WIC at the Crossroads of the Opioid Epidemic

by Danièle Todorov

The complexity and pervasiveness of the opioid epidemic has forced government agencies to be innovative with their resources. The Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) in a prime position to care for pregnant women affected by the epidemic and has stepped up to the plate.

In January of 2016, then Secretary of Agriculture Tom Vilsack was appointed by President Obama to lead an interagency taskforce to address the opioid epidemic in rural America. Secretary Vilsack, who’s been outspoken about his own mother’s struggle with prescription drug addiction, knew that compassion and collaboration would be vital. His agency, the USDA, has unique resources and relationships in rural areas, putting it in a prime position to address the epidemic.

Addressing the epidemic is no simple task. According to the CDC, 91 Americans died daily from opioid overdose in 2015. Nearly half of these deaths involved a prescription opioid, used in the treatment of pain. In a town hall meeting in Missouri last July, Secretary Vilsack stated that due to “the devastating toll that opioid misuse has taken on our communities, and particularly rural areas, I have tasked USDA with creatively using all of the resources at our disposal to stem the tide of this epidemic” [1]. Interestingly, Secretary Vilsack highlighted WIC as a resource that could be creatively used. “For many women”, he stated, “WIC is their first point of entry into the healthcare system, and we have an opportunity to intercept and potentially prevent dangerous health outcomes for both the mother and the child” [1].

Pain management is an important part of pregnancy care. The prescription of opioids for pain in pregnancy is increasingly common; 1 in 5 Medicaid-enrolled women were prescribed an opioid at some point during their pregnancy in 2014 [2]. However, the effect of opioids on birth outcomes is understudied. In utero opioid exposure may be associated with preterm delivery and low birth weight [3]. Exposed neonates may develop withdrawal symptoms, a condition known as neonatal abstinence syndrome, which is associated with increased risk of seizures and breathing difficulties [3]. Similarly understudied are the rates of opioid abuse during pregnancy. We do know that pregnant women with substance abuse problems are particularly vulnerable to food and job insecurities and unstable housing, which exacerbate potential health complications [4].

The healthcare system often stigmatizes and underserves pregnant women with substance abuse problems. However, WIC is increasing its ability to engage them in care. WIC’s mission is to promote the health of low-income women and their children by providing nutritious food, health education, and referrals. Starting in 2014, WIC agencies have increased staff training surrounding substance abuse [1]. Staff are better equipped to notice potential substance abuse, to educate WIC participants about the dangers of substance abuse during pregnancy and breastfeeding, and to connect them with local resources. These expanded roles align with WIC’s mission, not only because they aim to protect the health of the women they serve, but because WIC “acknowledges that substance use is incompatible with good nutrition” [5].

WIC is forming relationships with women at a promising point in time in their lives. In their staff training guide, WIC cites a study showing that women are “more motivated to improve their lifestyle and health habits during periods when they make the transition from one life situation or role to another… WIC participants are a natural target audience for substance use information because they are, by definition, in the life transition stage of pregnancy and new motherhood” [5].

WIC is playing an important part in the collaborative response to the epidemic. As the director of the USDA, Secretary Vilsack understood that a holistic response was the only effective solution and embraced President Obama’s mandate. “This disease isn’t a personal choice,” says Secretary Vilsack, “and it can’t be cured by willpower alone. It requires responses from whole communities, access to medical treatment, and an incredible amount of support. To me, our mandate is clear: don’t judge, just help” [6]. Secretary Vilsack’s endorsement of his replacement as Secretary of Agriculture, nominee Sonny Perdue, gives hope that the USDA will continue this vital endeavor.

Sources

  1. Agriculture Secretary Vilsack Announces Substance Misuse Prevention Resources for Low Income Pregnant Women and Mothers In Order to Battle the Opioid Epidemic, U. Office of Communications, Editor. 2016.
  2. Desai, R.J., et al., Increase in prescription opioid use during pregnancy among Medicaid-enrolled women. Obstetrics and gynecology, 2014. 123(5): p. 997.
  3. Patrick, S.W., et al., Prescription opioid epidemic and infant outcomes. Pediatrics, 2015. 135(5): p. 842-850.
  4. Sutter, M.B., S. Gopman, and L. Leeman, Patient-centered Care to Address Barriers for Pregnant Women with Opioid Dependence. Obstetrics and Gynecology Clinics of North America, 2017. 44(1): p. 95-107.
  5. Substance Use Prevention: Screening, Education, and Referral Resource Guide for Local WIC Agencies, F.a.N.S. U.S. Department of Agriculture, Editor. 2013.
  6. USDA. Addressing the Heroin and Prescription Opioid Epidemic. 2016 02/17/17].

