The Food Marketing Institute (FMI) is pleased to respond to the U.S. Department of Agriculture’s (USDA’s) request for comments on the implementation of Special Supplemental Nutrition Program for Women, Infants and Children (WIC): Revisions in the WIC Food Packages; Interim Rule at 7 CFR Part 246.

Full Comments

  February 1, 2010 Via Electronic Portal and U.S. Mail Ms. Patricia N. Daniels Director, Supplemental Food Programs Division Food and Nutrition Services United States Department of Agriculture 3101 Park Center Drive, Room 528 Alexandria, Virginia 22302 Re: 7 CFR Part 246; Special Supplemental Nutrition Program for Women, Infants and Children (WIC): Revisions in the WIC Food Packages; Interim Rule (Docket No. FNS-2006-0037) Dear Ms. Daniels: 1 The Food Marketing Institute (FMI) is pleased to respond to the U.S. Department of Agriculture’s (USDA’s) request for comments on the implementation of Special Supplemental Nutrition Program for Women, Infants and Children (WIC): Revisions in the WIC Food Packages; Interim Rule at 7 CFR Part 246. FMI supports USDA’s goal of providing WIC customers with access to and education about healthy fruits and vegetables as part of the new WIC food package. FMI surveyed its members on how the expansion of a program that has gone from some 500 approved food items to more than 12,000 items to date is progressing from the vendors’ perspective. To that end, we provide the following comments relative to the new WIC Food Package, and then following, we present general comments on the WIC program as we also received those from our members. However, the general                                                              1    FMI conducts programs in public affairs, food safety, research, education and industry relations on behalf of its 1,500 member companies — food retailers and wholesalers — in the United States and around the world. FMI’s U.S. members operate approximately 26,000 retail food stores and 14,000 pharmacies. Their combined annual sales volume of $680 billion represents three-quarters of all retail food store sales in the United States. FMI’s retail membership is composed of large multi-store chains, regional firms and independent supermarkets. Its international membership includes 200 companies from more than 50 countries. FMI’s associate members include the supplier partners of its retail and wholesale members.      Ms. Patricia N. Daniels February 1, 2010 Page 2     comments we received are indirect issues that arose partially because of the increase in the number of available products. February 1, 2010 I. Revisions in the WIC Food Package Via Electronic Portal and U.S. Mail A. Stocking Requirements Ms. Patricia N. Daniels The federal program should not permit the promulgation of specific minimum stocking Director, Supplemental Food Programs Division requirements beyond the requirement for vendors to maintain two or more varieties in the fresh, Food and Nutrition Services frozen, or canned category of produce. Vendors are finding it difficult to maintain minimum stock United States Department of Agriculture levels in items such as soy beverages and tofu. In this instance, there should not be a minimum 3101 Park Center Drive, Room 528 stocking or inventory requirement since it is only a substitute for milk, and the product already has Alexandria, Virginia 22302 a limited customer base. This is an undue burden to retailers when inventory requirements exceed the product sold and the product must be discarded when the expiration date is reached. Another example of an undue hardship is the requirement of liquid concentrates of infant formula. This is a Re: 7 CFR Part 246; Special Supplemental Nutrition Program for Women, Infants case where the minimum stock requirement is higher than the demand of WIC Recipients. and Children (WIC): Revisions in the WIC Food Packages; Interim Rule (Docket No. FNS-2006-0037) In another instance, some states allow only one brand of jar baby food for WIC eligible Recipients to purchase. If a Recipient has a prescription that allows her to purchase upward of Dear Ms. Daniels: thirty jars at a time, it will only take a few other WIC Recipients in a day to deplete the stock of that category of food, particularly in smaller grocery stores. USDA should encourage all states to 1 The Food Marketing Institute (FMI) is pleased to respond to the U.S. Department of approve more than one brand of jar baby food. As manufacturer and store coupons are available, the Agriculture’s (USDA’s) request for comments on the implementation of Special Supplemental prices of different brands will fluctuate, thus encouraging WIC Recipients to learn how to avail Nutrition Program for Women, Infants and Children (WIC): Revisions in the