June 16, 2022
IFPA recently submitted comments to the U.S. Department of Agriculture about the WIC cash-value benefit. Full comments are below:
June 3, 2022
Food and Nutrition Service
U.S. Department of Agriculture
Dear Ms. Morgan,
On behalf of the International Fresh Produce Association, we respectfully submit the following comments to the U.S. Department of Agriculture around its proposed information collection entitled “Reasons for Under redemption of the WIC Cash-Value Benefit”. The International Fresh Produce Association (IFPA) was founded in 2022 on the deep-seated history of leadership of the United Fresh Produce Association (UFPA) and the Produce Marketing Association (PMA). IFPA is the largest and most diverse association serving the entire global fresh produce supply chain, and the only to seamlessly integrate world-facing advocacy and industry-facing support. A core component of the association’s work has been increasing fruit and vegetable consumption through federal policy and programs, including the Supplemental Nutrition Program for Women, Infants and Children (WIC).
As the USDA has recognized through its research and policies, including the Dietary Guidelines for Americans, access and consumption to fruits and vegetables is vitally important across all populations and especially for those served under the WIC.
Specifically, nutrition during pregnancy is one of the key factors that impacts fetal growth and development. It is imperative that pregnant individuals consume a health-promoting diet throughout pregnancy, and fruits and vegetables are a necessary part of that diet. Multiple studies have shown that fruit and vegetable intake impact infant birth weight. One such study found that low vegetable intake during pregnancy was associated with a small for gestational age birth weight, while several others have determined that increased fruit and vegetable intake is linked with higher birth weight. Additionally, fruit and vegetable consumption during pregnancy is associated with positive changes in the infants’ gut microbiota. This evidence supports the conclusion that adequate fruit and vegetable consumption is paramount during pregnancy.
The importance of adequate nutrition does not end when pregnancy ends; diet quality has a significant impact on health during the postpartum period as well. Poor dietary quality, specifically low vegetable intake and inadequate dietary variety, has been associated with postpartum depression in lactating women. In addition to the negative impact on maternal mental health, inadequate vegetable intake and subsequent postpartum depression would likely impact a mother’s ability to perform parental duties, therefore potentially impacting the health of the infant as well. Furthermore, postpartum individuals with full-time jobs and those who identified as low-income are more likely than their financially stable counterparts to reduce their vegetable consumption to an inadequate level after giving birth. These results underscore the importance of promoting adequate vegetable and fruit intake in the low-income postpartum population to support maternal and child health.
Fruit and vegetable intake during late infancy and early childhood can have long-term effects on children. According to a study published in the journal Pediatrics, children who consumed fruits and vegetables less than one time per day during late infancy were more likely to have a lower consumption of fruits and vegetables at six years of age. This finding emphasizes the significance of adequate fruit and vegetable intake in early childhood, as well as the importance of breaking down barriers to intake in this age group. A recent study of school-aged children found that fruit and vegetable intake was positively associated with mental wellbeing, highlighting the idea that proper nutrition should be a key component of any public health effort to promote childhood wellbeing.
Accordingly, programs and services that can help increase access to fruits and vegetables, such as the WIC CVB, are of the utmost importance when it comes to promoting fruit and vegetable intake during pregnancy, postpartum, and early childhood. In the short time since the CVB was increased through the American Rescue Plan, fruit and vegetable intake among WIC participants increased. A recent report by the National WIC Association and the Nutrition Policy Institute found that fruit and vegetable intake among children increased by ⅓ cup after the CVB increase took effect. The report also found that a majority of WIC participants deemed the increased amount to be adequate, in contrast to the consensus among participants that the original amount of $9 per child was not enough.
The increase in fruit and vegetable intake as a result of the CVB increase suggests that the enhanced benefit is, overall, in the best interest of WIC participants. According to a recent study conducted at the University of Delaware, the most common reasons for under redemption include difficulty using the exact amount provided and lack of clarity about how and where CVB can be used. A separate study, which was conducted with WIC participants in Massachusetts prior to the American Rescue Plan CVB increase, noted that many WIC participants experienced low program satisfaction due to insufficient benefits for fruits and vegetables. Based on this existing evidence, the CVB increase and possibly increasing the CVB even further may contribute to increased participation in WIC and increased fruit and vegetable intake. A third recent study found that the CVB increase resulted in higher rates of food security, CVB redemption, and satisfaction with the CVB program.
Based on feedback from WIC participants and state agencies administering the WIC program, several program enhancements could be made to increase the redemption of CVB. The following recommendations should be considered to ensure participants are utilizing the full CVB.
As USDA works to collect additional information around ways to improve redemption rates of the CVB, we encourage consideration of the following support:
Recommendation 1: Increased awareness of CVB among participants. Providing more support within communities regarding how and where to redeem CVB may help increase redemption rates even further and contribute to increased intake of fresh produce among the WIC population. WIC state and local agencies may consider various communication channels to increase awareness including text messages, mailers, and verbal reminders at WIC appointments.
Recommendation 2: Consistent CVB amount. The CVB amount has varied over the last couple of years due to legislative actions including the American Rescue Plan and most recently, the Omnibus. Participants may be unaware of the current CVB amount or may be hesitant to purchase additional fruits and vegetables for fear of overspending. WIC state and local agencies should include the current CVB amount in their communications and USDA should increase the CVB permanently to reduce confusion among the WIC population and provide stability to put a successful communication plan in place.
Recommendation 3: Allow CVB redemption before 12 months of age. Current WIC guidelines limit the use of the CVB before one year of age, despite many participants wishing to serve age-appropriate fruits and vegetables. Additionally, the 2020-2025 DGA encourages the introduction of foods before one year of age all the food groups, including appropriately prepared fruits and vegetables, when an infant is showing readiness. Accordingly, USDA should adjust regulations that allow CVB to be provided for infants under 12 months when appropriate.
Recommendation 4: Retail Partnerships. USDA should explore best practices around retail engagement for WIC CVB redemption. For example, state and local WIC agencies could partner with WIC-authorize retailers to encourage signage and promotion of usage of the CVB.WIC participants may be hesitant to use the CVB at retail locations if they are unsure if it is accepted there, what products are eligible, or if they do not have confidence in the amount available.
Increased fruit and vegetable intake is one of the best ways to improve diet quality and health. WIC remains one of the crown jewels of USDA evidence-based programs in that it ensures participants have access to nutrient-dense options consistent with the DGAs, including fruits and vegetables during a critical window. IFPA continues to support the WIC CVB increase and we look forward to working with USDA, our members and partners to increase redemption of the CVB.
Mollie Van Lieu
Nutrition and Health
International Fresh Produce Association