COVID-19: Elder Nutrition Programs

Group of older adults having breakfastElder nutrition programs (ENPs) are encouraged to use existing emergency plans to the extent possible and coordinate with local public health departments to plan for alternative approaches for service provision as a result of COVID-19 concerns. If a decision is made at the local level to decrease or modify ENP services as a result of concerns over COVID-19, there may be some programmatic changes that will require guidance or approval from the Bureau of Aging and Disability Resources (BADR) or the Administration for Community Living (ACL). Because the wellness and safety of ENP employees, volunteers, and participants are of primary concern, ENPs are encouraged to plan for approaches that protect older adult citizens while supporting local operations and resources.

Encourage sick employees and volunteers to stay home. If employees or volunteers have a fever, cough, or shortness of breath, do not allow them to work or volunteer. People who think they have been exposed to the virus should contact the local public health department and their health care provider for possible testing.

Please continue efforts to educate participants, staff, and volunteers on precautions they can take to keep themselves safe, such as:

  • Frequent and thorough handwashing with soap and water.
  • Covering coughs and sneezes.
  • Avoiding touching the nose, eyes, and mouth.
  • Staying home when sick.

As a reminder, updated information is located on our COVID-19 webpages with links to the Centers for Disease Control and Prevention (CDC) website where there is a wealth of resources and educational materials. The DHS Outbreaks in Wisconsin webpage is updated daily by 2 p.m.

DHS has established a number of email addresses to provide information and assistance on several topics or for specific partners.

Category Phone Number, Email, or Website
Questions about Elder Nutrition Program policy

Sara Koenig, Bureau of Aging and Disability Resources

Questions from the general public

Call 211
Text COVID 19 to 211-211
211 Wisconsin website
DHS webpage

Questions about workplace safety or personal protective equipment (PPE) procurement DHS PPE Email
Questions from local and tribal health departments DHS Local and Tribal Health Response Email

 

We also want to hear from you as you identify innovative approaches to providing these important services during the COVID-19 outbreak. Thank you for all you do to ensure the safety of Wisconsin's older adult citizens!

Frequently Asked Questions

Can carryout, pick-up, or curbside meals be provided to congregate meal participants who have concerns about eating in the dining center with others or when dining centers closed due to the COVID-19 concerns?

Yes, carryout, pick-up, or curbside meals can be provided temporarily. Per ACL, because these meals are not provided in a congregate setting, they must be reported as home-delivered meals and use C2 funds. See the Older Americans Act (OAA) Funding Information document for more information about possible funding sources and nutritional requirements.
 

Can shelf-stable or frozen meals be provided to congregate meal participants who have concerns about eating in the dining center with others or when dining centers are closed due to COVID-19 concerns?

Yes, shelf-stable or frozen meals can be provided temporarily (see question above). See the Older American's Act (OAA) Funding Information document for more information about possible funding sources and nutritional requirements.

BADR recommends that frozen meal options be explored first with a goal of providing some variety, just in case delivery frequency must be decreased for long periods of time. Ensure that participants have suitable appliances for maintaining frozen food in a frozen state and for heating meals to proper serving temperature.

Shelf-stable meals may be provided when necessary, but their use should be limited because these products are usually very high in sodium and may not contain adequate potassium or protein. Meals may also provide too much carbohydrate and too many added sugars. All of these are nutrients of concern for older adults with hypertension, heart disease, and diabetes, who are already at a higher risk for COVID-19 complications.

Can shelf-stable or frozen meals be provided to home-delivered meal participants?

Yes, shelf-stable or frozen meals can be provided. See the Older Americans Act (OAA) Funding Information document for more information about possible funding sources and nutritional requirements.

BADR recommends that frozen meal options be explored first to allow for some variety, just in case delivery frequency must be decreased for long periods of time. Ensure that participants have suitable appliances for maintaining frozen food in a frozen state and for heating meals to proper serving temperature.

