Food Package I—Infants Under 6 Months

Proposed revision Modify/clarify what constitutes partial (mostly) breastfeeding in the first 30 days.

• After a breastfeeding assessment by a competent professional authority, an infant can be prescribed up to 364 fluid ounces of infant formula and still be classified as a partially (mostly) breastfed infant (food package I-BF/FF-A).
• The infant's mother is eligible to be prescribed food package V-B (partially [mostly] breastfeeding woman).

Rationale and benefit The current rule was intended to encourage women who initiated breastfeeding to do so exclusively, while allowing a small amount of infant formula as a supplement. Under this provision, infants receiving more than 104 fluid ounces of reconstituted infant formula in the first month of life are considered fully formula fed, even if the provision of infant formula is substantially less than the amount that can be prescribed in food package I-FF-A (full nutrition benefit = 806 fluid ounces). The proposed revision is intended to support partial breastfeeding and to prevent premature categorization of the dyad as fully formula-fed. This recommendation is not intended to undermine the success of states or local agencies that have identified the resources needed to support breastfeeding. Rather, it is meant to bolster the importance of the support and counseling needed to establish and sustain breastfeeding in the immediate postpartum period. The proposed revision maintains the federal requirement that routine issuance of infant formula in the first month is not standard; it would give state agencies and WIC staff greater flexibility to tailor food package I-BF/FF-A and to support women who choose to partially (mostly) breastfeed their infants.

Proposed revision Allow tailoring of all prescribed infant formula quantities.

• Across all infant food packages, the maximum formula quantities should be considered “up to” amounts. All formula prescribed to infants should be tailored to the individual needs of the infant.
• The amount of formula that can be prescribed in food package I-BF/FF-A and I-BF/FF-B is up to 364 fluid ounces (monthly maximum allowances of 388 fluid ounces reconstituted liquid concentrate, 384 fluid ounces ready-to-feed, or 435 fluid ounces reconstituted powder).
• The amount of formula that can be provided in food package I-BF/FF-C is up to 442 fluid ounces (monthly maximum allowances of 460 fluid ounces, reconstituted liquid concentrate, 474 fluid ounces ready-to-feed or 522 fluid ounces reconstituted powder).
• The amount of formula that can be prescribed in food package I-FF-A is up to 806 fluid ounces (monthly maximum allowances of 823 fluid ounces, reconstituted liquid concentrate, 832 fluid ounces ready-to-feed, or 870 fluid ounces reconstituted powder).
• The amount of formula that can be prescribed in food package I-FF-B is up to 884 fluid ounces (monthly maximum allowances of 896 fluid ounces reconstituted liquid concentrate, 913 fluid ounces ready-to-feed or 960 fluid ounces reconstituted powder).

Rationale and benefit The current WIC policy guidelines state that the maximum monthly allowance of infant formula should not be used as the standard for issuance unless the mother is not breastfeeding the infant at all (USDA/FNS, 2016d). The committee, however, recommends formula prescriptions be tailored to the individual needs of the infant. This proposed revision would give clinics greater flexibility to tailor the infant formula quantities prescribed to all infants who are not fully breastfed. Aside from food package I-BF/FF-A (previously described), the maximum quantities are unchanged.

Food Package II—Infants Ages 6 to Less Than 12 Months

Proposed revision Allow tailoring of all prescribed infant formula quantities.

• Similar to food package I, across all infant food packages, the maximum formula quantities should be considered “up to” amounts. All formula prescribed to infants should be tailored to the individual needs of the infant.
• The amount of formula that can be provided in food package II-BF/FF is up to 312 fluid ounces (monthly maximum allowances of 315 fluid ounces reconstituted liquid concentrate, 338 fluid ounces ready-to-feed, or 384 fluid ounces reconstituted powder).
• The amount of formula that can be provided in food package II-FF is up to 624 fluid ounces (monthly maximum allowances of 630 fluid ounces reconstituted liquid concentrate, 643 fluid ounces ready-to-feed, or 696 fluid ounces reconstituted powder).

Rationale and benefit Rationale and benefits of allowing tailoring of the prescribed infant formula quantities are the same as for younger infants. See “Food Package I—Infants Under 6 Months” for details.

Proposed revision Reduce the quantity of infant cereal prescribed in food package II.

• Food package II-BF recipients are prescribed 16 ounces of infant cereal per month.
• Food packages II-BF/FF and II-FF recipients are prescribed 8 ounces infant cereal per month.

