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This memorandum outlines a proposal to modify … - nestle and general mills
A PROPOSAL TO CREATE A DEMONSTRATION PROJECT IN NEW YORK CITY TO MODIFY ALLOWABLE PURCHASES UNDER THE FEDERAL SUPPLEMENTAL NUTRITION ASSISTANCE PROGRAM
Introduction
Since its introduction in the Federal Food Stamp Act of 1964, the Food Stamp Program’s intent has always been to “provide for improved levels of nutrition among low-income households”. The Food and Nutrition Act of 2008 reinforced this aim, declaring it a policy of Congress “in order to promote the general welfare, to safeguard the health and well-being of the Nation’s population by raising levels of nutrition among low-income households”.[i]
However, despite the clearly stated intentions of the Food Stamp Program, now called the Supplemental Nutrition Assistance Program (SNAP), a large proportion of expenditures under the SNAP support the purchase of food items defined by the United States Department of Agriculture (USDA) to be of little or no nutritional value, including soda and other sugar-sweetened beverages [“sweetened beverages”[1]]. According to a 1999 USDA survey, 20% of the total caloric intake of SNAP households was from fats, oils, sweets, and soda – with soda accounting for almost 6% of total caloric intake.[ii]
The use of SNAP benefits to purchase foods of little or no nutritional value not only contradicts the intent of the program, it also effectively subsidizes a serious public health epidemic. Sweetened beverages are a major contributor to obesity, and although federal food assistance policy increasingly has emphasized improved nutrition, the twin crises of obesity and diabetes continue to worsen across America. Estimates from 2007-2008 suggest that 34% of American adults and 17% of children were obese, which means adult obesity has doubled and child obesity has tripled since 1980.[iii] Faced with these alarming trends, the White House Task Force on Childhood Obesity issued a report in 2010 that included recommendations calling for the nation’s food assistance programs to be part of the solution by encouraging access to nutritious foods and offering incentives and eliminating disincentives to unhealthy eating habits.[iv]
In addition to being inconsistent with the program’s stated goal of improving nutrition among low-income households, allowing the purchase of sweetened beverages directly competes with the USDA’s nutrition education programming at the federal and local level. An estimated $75 to $135 million dollars of SNAP funds were spent on sweetened beverages in New York City (NYC) alone in 2009.[v] This use of federal funds to purchase a group of products that are leading contributors to the diabetes and obesity epidemics (and whose extensive consumption contradicts the USDA’s own recommended dietary guidelines) far outstrips current federal funding for prevention of these health problems. Especially in this extremely challenging economic and fiscal climate, federal nutrition programs and policy should be coordinated to support the goals of nutrition education and the fight against the epidemic of obesity, not to contradict them.
As such, the following proposes a demonstration project to be operated in New York City to modify the list of allowable purchases under the SNAP to exclude the purchase of sweetened beverages with SNAP benefits. The proposed demonstration project will support the stated goal of the SNAP to improve the nutrition of low-income households, while allowing an opportunity to evaluate whether such a restriction can reduce consumption of these beverages.
Proposal
The New York State Office of Temporary and Disability Assistance (OTDA) is proposing that it be granted permission to modify the list of allowable food items to be purchased with SNAP benefits in NYC as a demonstration project. Specifically, the demonstration project would add to the list of exclusions in the definition of “Food” under Section 3 [7 U.S.C. 2012(k)] of the Food and Nutrition Act of 2008:
• Sweetened beverages containing more than 10 calories per cup (exempting fruit juice without added sugar, milk products, and milk substitutes).
Authorized SNAP retailers in NYC will be required to modify the list of allowable purchases by re-programming their point-of-sale (POS) systems using a list of restricted beverages provided by the NYC Department of Health and Mental Hygiene (DOHMH). Currently, these retailers program their systems to accommodate other SNAP exclusions (e.g., alcohol, tobacco, prepared foods, nutrition supplements, etc.) and the proposed change will minimally impact their operations. Retailers who rely on a manual process to identify allowable purchases will be required to update their list of exclusions to include the beverages identified on the DOHMH list and implement as appropriate for their operation. The NYC Human Resources Administration (HRA) will be responsible for engaging retailers and retailer trade associations prior to implementation to gain buy-in and explain the new restrictions. In addition, informational materials will be distributed to retailers prior to implementation so that they are fully informed of the new restrictions. HRA will be available and responsive to retailer concerns and implementation issues.