Danièle Todorov is a first-year nutritional epidemiology student with a focus on pregnancy nutrition and birth outcomes.

 

Exiting the Echo Chamber

by Kathleen Nay

Many of us were unexpectedly blindsided by the results of the 2016 Presidential Election, but maybe we shouldn’t have been. Four Friedman students saw a need for greater diversity in our political discourse, and decided to do something about it. They piloted Let’s Talk, a four-week program designed to help fellow students engage in more respectful, tolerant, and empathetic dialogue with people of diverse political perspectives.

On November 9 of last year, I woke up reeling. I had truly not expected the results of the previous evening. In the days and weeks leading up to the election I had felt lighthearted. I was sure that someone as awful as Donald Trump couldn’t win the presidency. I felt optimistic that we’d soon have our first female president. I believed, generally, in the goodness of America.

So to wake up to a Trump presidency was, for me, devastating. I felt utterly blindsided. Looking around at the somber faces of my fellow Boston commuters that morning, I recognized that I wasn’t alone in my stupefaction.

It seems painfully, unnervingly obvious now, but at the time I wondered, how did we not see this coming? What did we miss? In the days and weeks immediately following the election, the answer surfaced in the form of two words: “echo chamber.” Apparently, these exist and we—or at least, I—live in one. Worse, it’s an echo chamber of my own making, thanks to my liberally curated social media feeds and preferred news outlets.

Shortly after Election Day I attended a presentation given by J.J. Bartlett, President of Fishing Partnership Support Services, a nonprofit organization dedicated to advocating for the health and wellbeing of fishermen and their families. In his talk, he said something that felt like a punch to the gut: “We ignore the primal scream of blue-collar workers at our own peril.” The words cut so deeply that I wrote them down. I knew that, as a student studying agriculture policy and hoping to someday work among and advocate for farmers and ranchers—the rural working class—I could no longer afford to ignore the primal scream that elected Donald J. Trump.

Fellow Friedman students Eva Greenthal, Kelly Kundratic, Hannah Kitchel, and Laura Barley had been awakened to the same realization—and decided to do something about it. “I did not personally know a single person who voted for Trump, and I really wanted to understand their motivations,” wrote Eva, in an email to me. “Frustrated by the lack of ‘opinion diversity’ at Friedman, I knew I would have to look beyond our university to gain this insight.” So she made a plan, joined forces with Kelly, Hannah, and Laura, and applied for funding from the Tisch Fund for Civic Engagement to pilot Let’s Talk, a research study designed to help students of diverse political leanings “exit the echo chamber.”

They partnered with Kelly’s alma mater, the West Virginia University Davis College of Agriculture, Natural Resources, and Design. While several school names were tossed around, WVU’s Davis College was an ideal candidate because, similar to the Friedman School, they offer graduate degrees in both agriculture and human nutrition. The program would work like this: Participants at both schools would dedicate 90 minutes per week over four weeks to ‘meet’ virtually and discuss the future of food, nutrition and agriculture over the course of the new administration, with the intent to identify common goals across party lines. The organizers would administer pre- and post-surveys, to assess whether participants’ perspectives on political topics changed after hearing the perspectives, hopes, and fears of their peers. Key objectives of the program were to promote mutual respect, tolerance, and understanding, and to challenge political stereotypes. Eva connected with Ask Big Questions (ABQ), an organization that provides dialogue facilitation training, so that the team could learn to lead positive and productive conversations.

The ABQ format is simple. It’s predicated on the idea that “big questions” are those that matter to everyone, anyone can answer, and invite people to share from their own experiences. By contrast, “hard questions” are those that matter to some people and require a level of expertise to answer; they tend to close conversational spaces and lead to debates about who is right and wrong. (Political arguments are often framed by these types of questions, appealing to people’s certainties of “right” and “wrong,” “truth” and “alternative truth.”)