Rationale and benefit

• The amount of infant cereal currently prescribed in food package II provides approximately 150 percent of the amount recommended by the AAP (AAP, 2014). Reducing the amount of infant cereal prescribed in food package II aligns with the concept of supplemental.
• Infant cereals are a favored first food and are good sources of zinc and iron. Because fully breastfed infants are not likely to receive zinc and iron from infant formula, food package II-BF recipients are prescribed more infant cereal per month compared to their partially (mostly) breastfed and fully formula-fed counterparts.

Proposed revision Reduce the quantity of jarred infant food vegetables and fruits provided to fully breastfed infants; offer CVV substitution option to all food package II recipients.

• Food package II-BF recipients are prescribed 128 ounces jarred infant food vegetables and fruits per month.
• All food package II recipients can substitute a $10 or $20 CVV for half or all of the jarred infant food vegetables and fruits, respectively.
• The CVV can be used to purchased vegetables and fruits in all forms allowed by the state agency (i.e., fresh, frozen, canned) except dried.

Rationale and benefit

• The IOM committee (2006) that put forth the first set of recommended food package changes did not provide nutrient-based rationale for the selected quantity of jarred infant food vegetables and fruits for food package II-BF recipients. Rather, it stated, “to encourage or promote full breastfeeding, the recommended amounts of [infant] food fruits and vegetables are more generous for fully breastfed infants than other infants” (page 103).
• The AAP does not provide specific intake recommendations for infant food vegetables and fruits, but it does acknowledge they are useful for transitioning infants to solid foods (AAP, 2014).
• Public comments indicated that 256 ounces of jarred infant food vegetables and fruits per month can exceed the need of the infant.
• The reduction of jarred infant food vegetables and fruits brings the fully breastfed infant's food package in better alignment with the concept of supplemental. Other incentives for full breastfeeding have been included in other aspects of the mother–infant dyad's food packages. For example, the quantity and variety of foods available to the breastfeeding mother during the infant's first 6 months are greater compared to the postpartum (nonbreastfeeding) package (increasing proximal incentives) and extend for 12 as opposed to 6 months (increasing distal incentives).
• Jarred infant food is retained in food package II as a convenient, shelf-stable form of vegetables and fruits for infants. The options for partial or complete substitution of jarred infant food vegetables and fruits with CVVs are intended to help participants meet their cultural needs and personal preferences. Caregivers can use the vegetables and fruits purchased with the CVV to prepare infant foods of varying textures that are suitable to the infant's developmental stage.
• Participants may be able to buy more servings of fruits or vegetables using the CVV compared to the jarred varieties.

Proposed revision Reduce the quantity of jarred infant food meat prescribed; offer canned fish substitution option.

• Food package II-BF recipients are prescribed 40 ounces of jarred infant food meat per month.
• Food package II-BF recipients have the option of substituting four jars (10 ounces) of infant food meat with 10 ounces of canned fish per month.

Rationale and benefit

• The AAP (2014) recommends provision of 1 to 2 ounces of meat per day, which corresponds to 30 to 60 ounces per month. Currently, food package II-BF provides 130 percent of the maximum of this recommended range.
• Redemption of jarred infant food meat is particularly low; published data and public comments indicate that it is not a preferred infant food.
• The committee considered, but could not identify nutritionally equivalent but preferred alternatives to jarred infant food meat suitable for inclusion in the WIC food packages. For these reasons, jarred infant food meat is retained in food package II-BF, at a reduced quantity.
• The option of substituting canned fish for some of the jarred infant food meat provides participants with a choice that better meets their cultural needs and personal preferences, while still providing key nutrients and within cost-containment parameters. Canned fish provides slightly more iron and some (but less) zinc per ounce and costs approximately half as much per ounce compared to jarred infant food meat. Because the nutrient profiles of jarred infant food meat and canned fish are not equivalent, the proposed revision does not allow for full substitution.

Food Package III—Participants with Qualifying Conditions

Proposed revision Clarify the role of WIC formula in food package III.

• Food package III recipients are permitted access to foods in the package that are appropriate for their age, physiological state, and medical condition without the requirement of a WIC formula (i.e., infant formula, exempt formula, WIC-eligible nutritionals).