Shelf-stable meals may be provided when necessary, but their use should be limited because these products are usually very high in sodium and may not contain adequate potassium or protein. Meals may also provide too much carbohydrate and too many added sugars. All of these are nutrients of concern for older adults with hypertension, heart disease, and diabetes, who are already at a higher risk for COVID-19 complications. 

Does BADR have recommendations for meal service provision during COVID-19?

BADR recognizes that local resources and capacity can vary during the COVID-19 emergency, especially when demand for meals, social distancing constraints, and employee and volunteer availability seem to be constantly changing. It is recommended that county and tribal aging units and providers attempt to provide quality meal services according to the following hierarchy as resources and capacity are available and the service can be provided safely under the guidance of local public health:

  1. Continuation of fresh (hot and/or cold) meal service using a carryout or home-delivery model. This could be done with current vendors or through new contracts with restaurants, grocery stores, or food vendors.
  2. Continuation of fresh (hot and/or cold) meal service with provision of two meals at a time, such as one hot and one cold or frozen.
  3. Provision of several frozen meals at a time with some fresh items, such as milk, bread, and/or fruit.
  4. Provision of several frozen meals at a time.
  5. Provision of several shelf-stable meals at a time with some fresh items.
  6. Provision of several shelf-stable meals or Federal Emergency Management Administration (FEMA) meals only. This should be a last resort, or a supplement to fresh or frozen meals.

Consider collaborations with food assistance programs to address additional food security needs of older adults, such as FoodShare, The Emergency Food Assistance Program (TEFAP), the Commodity Supplemental Food Program (CSFP), and the Senior Farmers Market Nutrition Program (SFMNP). 

What are some options for providing nutrition services that can utilize other funding sources?

Increased provision of carryout and home-delivered meals will quickly use the program's Title III-C2 allocation. The Older Americans Act, Families First Coronavirus Response Act (FFCRA), and Coronavirus Relief and Economic Support (CARES) Act allows requests to transfer funds. Wisconsin’s Major Disaster Declaration on April 4, 2020, also allows flexibility in use of federal funds for disaster relief. See the Older Americans Act (OAA) Funding Information document for more information regarding funding transfers.

Can grocery services, such as grocery shopping assistance, pick-up or delivery be provided?

Yes, grocery services, such as shopping assistance, pick-up, delivery or other distribution can be provided with Title III-B dollars. Title III-C and NSIP dollars may only be used to provide meals. Grocery delivery should not replace meal delivery. Instead, groceries should be used to supplement meal delivery by helping to provide the two-week supply of foods that the Red Cross recommends people have on hand in the home during an emergency. See the Older Americans Act (OAA) Funding Information document for more information.

Do bags or boxes of groceries or food count as a meal under III-C?

No, bags or boxes of groceries do not count as a meal. County and tribal aging units or providers may use III-B funds to assemble bags or boxes of preselected nutritious foods that would contribute to a healthy diet and the management of chronic disease. Programs can also use the expertise of their program nutritionist to create sample menus using the food in the bags or boxes as nutrition education under III-B or III-C.

It is important to consider that the food item packaging should be easy to open and the foods should be easy to prepare. Examples of nutritious foods include lower sodium canned meats, fish, soups, stews, vegetables or vegetable juices. Fruits canned in their own juices, dried fruit, and whole grains, such as crackers, pasta, and rice, are also good choices.

Can ENPs reduce home-delivered meal delivery frequency to minimize contact?

Yes, but nutrition programs will contact BADR and the AAA to let them know of these changes in delivery frequency.

