Academy Provides Administration for Community Living with Feedback on Grandparents Raising Grandchildren

February 7, 2020

The Honorable Lance Robertson, MPA
Administrator and Assistant Secretary for Aging
Administration for Community Living
330 C St SW
Washington, DC 20201

Re: Grandparents Raising Grandchildren (Docket 2019-26437)

Dear Mr. Robertson:

The Academy of Nutrition and Dietetics (the “Academy”) appreciates the opportunity to submit these comments to the Administration for Community Living at the U.S. Department of Health and Human Services, responsive to its December 9, 2019 request for information for the Family Caregiving Council: "Supporting Grandparents Raising Grandchildren." Representing more than 104,000 registered dietitian nutritionists (RDNs),1 nutrition and dietetics technicians, registered (NDTRs), 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 work with Americans in all walks of life — from prenatal care through end of life care — providing a variety of nutrition care services, including nutrition for older adults and nutrition education for children and adolescents.

The Academy applauds the initiative to collect best practices, resources, and challenges to help inform the goals, objectives, and recommendations that the newly-formed RAISE Family Caregiving Advisory Council will include in its Initial Report to Congress and the Family Caregiving Strategy. The Academy believes that nutrition and food access, including access to free school meals and senior nutrition programs, plays a vital role in child and student health and success as well as the health and well-being of older adults and those providing kinship care.

A. Enhancing Access to Federal Nutrition Programs

To maintain mental and physical health and achieve education success, it is imperative to meet the nutritional needs of children. The National School Lunch and Breakfast programs are an important safety net for many low-income families who may struggle to afford healthy meals. Typically, children are eligible for free school meals if their household income is 130% or below the federal poverty line. These meals help provide children an opportunity to thrive in school while offering some economic relief in an otherwise strained family budget.

Acknowledging the critical role that access to free school meals can play in reducing food insecurity, federal law establishes automatic eligibility for free school meals to certain groups of vulnerable children. This determination, which reduces the costs and effort associated with duplicative paperwork, is called categorical eligibility. Currently children who live in households that participate in SNAP, TANF, and other federal programs2 or are homeless or in foster care3 are categorically eligible for free school meals.

Regrettably, another growing group of vulnerable children who are not currently covered by categorical eligibility are those living in kinship care. If federal law were amended to ensure children in kinship care were categorically eligible for free school meals, it would ease some of the financial burden and the attendant stresses that family members—especially grandparents living on fixed incomes—take on. The Caregivers Access and Responsible Expansion for Kids Act of 2019 (S. 2760) aims to expand categorical eligibility to children being raised by (1) a relative who receives adoption or guardianship assistance; (2) grandparents or other relatives due to placement by a state or tribal child welfare agency; (3) living in grand family housing or receiving housing assistance under the Native American Housing Assistance and Self-Determination Act of 1996; (4) and children who are automatically eligible for Medicaid.

The Academy supports these and other efforts that keep children with family members when they are unable to be with their parents.

Other federally funded programs meriting examination for their ability to support seniors responsible for the care of grandchildren include the Child and Adult Care Food Program, Congregate Nutrition Program and the Home-Delivered Nutrition Program. The Government Accountability Office just published a November 2019 report examining federal nutrition assistance programs intended to meet the needs of older adults and recommended monitoring, oversight, and technical assistance strategies for enhancing their effectiveness.4 The Academy believes it is imperative that these programs not only reach their intended target population, but actually deliver the varying appropriate nutrition requirements seniors need to thrive—especially seniors raising a second family and taking on other non-traditional roles.

B. Meeting the Needs of Caregivers

According to the State Fact Sheets for Grandfamilies (2017),5 2,685,185 grandparents are householders responsible for grandchildren living with them. Of these grandparents, 21%  are experiencing poverty and 24.9% have a disability.5 These households may qualify for assistance programs; one best practice should be ensuring that these households have full access to benefits for which they qualify in order to relieve financial and emotional pressures associated with becoming elderly caregivers. Older adults have additional needs and challenges, including being at higher risk for malnutrition due to chronic conditions, physiological changes, and barriers to healthy food access.6 The enhanced risk of malnutrition in older adults can be compounded by the responsibility of being a new caregiver. These households frequently experience increased burdens and pressures to meet nutritional needs of all family members, which in turn affects the physical and mental health and emotional and financial well-being of the caregiver. It is important to examine how all Older Americans Act programs are being utilized by those who are eligible.

Additionally, grandparents may have trouble navigating and accessing appropriate resources. Another best practice would include kinship navigation programs that serve to:

"Provide information, referral, and follow-up services to grandparents and other relatives raising children to link them to the benefits and services that they or the children need. Kinship navigator programs also sensitize agencies and providers to the needs of relative-headed families."7

An example of an effective kinship navigation program is SHARE New Mexico, a program that works to inform caregivers of existing resources in one convenient location. The program includes a toll-free, statewide help line that connects users to a bilingual navigator who can direct callers to appropriate resources.8 An additional best practice within these programs, according to program managers, is the existence of an online resource directory that houses all information and resources and can be filtered based on participants' county and location. Kinship navigator programs also create and distribute resources, such as flyers and presentations, that are ready to be shared with the local community informing it about the program and its offerings.

C. Meeting the Needs of Native American Tribes

The Academy believes best practices and resources to meet the needs of Native American tribes have room for expansion, which should include input and information directly from tribal leaders and community members. In addition, existing connections to land-grant universities and extension programs may be leveraged in order to provide appropriate resources using existing infrastructures to Native American tribes. Finally, members of Native American tribes should have access to programs that they may be eligible to participate in, such as the Food Distribution Program on Indian Reservations.

The Academy appreciates the opportunity to comment on the ACL's request for information, "Supporting Grandparents Raising Grandchildren." Please contact either Jeanne Blankenship by telephone at 312/899-1730 or by email at or Pepin Tuma by telephone at 202/775-8277 ext. 6001 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

Pepin Andrew Tuma, JD
Sr. Director, Government & Regulatory Affairs
Academy of Nutrition and Dietetics