WIC Food Packages; themselves to the least expensive price. Interim Rule at 7 CFR Part 246. Finding available stock of 16 oz. bread remains an issue. Traditionally, bread is baked and FMI supports USDA’s goal of providing WIC customers with access to and education about available in 20oz loaves and whole grain 20 oz. loaves in a store brand remain less expensive and healthy fruits and vegetables as part of the new WIC food package. FMI surveyed its members on more available than 16 oz. bread loaves. The same holds true for a 16 oz. whole grain/whole wheat how the expansion of a program that has gone from some 500 approved food items to more than tortilla. We respectfully request that USDA reconsider mandating the 16 oz whole grain bread and 12,000 items to date is progressing from the vendors’ perspective. To that end, we provide the allow the purchase of “up to” a 20 oz loaf of bread. following comments relative to the new WIC Food Package, and then following, we present general comments on the WIC program as we also received those from our members. However, the general B. WIC Package                                                              New WIC package differences in the states complicate store operations for our multi-state 1retail operators and distributors. For example, our members tell us that some States allow only fresh    FMI conducts programs in public affairs, food safety, research, education and industry relations on behalf of fruits and vegetables, some States allow fresh, canned and frozen fruits and vegetables, some States its 1,500 member companies — food retailers and wholesalers — in the United States and around the world. FMI’s U.S. allow only fresh and frozen fruits and vegetables and still other States allow only fresh and canned members operate approximately 26,000 retail food stores and 14,000 pharmacies. Their combined annual sales volume fruits and vegetables. Making uniform across the states the approved type (i.e. fresh, canned, of $680 billion represents three-quarters of all retail food store sales in the United States. FMI’s retail membership is frozen) of fruit and vegetable products will streamline retail processes and reduce costs for WIC composed of large multi-store chains, regional firms and independent supermarkets. Its international membership Recipients. Additionally, increased access to all types of fruits and vegetables will give WIC includes 200 companies from more than 50 countries. FMI’s associate members include the supplier partners of its Recipients more flexibility in their shopping choices. retail and wholesale members.       Ms. Patricia N. Daniels Ms. Patricia N. Daniels February 1, 2010 February 1, 2010 Page 2 Page 3       comments we received are indirect issFMI also encourages USDA to mues that arake uniformose partially b among the states the acceptance of somecause of the increase in the nume ber sugar in canned vegetables. In somof available products. e instances, such as in canned green peas, sugar is added during February 1, 2010 the canning process to keep the sk in of the pea from rupturing. As you know, all ingredients must be listed with the nutrition fact box. Currently, thI. Revisions in the WIC Food Package ere is no way to know if a sugar is added for flavoring or for canning processes. Via Electronic Portal and U.S. Mail A. Stocking Requirements Ms. Patricia N. Daniels The federal program should not permit the promulgation of specific minimum stocking C. Cash Value Vouchers and Split-Tender Director, Supplemental Food Programs Division requirements beyond the requirement for vendors to maintain two or more varieties in the fresh, Food and Nutrition Services The addition of cash value vouchers with random weights has caused time in the check-out frozen, or canned category of produce. Vendors are finding it difficult to maintain minimum stock United States Department of Agriculture lane to doublevels in itemle for Ws such as soy beverages and tofu. IC Recipients and those in In this instance, there should not be a mline behind them. Couple this with the prohibinimum ition 3101 Park Center Drive, Room 528 stocking or inventory requirement since it is only a substitute for milk, and the product already has by some states to allow the WIC Recipient to pay the difference (or to “split the tender”) between Alexandria, Virginia 22302 a limited customer base. This is an undue burden to retailers when inventory requirements exceed what her vouchers will cover and what she has brought to the cash register to purchase, and this the product sold and the product must be discarded when the expiration date is reached. Another slows down lane time and prevents the Recipient from completing her desired purchase. Some example