Rationale and benefit

• The proposed revision is intended to facilitate the issuance of a food package appropriate for participants with qualifying conditions, without the provision of unnecessary items.
• Public comments indicated that a WIC formula in addition to supplemental foods for food package III recipients may not be necessary in all cases. The proposed revision would allow participants to be prescribed supplemental food(s) that qualifies them for food package III with medical documentation (e.g., whole milk for older children and women) without being required to be prescribed a WIC formula.
• The proposed revision upholds the provision in the current rule that states' health care providers providing oversight of the medical management of the participant may refer to the WIC registered dietitian and/or qualified nutritionist for identifying appropriate supplemental foods (excluding WIC formula) and their prescribed amounts, as well as the length of time the supplemental foods are required by the participant.

Food Package IV—Children Ages 1 to Less Than 5 Years

Proposed revision Reduce the amount of juice prescribed; offer a CVV substitution option.

• Children are prescribed 64 fluid ounces of juice per month.
• A $3 CVV can be substituted for the 64 ounces of juice.

Rationale and benefit

• The role of juice in the food package has historically been to provide a source of vitamin C (which overlaps with one of the roles of the CVV) and is a convenient means of providing fruit to children.
• The amount of juice in the current packages for children provides more than 100 percent of the lower end of the AAP recommended limit of 4 ounces per day (AAP, 2014). The reduction of juice, therefore, better aligns with the concept of supplemental.
• The AAP (2014) recommends that most fruit intake should be from whole fruit because whole fruit also contributes fiber and other plant-based compounds that are removed during processing. The DGA include a recommendation that at least half of fruit intake should be from whole fruit, and state that most individuals in the United States “would benefit from increasing intakes of fruit, mostly whole fruit” (USDA/HHS, 2016). The option for CVV substitution aligns with both the AAP and DGA recommendations and allows recipients to select from options that may better meet their cultural needs and personal preferences.
• All juice offered through the WIC program (across food packages) would be 64 fluid ounces, decreasing vendor burden and streamlining options across food packages.
• The cost savings from the reduction of juice allows for other revisions across the food packages.

Proposed revision Reduce the amount of milk prescribed to children; specify substitution options.

• Food package IV-A recipients are prescribed 12 quarts of milk per month. Food package IV-B recipients are prescribed 14 quarts of milk per month.
• Children can substitute up to 4 quarts of milk per month, choosing either to substitute 2 quarts of yogurt for 2 quarts for milk or to substitute 1 pound of cheese and 1 quart of yogurt for 4 quarts of milk.
• Soy-based yogurt substitute and soy-based cheese substitute are allowable yogurt and cheese substitution options, respectively, for individuals with lactose intolerance, a milk allergy, or who consume a vegan diet. Soy-based yogurt and cheese substitutes must meet calcium and protein specifications (described later).

Rationale and benefit

• Milk in the current food packages provides what the committee considered a greater than supplemental amount of dairy (e.g., 85 percent of the recommended dairy amount for children ages 2 to less than 5 years). At the same time, intakes of dairy foods, were below recommended amounts. These data suggest that redemption of milk and/or consumption of redeemed amounts of milk are less than optimal.
• The committee received public comments requesting a reduction in the amount of milk prescribed. Comments requesting reductions indicated that participants are unable to use the amount of milk provided and that milk is not always compatible with cultural needs or personal preferences.
• The revised food package IV-B provides 75 percent of the recommended amounts of dairy for children ages 2 to less than 5 years. Because the DGA food patterns do not apply to children ages 1 to less than 2 years, the committee considered that the dairy needs for this group are likely lower than those for children ages 2 to less than 5 years. Milk prescribed in food package IV-A, therefore, is 2 quarts less than the amount provided in food package IV-B.
• The two substitution options are structured to allow full redemption of fluid milk in gallon and half gallon sizes, and eliminate the single quart (“dangling quart”) of milk, which public comments indicated was difficult to find and is often more expensive.
• The option for substitution of two quarts of yogurt in place of two quarts of milk may improve intakes for participants who prefer dairy in this form. Soy options are allowable for participants with lactose intolerance, a milk allergy, and those who consume a vegan diet. The options are intended to provide participants with flexibility to select substitutions that better meet cultural needs and personal preferences.

Proposed revision Limit the whole grain bread option to 100% whole wheat bread; expand list of whole grain options that states may choose to allow; provide a range of allowable sizes; reduce the maximum amount of bread prescribed.

