NYHealth responded to the U.S. Department of Agriculture Food and Nutrition Service request for public comments on proposed changes to WIC (the Special Supplemental Nutrition Program for Women, Infants, and Children). These changes would increase the benefits for fruits and vegetables and provide WIC State agencies with greater flexibility to prescribe and tailor food packages that better meet participants’ diverse needs and preferences.
February 9, 2023
Allison Post, Policy Chief
WIC Administration, Benefits, and Certification Branch, Policy Division
Food and Nutrition Service, U.S. Department of Agriculture
1320 Braddock Place, Alexandria, Virginia 22314
Docket ID: FNS-2022-0007-0001
Re: Special Supplemental Nutrition Program for Women, Infants, and Children: Revisions to the Women, Infants, and Children Food Packages
Dear Ms. Post:
The New York Health Foundation (NYHealth) appreciates the opportunity to comment on the U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS) proposed rule regarding revisions to the women, infants, and children food packages for the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC).
NYHealth is a private foundation that works to improve the health of all New Yorkers, especially people of color and others who have been historically marginalized.[1] Our Healthy Food, Healthy Lives program seeks to advance policies and programs that connect New Yorkers with the food they need to thrive.[2] Maximizing participation in nutrition benefits programs is a core strategy of this program. Our work has provided us with in-depth knowledge of how food insecurity has widespread negative ramifications on the health of individuals and their families, as well as the ways the proposed rule could improve the lives of women, infants, and children in New York.
We support the adoption of the proposed rule, specifically the proposals to increase the Cash-Value Benefit (CVB) for fruits and vegetables and to expand choice within the women, infants, and children food packages. Federal law requires USDA to review the contents of WIC packages every 10 years and update the options to reflect nutrition science, public health concerns, and cultural eating patterns.[3] Increasing the CVB, expanding the number of culturally-relevant food options, and increasing the variety of product sizes available for purchase should improve WIC program participation and, in turn, improve nutrition security for hundreds of thousands of New Yorkers.
Section I of this comment explains how the proposed changes are consistent with federal policy. Section II describes how the proposed changes will benefit New York, potentially increasing participation while decreasing food insecurity. Section III outlines NYHealth’s support for specific provisions.
I. The Proposed Changes Are Consistent with Federal Policy and Updated Recommendations
The proposed changes are both timely and consistent with federal policy. The proposed WIC packages would better align with current recommendations, including the Dietary Guidelines for Americans (DGAs), the national framework for healthy eating that forms the basis of all federal nutrition policy and programs. For instance, existing WIC rules predate the 2020 DGAs, which—for the first time ever—included recommendations for pregnancy, lactation, and the first two years of life.[4] The 2020 DGAs emphasized seafood as an important source of nutrients for women, infants, and children, but seafood is not currently included in the child food package.
The most recent examination of the WIC food packages, conducted in 2017 by the National Academies of Sciences, Engineering, and Medicine (NASEM), also identifies gaps in nutrient intake among the WIC population and articulates actionable steps to align the packages with the DGAs. For example, NASEM recommends increasing the CVB for fruits and vegetables and including seafood in the child food package.[5] USDA’s proposed rule both better aligns the WIC program with the NASEM report recommendations and is consistent the White House’s newly announced National Strategy on Hunger, Nutrition, and Health (National Strategy).[6] The National Strategy acknowledges that stronger nutrition standards across federal programs can “help increase diet quality of beneficiaries and spur companies to reformulate food products.” Specifically, the National Strategy commits to update the foods included in WIC packages “to better align with the most recent Dietary Guidelines for Americans” and to provide a Cash-Value Benefit “at a level that supports fruit and vegetable access and recommended consumption.”
II. The Proposed Updates Have the Potential to Increase Nutrition Security and Improve Health in New York State
WIC participants struggle with, as one New Yorker put it, “money, transportation, the pandemic, a new baby on top of all that—making each thing that much more difficult.”[7] Increasing the CVB and expanding the scope and available product sizes of healthy, culturally-relevant foods included in the food packages could benefit approximately 6.3 million WIC participants nationwide and 400,000 New Yorkers.[8] Specifically, the proposed changes could help reduce cost concerns, decrease transportation barriers, and alleviate food storage constraints that abound in a populous state with high living costs, like New York.
Prior to the COVID-19 pandemic, one in ten New Yorkers—nearly two million people—were food insecure.[9] Families with children have been hit especially hard. At the pandemic’s peak, more than one in five New York adults with children reported that their children did not have enough to eat in the prior week, with rates more than three times as high for Hispanic and Black families as for white families.[10] With rising food and gas prices, as well as overall inflation, affording food is likely even harder now.