Similar proposals to eliminate foods of minimal nutritional value from allowable SNAP purchases have been submitted to USDA by other state and local entities, including the Minnesota Department of Human Services in 2004. We believe this proposal effectively addresses the reasons cited by USDA for denial of these other waiver requests. We believe that this proposal will be significantly less complicated to implement, both from policy and logistical perspectives. In addition, we propose a comprehensive and rigorous evaluation of the demonstration project to test whether the restriction is effective in reducing the consumption of sweetened beverages among SNAP participants.
Justification for Request
• The proposed modification supports the stated nutritional goal of the Supplemental Nutrition Assistance Program.
Federal food policy has a long history of working to improve nutrition among the nation’s poor, which was continued in the Food and Nutrition Act of 2008. The emphasis on nutrition education as part of the program began as early as the 1980s, with the Food Security Act of 1985, which required state agencies to encourage recipients to participate in nutrition education programs. In 1990, Food Stamp Program funding was dedicated to projects aimed at improving nutrition education activities and for fiscal year 2009 over $341 million in federal funding was approved for SNAP nutrition education programming, covering half of the total amount spent by states.[vi] There has also been an increasing emphasis on finding innovative ways to improve nutrition among America’s poor. Welfare reform in 1996 permitted the USDA to waive program requirements to conduct pilot projects to improve nutrition among needy families and the Food and Nutrition Act of 2008 allowed the same. Allowing the purchase of foods with minimal nutritional value under the current program is a direct contradiction of these efforts and the stated federal policy to improve nutrition among the nation’s poor.
• Obesity is a significant and growing problem across the country and in NYC.
The significance of the obesity problem is clear and the costs are staggering. In NYC, 22.6% of adults were obese in 2008, compared to 12.3% just over a decade ago. Furthermore, being overweight is a condition that affects the majority of NYC adults, with 57.9% either overweight or obese in 2008. There are also large disparities in obesity rates by income level. In 2008, 27.4% of NYC adults in poverty were obese, compared to 15.2% of adults with incomes greater than 500% of poverty. These high levels of obesity have led to other health problems, including diabetes, the prevalence of which is 12.5% and rising in NYC.[vii]
The higher incidence of obesity translates into significant health-related costs at the federal and local levels. In 2000, the total cost of obesity in the United States was estimated to be $117 billion.[viii] Nearly half of all medical spending related to adult obesity is financed by the public sector, through Medicaid and Medicare.[ix] The proposed modification of allowable purchases under the SNAP is one component of the City of New York’s (City) coordinated strategy to combat obesity and diabetes by increasing access to healthy foods, decreasing access to unhealthy foods, and getting New Yorkers engaged in physical activity.
• Obesity and diabetes have been linked to increased consumption of sweetened beverages.
Many studies have attributed rising rates of obesity and diabetes to increased calorie consumption, much of which comes from sweetened beverages.[x] The USDA Economic Research Service recognized this in a July 2010 report and acknowledged the use of economic incentives to decrease consumption of sweetened beverages as a strategy for reducing obesity.[xi] Americans consume 200 to 300 more calories per day than 30 years ago, with the largest single increase due to sweetened beverages.[xii] In addition, nearly half of the sugar consumed by Americans comes from sweetened beverages.[xiii] Among children, more than 10% of daily caloric intake has been attributed to sweetened beverages, and it is even higher in adolescents. In fact, each additional sweetened beverage per day increases a child’s risk of obesity by 60%.[xiv] Randomized controlled trials have shown that substituting sweetened beverages with low calorie drinks decreases body mass index in overweight children.[xv] Another study found the risk of developing diabetes was 83% higher among women who consumed one or more sweetened beverages a day.[xvi] While restricting the purchase of sweetened beverages under the SNAP alone will not solve the problems identified above, it is an important component in a comprehensive effort to reduce consumption of these products among all NYC residents.
• Low-income populations are more likely to consume low-cost foods that contribute to obesity and diabetes, including sweetened beverages.
