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Administration on Aging Listening Session on Older Americans Act - Gerontological Nutritionists DPG, Dec. 4, 2001

Good morning. My name is Amy Nickerson. I am pleased to have the opportunity to present comments on the new regulations for the Older Americans Act. Today I am speaking on behalf of the Gerontological Nutritionists, a specialty practice group within the American Dietetic Association. For two years I have been the Legislative Chair for the Gerontological Nutritionists practice group

I am a registered dietitian with more than 20 years of professional experience. For the last five years I have worked at the Vermont Department of Aging and Disabilities managing the Title III-C Nutrition Program.

The evidence is clear that nutrition plays a vital role in the health and well-being, functional capacity, independence and quality of life for older adults. The OAA ensures the delivery of services to help meet that end. While the most recent reauthorization of the Act addresses many important services for older adults, there are some sections that warrant clarification.

The reference to the general provision of nutrition services in Section 331, part C, is vague with respect to nutrition education and other appropriate nutrition services. Use of the word may include rather than provide gives no clear direction to the aging network. Some state, area, and local provider agencies perceive nutrition education services and other appropriate nutrition services as non-essential and expensive. Nutrition education
services, based on participant needs, provided by a qualified nutrition professional are essential and AoA guidance should make that clear.
Furthermore, AoA regulations should clearly define what constitutes nutrition education. Additionally, AoA regulations should define appropriate nutrition services, citing examples that include, but are not limited to, nutrition screening, education, assessment, counseling, care planning, and health and wellness programs.

The language referring to home delivered meal services specifies different allowable meal types including supplemental foods in Sec. 336, subpart 2. The term supplemental foods has multiple definitions. Although supplemental foods in the Act refers to USDA commodities that were more commonly distributed to OAA Nutrition Programs in the 1980s, many professionals and providers interpret supplemental foods to mean medical foods, nutrition supplements, liquid meals. I recommend that when the Older Americans Act is next reauthorized, the term supplemental commodity foods or merely commodity foods be used. In the meantime, AoA guidance should clarify that supplemental foods in this section of the Act refers to USDA commodity foods.

The OAA requires the provision of meals, that where practical, are adjusted to meet any special dietary needs of program participants (Sec.339 (2)(A)). Clarification is needed regarding the use of medical foods, foods for special dietary uses, dietary supplements, and functional foods in meeting individual needs, including special diets, and clarification is needed regarding the use of federal funding for them. I recommend that AoA guidance clarify the use and funding of medical foods, foods for special dietary uses, dietary supplements, or functional foods. Further, guidance should allow their use in a "meal" when prescribed by a registered dietitian or physician in conjunction with an individualized nutrition care plan. At a minimum, AoA guidance should encourage state units on aging to develop policies regarding the incorporation of readily available, cost-neutral functional foods.

My final recommendation relates to the welcome emphasis on safe food handling. Food safety is not consistently addressed by state units on aging, area agencies on aging or at the local level. In Vermont, for example, the Department of Health is not involved in OAA Nutrition Program food safety issues. Staff from the Vermont Health Department does not conduct inspections of community meal sites nor offer guidance. As a result, safe food handling practices differ across community meal sites in Vermont. I recommend that AoA regulations require state units on aging to clarify realistic time and temperature holding limits to ensure food safety, food quality and nutrient retention.

In conclusion, I would like to echo the comments of ADA's president Susan Borra on the need for qualified professional nutrition expertise at the state unit on aging level. I believe that a registered dietitian is uniquely qualified to provide valuable service by interpreting the nutrition and health promotion sections of the OAA, and by providing guidance, technical assistance and oversight for the Nutrition Program.

I encourage the AoA to look to the Gerontological Nutritionists practice group as a resource when developing future guidance and policy. We support and work with the National Policy and Resource Center on Nutrition and Aging.

Thank you for the opportunity to speak at today's listening session.