Based on a 1,507-person statewide Survey of Food and Health that the Foundation conducted in 2021, we know that approximately half of all food-insecure households with children have children who had gone hungry that calendar year.[11] Three of every four such households cannot afford to feed their children a balanced meal, and more than 80% rely on low-cost foods. Typically, households with hungry children also include adults who are hungrier than their childless peers. Adults in food-insecure households with children cut or skip meals at higher rates and for longer periods than do food-insecure households without children. Nearly 90% of food-insecure adults with children have skipped meals in the past year. As one survey respondent explained, “After paying bills, there isn’t much left to spend on food or anything else. So I buy food specifically for the kids.”
Food insecurity has harmful long-term effects on children’s health, and it has a more immediate impact on adults’ health. Food-insecure children are more likely to have stunted development and asthma.[12],[13] They have higher rates of hospitalization, but are less likely to have access to health care. Food insecurity can also permanently affect intellectual and social development. Children with uncertain access to food tend to have lower test scores and a greater likelihood of behavioral problems, including hyperactivity and anxiety.[14] Similarly, food-insecure adults with children are twice as likely to report poor or fair health and three times more likely than food-secure adults with kids to report stress, anxiety, or depression.[15] Compared to their peers with no children, food-insecure New Yorkers with children are more likely to delay or forgo both medical care and prescription medicine purchases to afford food, decisions that can be even more dangerous when pregnant.
WIC has the potential to reduce food insecurity and improve health outcomes for pregnant and breastfeeding women, as well as children. Participation can improve pregnancy and birth outcomes, reduce the risk of infant mortality, improve breastfeeding rates, increase consumption of under-consumed food groups, improve dietary quality, and reduce prevalence of childhood obesity.[16],[17],[18],[19],[20] Despite this potential, the program remains under-enrolled both in New York and nationally, with significant disparities in participation by race. [21] For example, white food-insecure New Yorkers are nearly twice as likely as Black food-insecure New Yorkers to participate in the program.[22]
Previous updates to the WIC packages, such as those adopted in 2009, demonstrate WIC’s potential to build nutrition security and reduce health disparities. The 2009 package revisions increased consumption of whole grains, fruits, vegetables, and legumes and reduced reported intake of sodium, saturated fat, and sugar.[23],[24],[25] As a result, children enrolled in WIC now have higher Healthy Eating Index (HEI) scores, a measure of diet quality that assesses how well a set of foods aligns with the DGAs.[26],[27] Rates of obesity for young participants have fallen, with the greatest improvements for American Indian, Hispanic, and Asian/Pacific Islanders, demonstrating WIC’s potential to strengthen nutrition outcomes in communities of color.[28]
Increasing the CVB and updating the contents of the program packages, as USDA proposes to do, could also increase program participation and decrease health disparities. For example, increasing the CVB could increase New Yorkers’ ability to access fresh fruits and vegetables. Given the especially high costs of living in New York, more than one-quarter of WIC participants say the current benefit levels are not enough to meet their household’s needs. Data from the Foundation’s Survey of Food and Health confirm that cost is the main barrier when it comes to New Yorkers getting the food they need.[29] As one respondent explained, “We do not have a lot of money to purchase as much fresh produce as we’d like, so we are often left purchasing cheap, ready-made, or microwave meals.” Other respondents confirmed that the WIC program could be improved by increasing the benefits and expanding the items that are eligible for purchase.[30]
The proposed changes could also reduce transportation barriers by allowing greater flexibility in product size. Across New York, food-insecure families with children are more than three-and-a-half times as likely as food-secure families with children to report that transportation is a barrier.[31] Many families do not use their own vehicle for food shopping; they walk, bike, get a ride from a friend or family member, or use public transportation. As one respondent to our 2021 Survey of Food and Health explained, “We do not live within a reasonable distance of any supermarkets (we do not have a car), so are often limited to purchasing whatever we can carry on the bus.”[32] Reliance on these alternatives can make it difficult for WIC participants to transport larger product sizes, often those approved by WIC, so greater flexibility in product size is a welcome improvement to the program.
Greater flexibility in product size could also lessen space and equipment constraints for WIC participants. For example, the current rule allows state agencies to authorize smaller product sizes. Across New York, food-insecure families with children are more likely than their peers without children to have trouble cooking at home.[33] They are more than twice as likely as food-insecure individuals without children to lack cooking equipment or a fridge and three times more likely to lack a stove. Enabling consumers to purchase healthy single-serve or multipack products could help lessen preparation and cold storage problems.