Research shows that soda, sugary snacks, and fast food are readily available in low-income neighborhoods and have replaced more nutritious foods like milk.[xvii] [xviii] A 2008 study found that consumption of non-sugar-free sodas was higher in SNAP participants and income-eligible non-participants than higher-income non-participants.[xix] In addition, numerous studies have found that poorer children are more likely to be overweight, and the link between obesity and socioeconomic status has become stronger in the past two decades.[xx] The disparity is also true with diabetes. In NYC’s poorest households, 16.3% of adults have diabetes, which is quadruple the 4% rate seen in the wealthiest households.[xxi] Given the increasingly recognized and documented health consequences from frequent and routine consumption of sweetened beverages -- consequences which have been most devastating to NYC’s poorest households, it is inappropriate for the City’s nutrition assistance program to support this consumption.
• Significant federal and local funding has been dedicated to nutrition education and the proposed modification would support rather than contradict these efforts.
The growing problem of obesity in the United States has led to increased spending for prevention and nutrition education programs at both the federal and local levels. In fiscal year 2004, the federal government spent approximately $530 million on nutrition education.[xxii] In the 2009 federal budget, the Centers for Disease Control and Prevention (CDC) alone included $947 million for health promotion, of which $41 million was earmarked for efforts to improve nutrition, increase physical activity, and reduce obesity levels. In addition to these efforts, the USDA was allocated over $341 million in federal funding for nutrition education in Fiscal Year 2009, funding that was matched by states. Given the significant public investment in healthy eating and obesity prevention, the SNAP should support rather than contradict these efforts.
• The proposed change complements, and is supported by, the USDA’s and the City’s strategies to improve nutrition among low-income populations.
This demonstration project would support the goals of USDA’s recently issued Strategic Plan, which specifically calls for “evaluating nutrition promotion interventions to implement and sustain evidence based strategies in communities across the Nation” and which also proposes a focus on areas where the USDA’s unique strengths and capabilities can have the greatest impact. The proposed revisions to the US Dietary Guidelines recently issued for public comment also recommend reduction of high-calorie, non-nutritious foods, including sweetened beverages.[xxiii]
Locally, the City has implemented a number of programs and services, designed to educate and improve access to nutritious food, that have laid the groundwork for and can work synergistically with the proposed pilot. Significant public funds have been invested to improve access to healthy foods in underserved neighborhoods, provide healthy school lunches and snacks, and increase physical activity among school-aged children. In fact, in 2007, the City established the first Office of Food Policy Coordination to better coordinate the City’s efforts and to highlight the commitment towards nutrition and health at the local level. Through a number of efforts by the Office of Food Policy Coordination and the NYC DOHMH (along with other City agencies), low-income neighborhoods have increased access to nutritious foods and beverages that will serve as appropriate substitutes for sweetened beverages. This means that even with the proposed restriction on using SNAP benefits for the purchase of sweetened beverages participants will have many other more nutritious options available.
Examples of City initiatives that will support the proposed pilot program include the following:
• The NYC DOHMH’s Healthy Bodegas Initiative has worked directly and successfully with over 1,000 retail food establishments in low income areas to increase their inventory and promotion of healthier drinks, which would serve as alternatives to sweetened beverages for SNAP participants. The initiative has also worked with approximately 120 stores to promote a variety of healthier foods, including healthier beverages like low fat milk, water, and other low to no calorie drinks. Stores have agreed to increase inventory of these items and promote them throughout the store using shelf talkers, point of selection advertisements, and product placement. Specifically, through this initiative, 21% of bodegas started carrying low-fat milk for the first time and 45% of retailers reported an increase in sales of low fat milk. Low fat milk sales increased from 16% to 53% of all milk purchases.[xxiv] The number of stores placing refrigerated water at eye level increased from 35% to 64% and the number purchasing at least one bottle of water increased from 6% to 12%.
• Green markets in New York City now accept SNAP benefits, which increase clients’ access to fresh fruits and vegetables, and the “Health Bucks” program provides vouchers for the purchase of additional fruits and vegetables to consumers who use SNAP benefits at green markets. These programs provide SNAP participants with healthier alternatives to sweetened beverages.
• The Department of City Planning and the State have worked together to launch the FRESH initiative, to provide incentives to supermarkets to locate in areas with poor access to healthy foods. This would provide another venue to use SNAP benefits for the purchase of healthier alternatives to sweetened beverages.
• The CDC has funded the City’s attempt to reduce obesity through policy, systems, and environmental changes that make healthy eating decisions easier. Interventions that affect the price of goods, as well as those that address the consumption of sweetened beverages specifically, have been encouraged by the CDC. Assessing the feasibility of policies to modify the price and accessibility of sweetened beverages was part of the City’s successful proposal to the federal government.
