Public Comment Summary Table and Consultation

Comments in Response to the Federal Register Notice & Efforts to
Consult Outside the Agency
Comments in Response to the Federal Register Notice
A 60-day Federal Register Notice published in the Federal Register on November 17, 2020, 85 FR 222
https://www.govinfo.gov/content/pkg/FR-2020-11-17/pdf/2020-25276.pdf (see Appendix D). A 30-day
Federal Register Notice published in the Federal Register on April 1, 2021, 86 FR 17153.
ACL received comments from two organizations and from two individuals about the NSOAAP. One
organization submitted multiple (10 comments). ACL reviewed all of the comments. The comment from
one of the individuals was not relevant. For ease of review, the remaining comments and their responses
have been grouped by topic or issue. The ACL responses for each topic/issue are detailed in Table A-1:

Table A-1

60-Day Federal Register Comments and ACL Responses

Topic/Issue
Food insecurity
in older adults

Risk of
malnutrition

Medicallytailored meals
for participants
requiring
special diets

Comment
“We support the inclusion of the USDA module to
provide national estimates of the rate of food
insecurity among OAA program participants. We
recommend this module be continuously included in
future administration of this survey.”
“We suggest that ACL consider adding malnutrition
screening questions in addition to the USDA
module’s food insecurity questions, such as:
• Do you ever eat only one meal daily?”
• Do limits on chewing, swallowing or physical
mobility ever prevent you from eating your homedelivered meals, even though you may be hungry?”
• Do limits on chewing, swallowing or physical
mobility ever prevent you from getting to your local
congregate meal site and eating your meal, even
though you may be hungry?”

ACL Response
ACL concurs and plans to
maintain the USDA module and
associated questions for the
foreseeable future.

“We suggest that ACL consider adding a question
about the need for therapeutic diets or texturemodified meals to better understand the needs of
participants as it relates to medically tailored
meals.”

ACL recognizes the importance of
capturing data on the capability
of OAA nutrition programs to
accommodate special diets. ACL
will call upon nutrition experts to
make recommendations and
inform a redesign of future
NSOAAP collection efforts.

ACL recognizes the importance of
reducing and assessing risk for
malnutrition. However, further
deliberation is needed to ensure
that we select the most
appropriate and universally
accepted language. ACL will call
upon the expertise of a nutrition
workgroup to make
recommendations to ACL on
selecting the best language to
use. The workgroup’s
recommendation will inform a
redesign of future NSOAAP
survey collection efforts.

Ethnic and
cultural
barriers to
communication
and nutritional
preferences

“We suggest that ACL consider including a question
about communication barriers to both the
congregate and home-delivered meals modules,
such as:
• Do you have language or cultural barriers to
talking with staff at your congregate meal site/ your
home delivery staff?
We also suggest that ACL consider adding a question
to both the congregate and home-delivered meals
modules about meals meeting cultural preferences.

Nutrition
counselor:
Rephrase
question to
improve clarity

Modify item
response in
nutrition
modules to
include
positive as well
as negative
changes.
Consistent
language in
meals
program.

“SVC1(k) asks whether the respondent has access to
a “nutrition counselor” who is providing dietary
advice based on the respondent’s condition,
medications, and related factors. We question why
the survey would not specify “a qualified nutrition
professional such as a registered dietitian” (or
registered dietitian nutritionist), since these
professionals are the most qualified to answer such
questions. Moreover, in 28 states, only licensed
professionals are legally eligible to provide such
advice. The term “nutrition counselor” allows for
substantial subjective interpretations, and could
theoretically include food service staff or other
program participants who may be providing such
advice against state law.”
“We note that the survey asks about changes in
meals, but almost all coding options for the
interviewer are about reductions or negative
changes with few opportunities for interviewers to
code any positive changes reported by participants.
In addition to coding for both reductions and
improvements in quality of the food, we
recommend adding the corresponding “positive”
option for all other codes. “
“Ensure that consistent language is used to describe
the program, particularly for congregate or senior
dining meals. Some questions use the term “meals
program” while others use the term “lunch
program” or, generically, “this service”, including
CNR20-23 where three different terms are used
across four consecutive questions. This also applies
to SVC1 question in Additional Services module. We
recommend using the term “meals program” unless
exclusively referring to lunch, as some programs
serve breakfast or dinner meals rather than lunch
meals.”

ACL recognizes that ethnic and
cultural barriers may affect
participants in the nutrition
programs. ACL will call upon
nutrition experts to make
recommendations and inform a
redesign of future NSOAAP
collection efforts.
ACL is considering a special
topical module related to equity
and underserved populations.
ACL recognizes “nutrition
counselor” may offer subjective
responses. However,
respondents may not know if the
qualifications of the person
providing dietary advice. ACL will
call upon nutrition experts to
make recommendations and
inform a redesign of future
NSOAAP collection efforts. The
use of terminology for this item
will be tested.

ACL concurs with this suggested
change. The requested change
has been made to the survey
instrument.