During the COVID-19 emergency, bulk drop meals are allowable, but it is important to understand and attempt to address limitations. For example,

  • Large deliveries of meals at one time can be difficult for participants to transport into their homes from outside their door. Some programs have created packages that come apart into multiple pieces so that participants can more easily transport them into their homes. Other programs have used chairs or tables outside the door so that participants do not have to lean over to pick up the meals and risk a fall.
  • Leaving perishable meals outside presents food safety concerns.  Programs can protect drivers, especially those who are older adults, by allowing drivers to drop the meal and making sure they see the participant retrieving the meal before leaving.  Programs can also call participants to ensure they are home to pick up the meal and make a follow-up call to ask participants if they retrieved the meal. Some nutrition programs ask drivers to ring the doorbell or knock, leave the meal outside the door, and return to their vehicle to wait for participants to come to get the meal. Others are calling participants ahead to let them know when they will be arriving to give participants time to get to the door. Still others are decreasing the number of deliveries and having staff whose time has opened up, as a result of fewer walk-in customers to the ADRC or fewer home visits, call participants to check on them.  When it is not possible for a home-delivered meal meal participant to come to the door, then the county should pursue other arrangements to get the meal to the person by contacting a caregiver or neighbor or other means to assure that the meal left will be taken inside the home. This may also mean the meal is delivered to an alternate location for delivery. Example: A home-delivered meal participant identifies a neighbor or friend who will come and take the meal inside the home.

What are the requirements for participant well-being or safety checks?

Procedures must be put in place to check on vulnerable participants’ well-being when an in-person delivery is not feasible. Vulnerable participants who require well-being or safety checks on weekdays when meals are not delivered include:

  • Participants who live alone.
  • Participants with difficulty with three or more activities of daily living (ADLs).

BADR also strongly recommends well-being or safety checks on weekdays when meals are not delivered for participants with identified dementia or chronic conditions that could be exacerbated by COVID-19 symptoms, such as respiratory conditions like COPD.
Consider arranging a schedule of telephone contacts with participants. Alternately, arrangements for regular contact may be made with other service providers, such as postal delivery workers, community paramedics, or neighborhood watch groups, to help with checking on the welfare of home-bound older adults.

Nutrition programs should notify the AAA if the program is unable to check on participants’ wellbeing each weekday.

If we are running short on volunteers or staff willing to work, what are our options?

Educate staff and volunteers on the level of risk, with guidance from local public health departments. Consult with local public health about whether dining center closures are necessary or whether contact with home-delivered meal participants needs to be reduced or eliminated. If staff or volunteers are sick, caring for a family member or friend who is sick, or are uncomfortable working due to potential risk, some alternative options include:

  • Adjusting tasks within the county or tribal aging unit so that staff can step in to fill positions.
  • Identifying alternative agencies that aging units can partner with to obtain temporary staff or volunteers.
  • Identifying alternative agencies that aging units can partner with for meal delivery.
  • Transitioning to bulk delivery of frozen or shelf-stable home-delivered meals to free up staff/volunteers.

Decisions should be made locally based on the resources available, with the goal to minimize service interruptions as much as possible for participants while ensuring the safety of staff and volunteers.

Can ENPs provide home-delivered meals without doing in-home assessments to determine eligibility?

Eligibility assessments are required as described in Chapter 8 of the Manual of Policies and Procedures for Wisconsin’s Aging Network. However, home-delivered meal assessments can be done via phone temporarily if local public health departments advise that staff and volunteers not enter homes. During the COVID-19 emergency, participants are not required to be “homebound” under normal circumstances. Home-delivered meals can be provided to anyone who meets eligibility requirements (for example, age 60 or older) and is in need of the meal. The home-delivered meal assessor can select from the available choices for the “Reason(s) meals are needed” or can write in “COVID-19” under “Other.” In alignment with current state policy, home-delivered meal assessment information must be collected within four weeks of beginning meal service.

Are home-delivered meal assessments required for older adults receiving carryout, pick-up, or curbside meals?

Programs are required to ask additional activities of daily living (ADL) and instrumental activities of daily living (IADL) questions used for federal reporting of all participants served with Title III-C2 funds, including those participants who are receiving carryout, pick-up or curbside meals and home-delivered meals.

