Academy February 2014 Comments to Administration for Community Living re Older Americans Act Survey

February 10, 2014

Elena Fazio Administration for Community Living
Office of Performance and Evaluation
Washington, DC 20201

Re: (Proposed Collection; Comment Request; National Survey of Older Americans Act Participants)

Dear Ms. Fazio:

The Academy of Nutrition and Dietetics (the "Academy") is pleased to comment on the proposed information collection regarding the National Survey of Older Americans Act (OAA) Participants (hereafter "Survey") published in the Federal Register December 10, 2013. The Academy is the world's largest organization of food and nutrition professionals, with more than 75,000 members comprised of registered dietitian nutritionists (RDNs),1 dietetic technicians, registered (DTRs), and advanced-degree nutritionists. Every day we work with Americans in all walks of life — from prenatal care through end of life care — providing nutrition care services and conducting nutrition research. We are committed to evidence-based strategies for improving the nation's health through food and nutrition.

The Academy supports the proposed information collection and believes it is necessary for the proper performance of the Administration for Community Living's (ACL's) functions.

The Administration on Aging (AoA) manages a comprehensive, coordinated, and cost-effective system of services that helps older adults maintain their health and independence in their homes and communities. The largest health program in the OAA is the nutrition program, which comprises congregate dining and home-delivered meals. The data derived from the Survey will provide important insight into the lives of participants, including the extent to which they rely upon the nutrition program for their total daily food needs, their food insecurity, and their level of nutritional risk. The Survey has been critical in helping policymakers understand the value and benefits of health and nutrition services.

AoA's annual performance data indicate that OAA nutrition programs effectively and efficiently help older Americans remain healthy and independent in their homes and communities. Data from the 2009 National Survey of OAA Participants found that 73 percent of congregate meal recipients and 85 percent of home-delivered meal participants report eating healthier meals as a result of their participation in the programs. Similarly, 58 percent of congregate meal recipients and 93 percent of home-delivered meal recipients say that the meals enabled them to continue living in their own homes. The Academy notes the increased efficiency of OAA programs since 2002 and the program's significant cost-benefit to taxpayers by enabling participants to live independently and healthy at home rather than be admitted to hospitals and long term care facilities.

Continued standardization of questions in the annual surveys facilitates useful comparisons. As more participants become comfortable with online technologies, ACL could consider the value and efficiency of transitioning from telephone interviews. The Academy appreciates the opportunity to comment on the proposed information collection and offers our assistance with your efforts.

Please contact either Jeanne Blankenship or Pepin Tuma with any questions or requests for additional information.

Sincerely,

Jeanne Blankenship, MS, RDN
Vice President, Policy Initiatives and Advocacy

Pepin Andrew Tuma, Esq.
Director, Regulatory Affairs Academy of Nutrition and Dietetics Academy of Nutrition and Dietetics


1 The Academy recently 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.