• The DOHMH, as well as other City agencies, has imposed nutritional standards for school and other meals that are more stringent than currently required by the USDA and exclude the sale of certain items, such as sodas.
• The DOHMH has trained thousands of daycare staff, parents, and children in physical activity and nutrition, implemented nutrition education curricula in schools, developed School Wellness Councils, and launched various public information and media campaigns, including on sweetened beverages.[xxv] DOHMH also has successfully restricted trans fats in restaurants and has instituted calorie labeling in chain restaurants.
• The City’s SNAP, administered by HRA, provides nutrition education to program participants. HRA participates in the New York State Eat Smart New York (ESNY) Program and educates up to 20,000 adults and over 50,000 children each year on healthy eating habits. The ESNY program curriculum focuses on educating consumers on eating recommended allowances of healthy foods and reducing consumption of sugars. The pilot program will complement these efforts by encouraging SNAP participants to purchase more nutritious foods rather than sweetened beverages.
• Tax exemptions for food purchased under the SNAP serve as an additional incentive to purchase sweetened beverages.
SNAP does not allow States to collect sales tax on items purchased with SNAP benefits. This means that program participants can purchase taxable food items, such as soda in New York State, at a lower cost if they use their SNAP benefits than if they used cash. The message being sent is clear - items such as soda are less costly under the SNAP. A recent USDA report supports the evidence that taxing sweetened beverages reduces consumption.[xxvi] Permitting SNAP benefits to be used for purchase of sweetened beverages tax-free promotes greater consumption of these empty calories.[xxvii]
• Given that a USDA precedent for defining sweetened beverages as a non-nutritious food already exists, the demonstration project will make SNAP rules more consistent with those of other programs.
The USDA already has set a precedent for defining sweetened beverages as a food with “minimal nutritional value” in their National School Lunch guidelines. The National School Lunch Program/School Breakfast Program excludes “foods of minimal nutritional value (FMNV).” The purchase of such foods with the “nonprofit school food service account (SFSA)” is prohibited, as is the serving of FMNV “during a meal service period(s) in the area(s) where reimbursable meals are served and/or eaten.” (See USDA Guidance on this subject dated January 16, 2001.) The Guidance pointedly and specifically cites as an example of FMNV “a carbonated beverage.”
Accordingly, this demonstration project would “allow greater conformity with the rules of other programs.” In addition, a USDA denial of this project would be in contradiction to its own explicitly stated and implemented policy in the School Lunch and Breakfast Programs as detailed in the 2001 Guidance, as well as a contradiction to the recently issued USDA Strategic Plan.
• Implementation of food restrictions would not increase program complexity and costs.
Currently, all retailers who accept SNAP benefits in New York State use the Electronic Benefit Transfer (EBT) system. Based on a file provided by the USDA, large retailers already program their integrated register and point-of-sale (POS) systems to automatically determine whether scanned purchases are allowable under SNAP guidelines. Many small retailers use manual registers and EBT-only POS terminals that require the merchant to enter the SNAP-eligible food purchases into the system, and therefore, rely on employee knowledge to determine allowable purchases. For the purposes of this demonstration, large retailers would need to re-program their register and POS systems to restrict sweetened beverages from purchase with SNAP benefits. Small retailers would be required to train their staff based on a list of restricted items provided by the City DOHMH. In both situations, adding sweetened beverages to the list of exclusions would not significantly increase program complexity or costs, because both of these activities (i.e., re-programming and staff training) already happen on a regular basis as staff turnover occurs and as products change.
• Participant and retailer confusion related to the proposed changes would be minimal.
Restrictions on food benefit purchases have been a component of the SNAP since its inception, and consumers and retailers are already accustomed to purchase restrictions. Therefore, concerns about confusing the consumer or increasing the stigma if purchases are rejected seem misplaced. Nevertheless, efforts to ensure that consumers are properly notified and that retailers are not adversely affected will be an important component of the implementation plan for the demonstration project.
A public information campaign will accompany the changes, and retailers will be informed in advance and given time to upgrade their systems and/or procedures. Specifically, the City DOHMH and HRA will meet with representatives from supermarket chains and trade associations that represent the full spectrum of the grocery industry (e.g., the Food Industry Alliance of New York State, Inc.) to discuss the changes, as well as to discuss ways to implement the changes in a manner that works for the retailers. Information will be shared with the food industry representatives to highlight the City’s comprehensive efforts to promote the purchase of healthier foods and beverages (e.g., Healthy Bodegas, Health Bucks, FRESH initiative, etc.), which should lead to increased sales of such products and relieve concerns about lost revenue from the sale of sweetened beverages.