• Food packages IV recipients are prescribed 16 to 24 ounces of 100% whole wheat bread or other allowable whole grain options per month.
• In addition to current whole grain options, states may authorize corn masa flour (nonwhole grain), cornmeal, teff, and buckwheat (specifications described later). States should authorize as many options as cost constraints allow.

Rationale and benefit

• Very few states offer whole grain bread options other than 100% whole wheat. Identification of suitable whole grain breads (greater than 50% whole grain) can be challenging for participants. Restricting authorized breads to 100% whole-wheat aligns with the current practices of most state agencies and reduces state agency burden to identify allowable whole grain options.
• When the current food packages were first introduced, the 16-ounce size of bread was uncommon in the marketplace. Manufacturers had to create this size of bread specifically for WIC participants and vendors had to stock it. This created vendor, manufacturer, and participant burden. The allowable bread size range allows for the purchase of more commonly available sizes of products, including bread ranging in size from 22- to 24-ounce. The range would also eliminate the need for manufacturers to create WIC-specific product sizes. Decreasing participant burden and expanding options may also increase availability and promote intake of whole grains, for which intake is below recommended amounts across most WIC participant groups.
• The proposed revisions would slightly reduce the amount of whole wheat bread and allowable options provided to children, from a maximum 32 ounces per month in the current package to a maximum of 24 ounces in the revised food package. This slight reduction helps to offset the cost of offering the range of bread sizes across food packages.
• Additional whole wheat bread substitutions are added as state options (corn masa flour [nonwhole grain], cornmeal, teff, and buckwheat) to provide culturally appropriate alternatives, which in turn, may help to promote intake.

Proposed revision Create a quarterly rotation of legumes, peanut butter, and fish; clarify authorized types of legumes and canned fished.

• Food package IV recipients are prescribed legumes, peanut butter, and fish in a rotation over the course of 3 months.
• The rotation consists of 1 pound (16 ounces of dry or 64 ounces canned [four 15- to 16-ounce cans]) of legumes, 16–18 ounces of peanut butter, and 10 ounces of canned fish.
• State agencies must authorize both dried and canned legumes.
• Authorized canned fish may be packed in water or currently authorized sauces and flavorings. Oil-packed is no longer authorized.

Rationale and benefit

• The amount of peanut butter prescribed in the current food packages provides 167 percent of recommend amounts of the protein food subgroup of nuts, seeds, and soy, and the amount of legumes provides approximately 177 percent of recommended amounts of beans and peas for children. Both items exceed what the committee considers to be a supplemental amount.
• The proposed revision specifies that state agencies must authorize both canned and dried legumes. According to the 2015 Food Policy Options report, 85 percent of WIC state agencies have already authorized canned legumes (USDA/FNS, 2015b). Therefore, the committee considered this change an administratively feasible strategy with the potential to promote redemption and consumption.
• Authoritative groups recommend consumption of 1.0 to 1.7 ounces of lower-mercury fish per day by children ages 1 to 4 years (AAP, 2014; FDA/EPA, 2014; USDA/HHS, 2016). Intake of seafood was either low or uncommon across subgroups of WIC participants. As such, the committee considered it important to include fish in additional food packages as costs allowed.
• In the revised food package IV, legumes, peanut butter, and fish are rotated on a quarterly basis in order to provide supplemental amounts and amounts that better align with participant preferences. Although the amount of fish offered in the food packages is small compared to DGA recommended amounts of seafood (19 percent for children), it is a significant improvement over the current packages that offer no fish. It also introduces this food into participants' diets.
• In the revised food packages, canned fish may be water packed, and may include the same sauces and flavorings that are currently allowed as a state option. Oil packed is no longer authorized. Water-packed varieties are more nutrient dense because water-packed fish is lower in energy but contains the same amounts of key nutrients per serving.

Proposed revision Increase the CVV. Food package IV recipients are prescribed a $12 vegetable and fruit CVV per month.

Rationale and benefit

• The CVV offers participants the most flexibility to meet their cultural food preferences and provides them with access to two food groups (vegetables and fruits) and nutrients (potassium and fiber) for which intakes were inadequate.
• The current amount of the CVV permits participants to purchase less than one serving of fruits or vegetables per day. Based on the committee's composite cost for vegetables and fruits most commonly purchased among WIC participants,⁷ $23 would be required for individuals who consumed a 1,300-kcal diet to meet half of the recommended intakes of vegetables and fruits.
• The committee increased the CVV across food packages to the extent possible within cost-neutral restrictions.