A registration form template with only the information required for federal reporting is available and will be shared with all nutrition directors via email. Programs can make registration forms available online for completion or for participants to complete and print ahead of time, ask the questions via phone when a participant makes a reservation, have staff/volunteers ask the questions at the time of service, or use other creative and convenient ways to obtain this information while minimizing contact.

BADR will not require nutrition programs to ask additional questions of participants who have current congregate registrations on file, but programs should ask the ADL/IADL questions when current FFY registrations are updated (according to timelines in Chapter 8 of the Manual of Policies and Procedures for Wisconsin’s Aging Network).

All new participants receiving carryout, pick-up or curbside meals or home-delivered meals should be asked all required questions for federal reporting, including ADLs and IADLs.

As a reminder, age is the only criteria for program eligibility. If participants refuse to respond to other questions, they cannot be denied service.

Are nutrition programs required to go to the customer's home for an in-person home-delivered meal reassessment after COVID-19 restrictions are lifted, even if it has been less than one year since the last assessment?

Home-delivered meal assessments and reassessments continue to follow existing state policies related to frequency. Programs are required to complete home-delivered meal assessments within four weeks of beginning meal service and at least annually afterward, even if participants temporarily suspend service from time to time to reduce contact during the COVID-19 emergency. Programs may need to conduct reassessments sooner than one year if resources are a concern and there is a need to prioritize services to those most in need.

BADR plans to allow flexibility to complete assessments via phone until further notice, in accordance with state and local public health guidance.

Since programs are receiving requests for meals for clients who do not meet OAA eligibility requirements of age 60 or older during the COVID-19 crisis, are there other funds available to serve these individuals?

Under the Older Americans Act, older individuals (60 years of age and older) and their spouses or domestic partners of any age are eligible to receive Title III-C nutrition services. These eligibility requirement extend to the federal supplemental funds (FFCRA, CARES). In addition, AAAs and county or tribal aging units have the option to develop policy allowing the following individuals to receive meals:

  • Volunteers who serve at congregate dining centers or deliver meals.
  • Individuals with disabilities who reside in housing facilities occupied primarily by older individuals where congregate nutrition services are provided (an already established dining center before COVID).
  • Individuals with disabilities who reside with older individuals receiving congregate or home-delivered meals.

Also, under the National Family Caregiver Support Program (NFCSP), individuals who reside with an eligible caregiver could be served if it would benefit the caregiver and enhance the ability of the caregiver to continue providing care to the care recipient.  As an example, a grandchild being raised by a grandparent could be served a meal if it would assist the grandparent. Contact the aging unit’s NFCSP coordinator if this is a consideration.

Consider collaborations with food assistance programs to address food security needs for individuals under 60, such as FoodShare, The Emergency Food Assistance Program (TEFAP), Child and Adult Care Food Program (CACFP), WIC, or USDA school meals programs.  BADR also encourages building strong, sustainable, and inventive partnerships with local businesses in your area that have a mission to serve other populations in order to meet community needs.

If there is a confirmed case of COVID-19 in our county/tribe or a neighboring county/tribe, do we need to close dining centers?

At this time, there is no statewide recommendation for the decision to maintain or close congregate dining centers, because the circumstances around COVID-19 cases and the degree of community exposure can vary widely. Contact your local public health department for direction.

My staff or volunteers may have been exposed to COVID-19. What do I need to do?

Contact your local public health department for direction. If someone in your agency acquires COVID-19 and public health requires closure of your agency, contact your local emergency manager to make a resource request to the state emergency operations center (SEOC) for assistance in continuity of operations during the time period your agency is closed.

Where can I find updated information related to food safety and COVID-19?

The following are good sources of updated information regarding food safety and COVID-19:

If local public health directs a dining center closure, are there requirements for how to notify participants?

Follow your local procedures for notifying participants of emergency closings and any direction from your local public health department.

If our local public health department recommends closure of particular dining centers, are we required to close ALL dining centers within our service area?