In addition to the public information campaign, HRA will obtain the names, addresses and email addresses, if available, of all SNAP retailers in NYC and notify them via mail or email of the new restrictions on SNAP purchases. Specific instructions on how to implement the change will be included in the letter, as well as a list of restricted beverages or the kind of beverages which qualify under the new guidelines. In addition, user-friendly pamphlets, posters and decals will be distributed to retailers to assist in the training of staff. These materials will inform the retailers of the new restrictions, educate them on the benefits of the demonstration project and enlist their cooperation in its successful outcome.
SNAP participants in NYC will be notified of the new restrictions through a mass mailing. This mailing will include both cash assistance/SNAP and non-cash assistance/SNAP households and also will educate SNAP participants on the health benefits of decreasing sweetened beverage consumption. In addition, posters will be placed in all HRA Job Centers and SNAP Offices throughout the City to inform participants of the new restrictions and educate them on the health benefits. Finally, posters explaining the new restrictions to participants will be sent to all SNAP retailers, who can display them in prominent areas of their establishments.
• Reasons for refusal of similar but non-identical waiver requests are either addressed by this proposal or require further substantiation.
OTDA believes that the several arguments that were made in USDA’s denial of similar proposals, including one made by the Minnesota Department of Human Services in 2004, can be countered as follows:
1) Interoperability – Given the USDA-grant funded Healthy Incentive Pilot project -- a much more complicated project in terms of its impact on EBT and interoperability, this issue should no longer be an obstacle to approval of a purchase restriction program. The restriction on purchases proposed in this demonstration is far simpler than the HIP. It would be comprehensive rather than selective within the project area, would be transparent to the consumer and would not require modification to the State’s EBT system.
2) Stigma – The argument that a demonstration project modifying the list of prohibited items would stigmatize SNAP households has been made in the past. However, there are already certain items that cannot be purchased with SNAP benefits, such as alcoholic beverages and hot food and hot food products prepared for immediate consumption. A stigma, if there is any, would already attach to SNAP benefits because of the above listed limitations. The extension of the list of prohibited items will not create any stigma that does not already exist.
3) Monitoring Retail Compliance – Monitoring the compliance with the demonstration project exclusions will be no more onerous or complicated than the present compliance monitoring regime once retailers, participants, and compliance personnel are informed of the new exclusions.
• The demonstration presents a unique opportunity to evaluate whether SNAP restrictions impact the purchase and consumption of sweetened beverages among low-income populations.
The demonstration would offer the opportunity to test whether restrictions on SNAP purchases would be effective in changing purchasing and consumption behavior. While nutrition education programs are clearly an important component in addressing the obesity epidemic, given the extent and increasing severity of the problem, additional efforts are needed. As recommended by the White House Task Force on Childhood Obesity, offering incentives and eliminating disincentives to unhealthy eating habits are important.[xxviii] Restricting sweetened beverages from being purchased with federally-funded SNAP benefits is one effort that is worth testing. As such, an evaluation is proposed as part of the demonstration project. The evaluation will evaluate the implementation process, retailer compliance with the new guidelines, and the impact on the purchase and consumption of sweetened beverages among SNAP participants. Research linking consumption of sweetened beverages and obesity leads to the conclusion that reducing consumption is consistent with the SNAP program goal of improving the nutrition of low-income populations.
Evaluation Plan
An evaluation of the demonstration project is planned in order to assess the implementation process of the proposed restrictions and whether it has the intended effect. The evaluation will utilize multiple data sources and will evaluate both the process and the impact of the demonstration project.
To examine the implementation process, the process evaluation will address the following question:
▪ How were the restrictions implemented in NYC and what were the implementation impacts on food retailers?
▪ Are retailers compliant with the new restrictions?
To evaluate the implementation process, key informant interviews of state and local officials will be used. The interviews will investigate the efforts to notify retailers and the public, as well as the technical and system-related processes necessary to implement the restrictions. Key informant interviews will also be conducted with a sample of NYC large and small food retailers to better understand the process they used to implement the restriction and their perspective on the impact that the change had on their operations.
