Comments to FNS re: SNAP Retailer Transaction Data

September 8, 2014
Vicky T. Robinson
Acting Chief, Retailer Management and Issuance Branch
U.S. Department of Agriculture
Retail Policy and Management Division,
Food and Nutrition Service
3101 Park Center Drive, Room 426
Alexandria, VA 22302

Re: Request for Information: Supplemental Nutrition Assistance Program (SNAP); Retailer Transaction Data

Dear Ms. Robinson:

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]: Enhancing Retail Food Store Eligibility” published August 20, 2013. The Academy is the world’s largest organization of food and nutrition professionals, representing more than 90,000 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 release of certain redemption data (in a manner that safeguards individual and retailer confidentiality and retailer trade secrets) can simultaneously (1) assist with the design, evaluation, and provision of nutrition education interventions, (2) ensure that SNAP retailers provide SNAP participants with access to healthy, nutrient-dense foods; and (3) potentially reduce fraud in the SNAP program.

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

Enhance Design, Evaluation, and Provision of Nutrition Education Interventions
Given the significant public health need, there is tremendous benefit to tracking changes in how SNAP dollars are spent so that all stakeholders, including those working in SNAP-Ed and the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), can work with retailers more knowledgeably to achieve national health objectives. At present, significant efforts are being made across the country to educate low-income consumers, conduct public/private marketing campaigns, and employ a variety of large-scale efforts to help low-income consumers, including SNAP clients, make healthier choices. However, the lack of available sales data prevents educators, public health practitioners, and the public from ascertaining the effectiveness of their efforts and what methods, or combination of efforts, are most impactful. This lack of useful data unfairly disadvantages the public programs performing this work. In addition, there are many variables that influence shopping choices, so basic demographics and store characteristics are needed to interpret the data fairly, which can be collected and disseminated in a manner that protects trade secrets and retailer confidentiality.

SNAP should seek synergies with WIC, recognizing the inherent differences in SNAP, which does not require purchase of a particular package of healthy foods. SNAP-Ed and WIC nutrition education can help recipients learn how to use foods effectively, which has been shown to lead to a healthier selection and use of SNAP foods as a young family grows. SNAP-Ed can also enhance education programs to encourage use of fresh fruits and vegetables in multiple simple recipes with few ingredients (as has successfully been done in the new www.eatfresh.org website). Making this information available seasonally for local and fresh products from USDA or a derivative, such as Cooperative Extension, would additionally help nutrition education and promote healthy food purchase.

We encourage FNS to work with retailers to address issues such as budgeting, sourcing, product selection and handling, and technology. Training retailers has been a major success of the WIC food package change, and the Academy anticipates similarly effective results could be realized with SNAP-Ed training for retailers. Members of the Association of SNAP-Ed Nutrition Networks and Other Implementing Agencies (ASNNA)—many of whom are RDNs—are qualified and interested in working with FNS to provide effective training and technical assistance to retailers who want to offer a greater supply of affordable, healthy fresh food consistent with the DGA.

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 DGA and 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
    1. Whether the recent authorization of these stores facilitated previously unavailable access to a SNAP-eligible retailer;
    2. Whether these newly authorized stores meet or exceed current and proposed eligibility standards; and
    3. Whether these stores have a statistically significant degree of trafficking or other fraud compared to supermarkets, superstores, or large grocers.
  • It is imperative to understand the extent to which these retailers actually effectuate the purpose of SNAP to provide access to a variety of healthy, nutritious foods without compromising the integrity of the program.
  • Noting that approximately 130,0009 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
    1. Whether these stores facilitated previously unavailable access to a SNAP-eligible retailer;
    2. Whether these newly authorized stores meet or exceed current and proposed eligibility standards for SNAP and current eligibility standards for WIC; and
    3. Whether these stores have a statistically significant degree of trafficking or other fraud compared to WIC-eligible stores, supermarkets, superstores, or large grocers.
    It is imperative to understand the extent to which these retailers actually effectuate the purpose of SNAP to provide access to a variety of healthy, nutritious foods without compromising the integrity of the program.

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 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.

The Academy is grateful for the opportunity to comment on initiatives to improve this critical program that impacts our citizens’ food insecurity and nutrition status. Please contact either Mary Pat Raimondi at 202-775-8277 ext. 6007 or by email at mraimondi@eatright.org or Pepin Tuma at 202-775-8277 ext. 6001 or by email at ptuma@eatright.org with any questions or requests for additional information.

Sincerely,

Mary Pat Raimondi, MS RDN Vice President, Strategic Policy and Partnerships
Academy of Nutrition and Dietetics

Pepin Andrew Tuma, Esq.
Director, 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. Web site: www.census.gov/main/www/popclock.html. Accessed June 2, 2013.

4 Food Security Status of U.S. Households in 2011. United States Department of Agriculture. Economic Research Service. Web site: www.ers.usda.gov/topics/food-nutrition-assistance/food-security-in-the-us/key-statistics-graphics.aspx. 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.