No, local public health departments might recommend closure of particular dining centers because the type of operation or the location of the dining center might pose a higher risk. If public health advises that risk at some dining centers is low and facilities continue open to the public, BADR recommends that programs maintain service levels as much as possible so that older adults have some level of access to services they need. Follow public health’s recommendations, but consistency across communities is not necessary.

If dining centers close or ENP services are otherwise decreased or modified as a result of COVID-19, do we need to complete any forms that are typically required by state policy?

No, because the COVID-19 situation is constantly evolving, please simply communicate service level changes as a result of COVID-19 concerns to BADR and the area agency on aging via email. If agencies are considering or entering into new contracts, such as new partnerships with restaurants, programs should notify the area agency on aging and BADR of those changes as well.

Under the “Safer at Home” order from Governor Evers, can nutrition programs still provide carryout or takeout meals?

Yes. Elder nutrition programs are considered essential services. In addition, it is stated in the order that restaurants can continue to provide takeout and delivery services. If restaurants are able to continue such services, essential nutrition services are also able to provide takeout meals.

Can nutrition programs use vehicles or other resources funded with Department of Transportation 85.21 or 8.215 funds to deliver meals?

Please contact the Wisconsin Department of Transportation to determine if such resources can be leveraged in this way in emergency situations.

Can nutrition programs use OAA and FFCRA C1 funding to support dining centers that are not operating by covering ongoing monthly costs, such as utilities or leases, so that when the pandemic is over those dining centers are able to open back up for congregate meals?

Yes. Title III-C1 allows for the support of congregate dining centers. Nutrition programs are able to pay for the maintenance of dining centers during the pandemic even though the centers are not currently operating.

Can we partner with another organization, like a school, to deliver meals and use C2 funds to pay for delivery costs associated with delivery to older adults?

Yes, this is an allowable C2 expenditure, as long as the C2 funds are being used for delivery to eligible participants.

Can nutrition programs use OAA or supplemental funds to provide pay increases to nutrition program staff?

Yes, this is an allowable expenditure under OAA or supplemental funds. Increases must be reasonable and justifiable and align with local policies.

If older adults are coming from another provider's service area, such as from another county, to pick up meals, is it okay to serve them, even if we are using Title III-C2 funds, which are typically use for home delivery to individuals who reside within our service area?

Yes.

Can a participant designate another individual to pick up a meal on their behalf?

Yes, under current state policy a spouse, domestic partner, family member, roommate, or close neighbor can pick up a meal on a participant’s behalf. Programs should obtain the designee’s contact information from the participant so that distribution staff will be able to accurately report who the meal is being delivered to.

Can ENPs provide more than one meal per day to participants on a contribution basis?

The Older Americans Act already allows providers to serve more than one meal to congregate or home-delivered meal participants per day and to serve meals more than five days per week, especially if participants are at high risk. Most older adults are considered at high risk during this emergency. It is important for programs to consider whether they have the resources and capacity to provide additional meals while still meeting demand. Procedures for targeting additional daily meals to those most in need should be established and shared with the area agency on aging (AAA).

Are there any changes to the OAA requirement to allow participants the opportunity to contribute toward the cost of their meals?

No, meals provided with OAA funds or COVID-19 supplemental funds (FFCRA, CARES, etc.) must be provided to eligible older adults on a contribution basis. Participants cannot be charged a fee for services, and the meals cannot be promoted as “free” meals. Methods for obtaining contributions may change as a result of COVID-19 precautions, but participants must be notified of the opportunity to contribute toward the cost of the meal in a noncoercive way. For example, as a result of COVID-19, programs are not required to accept contributions on-site but may ask participants to contribute via mail or online. Programs are encouraged to develop innovative solutions for obtaining participant contributions.

What flexibility is available regarding nutrition education?

While it may be challenging to provide nutrition education in times of crisis, it is nonetheless important in the context of managing health. County and tribal aging units and providers may provide written materials as nutrition education. BADR and the AAAs are exploring options for nutrition education to be provided virtually, and county and tribal aging units and providers are also encouraged to explore virtual or telephonic methods for providing this important service.
 

