With the release of the 2025–2030 Dietary Guidelines for Americans (DGA) and the recent Centers for Medicare & Medicaid Services (CMS) memorandum reinforcing expectations for food and nutrition services in acute care, there has been increased attention on how nutrition guidance is interpreted and applied across healthcare settings.
As a team of Registered Dietitians at DiningRD, we recognize that nutrition science – and how it is interpreted and applied – continues to evolve across senior living.
Let’s take a look at a few key areas.
What’s Emphasized in the 2025-2030 Dietary Guidelines
Dietary guidelines are a public tool meant to be interpreted at the population level, giving guidance to Americans on strategies for overall health. The most current dietary guidelines emphasize:
- Dietary patterns over daily minimums
Nutrition is evaluated across the full dietary pattern – not just single-day targets.
- Prioritization of high-quality, nutrient-dense protein foods
Emphasis on including a variety of protein sources at meals, including animal proteins such as eggs, poultry, seafood, and red meat, alongside plant-based options such as beans, peas, lentils, legumes, nuts, and seeds. Processed meats are limited.
- Whole fruit over juice
Juice is limited; whole fruit is preferred for fiber and nutrient density.
- Vegetable variety across subgroups
Increased focus on intentional inclusion of dark green vegetables (such as spinach, kale, and broccoli), red and orange vegetables (such as carrots, sweet potatoes, and tomatoes), legumes (beans and lentils), starchy vegetables (corn, peas, potatoes), and other vegetables across the menu cycle to ensure a broad spectrum of nutrients.
- Whole grains over refined grains
Prioritizing 100% whole grains and meeting fiber requirements, while limiting processed, refined grains.
- Limits on added sugars and sodium
Avoiding sugar-sweetened beverages and highly processed foods with clearer boundaries and parameters for added-sugars to support long-term health.
- Eating the right amount for a person’s individual needs
Tailoring calorie needs to the individual while supporting appropriate portions and overall intake based on health status and goals.
These areas reinforce a long-standing principle in senior nutrition: adequacy and balance are achieved over time – not in a single meal.
What This Means for Our Menu Planning Approach
At DiningRD, we have long evaluated menus using both daily minimum planning benchmarks and overall dietary pattern analysis across the menu cycle. Structured daily minimums provide operational consistency and an adequate baseline for most older adults, while full-cycle review ensures alignment with broader nutrition standards.
Many of the areas emphasized in the updated DGA reflect practices we have already implemented – particularly through enhancements made over the past year within our Approve My Menu feature.
Over the last year, we have:
- • Continued using daily minimum planning benchmarks while strengthening cycle-based evaluation, with nutrient analysis across the full menu cycle.
- • Prioritized whole grains more intentionally, with increased attention to dietary fiber adequacy to support overall diet quality and daily fiber targets.
- • Continued the use of dairy or fortified alternatives as the standard offering.
- • Increased intentional inclusion of vegetable subgroups across menu cycles.
- • Continued to reduce processed meats across menus.
- • Strengthened documentation and review processes to support survey readiness.
Through Approve My Menu, communities receive structured menu review aligned with:
- • Current national dietary guidelines and best practices
- • 42 CFR §483.60 (Food and Nutrition Services)
- • Appendix PP of the State Operations Manual (interpretive guidance)
- • Professional standards of practice
- • Evidence-based nutrition benchmarks
In summary, recent DGA updates are part of our balanced framework, and are considered in conjunction with other regulatory standards such as the Dietary Reference Intakes (DRIs) from the National Institutes of Health, CMS regulations, and professional standards of practice to build menus that are:
✔ Nutritionally sound
✔ Operationally practical
✔ Survey-ready
✔ Resident-centered
A Note on Evolving Protein Recommendations
An area currently receiving increased attention is protein intake for older adults.
While the long-standing Recommended Dietary Allowance (RDA) for healthy adults remains at 0.8 g/kg body weight per day, the new Dietary Guidelines recommend higher protein targets for older adults – 1.2–1.6 g/kg/day, depending on clinical status.