Big Questions vs. Hard Questions. AskBigQuestions.org

Big Questions vs. Hard Questions. AskBigQuestions.org

Using the ABQ model, the Let’s Talk team devised big questions that, while tied to political issues, they felt everyone could relate to. These included “How do we connect?,” “What do we assume?,” and “Who are we responsible for?” By design, these questions are broad and ambiguous. But Eva, Kelly, Hannah and Laura, along with the facilitators at WVU, coupled the questions with media clips—PSA videos, TED Talks, and news media addressing food-and-agriculture issues—to give them context and guide more in-depth conversation.

“I like that this format for conversation allows me to speak from my experiences to explain why I feel the way I do about difficult topics,” writes Kelly. “Too often we see others engaging in conversation that can be either very defensive or offensive, and no one leaves…feeling accomplished. When you learn to speak with your experiences, it’s easier to see others as culminations of experience, and have a better understanding of the topic and the speakers.”

Laura added that keeping communication lines open with certain family members that voted for Trump has, for her, been of utmost importance in preserving those relationships since the election. She wanted to help facilitate that for others through Let’s Talk. To ensure respectful dialogue throughout the course of the project, participants brainstormed an “Agreement of Mutual Responsibility” designed to hold one another accountable. Among the things participants were mutually responsible for were directives to use “I” statements, to speak from personal experience as often as possible, and to listen with intent to understand.

Let's Talk Project Goals and Agreement of Mutual Understanding. Photos: Kathleen Nay

Let’s Talk Project Goals and Agreement of Mutual Responsibility. Photos: Kathleen Nay

When asked why they feel Let’s Talk is an important endeavor for the Friedman School to take on, all four organizers agreed that while interdisciplinary work is a cornerstone of the Friedman agenda, there’s a level of political diversity missing from our education. “We need more interdisciplinary work that also crosses state lines and regions,” says Hannah. Laura adds that Let’s Talk “feels like a much-needed expansion of our essential coursework, and delivers us from circulating the same policy discussions that we have in class.” They hope that Let’s Talk can serve as a replicable model that other schools might use to facilitate dialogue among students of varying political persuasions.

As a Let’s Talk participant, I was eager to engage in political discourse with the students at WVU, but I frequently felt frustrated when our 90-minute sessions ended just as the conversation was getting deep. Eva acknowledges that time has been a challenge from the beginning—the time needed to adequately develop the project since the idea formed in November, the time that each organizer was able to commit to planning and preparation, and the amount of time they felt they could fairly ask participants to dedicate each week. But the fact that so many students signed up to participate, despite adding an extra 90 minutes per week to everyone’s already-busy schedules, speaks volumes: Friedman students value opportunities for cross-political dialogue.

Although I’ve been disappointed that the time constraints have capped the length and depth of our Let’s Talk sessions, I’m encouraged. I’m encouraged by the initiative of my Friedman colleagues and inspired by their clear-eyed vision for political discourse that is respectful, tolerant, and empathetic. I’m hopeful, too, that although Let’s Talk has now ended, our conversations won’t; one component of the program has been to match participants with email “pen pals” at the partner school for future correspondence.

While I was disappointed that our discussions didn’t go deeper, I feel that even after only four weeks, I am better equipped to confront my own assumptions and to listen to why, not just what, people believe. Let’s Talk introduced me to a toolbox of conversation techniques that will make me more receptive to diversified political dialogue. It’s an important first step toward shattering our personally- and artificially-crafted echo chambers. The Friedman School has work to do. And I do, too.

Kathleen Nay is an AFE/UEP student in her second year. Eva Greenthal is a first year FPAN MS/MPH student. Kelly Kundratic, Hannah Kitchel and Laura Barley are first year AFE students. Let’s Talk was funded by the Tisch Fund for Civic Engagement, the Friedman School, Friedman Student Council, and three generous individual donors.

 

Turning a Moment into a Movement

by Sam Hoeffler

Donald Trump is the president of the United States. Now what? Join the movement.