The process evaluation will also include a compliance component, which will measure the extent to which sweetened beverages are purchased with SNAP benefits after the restrictions are in place. Data will be collected with “secret shopper” visits by the evaluation team. A random selection of small retailers (i.e., retailers that utilize EBT-only terminals) will be visited and evaluators will attempt to purchase sweetened beverages and other non-eligible items with SNAP benefits. The level of compliance will be documented and shared with HRA, who will provide additional training to those retailers who were not compliant. Follow-up visits by the evaluation team will be scheduled for all non-compliant retailers to assess whether further education efforts were effective. The results of the initial and follow-up visits will be analyzed and included in the evaluation report. Since large retailers program their EBT systems to accommodate the restrictions, compliance will be less of an issue. The number of retailers included in the sample and the selection methods will be developed in consultation with the external evaluators and included in the final evaluation plan.
Because compliance with other restrictions on SNAP purchases in New York State is monitored by the USDA, HRA is open to suggestions from the USDA on other ways to monitor compliance with the new restrictions. In addition, HRA and the DOHMH will work with the USDA to determine the appropriate response to non-compliant retailers.
To examine the impact of the demonstration project, the evaluation will address the following question:
▪ Does the SNAP restriction on sweetened beverages impact the overall purchase and consumption of these items among SNAP participants?
Specifically, the impact evaluation will explore whether self-reported purchase and consumption of sweetened beverages by SNAP participants was reduced as a result of the restriction or whether consumption remained the same because participants purchased these items with cash. SNAP participants will be compared to two groups unaffected by the demonstration project, including (1) non-SNAP participants in NYC and (2) SNAP participants in neighboring counties (if possible).
The data sources that will be used for the impact evaluation include:
A population-based telephone survey: The City is planning a telephone survey on consumption of sweetened beverages. The baseline will take place in September, 2010 with a follow-up study in late 2011. This survey tracks changes in public opinion regarding acceptability and access to sweetened beverages, in addition to self-reported consumption of sweetened beverages. Additional questions will be added to assess whether respondents receive SNAP benefits and an estimate of the amount of sweetened beverages purchased with SNAP benefits and with cash. This will allow a baseline assessment of sweetened beverages purchases and consumption among SNAP participants and non-participants, as well as an evaluation of changes in self-reported purchases and consumption from before to after pilot implementation. The final evaluation plan will include details on how the sample size was determined, the sampling strategy, and estimates of sampling error rate and confidence intervals based on the sample size.
Retail store cash register data. The City is currently exploring collaborations with a grocery store supplier of over 1,000 stores in NYC and neighboring areas that would provide electronic data on beverages purchased using SNAP benefits and cash among SNAP participants. The supplier is able to provide an aggregate list of their products purchased by SNAP participants in a given timeframe across stores in a specific zip code – this list includes items purchased during a transaction where EBT was used, including items that may have been bought with cash. This information will permit an analysis of the change in purchases of sweetened and healthy beverages from before to after pilot implementation by SNAP participants who shop at those stores. It may also be possible to compare the purchasing behavior of affected SNAP participants to SNAP participants in neighboring areas. In addition, it would also provide data on other food purchases by SNAP participants to determine whether more nutritious foods were purchased before and after the pilot implementation.
Customer exit and receipt surveys. Another option is to conduct customer exit surveys at a representative sample of retail establishments in NYC to determine the amount of sweetened beverages purchased with SNAP benefits and with cash. Although this method would require significant resources, it would provide information on both beverage purchases and on the individuals purchasing them. Information is available on the amount of SNAP-related sales by retailers in NYC, which could be used to identify the sample of retail establishments.
In addition, to the above data, the City has purchased data on supermarkets beverages sales for 2008-09 from Nielsen. Since SNAP participants make up 20% of individuals in NYC, this demonstration project, in combination with other City initiatives, has the potential to impact beverages sales citywide. The dataset will be analyzed with future Nielsen data to assess trends in the sales of sweetened beverages and alternative healthier beverages.
Evaluation Partners
External evaluators will conduct the evaluation under contract with DOHMH and/or HRA. The external evaluator will be selected by DOHMH and HRA with the assistance of New York State OTDA and the New York State Department of Health. The external evaluator will be responsible for developing a final evaluation plan under the oversight of DOHMH and HRA based on the broad framework presented in this proposal.
The total cost of the evaluation will depend on the availability of existing data and the need for primary data collection. The City is examining internal funding sources, as well as grant funding to cover the cost of evaluation.
