Task Force on Supplemental Food Delivery in the WIC Program – Recommendations Report
Since 1974, the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) has enhanced access to healthy foods and delivered critical nutrition services for new and expectant parents, babies, and young children. WIC has a long history of innovating to strengthen the impact of its public health services, including a nationwide transition to electronic-benefit transfer payments (EBT) in retail settings in the 2010s. For WIC to maximize its proven nutrition support, swift and focused action is critical to provide a modern, accessible, and equitable shopping experience for the nearly 6.4 million current participants and the next generation of WIC families.
The Consolidated Appropriations Act for fiscal year 2021 (PL 116-260) authorized the U.S. Department of Agriculture (USDA) to convene a Task Force on Supplemental Foods Delivery (“Task Force”) to “study measures to streamline the redemption of supplemental foods benefits that promote convenience, safety, and equitable access to supplemental foods, including infant formula”. The Task Force was specifically instructed to review online and telephonic ordering, curbside pickup and payment, online and telephone purchasing, home delivery, self-checkout, and other measures that limit or eliminate consumer presence in a physical store.
The Task Force was convened in March 2021 and met regularly through the time of publication of this report. The Task Force’s work was informed by prior and parallel processes to modernize shopping options for USDA nutrition programs, including: USDA staff scaling up the Supplemental Nutrition Assistance Program (SNAP) Online Ordering Pilot Project; the Gretchen Swanson Center for Nutrition, which administers the USDA WIC Online Ordering Grant; the WIC Online Ordering/Purchasing/Home Delivery Working Group, convened by the National WIC Association in spring 2020; and additional pilot projects and local innovations being developed across the country. The Task Force consisted of the 18 member organizations, cutting across multiple sectors to ensure a diverse range of input from WIC providers, retailers, manufacturers, EBT processing companies, advocacy organizations, WIC participants, and additional stakeholders. Additional information about each member and their organization can be found in Appendix A: Task Force Member & Organization Information.
The Task Force was assembled in the midst of the COVID-19 pandemic, which presented public health challenges to the in-person shopping experience. During the pandemic response in 2020, USDA recognized the imperative to provide a broader range of shopping options for participants in federal food assistance programs, significantly scaling up the SNAP online purchasing pilot to permit online shopping with SNAP benefits. Similar initiatives were not immediately feasible for WIC participants, as the SNAP and WIC programs have wide-ranging differences in their structure, administration, funding, and approach to transaction processing. In addition, SNAP had been developing online purchasing solutions since it was first authorized in the 2014 Farm Bill.
The need for modern shopping options for WIC participants predates the pandemic. WIC is an effective program that delivers healthier outcomes for participating families through nutrition education, supplemental nutritious foods, and referral to health care and other service programs. However, eligible individuals are less likely to access WIC services if the shopping experience is overly burdensome or stigmatizing. Driving innovation in WIC transaction platforms both affirms equitable treatment for low-income families and invests in the long-term health of America’s next generation. The Task Force urges swift and focused USDA action to partner with WIC providers, retailers, suppliers, technology experts, processors, and all other interested stakeholders to develop and implement modern, forward-looking solutions that streamline the WIC transaction.
Online purchasing is currently prohibited in program rules, and the regulations do not allow for transactions via a virtual platform. To support the modernization of WIC benefit delivery, USDA must address outdated WIC regulations – many dating from an era when WIC benefits were issued on paper vouchers. These dated regulations are a significant barrier to present and future benefit innovation. Since the establishment of the Task Force, USDA has indicated in the Unified Regulatory Agenda that it will pursue rulemaking later in 2021 to address regulatory barriers to online ordering and modernize relevant regulations. The Task Force urges that this report be considered in developing the proposed rule and serve as a foundation for additional stakeholder input during notice and comment in the rulemaking process.
In contemplating the steps that would reduce regulatory barriers and unleash the potential of new delivery systems, the Task Force adopted four guiding principles as part of the development of its recommendations:
- Pursue the most intelligent ordering and payment approach to the extent possible. WIC benefits are issued monthly by food category. In a paper voucher system, participants had forfeited benefits when all issued foods on a food instrument were not redeemed in a single transaction. With the introduction of EBT and other forward-looking technologies, participants are permitted to redeem discrete items and conduct multiple transactions throughout the benefit month. When developing new transaction models, participants should have the clearest picture possible of their remaining benefits balance at all points of the transaction. This information should be used as part of the transaction to ensure that the appropriate foods and quantity limits are applied. While it is our preference that the most intelligent ordering and payment approach is pursued, the Task Force does not want to limit a vendor from using a less intelligent approach such as a telephonic ordering if it allows them to support improved service delivery to WIC customers.
- Following existing commercial models, where possible. WIC innovation builds on existing progress by the retailer community to scale up online shopping platforms for SNAP recipients and the general shopping public. In many cases, retailers will seek to create interoperable virtual platforms that can accommodate transactions across federal nutrition programs. WIC reforms and innovation should be mindful of existing commercial models to prevent significant reformulation of existing platforms.
- Treat WIC participants equally to other retail consumers. WIC participants deserve an equitable and safe shopping experience that is equivalent to the general shopping public. Secure platforms should be established that ensure WIC participants can access the same variety of online shopping options without stigma, added difficulty, or personal cost.
- Focus on best practices. As retailers and WIC providers scale up new platforms, it is critical that existing safeguards continue to ensure convenient, safe, and equitable access. WIC innovation must continue moving forward to remain on par with, or even ahead of, other commercial transaction technologies. WIC EBT remains a relatively recent option, even though similar technology was available to the shopping public decades prior. Working within the parameters of WIC’s federal purpose, new technologies should ensure convenient and equitable access to supplemental foods. WIC transaction models should inform broader innovation for retailer platforms, while also staying abreast of advances made on SNAP and other commercial platforms and ensuring responsible program integrity.
With these guiding principles, the Task Force proceeded with outlining the approach to online ordering and purchasing that we believe is the most intelligent option, follows commercial models, focuses on best practices, modernizes the regulatory framework, and provides for the best end user experience. The Task Force is cognizant that the approach recommended (and in fact, any approach) will require system updates and/or new development for all WIC stakeholder systems to include retailers, EBT processors, third party processors (TPPs), and WIC management information systems (MIS). The extent of the modifications will vary across systems, but in all cases, there will be a cost and time necessary to make the changes. To that end, the Task Force recommends moving forward with modernizing the WIC shopping experience in a way that upholds the safety and integrity of the delivery of WIC food benefits but doing so as quickly and efficiently as possible. We recognize there may be a need for interim stages that involve less intelligent methods in order to move online ordering and purchasing forward toward the long-term goal of the Task Force’s recommended approach. Additionally, the Task Force agrees that designated funding to support system changes and other costs associated with the implementation of online ordering and purchasing for all WIC state agencies will be critical to the success and timeliness of the efforts.
This final Task Force report includes comprehensive recommendations to USDA on next steps to advance WIC innovations associated with modern transaction models and participant redemption of supplemental foods. The report includes: in Section Two, definitions for terms utilized throughout the report; in Section Three, a narrative detailing recommendations on how transactions should be processed with the introduction of virtual platforms to WIC; in Section Four, a summary of proposed regulatory changes that will enhance innovation and reduce barriers to scaling up online shopping platforms; and in Section Five, a summary of additional considerations as USDA partners with stakeholders in the regulatory process to achieve progress in the WIC retail space.
January 18, 2022