III. NYHealth Supports USDA’s Proposals to Increase the Cash-Value Benefit for Fruits and Vegetables and to Expand Choice Within the Women, Infant, and Children Food Packages
USDA’s proposals to increase fruit and vegetable amounts and expand choice within the WIC food packages are especially likely to benefit participants in New York, where the cost of living is high and the food needs are diverse. For these reasons:
We support USDA’s proposal to increase the Cash-Value Benefit for fruits and vegetables.
In response to rising economic hardship during the COVID-19 pandemic, USDA temporarily increased the CVB from $9–11 to $35 per person per month at the pandemic’s peak. This increase was one of the most substantial investments in nutrition security in recent years and resulted in rapid, measurable increases in fruit and vegetable consumption: approximately ¼ cup per day for WIC-enrolled children.[34] Americans, including WIC-eligible populations, under-consume fruit, and 100% of postpartum women, 99% of pregnant women, and 99% of children enrolled in WIC fall short of DGA-recommended vegetable intake.[35]
Higher CVB for fruits and vegetables can improve health outcomes and close disparities in consumption created by income. For example, families may be more willing to serve new fruits and vegetables they previously feared their children wouldn’t eat. Research shows that young children may need up to 10 exposures to accept a new food.[36] With only $9 per month for fruits and vegetables, families were hesitant to risk limited resources to purchase a wide range of produce and may have instead opted for familiar staples. The enhanced benefit empowers parents to introduce children to a wider variety of fruits and vegetables, potentially shaping their dietary preferences for the long term.
We support USDA’s proposal to broaden the range of culturally relevant whole grains. One hundred percent of women and 93% of children who participate in WIC do not meet DGA-recommended intake for whole grains.[37] Black and Hispanic families face the greatest intake disparities, with the average Hispanic toddler consuming only 26% of recommended whole grain intake.[38] Introducing whole grains during childhood is critical. Their consumption boosts intake of priority nutrients like fiber and iron and is associated with reduced risk of cardiovascular disease, type 2 diabetes, and other chronic diseases.[39] By offering a broader range of nutritionally appropriate grain options, USDA will make the program more culturally relevant to a wider range of New Yorkers, including immigrants and refugees.
We support USDA’s proposal to include seafood in the child and adult food packages. Seafood is an important source of nutrients like iron, choline, omega-3 fatty acids, calcium, and vitamin D that are priorities for the WIC population.[40] The 2020 DGAs—the first edition with distinct recommendations for pregnancy, lactation, and early childhood—emphasized the benefits of seafood consumption for pregnant and breastfeeding women, noting the potential benefits to a child’s cognitive development. Yet, 100% of children enrolled in WIC fall short of DGA-recommended seafood intake.[41] USDA’s proposed rule would greatly expand access to seafood from only 3.4% of WIC participants to an estimated 58.7%.
We support USDA’s efforts to increase product size flexibility across food categories. USDA’s proposed rules offer greater flexibility to state WIC agencies to authorize smaller product sizes across all food categories except for infant formula. Product size flexibility could increase participants’ ability to purchase healthy products currently unavailable through the program. For example, these changes will make it easier for consumers to purchase healthy single-serve and multipack dairy items such as yogurt containers, string cheese, and drinkable yogurts.
We support the inclusion of plant-based dairy alternatives that are nutritionally equivalent to approved animal-milk products and meet minimum nutrient standards for protein, calcium, vitamin D, and potassium. To further accommodate special dietary needs and cultural and personal preferences, we urge USDA to set standards for plant-based beverages that will encourage manufacturers to fortify products and ensure healthy plant-based products are available in the marketplace. Allowing plant-based dairy alternatives that meet nutrition standards to be a part of food packages will enable WIC to better serve participants with allergens or dietary patterns that do not include dairy.
IV. Conclusion
Thank you for the opportunity to provide comments. WIC provides a critical safety net for hungry New Yorkers. Increasing the Cash-Value Benefit and expanding the cultural relevancy of the food packages could help to increase nutrition security for women and children in New York and across America. The New York Health Foundation strongly supports this proposed rule. We look forward to supporting FNS’s efforts to address nutrition security.
Sincerely,
David Sandman, Ph.D.
President and CEO
New York Health Foundation
[1] New York Health Foundation. What we do. https://nyhealthfoundation.org/what-we-do/. Accessed January 2023.
[2] New York Health Foundation. Healthy food, healthy lives. https://nyhealthfoundation.org/what-we-fund/healthy-food-healthy-lives/. Accessed January 2023.
[3] 42 U.S.C. § 1786(f)(11)(C).
[4] U.S. Department of Agriculture, U.S. Department of Health and Human Services. Dietary Guidelines for Americans, 2020-2025. 2020. https://www.dietaryguidelines.gov/sites/default/files/2021-03/Dietary_Guidelines_for_Americans-2020-2025.pdf. Accessed January 2023.