Food Package V-A—Pregnant Women

Proposed revision Create separate food packages for pregnant and partially (mostly) breastfeeding women.

• Pregnant women are issued food package V-A, which is different from food package V-B for partially (mostly) breastfeeding women, up to 1-year postpartum.

Rationale and benefit One of the committee's objectives with the revised food packages was to promote and incentivize any level of breastfeeding. To do this within cost-neutral parameters, food package V was divided into two distinct food packages.

Proposed revision Reduce the amount of juice prescribed; offer a CVV substitution option.

• Pregnant women are prescribed 64 fluid ounces of juice per month.
• A $3 CVV can be substituted for the 64 ounces of juice.

Rationale and benefit The rationale and benefits are comparable to those presented for the children's food package. See “Food Package IV—Children Ages 1 to Less Than 5 Years” for details.

Proposed revision Reduce the amount of milk prescribed; specify substitution options.

• All women are prescribed 16 quarts of milk per month.
• Food package V-A recipients can substitute up to 4 quarts of milk per month, choosing either to substitute 2 quarts of yogurt for 2 quarts for milk or to substitute 1 pound of cheese and 1 quart of yogurt for 4 quarts of milk.
• Soy-based yogurt substitute and soy-based cheese are authorized yogurt and cheese substitution options, respectively, for individuals with lactose intolerance, a milk allergy, or who consume a vegan diet. Authorized soy-based yogurt and cheese must meet calcium and protein specifications (described later).

Rationale and benefit

• For women who are pregnant, postpartum, or breastfeeding, the Estimated Average Requirement (EAR) for calcium is 800 mg, and the corresponding DGA recommendation for the intake of dairy, which is the major dietary source of calcium, is 3 cup-equivalents per day. Therefore, it is reasonable to provide the same quantity of the key food group for this nutrient (dairy) across food packages for women. As revised, the food packages for women provide 71 percent of the recommended amounts of dairy. The revised food packages for women provide approximately 100 percent of the calcium EAR for women.
• Rationale and benefits of the milk substitution options are the same as for children. See “Food Package IV—Children Ages 1 to Less Than 5 Years” for details.

Proposed revision Limit the whole grain bread option to 100% whole wheat bread; expand the list of whole grain options states may choose to authorize; provide a range of authorized sizes.

• Food packages V-A recipients are prescribed 16 to 24 ounces of 100% whole wheat bread or authorized whole grain options per month.
• In addition to current whole grain options, states may authorize corn masa flour (nonwhole grain), cornmeal, teff, and buckwheat (specifications described later). States should authorize as many options as cost constraints allow.

Rationale and benefit Rationale and benefits of the revisions to the whole grain bread and associated substitution options are the same as for children. See “Food Package IV—Children Ages 1 to Less Than 5 Years” for details.

Proposed revision Create a quarterly rotation of legumes, peanut butter, and fish; clarify authorized types of legumes and canned fish.

• Food package V-A recipients are prescribed legumes, peanut butter, and fish in a rotation over the course of 3 months.
• Food package V-A recipients are prescribed 2 pounds (32 ounces of dry or 128 ounces canned [eight 15- to 16-ounce cans]) of legumes, 16 to 18 ounces of peanut butter, and 10 ounces canned fish on a quarterly basis. States may decide to issue 2 pounds of legumes in 1 month (to create a quarterly rotation with tuna) or spread the legumes over 2 months. Peanut butter may only be issued once per quarter. State agencies must authorize both dried and canned legumes.
• Authorized canned fish may be packed in water or currently authorized sauces and flavorings. Oil packed is no longer authorized.