Are other specific nutrition program requirements being waived or modified as a result of COVID-19?

The following program requirements are modified as a result of COVID-19:

Meal Cost Tools

  • According to the “Meal Cost Analysis” section in Chapter 8 of The Manual of Policies and Procedures for Wisconsin’s Aging Network, “each program must calculate the total meal cost using the required meal cost tool developed by BADR at least annually.” Typically, BADR releases an updated version of the cost allocation tool in March, and programs are required to submit updated tools for the previous calendar year by May 31.
  • In 2020, submission of a meal cost tool for the 2019 calendar year to BADR will not be required. However, for the purposes of entering into new contracts with MCOs or other agencies for meal provision, programs should utilize the tool to calculate updated costs. The most recent version of the meal cost tool from CY 2018 can be used.
  • Note that nutrition programs may find value in calculating meal costs during the pandemic, as costs have likely changed as a result of COVID-19 programmatic changes. It is possible that BADR may ask, at a future time, programs to use the meal cost tool to provide data related to meal costs during the pandemic.  
  • When you calculate updated costs, please use the tool and keep it on file for documentation purposes.

Participant Surveys

  • According to the “Participant Input” section in Chapter 8 of The Manual of Policies and Procedures for Wisconsin’s Aging Network, “A system will be developed to formally assess, at least once per year, the satisfaction of senior dining and home-delivered meal participants for both food quality and delivery of services. This can be accomplished through comment cards, customer satisfaction surveys, taste tests, or pilot menus. The ACL encourages use of survey questions that assess program outcomes. Outcome-based survey questions developed by BADR must be provided to participants no less than once per calendar year. Survey results will be reported to the AAA and BADR as requested.”
  • In 2020, nutrition programs will not be required to distribute the annual participant surveys that BADR typically requires and report survey results to BADR and the AAA. Due to the unusual circumstances associated with COVID-19, annual survey results will not represent “typical” nutrition program operations and the data will not provide us with information that can be used to analyze trends. BADR continues to strongly encourage that programs obtain input from participants in some fashion during the year; however, programs will not be required to use statewide required questions and submit them to BADR.
  • Note that nutrition programs may find value in distributing comment cards or other customer satisfaction surveys in 2020, especially if programs are implementing new practices that they would consider sustaining post-pandemic. 

COVID-19 Funding for Elder Nutrition Programs

Families First Coronavirus Response Act

The Family First Coronavirus Response Act (FFCRA) supplementary funds granted to Wisconsin by the Administration for Community Living under P.L. 116-131 have been distributed, through the area agencies on aging (AAAs), to county and tribal aging units based on Wisconsin’s ACL-approved funding formula.

Funds expended from the FFCRA are to respond to the Coronavirus Emergency by providing Older Americans Act (OAA) services related to the response. Funds must be expended on allowable Older Americans Act activities as defined by the Older Americans Act and State and local policy.

FFCRA funding includes support for:

  • Title III-C1 activities, including congregate meals, nutrition education, and nutrition counseling
  • Title III-C2 activities, including home-delivered or carryout meals, nutrition education, and nutrition counseling

Funds are available for use beginning April 1, 2020. Currently, county and tribal aging units have sub-contracts with AAA that end on December 31, 2020. There will be an opportunity for aging units to carryover unspent FFCRA funds into 2021.  All FFCRA funds must be expended by September 30, 2021.

County and Tribal Aging Unit and/or Service Provider match is waived for FFCRA funds. County and tribal aging units are encouraged to continue to report match if possible; however, match is not required.

Coronavirus Aid, Relief, and Economic Security Act

The Coronavirus Aid, Relief, and Economic Security Act (CARES) supplementary funds granted to Wisconsin by the Administration for Community Living under P.L. 116-136 will be distributed, through the AAAs, to county and tribal aging units based on Wisconsin’s ACL-approved funding formula.