of an undue hardship is the requirement of liquid concentrates of infant formula. This is a Re: 7 CFR Part 246; Special Supplemental Nutrition Program for Women, Infants States allow WIC Recipients to pay any overage, between what her voucher allows and in what she case where the minimum stock requirement is higher than the demand of WIC Recipients. and Children (WIC): Revisions in the WIC Food Packages; Interim Rule wishes to purchase by using cash, credit, EBT SNAP benefits, etc. to pay the difference. Other (Docket No. FNS-2006-0037) States require the WIC Recipient to take away items from her cart in order to stay within the set In another instance, some states allow only one brand of jar baby food for WIC eligible Recipients to purchase. If a Recipient has a prescription that allows her to purchase upward of amount that her voucher will cover. Disallowing the use of split tender is an unnecessary burden on Dear Ms. Daniels: thirty jars at a time, it will only take a few other WIC Recipients in a day to deplete the stock of that the WIC Recipient and hails back to the pre-EBT SNAP days, when embarrassment and stigma category of food, particularly in smaller grocery stores. USDA should encourage all states to 1 were associated with public assistance. To completely prevent placing a spotlight on the WIC The Food Marketing Institute (FMI) is pleased to respond to the U.S. Department of approve more than one brand of jar baby food. As manufacturer and store coupons are available, the Recipient, another option would be to allow benefits to roll into the next month, as SNAP benefits Agriculture’s (USDA’s) request for comments on the implementation of Special Supplemental prices of different brands will fluctuate, thus encouraging WIC Recipients to learn how to avail Nutrition Program for Women, Infants and Children (WIC): Revisions in the WIC Food Packages; do. themselves to the least expensive price. Interim Rule at 7 CFR Part 246. II. General WIC Comments Finding available stock of 16 oz. bread remains an issue. Traditionally, bread is baked and FMI supports USDA’s goal of providing WIC customers with access to and education about available in 20oz loaves and whole grain 20 oz. loaves in a store brand remain less expensive and healthy fruits and vegetables asA. Shelf Tags part of the new WIC food package. FMI surveyed its members on more available than 16 oz. bread loaves. The same holds true for a 16 oz. whole grain/whole wheat how the expansion of a program that has gone from some 500 approved food items to more than tortilla. We respectfully request that USDA reconsider mandating the 16 oz whole grain bread and As you know, the new WIC package has increased food stuffs available for WIC Recipients 12,000 items to date is progressing from the vendors’ perspective. To that end, we provide the allow the purchase of “up to” a 20 oz loaf of bread. to purchase fromfollowing comments relative to the new W some 500 to around 12,000 itemIC Food Packs. A large and new numage, and then following, we present general ber such as this brings comments on the WIC program as we also received those from our members. However, the general with it additional complications in terms of what is known by both the retail clerk and the WIC B. WIC Package Recipient about what is purchasable. One way to assist the WIC Recipient in picking out approved                                                              New WIC package differences in the states complicate store operations for our multi-state foods is the use of shelf tags as an aid. However, ensuring that a shelf tag is present for each and 1retail operators and distributors. For example, our members tell us that some States allow only fresh every one of these items, particularly given seasonal variability, is virtually impossible. Prohibiting    FMI conducts programs in public affairs, food safety, research, education and industry relations on behalf of fruits and vegetables, some States allow fresh, canned and frozen fruits and vegetables, some States retailers from using any shelf tags if they cannot guarantee that a shelf tag is present for every its 1,500 member companies — food retailers and wholesalers — in the United States and around the world. FMI’s U.S. allow only fresh and frozen fruits and vegetables and still other States allow only fresh and canned members operate approximately 26,000 retail food stores and 14,000 pharmacies. Their combined annual sales volume single WIC-eligible item will mean that WIC customers will be missing a potentially useful guide fruits and vegetables. Making uniform across the states the approved type (i.e. fresh, canned, of $680 billion represents three-quarters of all retail food store sales in the United