Conclusion
This proposal offers a valuable opportunity to make the SNAP even more effective in achieving its stated policy goal of improving nutrition for low-income families. It also eliminates an explicit conflict between the goals of the SNAP and its day-to-day implementation in recipient households. It is inspired in large part by USDA’s own guidelines for defining what is and is not nutritious, and reflects a relatively simple and cost-effective means of reconciling those guidelines with the longstanding intentions of the nation’s largest food assistance program.
In addition, the proposed demonstration project recognizes the growing nationwide consensus that consumption of sweetened beverages must be reduced in order to improve the health of Americans. National organizations that have supported measures in this direction include the American Academy of Pediatrics, American Heart Association, American Cancer Society, Save the Children, and the National Association of County and City Health Officials. In New York, 200 organizations recently supported proposals to tax sweetened beverages to reduce consumption, including the New York Academy of Medicine, Greater New York Hospital Association, Medical Society of the State of New York, New York State Public Health Association, numerous faith-based organizations, and a major union. By reducing access to sweetened beverages, this demonstration project is consistent with the City of New York's comprehensive efforts to improve the nutrition of all New Yorkers, including low-income households.
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[1] For the purposes of this proposal, a sweetened beverage is defined as a carbonated or non-carbonated beverage (including syrup or powder for the preparation of beverages) that is sweetened with sugar or another caloric sweetener (e.g., high fructose corn syrup, sucrose, honey, etc.) and has at least 10 calories per 8 ounces of the beverage. Examples include non-diet soda, sweetened fruit drinks, sweetened iced tea, powdered lemonade etc.) Infant formula, milk products, milk substitutes and dietary aids are not deemed sweetened beverages.
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[i] [Section 2, 7 U.S.C. 2011].
[ii] Cohen, Ohls, Andrews, Ponza, Moreno, Zambrowski, and Cohen (1999). “Food Stamp Participants Food Security and Nutrient Availability”( pg. 88). Submitted to the USDA by Mathematica Policy Research, Inc.
[iii] Source: National Center for Health Statistics of the CDC using data from the National Health and Nutrition Examination Survey (NHANES).
[iv] Source: White House Task Force on Childhood Obesity, Report to the President, “Solving the Problem of Childhood Obesity Within a Generation”, Chapter IV, pg. 61.
[v] Based on Nielsen beverage market data for 2009, the prevalence of SNAP participants in NYC, and prior studies of SNAP purchasing behavior,
[vi] http://www.ers.usda.gov/Briefing/SNAP/nutrition_education.htm (retrieved July 28, 2010).
[vii] Thorpe LE, Upadhyay UD, Chamany S et al. Prevalence and control of diabetes and impaired fasting glucose in New York City. Diabetes Care. 2009;32:57-62.
[viii] Centers for Disease Control (2008). Preventing chronic diseases: investing wisely in health preventing obesity and chronic diseases through good nutrition and physical activity. Retrieved December 3, 2008, from CDC Website: http://www.cdc.gov/nccdphp/publications/factsheets/Prevention/pdf/obesity.pdf.
[ix] Government Accountability Office (2005). Childhood obesity: most experts identified physical activity and the use of best practices as key to successful programs. (GAO report GAO-06-127R). Retrieved December 3, 2008, from http://www.gao.gov/new.items/d06127r.pdf
[x] See Finkelstein EA, et al. Economic causes and consequences of obesity. Ann Rev Pub Health. 2005; 26:239-257 and Guthrie JF, Morton JF. Food sources of added sweeteners in the diets of Americans. J Am Diet Assoc. 2000;100:43-51.
[xi] Smith, Travis A., Biing-Hwan Lin, and Jonq-Ying Lee. Taxing Caloric Sweetened Beverages: Potential Effects on Beverage Consumption, Calorie Intake, and Obesity, ERR-100, U.S. Department of Agriculture, Economic
Research Service, July 2010.
[xii] Finkelstein EA, et al. Economic causes and consequences of obesity. Ann Rev Pub Health. 2005; 26:239-257.
[xiii] Guthrie JF, Morton JF. Food sources of added sweeteners in the diets of Americans. J Am Diet Assoc. 2000;100:43-51.
[xiv] 7. Ludwig DS, Peterson KE, Gortmaker SL. Relation between consumption of sugar -sweetened drinks and childhood obesity: a prospective, observational analysis. Lancet. 2001;357(9255):505-508.