ACL recognizes that the language
used to describe the meals
programs may need to be revised
to be more consistent. ACL will
call upon nutrition experts to
make recommendations and
inform a redesign of future
NSOAAP collection efforts.
The term “meals program”
throughout due to the variety of

Living
independently

Context of
“secure”

“SVC3 asks about continuing to “live independently”
vs. “living at home” (as they do in CS15, CNR23,
HNR28, HC9 and TR20). The terminology “living
independently” is preferred. Simply continuing to
live “at home” does not mean that the person is
living independently, is living in their own home (vs
that of a relative), or has autonomy over where he
or she lives.”
“SVC3(b) should be more specific with regard to the
context of “secure.” We are unsure whether the
context is financial, food-based, or related to
physical safety.”

Multiple meals

“HNR5 should be re-phrased to reflect the fact that
many HDM clients receive more than one meal and
may consume multiple HDMs in a day.”

Care recipients
under age 60
with dementia

The 2020 reauthorization of OAA allows “individuals
living with dementia under the age of 60 to access
certain OAA supports like nutritional services and
respite care through the National Family Caregiver
Support program. We respectfully request that ACL
analyze the data collected on these younger
individuals and the services they receive so that
those services can be tailored and improved.”
The advocacy organizations “support ACL's request
to add an emergency preparedness module to the
survey…”.

Emergency
preparedness

Question on
participant sex
(gender
identity)

“I encourage the modification of the questions
about participant sex to include response options
(which are recorded but not verbally offered as
options) to include "transgender" and or "other"
with a write-in option.
The questions this relates to are: DE1 (DEGENDR);
CGC (CGPMF); CG83 (CGPMF) - both of the last have

food services during the COVID19 pandemic.
ACL concurs with this suggested
change. The requested change
has been made to the survey
instrument.

The question refers to how
participants feel about additional
services that they or their care
recipient receive.

ACL recognizes that the use of
the word “secure” may be
ambiguous. ACL will call upon
experts in the aging network to
make recommendations to
inform a redesign of future
NSOAAP collection efforts.
ACL recognizes that the question
may need to be modified. ACL
will call upon nutrition experts to
make recommendations and
inform a redesign of future
NSOAAP collection efforts.
While ACL recognizes the value of
collecting data on care recipients
of the NFCSP who are under 60,
that is not the focus of the
NSOAAP. The focus of the
NSOAAP is the service recipients,
that is, the caregivers.
ACL is not going to add this
module for the 2021
administration but still plans to
use it in the future.
In order to improve demographic
data collection related to the
LGBT community, ACL is
supporting the Measuring Sex,
Gender Identity, and Sexual
Orientation for the National
Institutes of Health an ad hoc
panel of the National Academies

the same variable labels and this should be
corrected in the survey construction.”

of Sciences, Engineering, and
Medicine which will review
current measures and the
methodological issues related to
measuring sex as a non-binary
construct, gender identity, and
sexual orientation. The panel will
produce a consensus report
which is expected in December
2021. ACL will use the report as a
foundation for testing new
survey questions and
administrative data elements.
The variable label in the survey
instrument for CGPMF was
corrected to RGENDER.

Efforts to Consult Outside the Agency
For updates to the 2019 survey instrument, ACL/AoA called upon the expertise of a work group to review
NSOAAP data collection tools and to make recommendations to ACL on selecting the best language to
use for revising questions in the survey instruments. The NSOAAP work group was comprised of experts
on aging data and survey methodology. The work group’s recommendation will inform a redesign of
future NSOAAP survey collection efforts.
For the addition of a special one-time 2021 module on questions related to COVID-19, ACL/AoA
convened a new advisory workgroup consisting of members from different State Units on Aging (SUAs),
Area Agencies on Aging (AAAs), academia and advocacy organizations on nutrition, aging, and family
caregiving. The advisory workgroup members were divided into three subgroups focusing on nutrition,
well-being and other services (transportation, case management, and homemaker services), and family
caregiving. Workgroup members discussed, evaluated, and ranked proposed COVID-related questions.
Through the result of the workgroup members’ voting and prioritization, a final selection of 10-13
questions by service category resulted in the final COVID-19 special module for 2021.
The majority of the remaining questions in the survey instruments for this proposed information
collection are based on those developed by ACL/AoA POMP grantees representing State Units on Aging
and AAAs. POMP grantees who have worked on the survey instruments include state and local level
representatives from Arizona, Florida, Georgia, Massachusetts, New York, North Carolina, and Ohio. The
development of the survey instruments has been an iterative process. There were no areas of disagreement
during the latest POMP revisions.
The POMP grantees tested the instruments with service recipients at the local AAA-level using several
methods:
1. Field-tested the survey instruments with a sample of service recipients and revised the
instruments based on their experience.

2. Conducted cognitive testing to ensure that the items on the survey instruments were interpreted as
intended.
3. Conducted validity testing on the survey instruments.
Westat (the contractor) has also consulted representatives from different State Units on Aging to develop
and test the instructions and procedures for generating client lists used for sampling. The state
representatives who have reviewed the instructions and procedures include:




Robin Tofil, Connecticut Department of Social Services, Aging Services Division
Jim Burd, Pennsylvania Department of Aging
Leonard Eshmont, Virginia Department for the Aging