States. FMI’s retail membership is that some retailers try to provide. Our members tell us that some States do not allow any frozen) of fruit and vegetable products will streamline retail processes and reduce costs for WIC composed of large multi-store chains, regional firms and independent supermarkets. Its international membership identification of WIC products, some States only allow retailers to use state-issued tags and some Recipients. Additionally, increased access to all types of fruits and vegetables will give WIC includes 200 companies from more than 50 countries. FMI’s associate members include the supplier partners of its States allow retailers to design and use their own WIC tag, but require state approval. We urge Recipients more flexibility in their shopping choices. retail and wholesale members.        Ms. Patricia N. Daniels Ms. Patricia N. Daniels Ms. Patricia N. Daniels February 1, 2010 February 1, 2010 February 1, 2010 Page 2 Page 4 Page 3         comments we received are indirect issUSDA to either amFMI also encourages USend the final regulations uniformDA to mues that arake uniformose partially bly across the states to allow re among the states the acceptance of somecause of the increase intailer the nums to use e ber sugar in canned vegetables. In somof available products. e instances, such as in canned green peas, sugar is added during shelf tags without requiring retailers to identify every single eligible item, or request that all States February 1, 2010 the canning process to keep the sk in of the pea from rupturing. As you know, all ingredients must implement shelf tag policies to help WIC mothers become more aware of WIC eligible products. be listed with the nutrition fact box. Currently, thI. Revisions in the WIC Food Package ere is no way to know if a sugar is added for flavoring or for canning processes. B. National Universal Product Code (UPC) Database Via Electronic Portal and U.S. Mail A. Stocking Requirements In addition to using shelf tags as an aid to assist WIC recipients, a tool that would provide Ms. Patricia N. Daniels The federal program should not permit the promulgation of specific minimum stocking maximuC.m benefits in term Cash Value Vouchers and Split-Tender s of a pleasant, efficient and less stressful shopping experience is the use Director, Supplemental Food Programs Division requirements beyond the requirement for vendors to maintain two or more varieties in the fresh, of a National UPC Database containing all approved products with their identifying UPC code. It is Food and Nutrition Services The addition of cash value vouchers with random weights has caused time in the check-out frozen, or canned category of produce. Vendors are finding it difficult to maintain minimum stock difficult to match a state description with an order book description that may result in the wrong United States Department of Agriculture lane to doubitemlevels in items authorized at retail. As Wle for Ws such as soy beverages and tofu. IC RecipienIC converts to ants and those in In this instance, there should not be a mline behind them Electronic Benefit Trans. Couple this with thfer (EBT) structure, a e prohibinimum ition 3101 Park Center Drive, Room 528 national UPC database is one critstocking or inventory requirement since it is only ical component of supporting a ma substitute for moilk, and the product already has re efficient process at the point- by some states to allow the WIC Recipient to pay the difference (or to “split the tender”) between Alexandria, Virginia 22302 a limited customer base. This is an undue burden to retailers when inventory requirements exceed of-sale, helping to reduce confusion and time in the checkout lane for WIC Recipients. what her vouchers will cover and what she has brought to the cash register to purchase, and this the product sold and the product must be discarded when the expiration date is reached. Another slows down lane time and prevents the Recipient from completing her desired purchase. Some example of an undue hardship is the requirement of liquid concentrates of infant formula. This is a FMI recognizes that this is a large undertaking, but providing the correct food stuffs to WIC Re: 7 CFR Part 246; Special Supplemental Nutrition Program for Women, Infants States allow WIC Recipients to pay any overage, between what her voucher allows and in what she Recipiencase where the mts from such a large quaninimum stock requtity that includirement is higher than the demes substitutions and prohibitions such as sugar and and of WIC Recipients. and Children (WIC): Revisions in the WIC Food Packages; Interim Rule wishes to purchase by using cash, credit, EBT SNAP benefits, etc. to pay the difference. Other salt, is a large