These funds have been issued to support preventing, preparing for, and responding to Coronavirus Disease 2019 (COVID-19). Funds must be expended on allowable Older Americans Act activities as defined by the Older Americans Act and state and local policy.

Wisconsin will be distributing CARES funding for:

  • Title III-B activities.
  • Title III-C2 activities, including home-delivered or carryout meals, nutrition education, and nutrition counseling.
  • Title III-E activities.

Funds will be available for use beginning April 1, 2020. Currently, county and tribal aging units have sub-contracts with AAA that end on December 31, 2020. There will be an opportunity for aging units to carryover unspent CARES funds into 2021. All CARES funds must be expended by September 30, 2021.

County and Tribal Aging Unit and/or Service Provider match is waived for CARES funds. County and tribal aging units are encouraged to continue to report match if possible; however, match is not required.

Use of Funds

Because FFCRA & CARES Act funding is specifically awarded for COVID-19 response, ACL and BADR encourage AAAs and county and tribal aging units to expend these federal funds in the following order:

1.    FFCRA Grant:

This grant is issued under the authority of the FFCRA for activities under subparts 1 and 2 of Part C, of Title III of the Older Americans Act. The terms and conditions of this funding and other requirements have the following order of precedence 1) OAA law; 2) executive order; 3) ACL program regulation; 4) federal administrative regulation found in 45 CFR Part 75; 5) state agency policies; 6) any additional DHS contract terms and conditions.

Note: Begin using these funds for services provided effective April 1, 2020.

2.    CARES Grant:

This grant is issued under the authority of the CARES for activities under Title III B, C, and E of the Older Americans Act. The terms and conditions of this funding and other requirements have the following order of precedence 1) OAA law; 2) executive order; 3) ACL program regulation; 4) federal administrative regulation found in 45 CFR Part 75; 5) state agency policies; 6) any additional DHS contract terms and conditions.

Until the CARES funds are awarded AUs should expend the FFCRA funds for C1 and C2 activities. The regular OAA funds would be expended next until the CARES funding is received. Do not hold off on spending regular OAA funds waiting for CARES Act funds to arrive.

3.    FY 2020 OAA Grants (the original allocations for program operations for 2020):

This grant is issued under the authority of the Older Americans Act for activities under Title III of the Older Americans Act. The terms and conditions of this funding and other requirements have the following order of precedence 1) OAA law; 2) executive order; 3) ACL program regulation; 4) federal administrative regulation found in 45 CFR Part 75; 5) state agency policies; 6) any additional DHS contract terms and conditions.

“Regular” Title III grant funds should be reserved until all COVID-19 supplementary funds have been expended.

NSIP funds may be used at any time to pay for domestically produced food used for congregate or home-delivered meals.

On April 4, 2020, Wisconsin was granted a Major Disaster Declaration (MDD) by the Federal Emergency Management Agency (FEMA) for all 72 counties and 11 federally recognized tribes. Such a declaration triggers Section 310(c) of the Older Americans Act (OAA), which allows states considerable flexibility in the use of federal funds received from ACL during the period of the MDD. If a county or tribal aging unit exhausts all funds in a given OAA Title during the MDD, county and tribal aging units should contact the AAA and BADR to request an additional transfer of funds between Titles to support services needed for disaster relief. This request will include a justification for the need to transfer funds for disaster relief services.

The FFCRA and CARES funds were appropriated to remain available until September 30, 2021, to prevent, prepare for, and respond to COVID-19.  After the major disaster or public health emergency has concluded there will likely continue to be expenses related to the COVID-19 response, such as stocking congregate meal kitchens that were suddenly closed.  

County and tribal aging units will be offered an opportunity to carry over unspent FY 2020 “regular” OAA allocations into CY 2021 as a result of the supplementary funding provided to respond to COVID-19. There will be an encumbrance carryover of SFY 2020 unspent State of WI GPR obligated in AIDS grants (i.e., CARS) used to support the regular OAA federal grants for nutrition programs. More information on this will be forthcoming.

