On Feb. 21, Foodlink submitted a public comment during the federal government’s rulemaking process concerning revisions made to the food packages for the Women, Infants & Children (WIC) federal nutrition program. The proposed rule aims to promote food security and food equity, while allowing greater flexibility that accommodate participants’ dietary needs and cultural food preferences. The changes also hope to better promote and support individual breastfeeding goals of participants.
Foodlink’s interest in WIC, from an advocacy standpoint, has been elevated in recent years after the Curbside Market began offering WIC-eligible foods at select sites — becoming the first mobile market in the nation to do so.
The Food and Nutrition Service (FNS) of the USDA invited comments on the proposed rule, and Foodlink submitted the following:
Foodlink welcomes the opportunity to provide comments on the proposed changes to WIC food packages. We are in full support of changes that will provide a wider variety of healthy foods that align with the latest nutritional science, and provide flexibilities to state agencies and vendors to make the program more accessible for all eligible participants.
Foodlink is a regional food bank and public health organization dedicated to ending hunger and building healthier communities in the Rochester and Finger Lakes region of New York. It is our responsibility to ensure we are providing hundreds of nonprofits within our network (e.g., food pantries, meal programs, shelters), with a healthy inventory of food and resources for thousands of food-insecure clients across our 10-county service area.
Aside from food banking, we operate numerous programs that address the root causes of food insecurity and poverty among the populations we serve. Convenient access to healthy food continues to be a barrier for many low-income households. Nearly 10 years ago, we launched the Curbside Market – a mobile market that travels throughout our region to cities, towns, villages, and neighborhoods where access to healthy foods is limited. In 2021, through the help of a USDA grant, the Curbside Market became the first mobile vendor in the nation to sell WIC-eligible foods. We offer WIC-eligible foods at 10 of our market sites and have plans to expand to 50+ sites this summer with the help of our dedicated staff, Curbside Market Ambassadors, and a newly hired WIC Outreach Specialist.
It is through this lens, with nearly 5 years of researching and implementing an innovative program designed to make WIC more accessible for eligible households, that we offer our comments related to the proposed rule changes and their potential impact on public health.
We applaud the following changes:
– The increase in the Cash Value Benefit (or Cash Value Voucher) has allowed Curbside Market customers to increase consumption of fresh produce. In low-income, low-access urban areas, retailers such as corner stores struggle to stock fresh produce, and we would encourage the USDA to consider ways to support small businesses in accessing more affordable fresh fruits and vegetables for their customers.
– Increasing the variety of whole grains to be more inclusive, such as the inclusion of quinoa, teff and whole-wheat naan. We know that, especially in New York State, program participation and perceptions vary widely based on race/ethnicity/geography/health status. This proposed rule is a welcome step forward to promote equity in the WIC food package.
– Offering more non-dairy substitutions for milk, such as soy-based cheese to accommodate those with medical conditions, dietary restrictions, or limited storage capacity.
– Providing greater flexibility with formula amounts and caloric intake to help mothers’ breastfeeding goals, which vary widely. It is important to provide this flexibility, along with proper lactation consultation, so that mothers can avoid shame when supplementing breastfeeding with formula.
We are also compelled to stress the importance of flexibility related to WIC vendors, as a lack of WIC-eligible vendors is often one of the greatest barriers to program access and benefit redemption. In Rochester, there are multiple zip codes in low-income areas where the closest WIC vendor is more than a mile away, which poses a significant barrier for families with transportation or mobility issues. We encourage the federal government to explore ways to limit restrictions on vendor eligibility – considering more options such as mobile WIC and online eWIC processing. We are urging the federal government to consider human-centered approaches to WIC processing that align with current technology and the actual lived experiences of WIC families.
Foodlink also looks forward to learning more about the 8 WIC state agencies selected to participate in a pilot program related to online shopping. Based on customer feedback at the Curbside Market, we are confident that WIC redemption rates would soar with the addition of online ordering nationwide.
Thank you for giving us the opportunity to submit a public comment. It is our hope that, over time, we can implement changes to WIC food packages, and reduce barriers to vendor eligibility to help improve program participation and benefit redemption for our Curbside Market customers, and the millions of families who rely on WIC across the nation.