undertakin g as well. A transitional interim approach for list development, flagging (Docket No. FNS-2006-0037) States require the WIC Recipient to take away items from her cart in order to stay within the set In another instance, some states allow only one brand of jar baby food for WIC eligible and enforcement should be considered until the national UPC database is available for this purpose. Recipients to purchase. If a Recipient has a prescription that allows her to purchase upward of am ount that her voucher will cover. Disallowing the use of split tender is an unnecessary burden on Dear Ms. Daniels: thirty jars at a time, it will only take a few other WIC Recipients in a day to deplete the stock of that C. WIC Voucher – “Do Not Exceed” Field the WIC Recipient and hails back to the pre-EBT SNAP days, when embarrassment and stigma category of food, particularly in smaller grocery stores. USDA should encourage all states to 1 were associated with public assistance. To completely prevent placing a spotlight on the WIC The Food Marketing Institute (FMI) is pleased to respond to the U.S. Department of approve mWIoC vouchers have a “dre than one brand of jar baby food. As o not exceed” field on thmanufacturer and store ce check, but it is nooupons are available, the t filled in. If it were to Recipient, another option would be to allow benefits to roll into the next month, as SNAP benefits Agriculture’s (USDA’s) request for comments on the implementation of Special Supplemental prices of different brands will fluctuate, thus encouraging WIC Recipients to learn how to avail be filled in with the monetary amount that a WIC Recipient must not exceed, it would be less Nutrition Program for Women, Infants and Children (WIC): Revisions in the WIC Food Packages; do. themselves to the least expensive price. confusing between cash value vouchers and regular WIC vouchers as well as giving the WIC Interim Rule at 7 CFR Part 246. Recipient and vendor the knowledge of what the check is worth. Many times, a vendor will not II. General WIC Comments know if the WFinding available stock of 16 oz. bread remIC Recipient has exceeded her monetary alloains an issue. Tradtment until thitionalle check is dy, bread is baked and eposited and FMI supports USDA’s goal of providing WIC customers with access to and education about available in 20oz loaves and wholreturned, and in some cases, without being paide grain 20 oz. loaves in a store brand rem because of an overage. By having the “do not ain less expensive and healthy fruits and vegetables asA. Shelf Tags part of the new WIC food package. FMI surveyed its members on more available than 16 oz. bread loaves. The same holds true for a 16 oz. whole grain/whole wheat exceed” field filled in, a clerk would be able to input this information into the cash register, and how the expansion of a program that has gone from some 500 approved food items to more than tortilla. We respectfully request that USDA reconsider mandating the 16 oz whole grain bread and receive a cash register prompt, for example, “thirty-five cents left” and the clerk would have the As you know, the new WIC package has increased food stuffs available for WIC Recipients 12,000 items to date is progressing from the vendors’ perspective. To that end, we provide the allow the purchase of “up to” a 20 oz loaf of bread. opportunity to inform the WIC Recipient, allowing her to decide if she would like to purchase any to purchase fromfollowing comments relative to the new W some 500 to around 12,000 itemIC Food Packs. A large and new numage, and then following, we present general ber such as this brings additional item s with a different tender. This also allows the vendor to receive in good faith money comments on the WIC program as we also received those from our members. However, the general with it additional complications in terms of what is known by both the retail clerk and the WIC that is owed themB. WIC Packa for foodge products that are sold. Recipient about what is purchasable. One way to assist the WIC Recipient in picking out approved                                                              New WIC package differences in the states complicate store operations for our multi-state foods is the use of shelf tags as an aid. However,D. WIC Store Licenses ensuring that a shelf tag is present for each and 1retail operators and distributors. For example, our members tell us that some States allow only fresh every one of these items, particularly given seasonal variability, is virtually impossible. Prohibiting    FMI conducts programs in public affairs, food safety, research, education and industry relations on behalf of fruits and vegetables, somSome States find it necessary to ime States