Provision of Title III Services Policy #6: Nutrition Services

This content is part of a public comment period. For more information, refer to Minnesota Board on Aging – State Plan on Aging.

Note: We updated content on this page on April 17, June 23 and Oct. 13, 2025. Changed content is indicated with [add] and [delete].

Authority Reference	OAA, Sections 307(a)(13), 331, 336, 337 and 339 45 CFR 1321.87 Minnesota Statutes 256.9752 and 148.621-635 Minnesota Rules 4625, 4626, 3250
Operating Category	Provision of Title III Services

Policies

1. Nutrition services are community-based interventions including congregate meals, home-delivered meals, nutrition education, nutrition counseling, and other nutrition services.

A. Congregate meals are meals meeting federal Older Americans Act requirements to eligible individuals and consumed while congregating virtually or in-person. These requirements include providing the following:

· i. A minimum of 33 1/3 percent of the DRIs for one meal per day.

· ii. A minimum of 66 2/3 percent of the DRIs for two meals per day.

· iii. A minimum of 100 percent of the DRIs for three meals per day. To a limited extent defined elsewhere in this policy, congregate meals may also be complemented with shelf-stable, pick-up, carry-out, drive-through, or similar meals paid for by Title III, part C-1 funds.

B. Home-delivered meals are meals meeting federal Older Americans Act requirements to eligible individuals and consumed at their residence or otherwise outside of a congregate setting, as organized by a service provider. Meals may be provided via home delivery, pick-up, carry-out, drive-through, or similar meals.

C. Nutrition education is information provided under Title III, parts C-1 or 2 which provides individuals with the knowledge and skills to make healthy food and beverage choices. Congregate and home-delivered nutrition services providers shall provide nutrition education, as appropriate, based on the needs of meal participants.

D. Nutrition counseling is a service provided under Title III, parts C-1 or 2 which must align with the Academy of Nutrition and Dietetics. Congregate and home delivered nutrition services providers shall provide nutrition counseling, as appropriate, based on the needs of meal participants, the availability of resources, and the expertise of a Registered Dietitian Nutritionist.

E. Other nutrition services include additional services provided under Title III, parts C-1 or 2 that may be provided to meet nutritional needs or preferences of eligible participants, such as weighted utensils, supplemental foods, oral nutrition supplements, or groceries.

2. Nutrition projects are defined as congregate dining sites or home-delivered meal programs that [4/17/25: add] are open and providing service [end add] [4/17/25: delete] operate [end delete] at least five days per week and provide meals as specified in this policy and the citations noted above.

[10/13/25: add] A. Due to limited resources available to support this level of service intensity, exceptions to allow specific congregate dining sites to be open fewer than five days per week will be considered under certain circumstances and must be approved in advance by both MBA and the AAA. Certain circumstances include the following:

· i. For congregate sites operating in rural areas. Refer to MBA Operations Policy #8: Rural Minimum Expenditures for the definition of “rural”;

· ii. To facilitate the provision of culturally specific or other congregate dining options for which a provider may only be able to operate fewer than five days/week or where there may be demand fewer than five days per week for this service;

· iii. In no case can a congregate site operate fewer than three days per week.

· iv. An AAA must analyze congregate dining site locations, service demand by populations with high nutritional risk, and provider capacity to serve five days/week prior to seeking MBA approval to have any congregate dining sites operate fewer than five days/week.

· v. [end add] [10/13/25: delete] a. [end delete] [6/23/25: add] Regardless of grab and go meals that may be available at a congregate site, each congregate site must be open and serve congregate meals at least five days per week [6/23/25: end add] [10/13/25: add] unless MBA and the AAA has approved them to operate fewer than five days per week based on the criteria in this policy [end add]. [6/23/25: add] Grab and go meals are a complement to the congregate dining program.

B. Home delivered meal providers must deliver at least five meals per week. Home-delivered meal providers may deliver those meals on fewer than five days, but must be open and available to provide nutrition services five days per week, including accommodating urgent service needs and requests. Home-delivered meal providers may deliver fewer than five meals per week to those clients requesting fewer meals per week. [end add]

3. Nutrition service providers must use at least the minimum Title III-C Nutrition Standards, which may be accessed at https://acl.gov/senior-nutrition/nutrition-guidelines. AAAs have the flexibility to establish higher standards than the minimum standards to meet local needs and circumstances.

4. All provisions of these policies apply to both congregate and home-delivered nutrition projects unless otherwise stated.

