Academy Comments to Nutrition and Aging Network Providers

August 2, 2019

Ms. Shannon Skowronski
Administration for Community Living
330 C St SW
Washington, DC 20201

Re: RFI - Nutrition and Aging Network Providers

Dear Ms. Skowronski,

The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit these comments to the Administration for Community Living's June 24, 2019 request for information "Nutrition and Aging Network Providers." Representing more than 107,000 registered dietitian nutritionists (RDNs),1 nutrition and dietetics practitioners, registered, and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the world and is committed to a vision of the world where all people thrive through the transformative power of food and nutrition and related support systems. Every day we provide a variety of nutrition care services for older Americans. Although the Academy is not within the Nutrition and Aging Network, our members work in State Units on Aging, Area Agencies on Aging and with local nutrition services providers.

The Academy strongly supports the efforts of ACL to conduct surveys to assess the content and quality of technical assistance to further improve the health of older Americans, thus extending community living, delaying admission to clinical facilities, and reducing health care expenditures. Programs and participants would benefit from increased 1) attention to treatment of senior malnutrition and 2) inter-agency cooperation to further support appropriate tools for, and documentation of, the cost-effectiveness of these programs.

A. Response to Question #1

These responses are examples of programs and resources received from various organizations:

  1. Wisconsin Bureau of Aging and Disability Resources - OAA policy guidance and interpretation. Best practices. Information and expectations of ACL and OAA
  2. Wisconsin Association of Nutrition Directors - Networking. Best practices. Peer to peer assistive problem solving.
  3. Greater Wisconsin Agency on Aging Resources - Policy guidance and interpretation. Best practices. Information and expectations of ACL and OAA
  4. Academy of Nutrition and Dietetics Policy Initiative and Advocacy team (DC office) – Legislative updates and strategies. Advocacy opportunities and direct advocacy by Academy staff. Partnership building. Opportunities to influence policy and policy makers.
  5. From Meals on Wheels America - Training on best practices. Marketing of OAA nutrition program. Strong, nationally recognized branding. Strong advocacy and respected leadership. Respected organization working on behalf of seniors and professionals and programs that help them.
  6. From Defeat Malnutrition Today - Increasing awareness of malnutrition in senior population while providing strategies to address the issue. Advocacy. Education. Partnership opportunities.

B. Response to Question #2

Examples of technical assistance which would be useful in nutrition-related program delivery shared by our members include:

  • Fact Sheets and Issue Briefs for staff trainings with corresponding consumer handouts
  • Webinars on such topics as
    • Working with Medicare Advantage plans to optimize meal benefits for beneficiaries
    • Nutrition focused physical exams for seniors as part of nutrition assessment
  • Increased guidance on the identification and treatment of senior malnutrition versus food insecurity
  • Technical assistance on business acumen including resources for effectively communicating with payors and outside funders and tools for making a business case for partnerships; how to effectively communicate with local and state stakeholders to increase program resources
  • Assistance with bridging programs services to medical care including how to provide medical nutrition therapy for Medicare and Medicare Advantage
  • Guidance for how to ensure III C1 and C2 remain independently funded

The Academy encourages ACL to work more closely with CMS to document that OAA programs help keep seniors out of hospitals and nursing homes through the examination and reporting of associated health outcome and utilization data regarding morbidity, mortality, hospital admission and re-admission.

The Academy appreciates the opportunity to comment on the "Nutrition and Aging Network Providers" docket. Please contact either Jeanne Blankenship at 312/899-1730 or by email at or Mark Rifkin at 202/775-8277, ext. 6011 or by email at with any questions or requests for additional information.


Jeanne Blankenship, MS, RDN
Vice President
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics

Mark E. Rifkin, MS, RD, LDN
Consumer Protection and Regulation
Academy of Nutrition and Dietetics

1 The Academy approved the optional use of the credential "registered dietitian nutritionist (RDN)" by "registered dietitians (RDs)" to more accurately convey who they are and what they do as the nation's food and nutrition experts. The RD and RDN credentials have identical meanings and legal trademark definitions.