As a protester at Trump’s inauguration in D.C. on Friday January 20th, I met many people who did not identify as activists. I encountered people who had never in their lives been motivated to make signs and march in protest. It was inspiring to see so many people in the streets on Friday, and an estimated 3.3 million people across the country marched on Saturday too. Yet in the afterglow of one of the largest demonstrations in national history, we mustn’t forget our reason for protesting: the rise of nationalism and fear mongering that brought Trump to office.

Trump is poised to push our country off a metaphorical ledge, where we would fall into cronyism, oligarchy, denial of science, restraint of the press, and deeper social inequality and unrest. We the people are the only thing holding the country back from that ledge and what lies below. We the people, standing with linked arms and clasped hands, must inch the country back to solid ground. We need to rediscover and reclaim a solid ground where we can come together and fight for the rights of all Americans to live full, healthy lives.

We need to transition from this historic moment of protest to a unified movement that demands change. The moment becomes a movement when we do not simply hold our elected officials back from running the country off a ledge, but when we begin to take action and shape this country with our own hands. We must look downward, at our own feet, at our own hands, at our own communities, and get organized.

The leaders of the Women’s March on Washington are making our transition into the movement easier. They’re offering us a clear way to get engaged, calling for people to take part in 10 Actions in 100 Days. The Friedman Justice League will be facilitating each of the ten collective actions proposed by the Women’s March on Washington organizers. The first action has been published, and it is a call for postcard- and letter-writing to elected officials.

Let’s let our politicians know that we are not going back to sleep. We have been pulled to the streets, and we want to be a part of the positive change that can come after such an outpouring of activism, advocacy, hope, and protest. All Friedman community members—students, staff, and faculty—are welcome to take part in a postcard-writing event this week. FJL will provide the supplies, and even information on certain topics and addresses of elected officials.

This event is a first step in turning this moment into a movement. See you there!

WHEN: Wednesday, February 1st (11:15-12:15) and Thursday February 2nd (12:30-1:15)

WHERE: Jaharis café

WHAT: FJL will have a table with all necessary supplies for postcards and letters

CONTACT: samantha.hoeffler@tufts.edu, caitlin.joseph@tufts.edu

Overdue for Overtime

by Julie Kurtz

A new California law just enacted the most revolutionary labor standards since the creation of the 40-hour work week.  What is it?  Well, it’s the 40-hour work week. But will it improve equality? Will it impact the cost of your food? Will equitable farm labor make your vegetables healthier? And will the new law change the curriculum at Friedman?

On Monday September 12th, California Governor Jerry Brown signed monumental legislation that should be of interest to all Friedman students. California Assembly Bill 1066 will require that agricultural workers be paid overtime for working more than eight hours in a day or forty hours in a week. While this may seem like a no-brainer, the current standard requires workers to work 10 hours/day and 60 hours/week before earning their overtime pay. The changes will be incremental starting in 2019, with full realization of the law by 2022 for most farms and 2025 for farms with fewer than 25 employees.

We take for granted the forty-hour week as a cornerstone of American work ethics, representing fair working hours and honoring the dignity of work. Many industries had a forty-hour workweek in place well before the 20th century. In the heat of the workers’ rights movements, victory came with the passage of the Fair Labor Standards Act in 1938, guaranteeing a maximum work hour week—or overtime compensation when forty hours were surpassed.

However, agricultural workers were exempt.

As were domestic workers.

In the 1930s African-Americans were disproportionately employed in agricultural and domestic labor. President Roosevelt signed the Fair Labors Standards Act knowing it was a compromise with Southern Congressmen who had a vested interest in excluding black employees to preserve the plantation-style economy of sharecroppers and black domestic workers.

While there are practical reasons why agricultural workers remained excluded from the labor rights that most Americans enjoy, mostly related to seasonality, it is clear that enormous power differentials persist between farm laborers and farm owners. In California more than 90% of farm laborers are Latino, and 80% are immigrants. Given the long history of labor exploitation in US Agriculture, what does it mean that the agricultural giant California has set this precedent of equality? Will the new overtime legislation be effective? Or are there loopholes that will inevitably allow the continued overworking of farm laborers? Will other states follow in California’s footsteps? And finally, to bring things back home, why should California Assembly Bill 1066 be discussed at 150 Harrison Avenue?