Special Notes on Use of Funds:

  • There is no change to the program income rules and regulations outlined in 45 CFR Part 75.307. Program income must be expended prior to receiving reimbursement of these federal funds.
  • Funds from all three sources (FFCRA, CARES and OAA) must be accounted for separately and this includes program income.
  • See COVID-19 Funding Sources for Elder Nutrition Programs for more information.

Reporting Requirements

County and tribal aging units and AAAs are required to report the use of the three grant awards (FFCRA, CARES, and FY 2020 OAA) separately. This means that the specific services provided, along with persons served, units of service, and expenditures must be reported by funding source. To make this easier, BADR is asking county and tribal aging units to spend one grant award at a time (see “Use of Funds” above) rather than using funding sources simultaneously to provide a particular service.

WellSky SAMS Reporting

FFCRA and CARES Act funded services will be differentiated in WellSky SAMS from OAA funded services with separate fund identifiers. Carryout meals will be distinguished from meals delivered to a participant’s home via a home-delivered meal subservice.

Other nutrition-related services can be provided with III-B, such as grocery services and well-being or safety checks. Nutrition-related services may also be provided with III-E, such as nutrition services for caregivers (after consultation with the NFCSP coordinator).

Information regarding SAMS reporting requirements is available. County and tribal aging units will receive an extension for SAMS data entry for services provided in April 2020 (until June 30, 2020).

Nutrition programs providing meals with C2 funds must ask required demographic questions associated with C2 funds of new participants within four weeks of beginning provision of meals. Existing congregate participants who have transitioned to home-delivered meals must also be asked the additional questions associated with C2 funds, but programs are given additional time to ask these questions (see the ENP FAQ document for details). Additional questions include ADLs and IADLs. In accordance with state policy, program participants cannot be denied service if they refuse to provide information other than their age (which is required for program eligibility). Responses are reported in “Assessments” in SAMS using the HDM Assessment Form.

Fiscal Reporting

FFCRA, the CARES Act, and the regular Title III funding, along with each grant’s program income, must be accounted for and reported separately. Normal reporting rules surrounding program income still apply. Program income is required to be spent prior to expending federal funds.   

AAAs will provide updated fiscal reporting forms to county or tribal aging units or providers.

AAAs will report each grant award separately to BADR on separate 180A and 180B forms.

Nutrition Standards Requirements

The FFCRA and CARES Act waive the requirement to provide meals that meet the dietary reference intakes (DRIs) and in accordance with the Dietary Guidelines for Americans (DGAs) in circumstances where food supply is insufficient to meet these standards. However, at a minimum, any meals provided must meet calorie requirements in Chapter 8 of The Manual of Policies and Procedures for Wisconsin’s Aging Network. The U.S. Congress, ACL, and BADR encourage the use of existing nutrition standards to provide nutritious meals to maintain health and manage chronic disease.

While this flexibility is helpful to ensure older adults have food in their homes during this challenging time, the nutrition standards in the DRIs and DGAs help older adults stay healthy. During emergencies (and public health emergencies such as COVID-19), maintaining nutrition requirements remain very important for older adults to help maximize their health and immune system. Adequate nutrition is essential for maintaining immune function. Nutrients, such as protein, the B vitamins, C, D and E as well as zinc, are important. These nutrients are found in enriched grain and whole grain products, fruit, vegetables, dairy, and protein foods. OAA nutrition program participants have high rates of chronic disease, including heart disease, hypertension, diabetes, and obesity. These chronic health conditions place an older adult at greater risk for infection and disease and makes them more susceptible to COVID-19 and its complications. Overall, these conditions are better managed by consuming lower sodium, lower saturated fat, and lower added sugar foods as much as possible.

For these reasons, if county or tribal aging units or other service providers are unable to provide meals in accordance with nutrition standards, the AAA (for example, GWAAR) must be notified.

 

 

Last Revised: September 30, 2020