Rationale and benefit

• Legumes are key sources of many nutrients (potassium, fiber, and folate) for which intakes below recommended amounts were prevalent across participant subgroups. Therefore, legumes are a valuable component of the WIC food packages. Provision of 2 pounds of dry legumes (or eight 15- to 16-ounce cans) every 3 months brings the amount prescribed closer to what is considered supplemental for women: between 47 and 59 percent of the DGA recommended amount.
• The amount of peanut butter in the current food packages for women provides up to 168 percent of recommended amounts. In the proposed revisions to the food packages, the same quantities of peanut butter currently provided every month will still be provided but only once every 3 months, which brings the prescription in better alignment with the concept of supplemental.
• Authoritative groups recommend consumption of 1.0 to 1.7 ounces of lower-mercury fish per day by pregnant and breastfeeding women (FDA/EPA, 2014; AHA, 2015; USDA/HHS, 2016).
• Inasmuch as intake of seafood was either low or uncommon across subgroups of WIC participants, the committee considered it important to include fish in additional food packages as costs allowed. Although the amount of fish offered in the food packages is small compared to DGA recommended amounts of seafood, it is a significant improvement over the current packages that offer no fish.
• Canned fish may be packed in water and may include the same sauces and flavorings that are currently allowed as a state option. Oil-packed is no longer authorized. Water-packed varieties are more nutrient dense because water-packed fish is lower in energy but contains the same levels of key nutrients per serving.
• In the revised food package V-A, legumes, peanut butter, and fish are rotated on a quarterly basis in order to provide supplemental amounts, and amounts that better align with participant preferences. Although the amount of fish offered in the food packages is small compared to DGA recommended amounts of seafood, it is a significant improvement over the current packages that offer no fish.

Proposed revision Increase the CVV. Food package V-A recipients are prescribed a $15 vegetable and fruit CVV per month.

Rationale and benefit Rationale and benefits of the increase in CVV are the same as for children. See “Food Package IV—Children Ages 1 to Less Than 5 Years” for details. In addition:

• The CVV provides access to vitamins A and C, folate, and other nutrients for which intakes were inadequate.
• Based on the committee's composite cost for vegetables and fruits most commonly purchased among WIC participants, $45 would be required for individuals who consumed a 2,600-kcal diet to meet half of the recommended intakes of vegetables and fruits.

Food Package V-B—Partially (Mostly) Breastfeeding Women Up to 1-Year Postpartum

Proposed revision Create separate food packages for pregnant and partially (mostly) breastfeeding women.

• Pregnant women are issued food package V-A, which is different from food package V-B for partially (mostly) breastfeeding women, up to 1-year postpartum.

Rationale and benefit

• One of the committee's objectives with the revised food packages was to promote and incentivize any level of breastfeeding. To do this within cost-neutral parameters, food package V was divided into two distinct food packages.

Proposed revision Reduce the amount of juice prescribed; offer a CVV substitution option.

• Partially (mostly) breastfeeding women are prescribed 64 fluid ounces of juice per month. A $3 CVV can be substituted for the 64 ounces of juice.

Rationale and benefit The rationale and benefits are comparable to those presented for the children's food package. See “Food Package IV—Children Ages 1 to Less Than 5 Years” for details.

Proposed revision Prescribe legumes and peanut butter on a quarterly rotation; clarify authorized types of legumes.

• Food package V-B recipients are prescribed 2 pounds (32 ounces of dry or 128 ounces canned [eight 15- to 16-ounce cans]) of legumes and 16 to 18 ounces of peanut butter on a quarterly basis. States may decide to issue 2 pounds of legumes in 1 month or spread the legumes over 2 months. Peanut butter may only be issued once per quarter.
• State agencies must authorize both dried and canned legumes.

Rationale and benefit The rationale and benefits are comparable to those presented for the pregnant women's food package. See “Food Package V-A—Pregnant Women” for details.

Proposed revision Add fish to the food package.

• Women receiving food package V-B are prescribed 10 ounces of canned fish per month.
• Authorized canned fish may be packed in water or currently authorized sauces and flavorings. Oil packed is no longer authorized.

Rationale and benefit

• Provision of canned fish on a monthly basis, rather than on a quarterly rotating basis, is intended to incentivize the partial (mostly) breastfeeding food package.
• Rationale and benefits for inclusion of fish in food package V-B are comparable to those presented for the pregnant women's food package. See “Food Package V-A—Pregnant Women” for details.

Proposed revision Reduce the amount of milk prescribed; specify substitution options.

• All women are prescribed 16 quarts of milk per month.
• Food package V-B recipients can substitute up to 4 quarts of milk per month, choosing either to substitute 2 quarts of yogurt for 2 quarts for milk or to substitute 1 pound of cheese and 1 quart of yogurt for 4 quarts of milk.
• Soy-based yogurt substitute and soy-based cheese are authorized yogurt and cheese substitution options, respectively, for individuals with lactose intolerance, a milk allergy, or who consume a vegan diet. Authorized soy-based yogurt and cheese must meet calcium and protein specifications (described later).

Rationale and benefit The rationale and benefits are comparable to those presented for the pregnant women's food package. See “Food Package V-A—Pregnant Women” for details.

