October 7, 2019
Food and Nutrition Service
U.S. Department of Agriculture
3101 Park Center Drive
Alexandria, VA 22302
RE: Proposed Collection; Comment Request-Reasons for Underredemption of the WIC Cash-Value Benefit (2019-17016)
Dear Ms. Morgan:
The Academy of Nutrition and Dietetics (the “Academy”) appreciates the opportunity to submit comments to the USDA in response to its request for feedback on the proposed collection on the underredemption of the WIC cash-value benefit originally published in the Federal Register on August 8, 2019 (84 FR 38937). Representing more than 107,000 registered dietitian nutritionists (RDNs),1 nutrition and dietetic technicians, registered (NDTRs), and advanced-degree nutritionists, the Academy is the largest association of food and nutrition professionals in the United States. We are committed to accelerating improvements in the nation’s health and well-being through food and nutrition.
The Academy supports efforts to collect information in order to make data-driven decisions about policies and programs. Better understanding the reasons that WIC recipients are not fully redeeming their cash-value benefits would be helpful in adjusting policies to ensure the greatest access to healthy fruits and vegetables. However, the Academy suggests that best practices be shared and elevated without limiting local flexibility, especially as it relates to the form of fruit and vegetables covered in the program. It is important to acknowledge state and regional differences and allow for tailoring of program delivery.
Most Americans are missing the mark when it comes to meeting the dietary patterns recommended through the Dietary Guidelines for Americans. Diet quality is particularly important for pregnant and post-partum women as well as children. To develop the 2009 WIC food package, the Institutes of Medicine reviewed data to see which nutrients are lacking in the diets of mothers and children.21Based on this review, the cash-value benefit was introduced for the first time to promote the consumption of fruits and vegetables. Research suggests that the introduction of this benefit has increased purchases of fruits and vegetables.3 The Academy supports efforts to improve the impact and intention of the cash-value benefit to promote fruit and vegetable consumption by examining what may be contributing to underredemption.
Academy members have expressed the need for caution when disseminating best practices and how that may impact local flexibility in delivering the cash-value benefit. For example, some states have limited the cash-value benefit to only fresh fruits and vegetables while other states have found that allowing for a larger range of fruits and vegetables, including canned and frozen varieties, has helped improve redemption rates. The Academy urges USDA to consider the variation among states, clinics and participants when determining how best to apply study data and to leave decisions on program delivery policies with local entities.
The Academy of Nutrition and Dietetics appreciates the opportunity to submit comments and applauds the USDA for making efforts to collect data which will help support efforts to improve fruit and vegetable consumption for WIC participants. Please contact either Jeanne Blankenship at 312/899-1730 or firstname.lastname@example.org, or Liz Campbell at 202/775-8277 ext. 6021 or email@example.com with any questions or requests for additional information.
Jeanne Blankenship, MS, RDN
Policy Initiatives and Advocacy
Academy of Nutrition and Dietetics
Liz Campbell, MA, RDN
Legislative & Government Affairs
Academy of Nutrition and Dietetics
1The Academy 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.
2The Academy of Nutrition and Dietetics CNR priorities. https://www.eatrightpro.org/-/media/eatrightpro-files/advocacy/legislation/academycnrrecommendations2019.pdf?la=en&hash=2ED58585C7C2565D281EC45C272759F11B8E230F Accessed on October 7, 2019.
3 Incentivizing fruit and vegetable purchases among participants in the Special Supplemental Nutrition Program for Women, Infants, and Children. https://pdfs.semanticscholar.org/36a6/c38c6a27fdf22e332703933eb548519d9cc7.pdf. Accessed on October 7, 2019.