5. The AAA shall award funds as available to provide nutrition projects, nutrition education, nutrition counseling, and other nutrition services to older persons. Title III C-I and C-2 funds and state appropriations for meals shall be awarded on a calendar year basis. The AAA must make available the full amount of the New Obligational Authority for Nutrition each year.

6. Payments for meals shall be based on the number of monthly service unit counts in PeerPlace for eligible individuals who received at least one unit of service during the service period multiplied by the relevant contractual rate. Payment should be made only for units of service delivered to eligible participants.

[4/17/25: add] 7. Service providers must ensure the following: for nutrition services, including both home-delivered meals and congregate dining: every unit of service reported for a given week must be tied to a specific person and a specific date of service. These data must be uploaded into PeerPlace on a weekly basis. This can be done electronically through bar code scanning or, if preferred by the service provider, manually. [end add]

[4/17/25: delete] 7 [end delete [4/17/25: add] 8 [end add]. Menus and Meal Standards

A. Menus must be planned on a cycle basis for a minimum period of five weeks. Cycle menus and special menus must be planned and/or approved by a Licensed Dietitian or Licensed Nutritionist at the AAA or nutrition provider level.

B. Meals must provide at least one-third of the Recommended Dietary Allowance (RDA) as established by the Food and Nutrition Board of the National Academy of Sciences Research Council, and comply with the U.S. Dietary Guidelines for Americans.

C. OAA requires that all meals served using OAA funds adhere to the current Dietary Guidelines for Americans, provide a minimum of one-third of the Dietary Reference Intakes.

D. If more than one meal is served daily, the combined meals must contain at least two-thirds of the RDA for two meals, and 100% of the RDA for three meals.

E. Liquid nutrition supplements may be used as a supplement to meals for individuals with special dietary needs, on a case-by-case basis. Prior to receiving liquid supplements, individuals will be assessed by a licensed dietitian or other qualified health professional, to determine nutritional needs appropriate for age, health condition, or illness and to identify special dietary needs and tolerances. The provider must have a system intact to monitor acceptability and consumption of liquid supplements, with follow-up visits as needed. The supplement chosen and amount dispensed must supply at least one-third of the RDA. A physician’s order may be required. Nutrition funds may not be used to provide life support. While OAA Title III funds may be used to purchase liquid supplements, a liquid supplement by itself cannot be counted as a meal. When counting meals for purposes of the Nutrition Services Incentive Program (NSIP) funding or for OAA reporting purposes, “meals” containing only liquid supplements cannot be counted. If liquid supplements are served in addition to a meal that meets the OAA nutritional requirements, that meal plus the liquid supplement would count as one meal. Additionally, NSIP funds can only be used to purchase domestically produced foods; not liquid supplements.

F. Vitamin and mineral supplements may not be purchased with nutrition project funds.

G. At a minimum, special meal menus such as diabetic and low sodium meals shall be available. Low fat meals are recommended. The AAA or nutrition provider shall determine the calorie and sodium levels which will be offered. The nutrition provider will provide appropriate instructions to food preparation sites and caterers. Substitutes for the high sugar and sodium items on the regular menus must be available. Information describing modified diets must be accessible for referring agencies.

· i. A physician’s diet order may be required to receive special menu meals and shall be renewed as agreed upon with the physician.

[4/17/25: delete] 8 [end delete [4/17/25: add] 9 [end add]. Food Procurement, Health, and Safety Standards

A. All food procurement from a vendor must meet minimum food grades and standards as per Title III Nutrition Standards and Definitions.

B. All goods privately contributed to the nutrition program must meet those standards of quality, sanitation, and safety that apply to foods that are purchased commercially by the program.

C. Foods prepared or canned in the home may not be used in meals provided by the nutrition service providers. Foods that are uncooked and donated by participants may be used and may also be prepared for freezing at the sites for future use.

D. All service providers must adhere to state or local Board of Health Requirements for Food and Beverage Establishments and be subject to review by the Health Department Sanitarians. Exceptions to these regulations must be approved by the State Board of Health in writing.

E. Food temperatures at the time of service and at the time of delivery must adhere to temperatures specified by Minnesota Food Code. https://www.revisor.mn.gov/rules/4626.0395/

F. Raw animal foods shall be cooked to temperatures specified by Minnesota Food Code. https://www.revisor.mn.gov/rules/4626.0340/

G. Nutrition programs must utilize temperature probes for checking food temperatures. In addition, refrigerators and freezers located at food preparation and service site must have thermometers.

H. Insulated hot and cold containers will be used on delivery routes to maintain foods at acceptable temperatures.

I. All nutrition services preparation sites must be licensed and serving sites must be approved by the state and local Boards of Health.