One of Friedman’s great strengths is our integrated approach to food. Friedman extends into every corner of the food system, from cutting edge nutritional science, consumer behavior, and food policy economics, to the environmental impacts of agriculture. Our system-wide approach enables Friedman to engage one of the most complex challenges on the planet: how to feed ourselves. But there is a realm where our reach rarely extends: labor.

I came to Friedman in part because we ask questions like “Is this tomato that is grown in nutrient-rich biodynamic soils healthier than a conventional tomato? Is it healthier for our bodies? Is it healthier for the land and for the sustainability of agriculture?” I’m thrilled that my education is helping me answer and provide insight to those questions. I’m less certain where on this campus we can ask: “Is this tomato that was grown by an equitably-paid farmer who has access to healthcare, leisure time, and education, as healthy as a tomato grown by a farmer who works 12-hour days, sees her children only briefly at dawn and night, and lacks a nutritious diet, time for education, and access to medical attention?”

Can healthy food come from an exploited workforce?

Second-year students from Friedman’s Agricultural Science & Policy II course recognized this gap in our education and knowledge. We do not feel equipped to evaluate and understand the impact of California’s new law in the grander context of the food system. As policy students we frequently discuss the “inputs” that go into our food: technology, land, and fertilizers. Labor is another input. But labor is people. We need a different set of tools to consider the migrant harvesters, the meat processors, the truck drivers, and the line cooks—the people without whom nutrition students would have nothing to study in the first place.

Fortunately we have a supportive faculty who has recognized the hole, and are working alongside us to bridge the gap. In fact, the entire Friedman community is invited to help bridge the gap:

  • In October the Friedman Seminar Committee will meet to determine Spring 2017 Seminar speakers and they will consider agricultural labor experts. To that end, students are invited (as they always are) to send speaker suggestions to Christian.Peters@tufts.edu.
  • Due to student requests, two AFE core courses (Nutr215 and Nutr333) will dedicate classroom time to address farm labor and the new California law. Interested students are invited to attend those lecture and discussion dates, and can email Timothy.Griffin@tufts.edu for more information.
  • As Friedman administration seeks to hire new faculty, we urge consideration of candidates with expertise in farm labor, food system law and justice.
  • Second-year AFE student Caitlin Joseph is spearheading a student-directed course on Agricultural Labor Policy and Justice in Spring 2017. Students interested in joining should contact her at Caitlin.Joseph@tufts.edu.

California AB 1066 did not materialize out of nowhere. How does its signing fit into the broader picture of dismantling inequality in the food system? As Friedman students and faculty, can we satisfactorily discuss nourishment if we are not equally concerned with the welfare of those who bring food to our table? What models exist to dismantle this systemic oppression? What impacts will those models have on the environment, on the economy, on nutrition, on academia, and mostly pertinently, on the labor force? And how can we integrate those models into the Friedman curriculum?

Julie Kurtz is in her second semester of the AFE program. She landed at Friedman after acting professionally in San Francisco, practicing Emergency Medicine in Minnesota, and farming in Bolivia.

 

Coming to a Presidential Candidate’s Plate Near You

by Carla Curle

With the presidential race narrowing down and the delegate counts ratcheting up for the top candidates, it still seems that food and agriculture policy are missing in the stump speeches and media interviews.

Even as the candidates campaigned in top agricultural states such as Iowa, Nebraska, and Illinois, the discussion of national food policy initiatives never seemed to make it to the forefront of the discussions. Instead, the Renewable Fuel Standard loomed large as a top issue for many agriculture voters in these states, so much so that fuel-based agriculture was one topic they were grilled on.

This is unfortunate, not only for Friedman School students, but for the entire country, which is plagued by rising rates of diet-related disease, proliferation of non-sustainable farming practices, and limited access to healthful foods. Grassroots efforts at local and regional levels such as Food Policy Councils and Farm to School activities are popping up all around the country, signifying a growing desire for positive changes to our food system. And according to a recent nationwide poll by the Johns Hopkins Center for a Livable Future, public support for food sustainability is high and crosses party lines. Of the 800 respondents, 92% believe that producing food in a sustainable way is a high priority and 79% want scientists — not politicians — to set the dietary guidelines.potu

In order to highlight this broken food system in the presidential race, the Plate of the Union Initiative was launched through a collaboration by the Union of Concerned Scientists, Food Policy Action, and the HEAL Food Alliance. This initiative includes a petition to our next president that can be signed by anyone with access to the Internet and an interest in the American food system, and includes the following statement:

Our food system is out of balance, and it’s time to take action. Current food policies prioritize corporate interests at the expense of our health, the environment, and working families. This has led to spikes in obesity and type-2 diabetes, costing taxpayers billions of dollars each year.