[5] National Academies of Sciences, Engineering, and Medicine. Review of WIC food packages: improving balance and choice: final report. 2017. https://nap.nationalacademies.org/catalog/23655/review-of-wic-food-packages-improving-balance-and-choice-final. Accessed January 2023.
[6] U.S. White House. Biden-Harris administration: national strategy on hunger, nutrition, and health. Sept. 2022. https://www.whitehouse.gov/wp-content/uploads/2022/09/White-House-National-Strategy-on-Hunger-Nutrition-and-Health-FINAL.pdf. Accessed January 2023.
[7] New York Health Foundation. Food insecurity in families with children. October 2022. https://nyhealthfoundation.org/resource/food-insecurity-in-families-with-children-2022/. Accessed January 2023.
[8] U.S. Department of Agriculture, Food and Nutrition Service. WIC data tables, monthly data: state level participation by category and program costs, FY 2022 (preliminary). 2023. https://www.fns.usda.gov/pd/wic-program. Accessed January 2023.
[9] Coleman-Jensen A, Rabbitt MR, Hashad RN, Hales L, Gregroy CA. Prevalence of household-level food insecurity and very low food security, average 2018-20. U.S. Department of Agriculture, Economic Research Center. April 22, 2022. https://www.ers.usda.gov/topics/food-nutrition-assistance/food-security-in-the-u-s/key-statistics-graphics/#map. Accessed January 2023.
[10] New York Health Foundation. Continuing impact of the COVID-19 pandemic on food scarcity in New York. June 1, 2021. https://nyhealthfoundation.org/resource/continuing-impact-of-the-covid-19-pandemic-on-food-scarcity-in-new-york/#key-findings. Accessed January 2023.
[11] New York Health Foundation. Food insecurity in families with children. October 2022. https://nyhealthfoundation.org/wp-content/uploads/2022/10/food-insecurity-in-families-with-children.pdf. Accessed January 2023.
[12] Zaslow M, Bronte-Tinkew J, Capps R, Horowitz A, Moore KA, Weinstein D. Food security during infancy: implications for attachment and mental proficiency in toddlerhood. Mat Child Health J. 2009;13(1):66-80.
[13] Thomas MMC, Miller DP, Morrissey TW. Food Insecurity and child health. Pediatr. 2019;144(4).
[14] Kimbro RT, Denney JT. Transitions into food insecurity associated with behavioral problems and worse overall health among children. Health Affairs. 2015;34(11).
[15] New York Health Foundation. Food insecurity in families with children. October 2022. https://nyhealthfoundation.org/wp-content/uploads/2022/10/food-insecurity-in-families-with-children.pdf. Accessed January 2023.
[16] Finger KR, Lob SH, Dove MS, Gradziel P, Curtis MP. Reassessing the association between WIC and birth outcomes using a fetuses-at-risk approach. Mat Child Health J. 2017;21:825-835.
[17] Soneji S, Beltrán-Sánchez H. Association of Special Supplemental Nutrition Program for Women, Infants, and Children with preterm birth and infant mortality. JAMA Netw Open. 2019;2(12):e1916722 and Kline N, Zvavitch P, Wroblewska K, Worden M, Mwombela B, Thorn B, Cassar-Uhl D. WIC participant and program characteristics, 2020: final report. U.S. Department of Agriculture, Food and Nutrition Service. 2022. https://fns-prod.azureedge.us/sites/default/files/resource-files/WICPC2020-1.pdf. Accessed January 2023.
[18] Whaley SE, Ritchie LD, Spector P, Gomez J. Revised WIC food package improves diets of WIC families. J Nutr Ed Behav. 2012;44(3):204-209.
[19] Weinfield NS, Borger C, Au LE, Whaley SE, Berman D, Ritchie LD. Longer participation in WIC is associated with better diet quality in 24-month-old children. J Acad Nutr Diet. 2020;120(6):963-971.
[20] Daepp MIG, Gortmaker SL, Wang CW, Long MW Kenney EL. WIC food package changes: trends in childhood obesity prevalence. Pediatr. 2019;143(5):e20182841.
[21] U.S. Department of Agriculture, Food and Nutrition Service. SNAP participation rates by state, all eligible people. 2020. https://www.fns.usda.gov/usamap#. Accessed January 2023.
[22] New York Health Foundation. NYHealth Survey of Food and Health. August 2022. https://nyhealthfoundation.org/wp-content/uploads/2022/11/NYHealth-survey-of-food-and-health.pdf. Accessed January 2023.