In senior living settings, protein needs are individualized based on medical condition, weight stability, functional goals, and overall health status. Our menu-planning approach supports adequate protein distribution throughout the day while allowing for individualized adjustments through care planning. We recognize the ongoing evolution in protein guidance for older adults and will continue to monitor emerging research, while acknowledging that many clinical conditions in aging populations already support higher protein provision, such as maintaining skin integrity and prevention of sarcopenia (muscle loss).
A Note on Saturated Fat and Dairy Discussions
Recent public conversations have also brought increased attention to dietary fat sources – particularly those higher in saturated fat – including whole milk, traditional fats like beef tallow, and red meat. While these discussions reflect evolving dialogue in nutrition science and food culture, at this time current federal dietary regulations continue to recommend moderation of saturated fats with a limit of less than ten percent of total dietary calories from saturated fat.
In senior living settings, decisions about fat sources and dairy selection are typically evaluated by clinical assessment, resident preference, and individualized care planning. For residents at risk of weight loss or malnutrition, higher-fat options from a variety of fat sources may be appropriate. For others managing cardiovascular risk, lower-saturated-fat approaches may be more optimal.
Based on this, our current menus continue to include low-fat dairy and fortified alternatives as standard offerings, recognizing many senior living communities routinely offer whole milk and other whole fat dairy products. Standards of practice and evidenced- based practice point to individualizing selections based on resident needs and preferences for best acceptance.
CMS Alignment: Expanding Focus on Food and Nutrition Services
In addition to the updated Dietary Guidelines, CMS recently issued a memorandum reinforcing expectations for hospital food and nutrition services in alignment with the 2025–2030 Dietary Guidelines.
Enforcement of dietary departments and their offerings will continue to occur through the existing CMS survey process, guided by the Conditions of Participation and interpretive guidelines in the State Operations Manual – and at this time, these accompanying regulations have not changed. In short, the recent CMS memo does not create new regulations, but it does signal where enforcement is heading.
We recognize the ongoing discussion within the dietetics and healthcare community on best approaches for acute care settings, particularly given the shorter stays and the focus on acute treatment. Menu systems used in this setting are individualized to patient care needs and prioritize nutritional intake and prevention of malnutrition as critical first priorities in nutritional care. Many acute conditions temporarily limit a patient’s ability to tolerate or consume foods recommended for long-term health.
Registered Dietitians in acute care and critical access hospital settings routinely provide education for patients on nutritional plans for longterm health and management of chronic disease such as diabetes, cardiovascular disease and obesity, which can be achieved when the acute illness has resolved and is included in discharge counseling and information.
Key areas of emphasis in the CMS memo that reinforce the new DGAs include:
- • Limiting ultra-processed foods, sugar-sweetened beverages, and refined carbohydrates.
- • Prioritizing whole, minimally processed foods and fiber-rich options such as whole grains.
- • Incorporating a variety of nutrient-dense foods, including fruits, vegetables, legumes, nuts, seeds, and protein sources.
- • Strengthening the role of nutrition as part of interdisciplinary care and quality improvement efforts.
What This Means in Practice
A common question is how these recommendations will be interpreted at the operational and survey level in a hospital or acute-care setting, particularly around topics such as whole grains or the elimination of processed foods.
Importantly, the CMS memo does signal a clear expectation to move toward higher-quality, less processed dietary patterns – including an increased use of whole grains and nutrient-dense foods. However, it does not establish specific numeric thresholds for any food group. Instead, surveyors are expected to evaluate whether organizations are making reasonable, evidence-based efforts to improve overall dietary quality while maintaining patient-centered care.
In senior living and long-term care settings, a best practice of offering a range of nutritionally appropriate options continues.
Allowing residents the ability to choose foods based on preference, tolerance, and individual needs gives communities the ability to:
- • Provide a range of healthy options that align with a healthy dietary pattern.
- • Maintain flexibility for resident acceptance and satisfaction.
- • Support adequate intake for residents by allowing them to choose which foods they would like to eat, which remains a primary clinical priority.