allow fresh, canned and frozen fruplement moratoriums on new Wits and vegetables, somIC vendors, but this e States retailers from using any shelf tags if they cannot guarantee that a shelf tag is present for every its 1,500 member companies — food retailers and wholesalers — in the United States and around the world. FMI’s U.S. limallow only fits competition and slows growth to areas that resh and frozen fruits and vegetables and still other need more retail outlets and does a disservice to States allow only fresh and canned members operate approximately 26,000 retail food stores and 14,000 pharmacies. Their combined annual sales volume single WIC-eligible item will mean that WIC customers will be missing a potentially useful guide fruits and vegetables. Making uniform across the states the approved type (i.e. fresh, canned, the WIC Recipient by preventing their shopping at the newest and most up-to-date stores in a given of $680 billion represents three-quarters of all retail food store sales in the United States. FMI’s retail membership is that some retailers try to provide. Our members tell us that some States do not allow any frozen) of fruit and vegetable products will streamline retail processes and reduce costs for WIC neighborhood. Our members tell us that vendor approval continues to be a slow and painstaking composed of large multi-store chains, regional firms and independent supermarkets. Its international membership identification of WIC products, some States only allow retailers to use state-issued tags and some Recipients. Additionally, increased access to all types of fruits and vegetables will give WIC task. Often stores change owners, and not store name, leaving the WIC Recipient in a quandary as includes 200 companies from more than 50 countries. FMI’s associate members include the supplier partners of its States allow retailers to design and use their own WIC tag, but require state approval. We urge well as confRecipients more flexibility in their sused as to how the store accepted WIC on Fridayhopping choices. but can no longer take their WIC retail and wholesale members.         Ms. Patricia N. Daniels Ms. Patricia N. Daniels Ms. Patricia N. Daniels Ms. Patricia N. Daniels February 1, 2010 February 1, 2010 February 1, 2010 February 1, 2010 Page 3 Page 4 Page 5 Page 2           USDA to either amcomments we received are indirect isscheck on Monday. Along the samFMI also encourages USend the final regulations uniformDA to me lines, it is very imues that arake uniformose partially bly across the states to allow re apormtant that vendors have ong the states the acceptance of somecause of the increase inthe flexibility to get tailer the nums to use e ber sugar in canned vegetables. In soma store licensed prior toof available products. opening day. If a store cannot acce instances, such as in canned green peas, sugar is added during ept WIC benefits on day one, WIC shelf tags without requiring retailers to identify every single eligible item, or request that all States February 1, 2010 the canning process to keep the skRecipients m ay never return to that store under the assumin of the pea from rupturing. As you know, all ingredients mption that they don’t and never will accept ust implement shelf tag policies to help WIC mothers become more aware of WIC eligible products. be listed with the nutrition fact box. Currently, thWI. IC benefits, even if it is the mRevisions in the WIC Food Package ost convenient shopping location for them and provides the greatest ere is no way to know if a sugar is added for access to healthy and nuflavoring or for canning processes. tritious foods. B. National Universal Product Code (UPC) Database Via Electronic Portal and U.S. Mail A. Stocking Requirements At the very least, we recommIn addition to using shelf tags as an aid to aend applications be expedited ssist WIC recipients, a tofor those operators who already ol that would provide Ms. Patricia N. Daniels have a WThe federal programIC vendor number in the should not permit the prstate, through another store. Aomulgation of specific mccordingly, we urge USDA to inimum stocking maximuC.m benefits in term Cash Value Vouchers and Split-Tender s of a pleasant, efficient and less stressful shopping experience is the use Director, Supplemental Food Programs Division prohibit states fromrequirements beyond the requirem putting a moratoriument for vendors to m on new licenses or otherwise numaintain two or more varieties in the fresh, erically restricting the of a National UPC Database containing all approved products with their identifying UPC code. It is Food and Nutrition Services The addition of cash value vouchers with random weights has caused time in the check-out numfrozen, or canned