If you are elected president, I urge you to take bold steps to reform our food system to make sure every American has equal access to healthy, affordable food that is fair to workers, good for the environment, and keeps farmers on the land.

The Plate of the Union Initiative also includes an Activist Toolkit (coming soon), which will allow users to download a toolkit with resources and ideas to help individuals get involved in reforming our current food system.

The Obama Administration has made significant strides in improving American nutrition, thanks largely in part to First Lady Michelle Obama. Over the past 8 years, changes to nutrition policy have been met by Republican opposition and significant industry pushback. Despite all of the hurdles, there have been meaningful improvements made to the school lunch program and WIC through the Healthy, Hunger-Free Kids Act. The next administration must build on these successes and continue to address the numerous food system issues that exist in this country.

Where do the current five candidates stand on food and farm policy?

Democratic Candidates:

Secretary Hillary Clinton’s policies focus on strengthening rural economies by investing in infrastructure and expanding access to credit, promoting clean energy and stewardship of the land, and increasing agricultural production and profitability for family farms. During her time as a senator from New York, Clinton worked to connect and bridge the divide between her lower-income urban constituents with upstate farmers through her “Farm to Fork” program.

Senator Bernie Sanders’ rural economy policy platform focuses on expanding support for young and beginning farmers, producing a nutritious and abundant food supply, and encouraging farmers to act as partners in promoting conservation and combating climate change. Sanders has also endorsed local food production and is worried about the “dangerous concentration of ownership that exists in agriculture and the food industry.”

Republican Candidates:

Senator Ted Cruz’s food policy positions stem from his belief in limited government. Cruz voted against the 2014 Farm Bill, mainly because of its food stamp provisions and issues with the crop insurance program that he felt needed reform. He believes that agricultural subsidies should be focused on smaller and lower income farmers rather than “large conglomerate agricultural operations.”

The Ohio Farm Bureau named Governor John Kasich a “Friend of Agriculture” in 2014 for his support of the public policy goals that align with maintaining Ohio’s agricultural economy. Kasich has worked with environmental organizations and farmers to pass legislation to reduce nutrient runoff from agricultural operations. Kasich is the only Republican candidate who believes that humans contribute to climate change, but he does not want to end the use of fossil fuels entirely.

Little is known about Donald Trump’s stance on food or agriculture policy, but a few enlightening moments on the campaign trail may offer us some information. He doesn’t believe in climate change, calling it a “hoax” on multiple occasions, which doesn’t bode well for the mitigation and adaption that world leaders are calling for. In terms of food stamps, he believes something is “clearly wrong” when half of food stamp recipients have been receiving benefits for almost a decade.

Act Now:

It’s up to voters to demand answers from the candidates on the issues that matter to all of us: sustainable agriculture, improved animal welfare, access to healthy and affordable food, and fair working conditions. What can you as a food voter do? Sign the petition, research the candidates’ positions and voting records, and make sure you vote in the primaries and the general election in November.

Carla Curle is a second-year AFE student. She is also involved in the interdisciplinary Water: Systems, Science and Society (WSSS) program and is a firm believer that systems approaches to addressing problems will be the wave of the future. Also a co-chair of Slow Foods Tufts, you can find Carla nerding out over coffee, fermented items of any kind, and locally grown veggies. You can contact Carla at carla.curle@tufts.edu.

FNS Proposes Stricter Standards for SNAP Retailer Eligibility

by Emily Nink

A proposed rule by the Food and Nutrition Service aims to close loops in retailers’ eligibility to accept SNAP benefits. Public comments on the rule are open until April 16, 2016.