J. Nutrition programs will certify food managers, as required by state and local health boards.

[4/17/25: delete] 9 [end delete [4/17/25: add] 10 [end add]. Collecting and Analyzing Data to Monitor and Plan Service Delivery

A. AAAs are required to examine patterns of utilization, prioritization, and efficiency with respect to their nutrition programs. These processes are important to help provide a consistent approach to analysis and decision-making about nutrition services on a statewide basis. The methodology for conducting these analyses is described under “Procedures” below.

[4/17/25: delete] 10 [end delete [4/17/25: add] 11 [end add]. Food Assistance Programs

A. All nutrition providers under Title III must request reimbursement from the ACL for meals served to eligible participants through the MBA. A reliable reporting system must be in place to assure accurate recording of Nutrition Services Incentive Program (NSIP) eligible meals.

B. To be eligible for NSIP reimbursement, a meal must meet all of the following criteria, as per the citations above.

· i. The meal or meals must meet federal OAA nutrition requirements. Including that that the meal meets the Dietary Guidelines for Americans and Dietary Reference Intakes consistent with OAA Section 339;

· ii. The meal or meals will be available under Title III of the OAA to individuals age 60 and over and their spouses, regardless of age, and may be made available to other eligible participants under the age of 60 which include (a) disabled individuals who reside in housing facilities occupied primarily by older individuals at which congregate nutrition service are provided; (b) individuals with disabilities who reside at home with and accompany older eligible individuals; and (c) individuals providing volunteer services during the meal hours;

· iii. The meal or meals will be available under Title VI of the OAA to older Indians who have attained the minimum age determined by the tribe for services or older Hawaiians, age 60 and over, and may be available to other under age 60 eligible participants as defined under Title III of the OAA;

· iv. The meal or meals must be served by an agency which has a grant or contract with an AAA;

· v. The meal is served to an individual who has an opportunity to voluntarily contribute toward the cost of the meal;

· vi. The meal is provided to the participant without a mandatory fee or on a means-tested basis. Although this may be a means for local organizations to subsidize the program, NSIP reimbursement cannot be authorized for meals with a set fee. Contributions may be collected but only on an understood voluntary basis; and

· vi. The earned NSIP reimbursement is guaranteed not to be used to supplant funds previously earmarked for services for older persons (i.e., replace funds that were awarded through grants/contracts for specific purposes).

[4/17/25: delete] 11 [end delete [4/17/25: add] 12 [end add]. Other Requirements.

A. All nutrition service providers must establish ongoing outreach services to assure that the maximum number of low income, hard-to-reach, isolated, and withdrawn older people have the opportunity to participate, including older minorities, hearing impaired, and visually impaired older people.

B. All nutrition service providers must establish and carry out a systematic program of nutrition education. Nutrition education is required quarterly and recommended monthly. Providers will use the MBA/NAPIS service definition to develop nutrition education plans. Nutrition education plans will be approved by the licensed dietitian or licensed nutritionist.

C. Meal providers must establish methods for provision and/or referral to other supportive services such as transportation, in-home services, and housing assistance.

D. Each congregate nutrition site must post in a conspicuous location, the average total cost of the meal and service, and a suggested contribution schedule. All eligible participants must be given the opportunity to contribute towards the cost of the meal and service consistent with the Voluntary Contribution Policy ([10/13/25: add] Title III Administrative and Financial Requirements Policy #15 [end add] [10/13/25: delete] Policy XX [end delete]). Service providers may establish procedures to accept SNAP/EBT as a form of voluntary contribution. Non-eligible participants and/or guests must pay the full cost of the meal, or an amount determined by the AAA and service provider.

E. Each service provider must periodically obtain the advice of persons competent in the field of nutrition, older individuals who are participants, and persons knowledgeable in the needs of the elderly and solicit their input about effective delivery of service.

[4/17/25: delete] 12 [end delete [4/17/25: add] 13 [end add]. Option for “Grab and Go” Meals

A. MBA and AAAs may spend up to 25 percent of C-1 funds to complement the congregate dining program through shelf-stable, pick up, carry-out, drive-through, or similar meals. AAA procedure regarding these meals will be outlined in the area plan. The 25 percent maximum shall be calculated based on the amount of Title III, part C-1 funds available after all transfers under 1321.9(c)(iii) are completed. Meals may be provided in this manner in the following circumstances:

· i. During disaster or emergency situations affecting the provision of nutrition services;

· ii. To older individuals who have an occasional need for such a meal; and/or

· iii. To older individuals who have a regular need for such a meal, based on an individualized assessment, when targeting services to those in greatest economic need and greatest social need.