category of produce. Vendors are ber of stores eligible for WIC licenses, and we encourage USDA to provide the necessary finding it difficult to maintain minimum stock difficult to match a state description with an order book description that may result in the wrong United States Department of Agriculture lane to doubresources to ensure vendors halevels in itemitems authorized at retail. As Wle for Ws such as soy beverages and tofu. IC Recipienve thIC converts to ants and those in e ability to obIn this instance, there should not be a mline behind them Electronic Btain licenses for store opening days. enefit Trans. Couple this with thfer (EBT) structure, a e prohibinimum ition 3101 Park Center Drive, Room 528 stocking or inventory requiremnational UPC database is one critent since it is only ical component of supporting a ma substitute for moilk, and the product already has re efficient process at the point- by some states to allow the WIC Recipient to pay the difference (or to “split the tender”) between Alexandria, Virginia 22302 a limited customer base. This is an undue burden to retailers when invent ory requirements exceed of-sale, helping to reduce confusion and time in the checkout lane for WIC Recipients. what her vouchers will cover and what she has brought to the cash register to purchase, and this the product sold and the product must be discarded when the expi* * * ration date is reached. Another slows down lane time and prevents the Recipient from completing her desired purchase. Some example of an undue hardship is the requirement of liquid concentrates of infant formula. This is a FMI recognizes that this is a large undertaking, but providing the correct food stuffs to WIC Re: 7 CFR Part 246; Special Supplemental Nutrition Program for Women, Infants States allow WIC Recipients to pay any overage, between what her voucher allows and in what she Recipiencase where the mFMI recognizes that this ists from such a large quaninimum stock requtity that includ a large undertaking by Reciirement is higher than the demes substitutions and prohibitions such as sugar and pients, USDA and the vendor and of WIC Recipients. and Children (WIC): Revisions in the WIC Food Packages; Interim Rule wishes to purchase by using cash, credit, EBT SNAP benefits, etc. to pay the difference. Other community. We commsalt, is a large undertakin end USDA forg as well. A transitional interim the proposal to include f approach for list developmruits and vegetables in the Went, flagging IC food (Docket No. FNS-2006-0037) States require the WIC Recipient to take away items from her cart in order to stay within the set package and we respectfully request that you coIn another instance, some states allow only nsider our comments in this regard. Fone brand of jar baby food for WIC eligible MI looks and enforcement should be considered until the national UPC database is available for this purpose. forward to continuing to work with you. Recipients to purchase. If a Recipient has a prescription that allows her to purchase upward of am ount that her voucher will cover. Disallowing the use of split tender is an unnecessary burden on Dear Ms. Daniels: thirty jars at a time, it will only take a few other WIC Recipients in a day to deplete the stock of that C. WIC Voucher – “Do Not Exceed” Field the WIC Recipient and hails back to the pre-EBT SNAP days, when embarrassment and stigma category of food, particularly in smaller grocerSincerely, y stores. USDA should encourage all states to 1 were associated with public assistance. To completely prevent placing a spotlight on the WIC The Food Marketing Institute (FMI) is pleased to respond to the U.S. Department of approve mWIoC vouchers have a “dre than one brand of jar baby food. As o not exceed ” field on thmanufacturer and store ce check, but it is nooupons are available, the t filled in. If it were to Recipient, another option would be to allow benefits to roll into the next month, as SNAP benefits Agriculture’s (USDA’s) request for comments on the implementation of Special Supplemental prices of different brands will fluctuate, thu s encouraging WIC Recipients to learn how to avail be filled in with the monetary amount that a WIC Recipient must not exceed, it would be less Nutrition Program for Women, Infants and Children (WIC): Revisions in the WIC Food Packages; do. themselves to the least expensive price. confusing between cash value vouchers and regular WIC vouchers as well as giving the WIC Interim Rule at 7 CFR Part 246. Recipient and vendor the knowledge of what the check is worth. Many times, a vendor will not II. General WIC Comments know if the WFinding available stock of 16 oz. bread remIC Recipient has exceeded her mJennifer Hatcheronetary alloains   