On February 17, the federal Food and Nutrition Service (FNS) filed a proposed rule to change retailer eligibility for participation in the Supplemental Nutrition Assistance Program (SNAP). The new ruling seeks to close loopholes and encourage healthier options at stores that accept SNAP benefits.Store_EBT

When applying for SNAP eligibility, retailers group their stock by first ingredient into four categories based on the 2010 Dietary Guidelines:

  1. Fruits and vegetables
  2. Breads and cereals
  3. Dairy
  4. Meat, fish and poultry

Under the new guidelines, retailers accepting SNAP benefits would have to:

  • Increase the number of stocked varieties in each of the staple food categories above from three to seven, and maintain six units per variety stocked at all times
  • Increase the number of categories in which perishable food varieties are stocked from two to three
  • Exclude foods with multiple ingredients (such as TV dinners and frozen pizzas) toward their stocking counts for staple foods, according to a new definition for staple foods (these items would still be eligible for purchase under SNAP, they just wouldn’t count toward a retailer’s eligibility)

The rule would not affect farmers’ markets or stores that specialize in a single staple food category (meaning 50 percent or more of their revenue is generated within a single category). FNS would also publicly disclose information on retailer disqualification for SNAP eligibility, in an effort to improve transparency and deter SNAP fraud.

The language of the proposal reveals the juggling act of regulating food retail to improve healthy food access. On one hand, FNS wants to encourage both a large number and wide range of retail options to accept SNAP benefits in their stores, acknowledging the importance of SNAP retailers in underserved areas. On the other hand, one of the best ways to improve healthy eating among SNAP recipients may be to regulate retailers rather than the individual beneficiaries, making eligibility more restrictive so that retailers expand their healthy food offerings.

One concern is that the rule might cause retailers to abandon their SNAP eligibility altogether, though, FNS doesn’t foresee this happening. Retailer authorization has been rising steadily—and the proposed rule is not intended to counteract this trend, but to incentivize owners to expand healthy options instead. To make sure the proposed rule doesn’t undermine healthy food access as a whole, the agency is requesting comments on other considerations for retailer eligibility. FNS could “consider factors such as distance from the nearest SNAP authorized retailer, transportation options to other SNAP authorized retailer locations, the gap between store’s stock and SNAP required stock for authorization eligibility, and whether the store furthers the purposes of the Program,” according to the proposed rule.

Balancing these two competing goals—broad access to SNAP retailers and healthy food availability at stores—is a policy puzzle on its own. Yet, the agency must also attempt to limit its own administrative burden, limit the cost of the change to retailers, and comply with other federal statutes, including the 2014 Farm Bill.

Ultimately, the proposed change is aimed at improving consumers’ eating habits—but by cracking down on retailers. The rule is a political stick, not a carrot. And that’s why retailers have taken advantage of loopholes in the past to increase their revenue through clever maneuvering. For instance, restaurants have split their businesses into two components (serving hot and cold foods) in order to gain SNAP eligibility for the portion of the business that sells cold foods that are ready to serve. And other businesses have heated food on-site after the point of sale, essentially serving restaurant food purchased with SNAP benefits. The new rule would close these loopholes for good.

The hope of FNS is that rather than losing eligibility (or finding new loopholes), retailers would expand their healthy offerings, ultimately improving the availability of healthy food overall. Of course, these eligibility requirements intervene only in the availability of healthy food, without addressing utilization. Will having seven varieties of type of staple food really increase the amount of healthy food purchased with SNAP benefits? Will six items in each variety suffice as a neighborhood source of healthy food? Or will the healthy options just sit on the shelves (an especial concern now that perishability is being emphasized)?

The public comments received via FNS’ request for information (preceding the proposed rules) reveal the myriad of potential details affected by the changes, and level criticisms ranging from minute to sweeping. Some are clearly aimed at protecting retailers from a perceived attack on profits. Others are rightly concerned with equity and sustainability.

Personally, I think that shifting the numbers slightly is unlikely to affect healthy food utilization much, when corner stores are only incentivized to do the bare minimum. Here’s the “fruits and vegetables” options at the corner store near my house:


potatoes

Incidentally, the Robert Wood Johnson Foundation Healthy Eating Research program recently released its own version of healthy food stocking guidelines for small retailers.

The new public comment period for the proposed rule ends April 16, 2016.

Emily Nink is a MS candidate in the Agriculture, Food and Environment program and a Policy Associate at the Public Health and Tobacco Policy Center.