Nutrition and Aging Resource Center 

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Nutrition Education: What are the Requirements? Updated: December 2021

Under the Older American Act (OAA), nutrition education is a service that must be provided. Section 331 

and 336 of the OAA authorizes states to provide nutrition education, nutrition counseling, and other 

nutrition services, as appropriate, based on the needs of meal participants. In addition, Section 339 

requires nutrition projects to utilize the expertise of a dietitian or other individual with equivalent 

education and training in nutrition science, or ifsuch an individual is not available, an individual with 

comparable expertise in the planning of nutritional services. 

It is the responsibility of State Units on Aging (SUAs) to develop policies, procedures, and guidance for 

service implementation; they may delegate some responsibility to area agencies on aging (AAA) or local 

providers, who may outline further policies and procedures. To find out how frequently your nutrition 

project needs to provide nutrition education, or other policies such as who can provide nutrition 

education, length and type of education methods permitted, etc, check with your SUA.

Definition of Nutrition Education

The State Performance Report (SPR)/Older Americans Act Performance System (OAAPS) indicates the 

following definition:

An intervention targeting OAA participants and caregivers that uses information 

dissemination, instruction, or training with the intent to support food, nutrition, and 

physical activity choices and behaviors (related to nutritional status) in order to 

maintain or improve health and address nutrition-related conditions. 

Content is consistent with the DGA; accurate, culturally sensitive, regionally 

appropriate, and considers personal preferences; and is overseen by a registered 

dietitian or individual of comparable expertise as defined in the OAA. 

The SPR/OAAPS definition does not require a specific length of time for nutrition education. In fact, brief 

interventions may be quite effective:

• Nudging in education

• Why nudges work and how to use them to keep students on track 

• The Use of Nudges and Other Behavioural Approaches in Education

Service Units

The service units for nutrition education must be reported. SPR/OAAPS definition allows for nutrition 

education to be delivered in-person or via video, audio, online, or through the distribution of hardcopy 

materials. Your SUA policies may be more restrictive or include additional, specific requirements. 

Estimated Audience Size

The audience size for nutrition education must be reported. SPR/OAAPS definition allows for duplicated 

counts of the persons who attend nutrition education sessions. Your SUA policies may require 
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unduplicated (each person is only counted once) counts. Resources that may be helpful for counting 

social media include:

• How to Find out Who Is Watching Your YouTube Videos

• How to track post views on Facebook

• About your activity dashboard

So, while the OAA authorizes nutrition education to be provided, and the State Performance 

Report/OAAPS requires reporting of nutrition education service units and estimated audience size, 

each SUA (and possibly AAA and local providers) establish specific implementation policies and 

procedures. We therefore encourage you to work directly with your SUA to clarify nutrition education 

requirements that apply to your organization. 

To Learn More

The National Resource Center on Nutrition and Aging has several resources about providing nutrition 

education including:

• Nutrition Education: What’s New for Reporting and Connecting with Clients

• Tele or Virtual Nutrition Education for Older Adults

• Native Elder Nutrition Education & Training Needs Assessment

• Emerging Learnings About Nutrition Status, COVID-19, & Nutrition Education in Older Adults 

Check back frequently, as materials are added on a regular basis.

How to Find Reliable Nutrition Education Materials 

OAA Senior Nutrition Programs may not have a dietitian or person of comparable expertise on staff. In 

these situations, an SUA may allow for nutrition education to be provided if it was developed by a 

reliable source, which is overseen by a dietitian or person of comparable expertise. 

Meeting nutrition education requirements can be easy and fun! 

Below is a list of valid websites that provide valuable nutrition education. This list is not all inclusive. A 

good rule of thumb is to stick with websites that have edu, gov, or org in the URL. Make it fun by 

combining this information with a program at your congregate site, an online game, or catchy handout.

Examples of these are: 

• https://acl.gov/senior-nutrition

• https://health.gov/dietaryguidelines/ 

• www.health.gov/paguidelines

• www.choosemyplate.gov

• https://www.nutrition.gov/

• https://www.nia.nih.gov/health/publication

• https://www.nal.usda.gov/fnic

• www.eatright.org 

• www.diabetes.org

• https://www.foodsafety.gov

• www.aarp.org/health 

• www.health.gov/nhic 

• www.cdc.gov 

• www.fsis.usda.gov