an issue. Tradtment until thitionalle check is dy, bread is baked and eposited and FMI supports USDA’s goal of providing WIC customers with access to and education about available in 20oz loaves and wholreturned, and in some cases, without being paide grain 20 oz. loaves in a store brand remGroup Vice President because of an overage. By having the “do not ain less expensive and healthy fruits and vegetables asA. Shelf Tags part of the new WIC food package. FMI surveyed its members on more available than 16 oz. bread loaves. The samGovernmente Relations holds true for a 16 oz. whole grain/whole wheat exceed” field filled in, a clerk would be able to input this information into the cash register, and how the expansion of a program that has gone from some 500 approved food items to more than tortilla. W  e respectfully request that USDA reconsider mandating the 16 oz whole grain bread and receive a cash register prompt, for example, “thirty-five cents left” and the clerk would have the As you know, the new WIC package has increased food stuffs available for WIC Recipients 12,000 items to date is progressing from the vendors’ perspective. To that end, we provide the   allow the purchase of “up to” a 20 oz loaf of bread. opportunity to inform the WIC Recipient, allowing her to decide if she would like to purchase any to purchase fromfollowing comments relative to the new W some 500 to around 12,000 itemIC Food Packs. A large and new numage, and then following, we present general ber such as this brings additional item s with a different tender. This also allows the vendor to receive in good faith money comments on the WIC program as we also received those from our members. However, the general with it additional complications in terms of what is known by both the retail clerk and the WIC that is owed themB. WIC Packa for foodge products that are sold. Recipient about what is purchasable. One way to assist the WIC Recipient in picking out approved                                                              New WIC package differences in the states complicate store operations for our multi-state foods is the use of shelf tags as an aid. However,D. WIC Store Licenses ensuring that a shelf tag is present for each and 1retail operators and distributors. For example, our members tell us that some States allow only fresh every one of these items, particularly given seasonal variability, is virtually impossible. Prohibiting    FMI conducts programs in public affairs, food safety, research, education and industry relations on behalf of fruits and vegetables, somSome States find it necessary to ime States allow fresh, canned and frozen fruplement moratoriums on new Wits and vegetables, somIC vendors, but this e States retailers from using any shelf tags if they cannot guarantee that a shelf tag is present for every its 1,500 member companies — food retailers and wholesalers — in the United States and around the world. FMI’s U.S. limallow only fits competition and slows growth to areas that resh and frozen fruits and vegetables and still other need more retail outlets and does a disservice to States allow only fresh and canned members operate approximately 26,000 retail food stores and 14,000 pharmacies. Their combined annual sales volume single WIC-eligible item will mean that WIC customers will be missing a potentially useful guide fruits and vegetables. Making uniform across the states the approved type (i.e. fresh, canned, the WIC Recipient by preventing their shopping at the newest and most up-to-date stores in a given of $680 billion represents three-quarters of all retail food store sales in the United States. FMI’s retail membership is that some retailers try to provide. Our members tell us that some States do not allow any frozen) of fruit and vegetable products will streamline retail processes and reduce costs for WIC neighborhood. Our members tell us that vendor approval continues to be a slow and painstaking composed of large multi-store chains, regional firms and independent supermarkets. Its international membership identification of WIC products, some States only allow retailers to use state-issued tags and some Recipients. Additionally, increased access to all types of fruits and vegetables will give WIC task. Often stores change owners, and not store name, leaving the WIC Recipient in a quandary as includes 200 companies from more than 50 countries. FMI’s associate members include the supplier partners of its States allow retailers to design and use their own WIC tag, but require state approval. We urge well as confRecipients more flexibility in their sused as to how the store accepted WIC on Fridayhopping choices. but can no longer take their WIC retail and wholesale members.