August 23, 2017
Desk Officer for Agriculture
Office of Information and Regulatory Affairs
Office of Management and Budget (OMB)
Departmental Clearance Office, USDA
OCIO, Mail Stop 7602
Washington, DC 20250-7602
Re: Supplemental Nutrition Assistance Program—Store Applications (OMB Control Number: 0584-0008_
Dear Sir or Madam:
The Academy of Nutrition and Dietetics (the "Academy") is pleased to comment on the United States Department of Agriculture's (USDA's) Food and Nutrition Service's (FNS's) request for information: "Supplemental Nutrition Assistance Program [SNAP]—Store Applications (OMB Control Number: 0584-0008)" published July 24, 2017. The Academy is the world's largest organization of food and nutrition professionals, representing more than 100,000 registered dietitian nutritionists (RDNs),1 registered dietitians (RDs), dietetic technicians, registered (DTRs), and advanced-degree nutritionists. Every day we work with Americans in all walks of life—from prenatal care through old age—providing nutrition care and conducting nutrition research. RDNs, RDs, and DTRs are currently involved in a variety of successful food and water insecurity programs at local, state, and federal levels. We are committed to improving the nation's health and meeting nutrition needs through the lifecycle and work to ensure that all Americans have access to a healthy, safe food supply by leading efforts to reduce food deserts and food swamps and by delivering effective nutrition education programs.
SNAP is a critically important tool for addressing the crisis of food insecurity in America. To the fullest extent permitted under existing law, the Academy is supportive of enhanced transparency and the use of new data collection methods in the SNAP program to assist the administration and enforcement of the Food and Nutrition Act (the "Act"), particularly in effectuating its purpose "to provide for improved levels of nutrition among low-income households."2 The data collection can simultaneously (1) determine the eligibility of retail food stores, wholesale food concern, and food service organizations applying for authorization to accept and redeem SNAP benefits, (2) monitor these firms for continued eligibility, and (3) sanction stores for noncompliance with the Act, which will enable FNS to more easily detect, and thus potentially reduce, fraud and abuse in the SNAP program.
A. Crisis of Food Insecurity in America
Food insecurity in America is a serious public health and economic problem. Of the 316 million people living in America,3 50 million Americans, including 8.6 million children were food insecure in 2011.4 These rates have substantially increased over the last two decades. In 1998, 10.2 percent Americans lived in food-insecure households; in 2011, 14.9 percent of U.S. households were food insecure at some time. Rising rates of childhood obesity and diabetes are signs that a population can be "well-fed" despite being poorly nourished.
The Academy believes that access to food is a basic human need and fundamental right. Food security is the linchpin of healthful living and must be achieved in the United States to improve the health of its citizens and residents.5 Because households undoubtedly experience job transitions, layoffs, and other disruptions regardless of the economy, robust safety net programs are vital to helping U.S. citizens and residents achieve food and nutrition security.6 Adequate funding for food and nutrition assistance programs and nutrition education programs such as SNAP-Ed are vital to maintaining the integrity of the nation's nutrition safety net. More detailed redemption data is vital to enhancing the effectiveness and administration of America's food and nutrition assistance programs.
It is the position of the Academy of Nutrition and Dietetics that systematic and sustained action is needed to achieve food and nutrition security for all in the United States. To eliminate food insecurity, a variety of interventions are needed, including
- adequate funding for and increased utilization of food and nutrition assistance programs,
- inclusion of food and nutrition education in such programs, and innovative programs that promote and support individual and household economic self-sufficiency.7
For too many Americans, SNAP provides — rather than merely supplements — their caloric intake, so enhanced retailer eligibility standards and concomitant education that help maximize the healthiness of food choices is critical.
Food insecurity, however, is only one problem SNAP aims to ameliorate. For too long, our country has failed to sufficiently focus on SNAP's original purpose "to provide for improved levels of nutrition among low-income households."8
B. Specific Data Valuable for the Administration and Enforcement of SNAP
The Academy respectfully suggests that more data is needed to ideally effectively administer and enforce the Act. Specifically:
- All SNAP retailers should submit SNAP sales data as a total and in subcategories aligned with the Dietary Guidelines for Americans and the Healthy People 2020 National Health Objectives. Where appropriate, the subcategories should be harmonized with those of WIC so there is: consistency in defining which foods are counted, maximum utility of the data within states (since WIC data are handled at the state level), and the lowest administrative burden possible for retailers.
- For foods other than those that WIC covers, redemption data should be classified in categories that include at least: salty snacks and sugar-sweetened beverages.