[xv] Ebbeling CB, Feldman HA, Osganian SK et al. Effect of decreasing sugar-sweetened beverage consumption on body weight in adolescents: a randomized controlled pilot study. Pediatrics. 2006;117:673:680.
[xvi] Schulze MB, Manson JE, Ludwig DS, et al. Sugar-sweetened beverages, weight gain, and incidence of type 2 diabetes in young and middle-aged women. JAMA 2004;292:927-934.
[xvii] Drewnowski A. The real contribution of added sugars and fats to obesity. Epidemiology Review 2007;29:160-171.
[xviii] Eaton, D.K. et al. (2006, June 9). Youth Risk Behavior Surveillance ---United States, 2005. The Morbidity and Mortality Weekly Report, 55(SS05);1-108. Retrieved December 8, 2008 from http://www.cdc.gov/mmwr/preview/mmwrhtml/ss5505a1.htm#tab52
[xix] “Diet Quality of Americans by FS Participation Status: Data from the National Health and Nutrition Examination Survey, 1999 – 2004, FNS, July 2008”
[xx] See Jones, D. Y., Neisheim, M. C. & Habicht, J.-P. (1985). Influences in child growth associated with poverty in the 1970s: an examination of HANESI and HANESII, cross-sectional US surveys. American. Journal of Clinical Nutrition, 42: 714–724. Yip, R., Scanlon, K. & Trowbridge, Fl (1993). Trends and patterns in height and weight of low-income U.S. children. Critical Reviews in Food Science and Nutrition. 33: 409–421. Rolland-Cachera, M.-F. & Bellisle, F. (1986) No correlation between adiposity and food intake: why are working class children fatter? American Journal of Clinical Nutrition. 44: 779–787. Mei, Z., K. S. Scanlon, L. M. Grummer-Strawn, D. S. Freedman, R. Yip, & F. L. Trowbridge. (1998). Increasing prevalence of overweight among U.S. preschool children: The Center for Disease Control and Prevention Pediatric Nutrition Surveillance, 1983-1995. Pediatrics, 101:1-6 and Chun, H. and Lin, B.H. (2004). Prevalence of childhood overweight among low-income households. American Agricultural Economics Association 2004 Annual Meeting. US Department of Agriculture and The University of Georgia. 2-24. Drewnowski A. The real contribution of added sugars and fats to obesity. Epidemiology Review 2007;29:160-171.
[xxi] New York City Department of Health and Mental Hygiene. Epiquery: NYC Interactive Health Data System - Community Health Survey 2008. July 13, 2010. http://nyc.gov/health/epiquery.
[xxii] Frost, A., & Walker, K. (n.d.) Food stamp nutrition education: promoting healthy eating and active lifestyles. United States Department of Agriculture, Food and Nutrition Service. Retrieved December 4, 2008, from http://www.nal.usda.gov/foodstamp/Training/October.ppt
[xxiii] Report of the USDGAC on the Dietary Guidelines for Americans, 2010, USDA May 28, 2010, p A-7.
[xxiv] New York City Healthy Bodegas Initiative, 2010 Report. Available at http://nyc.gov/html/doh/downloads/pdf/cdp/healthy-bodegas-rpt2010.pdf. Accessed July 21, 2010.
[xxv] For information on the City of New York’s efforts visit http://www.nyc.gov/html/doh/html/cdp/cdp_pan-calorie.shtml.
[xxvi] Smith, Travis A., Biing-Hwan Lin, and Jonq-Ying Lee. Taxing Caloric Sweetened Beverages: Potential Effects on Beverage Consumption, Calorie Intake, and Obesity, ERR-100, U.S. Department of Agriculture, Economic
Research Service, July 2010.
[xxvii] Smith, Travis A., Biing-Hwan Lin, and Jonq-Ying Lee. Taxing Caloric Sweetened Beverages: Potential Effects on Beverage Consumption, Calorie Intake, and Obesity, ERR-100, U.S. Department of Agriculture, Economic
Research Service, July 2010.
[xxviii] Source: White House Task Force on Childhood Obesity, Report to the President, “Solving the Problem of Childhood Obesity Within a Generation”.
Where are General Mills cereals made? From its headquarters in Switzerland, CPW first launched General Mills cereals under the Nestlé label in France, the United Kingdom, Spain, and Portugal in 1991. Today, CPW competes in more than 140 international markets.
