November 7, 2016
Food and Nutrition Service
U.S. Department of Agriculture
3101 Park Center Drive, Room 1014
Alexandria, VA 22302
Re: Comment Request-Third National Survey of WIC Participants (NSWP-III) (OMB No. Not yet assigned)
Dear Dr. Panzera,
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit comments to the United States Department of Agriculture (USDA) related to its September 8, 2016 information collection, "Comment Request-Third National Survey of WIC Participants (NSWP-III)." Representing more than 100,000 registered dietitian nutritionists (RDNs),1 dietetic technicians, registered (DTRs), and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States and is committed to improving the nation’s health through food and nutrition across the lifecycle.
The Academy supports NSWP-III and believes that, as with NSWP-II, it is critical "to gather information on participant characteristics, the policies and operations of State and local WIC agencies, and the level of improper payments to recipients."2 The information gathered in these surveys is highly valuable to effective and efficient performance of the WIC program and has significant practical utility for both USDA and the public, particularly in light of the decrease in participation nationwide.
Many Academy members work in community settings with WIC participants and at WIC agencies, and respectfully offer the following recommendations for minimizing the burden of the collection and enhancing the quality, utility, and clarity of the information to be collected:
- A web-based survey with flexible and sufficient response time and even text notification with a link to the survey would ease the burden of time in the clinic setting for participants and would address a millennial’s most likely preferred means of communication. Repeated notifications and the ability to partially complete and return to the survey for later completion (with reminders to do so) should also be considered.
- The web-based survey for State & Local WIC staff to complete is an excellent methodology to minimize burden with the respondents being able to partially complete and then to return to complete the survey over at least a one month time frame.
- For the WIC participants responding, the best methodology is the use of a smartphone app-based survey, not clinic, home or phone which can be perceived as too intrusive. Many participants today want to be in and out of the WIC clinic as quickly as possible and having them fill out a survey in the clinic would add to their stress of being in the clinic longer than they have planned or scheduled. It is very hard to reach participants by phone and a home visit might be perceived in a suspicious manner, causing distress to the WIC participants.
- The survey might benefit from evaluation of millennial's preferred means of communication. A WIC Colorado research group determined that phone calls were not effective and participants did not want to talk about themselves or their families by phone with total strangers.3 Texting is very popular and received positively by the WIC participants. Thus, texting a survey link to a WIC participant would be received very well.
- The survey questions need to be clear as to the information that is being requested so that there is no ambiguity or doubt regarding what is being requested. The questions could be tested to determine a respondent's understanding of the intent of the question before incorporating into the final survey, including confirmation that the respondent’s answer will not impact receipt of WIC benefits.
- USDA should consider reducing the number of questions and simplifying them as much as possible. In addition, some Academy members are concerned there is presently insufficient time for the responders to answer all questions.
- We encourage the use of a sufficient number of data analysts and epidemiologists for analyzing the responses and information for practical application and improvement of WIC services for all populations across the nation. Survey questions could also be structured to allow comparison with other USDA and federal studies, such as the National Food Study Pilot.
- NSWP-III should collect data sufficient to assess whether record decreases in participant caseload across the nation could be due, in part, to errors made in the income determination related to participants being incorrectly identified as over income and denied participation. The data collected from the State and Local WIC staff could provide information on potential errors in determining if participants meet the income criteria to qualify.
The Academy sincerely appreciates the opportunity to offer comments regarding NSWP-III. Please contact either Jeanne Blankenship by telephone at 312-899-1730 or by email at firstname.lastname@example.org or Pepin Tuma by telephone at 202-775-8277 ext. 6001 or by email at email@example.com 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 National Survey of WIC Participants Ii Report Summary. United States Department of Agriculture Food and Nutrition Research Service website. Accessed November 2, 2016.
3 "Informing Outreach and Increasing Awareness of Nutrition Programs: Research Report and Communication Recommendations." Report to Colorado Department of Public Health and Environment, written by Joining Vision and Action and Merritt+Grace. August 2016.