Technology can also play a role in allowing optimal choices, with tools such as DiningManager’s TableSide supporting real-time ordering and allowing residents to select from a range of compliant, nutritionally appropriate menu options.
A Final Note
The dietary guidelines are developed for the general population and are meant to be used as an overarching guide for a healthy eating pattern.
Older adults in long-term care settings, and in particular skilled nursing communities, often live with chronic conditions, changes in appetite, and swallowing considerations. In skilled nursing and assisted living communities, nutrition care must align not only with federal guidance, but also within the broader realities of resident care, honoring cultural preferences and deeply personal food traditions, and meeting standards for:
- • 42 CFR §483.60 and CMS survey expectations
- • Individualized care planning
- • Clinical judgment
- • Resident choice, Self-Determination (F561)
- • Functional status and quality of life
The role of the Registered Dietitian in guiding menu development, monitoring nutritional adequacy, and individualizing recommendations based on clinical status, preferences, and outcomes is especially important in senior living and long-term care. The risk of undernutrition and malnutrition in older adults is significant, and it is critical to ensure regulatory alignment supports resident-centered care and quality of life.
DiningRD menus provide a strong foundation that meet regulatory requirements and from there, tools such as MealCard and TableSide allow for personalization at the individual resident level – supporting preferences, therapeutic needs, substitutions, and real-time changes in condition.
No. The Dietary Guidelines and CMS memo do not require immediate or drastic changes. Instead, they reinforce a direction toward improved dietary quality over time.
The CMS memo for hospitals provides an example of replacing all refined grains with 100% whole grains as part of improving overall dietary quality, but at this time, accompanying regulations do not establish a specific requirement for 100% whole grain offerings.
Menus should be designed to support dietary fiber adequacy in alignment with current nutrition guidance. The Dietary Guidelines for Americans recommend approximately 22–28 grams of fiber per day for women and 28–34 grams per day for men, depending on age, while the Dietary Reference Intakes (DRIs) provide similar targets based on calorie intake.
Communities should be able to demonstrate reasonable, evidence-based efforts to increase whole grains and other fiber-rich foods across the menu cycle. Documentation, menu review, and dietitian oversight are key to supporting this approach.
Not necessarily. The CMS memo for hospitals includes examples of dietary targets, such as limits on added sugars, to illustrate alignment with current nutrition guidance. At this time, these are not established as strict per-meal requirements in regulations, but they do reflect the direction of expectations.
Communities should be able to demonstrate that menu offerings align with evidence-based nutrition standards, including thoughtful efforts to manage added sugars, improve dietary quality, and support resident needs. Documentation, menu review, and dietitian oversight are key to supporting this approach. Diet manuals should document short-term diets needed for specific clinical care such as clear or full liquid diets.
Enforcement of the CMS memo for hospitals will continue through the existing CMS survey process. Surveyors will evaluate overall dietary quality, documentation, and whether a community’s approach aligns with current nutrition science.
Resident choice remains essential and mandated under CMS guidelines. Communities should offer a range of nutritionally appropriate options while allowing residents to select foods based on preference and need.
TableSide allows residents to choose from compliant, nutritionally appropriate options in real time, supporting both dietary quality and resident satisfaction.
Registered Dietitians play a critical role in helping communities navigate evolving nutrition guidance while maintaining regulatory compliance. They support menu development and review, ensure nutritional adequacy across the menu cycle, and provide documentation aligned with CMS expectations.
Dietitians also individualize nutrition interventions based on resident needs, preferences, and clinical conditions – helping communities balance regulatory requirements with resident-centered care.
Not necessarily. Protein needs vary by individual. While higher protein targets are being discussed for older adults, protein needs should be assessed by a registered dietitian and intake should be determined based on clinical condition, goals, and tolerance.
Approve My Menu from DiningRD provides structured menu review, documentation, and validation that menus meet regulatory expectations and evidence-based standards across the full menu cycle.
This information reflects current guidelines and regulatory considerations at the time of publication. DiningRD will continue to monitor updates and evolving standards to ensure our approach remains aligned with the most current evidence and requirements.