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Developed in collaboration with Administration for Community Living National and Regional Staff.

The National Resource Center on Nutrition and Aging is hosted by Meals on Wheels America 

as part of a cooperative agreement with the Administration for Community Living, Department of Health and Human Services, Washington, D.C. 20201 -

supported by grant number 90PPNU0001.

Frequently Asked Emergency Management 

Questions For Title VI Aging Services Professionals 

1. Can a meal site move to a temporary food facility such as a firehouse, church, parks

and recreation, etc. in case of emergency?

Yes. The Title VI Program/Tribe should ensure current policy and procedures address 

procedures for moving a nutrition site in case of emergencies. Older Americans Act (OAA)

provides guidance on the types of structures permitted as a meal site. Program providers 

should work with local health authorities to assure that their requirements (for example, an 

application and inspection) for temporary food facilities are met. If the meals meet the 

requirements for meals served through the OAA, they can be counted for Nutrition Services 

Incentive Program (NSIP) and Title VI funding.

For reference: OAA SEC. 339. NUTRITION A State that establishes and operates a nutrition 

project under this chapter shall—(2) ensure that the project—(A) provides meals that—(F) 

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. 

2. Could a meal site shut down and offer meals at another meal site location?

Yes, if a nutrition program (i.e. a provider that serves numerous meal sites within a 

geographic area) has to close down a site on a particular day for an emergency, they may 

move the meal site to another location within their jurisdiction. They may do so provided

there is an open meal site that day within their catchment area that can accommodate the 

additional participants. If the meal site is a distance from the original location, 

transportation should be provided to ensure seniors can attend the alternative meal site 

location. If transportation is not an option due to the magnitude of the emergency, then 

other options should be explored such as setting up a temporary food facility or 

encouraging program participants to consume available shelf stable/ emergency meals.
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Developed in collaboration with Administration for Community Living National and Regional Staff.

The National Resource Center on Nutrition and Aging is hosted by Meals on Wheels America 

as part of a cooperative agreement with the Administration for Community Living, Department of Health and Human Services, Washington, D.C. 20201 -

supported by grant number 90PPNU0001.

3. When are providers allowed to distribute emergency meals to program participants 

for planned weather-related emergencies? 

The OAA does not address this issue. Tribes and programs can determine for themselves the 

best time to distribute emergency meals. It is generally good practice to have them in the 

participant’s home prior to when service interruptions are anticipated to occur. Program 

participants should be informed about the use of these meals, and these meals should be 

consumed within one year or according to expiration dates. All meals should be date 

labeled.

4. When do providers count the emergency meals delivered to program participants?

The OAA does not address this issue, however it is recommended that the meal would be 

counted when it is delivered.

5. A nutrition provider has a fire at their facility, and they lost some food inventory. In 

this example scenario, would the US Department of Agriculture (USDA) assist in 

providing reimbursement for NSIP commodities that are lost?

No. However, 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. To qualify, these emergencies must be Presidential 

declared emergencies. Money to buy and replenish food stocks used in emergencies comes 

from special funds that are available to the Secretary of Agriculture for food purchases. 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. 

Information on Disaster Response programs is also available on the USDA website at USDA

Natural Disaster Assistance.

If the Tribe has additional nutrition funds, they may use their funds to replace food that 

meets NSIP criteria. Facilities where foods are stored will carry insurance for fires, flooding, 

etc. so the nutrition provider should refer to its insurance policy to determine if the value of 

the donated foods would be covered in this instance. 
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Developed in collaboration with Administration for Community Living National and Regional Staff.

The National Resource Center on Nutrition and Aging is hosted by Meals on Wheels America 

as part of a cooperative agreement with the Administration for Community Living, Department of Health and Human Services, Washington, D.C. 20201 -

supported by grant number 90PPNU0001.

6. If a congregate nutrition provider has an emergency and they use shelf-stable meals,

can those meals be counted as NSIP meals?

Yes, in emergency situations only (remember: the purpose of congregate nutrition program 

includes socialization), these meals can be counted as NSIP (assuming, of course, that the 

shelf-stable meals are domestically produced, and program participants meet NSIP 

requirements). A provider cannot, on a routine basis, count shelf-stable meals as NSIP 

meals. A prudent program administrator would count the meal when it is served.

7. If a nutrition provider wants to send a congregate meal home with a senior, can it be 

counted as an OAA Title III C-1 (congregate meal money) meal?

No, you can’t count it as an OAA Title IIIC-1 meal if you are sending a meal home. Meals 

consumed at home cannot be part of a C-1 site program. If the emergency has limited the 

participants’ ability to attend a meal site, shelf-stable may be your best option. The provider 

may count shelf-stable meals as NSIP meals (assuming, of course, that both the shelf-stable 

meals and the program participants meet NSIP requirements). The shelf-stable meals can be 

counted when they are delivered.

8. Are any accommodations ever made by the Administration for Community Living 

(ACL) for a Tribe regarding NSIP funding for disasters (i.e. NSIP funding for next year 

will likely decrease as a result of emergencies)?

NSIP reimbursement is based on the previous year’s meals served, so it is possible that you 

may see a funding decrease as a result of your emergency. If a tribe reports a decrease 

greater than 10%, they are required to submit a variance explanation. The variance 

explanation briefly describes the cause for the decrease.

To limit the impact of serving fewer meals, a nutrition provider may deliver shelf-stable 

meals to home-delivered meal program clients to be consumed on those days when service 

may be disrupted. In the event of an emergency where Title IIIC program participants 

consume their shelf-stable meals, the nutrition provider may deliver shelf-stable meals to 

replenish those consumed during the emergency event. Then the provider may count those 

replenishment shelf-stable meals as NSIP meals (assuming, of course, that both the shelf-
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Developed in collaboration with Administration for Community Living National and Regional Staff. 

The National Resource Center on Nutrition and Aging is hosted by Meals on Wheels America 

as part of a cooperative agreement with the Administration for Community Living, Department of Health and Human Services, Washington, D.C. 20201 - 

supported by grant number 90PPNU0001.

stable meals and the program participants meet NSIP requirements). The shelf-stable meals 

can be counted when they are delivered, as it would not be possible to know when the 

meals actually are consumed.

9. Can the Title VI meal be served outside of the lunch hour to accommodate the

additional logistics that may arise as a result of the emergency?

Yes. The OAA does not address specific implementation issues. It is the responsibility of the 

Tribe to develop regulations, policies, procedures, guidance and technical assistance to 

address program administration. The OAA requires that the program consult with local 

service providers to decide the best time of service considering the local need for lunch, 

dinner or even breakfast programming. This is the case even without an emergency.