- The aggregate data should ideally be reported monthly by each store with demographic descriptors compiled by usable geographic categories, e.g., census tract, zip code, city, county, region/media market, and state. These should be in terms of total monthly sales for all food on which SNAP dollars may be spent as a denominator and as sales in the food subcategories above. Store categories should be broken out by size, such as the number of cash registers, and by conventional market designations, such as gas stations/convenience stores, produce stores, drug stores, independent supermarkets, and chain supermarkets.
- Retailers may list any nutrition promotion, community service efforts and public/private partnerships in which they are collaborating, including local and state SNAP-Ed retail initiatives, double value programs, foundation and health care initiatives, Fruits & Veggies—More Matters™, Let’s Move—Cities, Towns and Counties, and similar programs.
- Noting the increase of almost 100,000 new stores authorized to redeem SNAP since 2005, the Academy recommends public disclosure of information as to the nature and location of these stores through established reporting systems, specifically
- Whether the recent authorization of these stores facilitated previously unavailable access to a SNAP-eligible retailer;
- Whether these newly authorized stores meet or exceed current and proposed eligibility standards; and
- Whether these stores have a statistically significant degree of trafficking or other fraud compared to supermarkets, superstores, or large grocers.
- Noting that approximately 130,000 stores are authorized to redeem SNAP that are not authorized to redeem WIC, the Academy recommends public disclosure of information as to the nature and location of these stores through established reporting systems, specifically
- Whether these stores facilitated previously unavailable access to a SNAP-eligible retailer;
- Whether these newly authorized stores meet or exceed current and proposed eligibility standards for SNAP and current eligibility standards for WIC; and
- Whether these stores have a statistically significant degree of trafficking or other fraud compared to WIC-eligible stores, supermarkets, superstores, or large grocers.
C. Safeguard Integrity of SNAP and Reduce Fraud
The Academy offers support for more rigorous program oversight to ensure integrity of funds, program effectiveness regarding outcomes, and thus the program itself. FNS should continue its notable efforts to reduce fraud and curb trafficking. Program integrity and good stewardship is correlated to retailers providing sufficient access to healthy foods and sharing data that will enhance nutrition education interventions. As FNS notes, retailers that do not provide sufficient healthful offerings often tend to be those stores that present the greatest integrity challenges for USDA.10 Citing the most recent trafficking study (2009-2011) in the proposed information collection, FNS found that "99.5 percent of all trafficking stores involve retailers other than supermarkets, superstores, and large grocers." (Emphasis in original.)
FNS should continue to provide strategies for easily reporting retailers who either do not meet eligibility standards or engage in fraud, such as a hotline number printed on any SNAP marketing signage within stores. The Academy is supportive of FNS's efforts to clamp down on the practice of retailers barred from SNAP merely changing names of storeowners (so-called straw ownerships) to restore eligibility, and recognize additional legislation may be needed to permanently disqualify repeat offender store locations. We also recommend that monitoring eligible retailers' compliance or risk of non-compliance with staple food and recommend development and implementation of systems that can monitor availability and assessment of quality produce. Simply stocking fresh fruits and vegetables is insufficient if the quality of the produce is compromised. Stocking requirements should be integrated into routine oversight practices, including technology-based and data-driven mechanisms.
The Academy appreciates the opportunity to comment on the proposed data collection. Please contact either Jeanne Blankenship at 312-899-1730 or by email at email@example.com or Pepin Tuma at 202-775-8277 ext. 6001 or by email at firstname.lastname@example.org with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Pepin Andrew Tuma, Esq.
Government & Regulatory Affairs
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.
2 Food Stamp Act of 1964, Pub. L. No. 88-525, 78 Stat. 703 (1964).
3 United States Census. Population clock. Accessed June 2, 2013.
4 Food Security Status of U.S. Households in 2011. United States Department of Agriculture. Economic Research Service. Accessed on June 2, 2013.
5 Holben DH. Position of the American Dietetic Association: Food insecurity in the United States. J Am Diet Assoc. 2010; 110: 1368-1377.
6 Nord M, Andrews M. Reducing Food Insecurity in the United States: Assessing Progress Toward a National Objective. Alexandria, VA: Economic Research Service, US Department of Agriculture; 2002. Food Assistance and Nutrition Research Report No. 26-2.
7 Holben DH. Position of the American Dietetic Association: Food insecurity in the United States. J Am Diet Assoc. 2010; 110: 1368-1377.
8 Food Stamp Act of 1964, Pub. L. No. 88-525, 78 Stat. 703 (1964).
9 Food and Nutrition Service, "Request for Information: Supplemental Nutrition Assistance Program (SNAP), Enhancing Retail Food Store Eligibility," Federal Register, Volume 78, Number 161, August 20, 2013.
10 Food and Nutrition Service, "Request for Information: Supplemental Nutrition Assistance Program (SNAP), Enhancing Retail Food Store Eligibility," Federal Register, Volume 78, Number 161, August 20, 2013.