[4/17/25: delete] 13 [end delete [4/17/25: add] 14 [end add]. State Nutrition Funds

State nutrition funds allocated to an AAA for nutrition support services may be used for the following:

A. Transportation of home-delivered meals and purchased food and medications to the residence of a senior citizen;

B. Expansion of home-delivered meals into unserved and underserved areas;

C. Transportation to supermarkets or delivery of groceries from supermarkets to homes;

D. Vouchers for food purchases at selected restaurants in isolated rural areas;

E. Supplemental Nutrition Assistance Program (SNAP) outreach;

F. Transportation of seniors to congregate dining sites;

G. Nutrition screening assessments and counseling as needed by individuals with special dietary needs, performed by a licensed dietitian or nutritionist; and

H. Other appropriate services which support senior nutrition programs, including new service delivery models.

I. An AAA may transfer unused funding for nutrition support services to fund congregate dining services and home-delivered meals.

Procedures

1. AAAs need to describe all responsibilities of service providers offering nutrition services in Requests for Proposals and contracts for these services.

[10/13/25: add] 2. AAAs seeking permission to have any congregate dining sites operate fewer than five days per week must request this exception in writing prior to signing a contract with a nutrition services provider.

3. [end add] [10/13/25: delete] 2. [end delete] AAAs shall conduct site visits to at least one third of its congregate and home-delivered meal sites (or twenty sites, whichever is less) each year. In addition, AAAs shall make spot-check site visits as needed as part of its monitoring responsibility. Please refer to AAA Operations Policy #8 (AAA Monitoring of Service Providers) for more information on monitoring requirements.

[10/13/25: add] 4. [end add] [10/13/25: delete] 3. [end delete] AAAs should analyze utilization, prioritization, and efficiency using the following process:

A. Utilization. Utilization should be the starting point for review of site level data. Providers are paid on the number of meals served, making the number of meals served a good unit of analysis for utilization.

· i. Measure: To what extent is the site providing Title III meals to older adults in sufficient quantity to impact the older adult’s nutritional health/intake?

· ii. Assumptions:
- Older adults who receive Title III meals only a few times a month are usually not those most in need. They probably have access to healthful foods through other means.
- Older adults who receive Title III meals more than 15 times per month are likely to be those most in need. They probably do not have access to healthful foods through other means.
- Older adults who are most in need may not receive Title III meals every day because they may receive meals through other means (i.e. EW or AC, family support, other services, etc.).
- Older adults may need meals for a short period of time, such as after a discharge from a hospital.

· iii. Indicators:
- Number and Percentage of participants by site who receive 5 or fewer meals in a selected one-month period.
- Number and Percent of participants by site who receive 15 or more meals in a selected one-month period.

B. Prioritization. Once utilization patterns are reviewed, it is important to look at prioritization. This process helps answer whether or not the site is serving those most in need.

· i. Measure: To what extent is the site providing meals to those most in need of access to healthful foods?

· ii. Assumptions:
- Missing data should be considered when reviewing prioritization data. As data collection improves over time, this measure will be more reliable.
- Up-to-date NAPIS registration/screenings also impact the reliability of prioritization data.

· iii. Indicators:
- Congregate
The percentage of program participants who have a nutrition risk conclusion of [4/17/25: delete] Moderate to [end delete] High.
The percentage of program participants who have incomes less than 200% Federal Poverty Level.
The percentage of program participants who are from a diverse population.
- Home-Delivered Meals
The percentage of program participants who have a nutrition risk conclusion of High.
The percentage of program participants who have 2 or more limitations in Activities of Daily Living (ADLs).
The percentage of program participants who have incomes less than 200% FPL.
The percentage of program participants who are from a diverse population.

C. Efficiency. Efficiency is important because it helps ensure the maximum impact of limited funds.

· i. Measure: To what extent is the site providing meals in an efficient manner?

· ii. Assumptions:
- There may be changes that could be made at the site level without having to close a site.
- There needs to be a balance between efficiency and choice (meal type, delivery method, and number of meals).
- Serving individuals with higher need may mean that costs are higher per meal.

· iii. Indicators:
- Total # Unduplicated Title III Persons/Year (Actual Prior Yr)
- Total # of Title III Meals (Actual Prior Yr)
- Current Meal Type
- Method of Meal Preparation
- Names of Meal Provider e.g. caterer, central prep, other
- Title III C2 Delivery Type
- Proximity to other nutrition sites