[23] Whaley SE, Ritchie LD, Spector P, Gomez J. Revised WIC food package improves diets of WIC families. J Nutr Ed Behav. 2012;44(3):204-209.
[24] Chiasson MA, Findley SE, Sekhobo JP, Scheinmann R, Edmunds LS, Faly AS, McLeod NJ. Changing WIC changes what children eat. Obesity. 2013;21(7):1423-1429.
[25] Andreyeva T, Tripp AS. The healthfulness of food and beverage purchases after the federal food package revisions: the case of two New England states. Prev Med. 2016;92:204-210.
[26] Tester JM, Leung CW, Crawford PB. Revised WIC food package and children’s diet quality. Pediatr. 2016;137(5).
[27] U.S. Department of Agriculture, Food and Nutrition Service. Healthy Eating Index. April 27, 2022. https://www.fns.usda.gov/healthy-eating-index-hei. Accessed January 2023.
[28] U.S. Centers for Disease Control and Prevention. Obesity among WIC-enrolled young children. Nov. 8, 2022. https://www.cdc.gov/obesity/data/obesity-among-WIC-enrolled-young-children.html. Accessed January 2023.
[29] New York Health Foundation. NYHealth Survey of Food and Health. August 2022. https://nyhealthfoundation.org/wp-content/uploads/2022/11/NYHealth-survey-of-food-and-health.pdf.pdf. Accessed January 2023.
[30] New York Health Foundation. Food insecurity in families with children. October 2022. https://nyhealthfoundation.org/wp-content/uploads/2022/10/food-insecurity-in-families-with-children.pdf. Accessed January 2023.
[31] New York Health Foundation. Food insecurity in families with children. October 2022. https://nyhealthfoundation.org/wp-content/uploads/2022/10/food-insecurity-in-families-with-children.pdf. Accessed January 2023.
[32] New York Health Foundation. Food insecurity in families with rural, suburban, and urban New York. November 2022. https://nyhealthfoundation.org/wp-content/uploads/2022/11/Food-Insecurity-in-Rural-Suburban-and-Urban-New-York.pdf. Accessed January 2023.
[33] New York Health Foundation. Food insecurity in families with children. October 2022. https://nyhealthfoundation.org/wp-content/uploads/2022/10/food-insecurity-in-families-with-children.pdf. Accessed January 2023.
[34] Ritchie L, Lee D, Felix C, Sallack L, Chauvenet C, Machell G, Whaley SE. Multi-state WIC participant satisfaction survey: cash-value benefit increase during COVID. National WIC Association, Nutrition Policy Institute. 2022. https://s3.amazonaws.com/aws.upl/nwica.org/nwa-multi-state-cvb-report-march-2022.pdf. Accessed January 2023.
[35] National Academies of Sciences, Engineering, and Medicine. Review of WIC food packages: improving balance and choice: final report. 2017. https://nap.nationalacademies.org/catalog/23655/review-of-wic-food-packages-improving-balance-and-choice-final. Accessed January 2023.
[36] U.S. Department of Agriculture, U.S. Department of Health and Human Services. Dietary Guidelines for Americans, 2020-2025. 2020. https://www.dietaryguidelines.gov/sites/default/files/2021-03/Dietary_Guidelines_for_Americans-2020-2025.pdf. Accessed January 2023.
[37] National Academies of Sciences, Engineering, and Medicine. Review of WIC food packages: improving balance and choice: final report. 2017. https://nap.nationalacademies.org/catalog/23655/review-of-wic-food-packages-improving-balance-and-choice-final. Accessed January 2023.
[38] U.S. Department of Agriculture, Agricultural Research Service. Food patterns equivalents database, 2011-2018. Jan. 6, 2021. https://www.ars.usda.gov/northeast-area/beltsville-md-bhnrc/beltsville-human-nutrition-research-center/food-surveys-research-group/docs/fped-data-tables/. Accessed January 2023.
[39] Seal CJ, Brownlee IA. Whole-grain foods and chronic disease: evidence from epidemiological and intervention studies. Proc Nutr Soc. 2015;74(3):313-9.
[40] U.S. Department of Agriculture, U.S. Department of Health and Human Services. Dietary Guidelines for Americans, 2020-2025. 2020. https://www.dietaryguidelines.gov/sites/default/files/2021-03/Dietary_Guidelines_for_Americans-2020-2025.pdf. Accessed January 2023.
[41] National Academies of Sciences, Engineering, and Medicine. Review of WIC food packages: improving balance and choice: final report. 2017. https://nap.nationalacademies.org/catalog/23655/review-of-wic-food-packages-improving-balance-and-choice-final. Accessed January 2023.
