are stated in detail on 

the CACFP website found here: www.fns.usda.gov/cacfp. These programs are two separate federally 

funded programs. The CACFP is a means-tested program and the OAA programs are not means-tested.
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The aging services network can coordinate these programs in a rare circumstance. However when 

participating in the program, aging service providers need to be cautious that the collaboration does not 

constitute “double dipping” and put either program into a payback situation for services which are 

construed to have been billed twice.

To coordinate the funding streams, programs need to have clear accounting procedures. The same meal 

cannot be funded by both the OAA and CACFP. This coordination needs to be deliberate and able to be 

audited. Without a careful audit trail, USDA might disallow the costs for the program. Programs need to 

understand what is included in their daily rate for approved adult day care programs, and this may vary 

depending on the funding source. Some rates include meals and snacks as a part of the daily rate, and 

this might preclude the inclusion of a meal funded by the CACFP or OAA funds.

Since an adult day care has different funding sources and payment models, they could fund different 

meals with different funding sources if the meal cost is not included in the daily rate for adult day care. 

For example, an adult day care provider could use CACFP funds for breakfast and a morning snack for 

those individuals who are CACFP eligible (based on income eligibility determination and use of the 

CACFP menu pattern which is different from the OAA pattern); not all individuals at the adult day care 

may be eligible for the CACFP, so the program would have to pay for the breakfast and snack for these 

individuals from other sources. For lunch, the program might use OAA funding for all individuals

(including those who received the breakfast and snack funded with CACFP) and use an OAA meal 

pattern, but not the CACFP pattern. But implementation can get complicated (and requires good cost 

accounting methods, good program implementation, good record keeping, meal component crediting in 

the CACFP, etc.) for such a program to pass audit, etc. 

Nutrition Services Incentive Program (NSIP)

Is NSIP, a USDA program?

No. But this idea persists in the aging services network. Starting in 1978, the USDA administered a 

different program that supported the provision of commodities or cash-in-lieu of commodities to OAA 

Nutrition Programs. In the 2006 amendments to the OAA, the program was renamed NSIP and 

completely transferred to ACL.

The NSIP is authorized by Section 311 of the OAA, funded by a federal appropriation to ACL and 

administered by ACL. USDA no longer provides any funding, nor does it have any administrative 

responsibilities for NSIP.

What is the relationship between NSIP and the USDA?

The NSIP provides a secondary source of funding that must be used to purchase domestically produced 

foods. The allocation can be applied to either congregate or home-delivered meals. SUAs and Tribes 

may elect to receive part of their NSIP allocation as commodities from the USDA if the SUA or Tribe 
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determines that doing so will enable them to better meet the needs of older adults. The SUA or Tribe 

can make this election annually. According to the most current data, six states and five tribes elected to 

spend part of their NSIP allocation on commodities. USDA assesses an administrative expense for 

providing these commodities. 

How does an SUA and/or AAA access commodities from NSIP?

The SUA/Tribe notifies their State Distributing Agency (SDA) which might be the state education or 

agricultural department or other department about their desire to use part of their NSIP allocation for 

commodities and the monetary amount of commodities that they are requesting. The SDA then notifies 

central office USDA Food Distribution. Based on these elections for commodities, the USDA Food 

Distribution and ACL execute an agreement for the federal fiscal year which includes an assessment of 

administrative costs for each state.

The SDA and the SUA/AAA/Tribe work together to distribute commodities to local service providers for 

use in their programs, ensuring that all USDA requirements for commodity usage and distribution are 

followed. Once a State/Tribe chooses to use commodities, the State/Tribe needs to meet the 

requirements of USDA in handling and accounting for the commodities.

If a SUA/Tribe wants to consider utilizing commodities as part of their NSIP allocation, the SUA/Tribe can 

contact the ACL Regional Administrator for assistance.