June 24, 2016
USDA 1994 Program
Office of Advocacy and Outreach
1400 Independence Avenue SW
Mail Stop 0601
Washington, DC 20250
Dear Mr. Shorty,
The Academy of Nutrition and Dietetics (the "Academy") appreciates the opportunity to submit these comments to the U.S. Department of Agriculture (USDA) related to its April 25, 2016 notice and request for comments regarding the 1994 Tribal Scholars Program. Representing more than 100,000 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 and is committed to improving the nation's health through food and nutrition across the lifecycle. Every day we work with Americans in all walks of life — from prenatal care through end of life care — providing nutrition care services and conducting nutrition research. Our members serve in numerous roles improving the health of native populations in community, clinical, government, and managerial settings.
The Academy strongly supports this data collection regarding the 1994 Tribal Scholars Program and recognizes its value in providing important opportunities for exceptional American Indian and Alaska Natives (AI/ANs) to study agriculture, food science and nutrition and gain important paid work experience.
A. Focusing on the Right Populations
Native populations are disproportionately affected by nutrition-related chronic diseases and conditions. "As with overweight and obesity, AI/ANs are disproportionately affected by diabetes, with some estimates suggesting that AI/ANs are 2.3 times more likely to have diabetes than are individuals in the U.S. general population. Furthermore, approximately 16.5 percent of the total AI/AN adult population served by the IHS have been diagnosed with diabetes, which is twice the diagnosed rate among non-Hispanic whites in the United States."2 In addition, "American Indian (AI) and Alaska Native (AN) children have approximately twice the levels of food insecurity, obesity, and Type II diabetes, relative to the averages for all U.S. children of similar ages."3
Poverty remains a critical problem among Native Americans and particularly among Native Americans living on reservations. AI/ANs living on reservations have a 39% poverty rate and those not on a reservation have a 26% poverty rate; these rates are the highest among any race in the United States. For these individuals and families in poverty, "[l]imited funds mean limited access to nutritious foods such as fresh fruits and vegetables or whole grain carbohydrates, which are often more expensive than commodity goods like flour or shortening."4
Many AI/ANs also lack access to health care options, with 23% of the population not possessing health insurance in 2012 and 38% relying on Medicaid for insurance.5 As one commentator notes, "Given this reality of severely underfunded healthcare services, the need to focus on preventive healthcare measures (e.g., healthful eating, exercise, routine care) becomes all the more vital in American Indian communities."6 The 1994 Tribal Scholars Program is one element of a solution, as it enables dynamic, engaged students with an insiders' perspective to promote the consumption of local and traditional foods and to integrate their own local culture and traditions into public health policy.
B. Impact of 1994 Institutions and the Tribal Scholars Program
The 1994 Tribal Scholars Program provides needed scholarship funds for students studying to become registered dietitian nutritionists or join other professions in the field of food and nutrition. In addition, Extension Programs at 1994 institutions provide education, training and other community services that cost-effectively improve health. Because scholarship recipients interested in becoming registered dietitian nutritionists are part of the same native populations they will eventually work with, many experts believe these native populations would be more inclined to listen to health advice.7
Diabetes prevention remains a particular focus of 1994 institutions, with some institutions such as United Tribes Technical College in North Dakota creating culturally competent resources such as their "Diabetes Education Center that provides theory and practice in wellness, food science, food safety, and community nutrition."8 United Tribes Technical College is also preventing "food-borne illnesses, reducing health costs, increasing worker productivity, and building stronger communities. A study that included North Dakota found an $8.82 return on every $1 invested in nutrition education."9 "Sisseton Wahpeton College has integrated education, extension, and research projects into a nutrition and dietetics program. The extension component delivers training to 8 to 13 year-old youth in basic nutrition, horticulture, food preservation, and food safety."10
The Academy sincerely appreciates the opportunity to support the 1994 Tribal Scholars Program, which will help improve the health status of the American Indian and Alaska Native (AI/AN) people by providing culturally competent health care and preventive health services. 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 "Addressing Child Hunger and Obesity in Indian Country: Report to Congress" Mathematica Policy Research. January 12, 2012. Accessed June 22, 2016. (Internal citations omitted.)
3 "Addressing Child Hunger and Obesity in Indian Country: Report to Congress" Mathematica Policy Research. January 12, 2012. Accessed June 22, 2016. (Internal citations omitted.)
4 Goetz, G. (2012, March 5) Nutrition a Pressing Concern for American Indians. Food Safety News.
5 "American Indian/Alaska Native Profile" The Office of Minority Health. September 17, 2012. Accessed June 22, 2016.
6 Kovacs, E and Ip, M. Address Health Disparities in American Indians — Cultivating Traditions and Promoting Nutrition Can Make a Difference. Today's Dietitian. Vol. 13 No. 6 P. 36.
8 Phillips, J. A Tribal College Land Grant Perspective: Changing the Conversation. Accessed June 22, 2016.
9 1994s Extension. Association of Public and Land-Grant Universities (February 2012). Accessed June 22, 2016.
10 Phillips, J. A Tribal College Land Grant Perspective: Changing the Conversation. Accessed June 22, 2016.