Proposed revision Limit the whole grain bread option to 100% whole wheat bread; expand list of whole grain options that states may choose to authorize; provide a range of authorized sizes.

• Food packages V-B recipients are prescribed 16 to 24 ounces of 100% whole wheat bread or authorized grain options per month.
• In addition to current whole grain options, states may authorize corn masa flour (nonwhole grain), cornmeal, teff, and buckwheat (specifications described later). States should authorize as many options as cost constraints allow.

Rationale and benefit Rationale and benefits of the revisions to the whole grain bread and associated substitution options are the same as for children. See “Food Package IV—Children Ages 1 to Less Than 5 Years” for details.

Proposed revision Increase the CVV. Food package V-B recipients are prescribed a $25 vegetable and fruit CVV per month.

Rationale and benefit

• Provision of a larger CVV compared to the postpartum and partially (minimally) breastfeeding food package (food package VI) is intended to incentivize the partial (mostly) breastfeeding food package.
• Rationale and benefits of the increase in CVV are the same as for pregnant women. See “Food Package V-A—Pregnant Women” for details.

Food Package VI—Nonbreastfeeding Postpartum Women, Up to 6-Months Postpartum and Partially (Minimally) Breastfeeding Women, Up to 6-Months Postpartum

Proposed revision Eliminate juice.

• Postpartum and partially (minimally) breastfeeding women, up to 6-months postpartum, are no longer prescribed juice through food package VI.

Rationale and benefit Juice was removed from food package VI to achieve cost-neutrality and to increase the relative value of the partially (V-B) and fully (VII) breastfeeding packages. To compensate for the reduced juice, the CVV for food package VI was increased (described later).

Proposed revision Align milk prescription across women's food packages; specify substitution options.

• All women are prescribed 16 quarts of milk per month.
• Food package VI recipients can substitute up to 4 quarts of milk per month, choosing either to substitute 2 quarts of yogurt for 2 quarts for milk or to substitute 1 pound of cheese and 1 quart of yogurt for 4 quarts of milk.
• Soy-based yogurt substitute and soy-based cheese are authorized yogurt and cheese substitution options, respectively, for individuals with lactose intolerance, a milk allergy, or who consume a vegan diet. Authorized soy-based yogurt and cheese must meet calcium and protein specifications (described later).

Rationale and benefit The rationale and benefits are comparable to those presented for pregnant women. See “Food Package V-A—Pregnant Women” for details.

Proposed revision Create a quarterly rotation of legumes, peanut butter, and fish; clarify authorized types of legumes and canned fished.

• Food package V-A recipients are prescribed legumes, peanut butter, and fish in a rotation over the course of 3 months.
• Food package VI recipients are prescribed 2 pounds (32 ounces of dry or 128 ounces canned [eight 15- to 16-ounce cans]) of legumes, 16 to 18 ounces of peanut butter, and 10 ounces of canned fish on a quarterly basis. States may decide to issue 2 pounds of legumes in 1 month (to create a quarterly rotation with peanut butter and canned fish) or spread the legumes over 2 months. Peanut butter may only be issued once per quarter.
• State agencies must authorize both dried and canned legumes.
• Authorized canned fish may be packed in water or currently authorized sauces and flavorings. Oil packed is no longer authorized.

Rationale and benefit The rationale and benefits are comparable to those presented for the pregnant women's food package. See “Food Package V-A—Pregnant Women” for details.

Proposed revision Increase the CVV. Food package VI recipients are prescribed a $15 vegetable and fruit CVV per month.

Rationale and benefit Rationale and benefits of the increase in CVV are the same as for pregnant women. See “Food Package V-A—Pregnant Women” for details.

Food Package VII—Fully Breastfeeding Women, Up to 1-Year Postpartum

Proposed revision Reduce the amount of juice prescribed; offer a CVV substitution option. Fully breastfeeding women are prescribed 64 fluid ounces of juice per month. A $3 CVV can be substituted for the 64 ounces of juice.

Rationale and benefit The rationale and benefits are comparable to those presented for the children's food package. See “Food Package IV—Children Ages 1 to Less Than 5 Years” for details.

Proposed revision Reduce the amount of milk prescribed; specify substitution options.

• All women are prescribed 16 quarts of milk per month.
• Food package VII recipients can substitute up to 6 quarts of milk per month, choosing either to substitute 2 quarts of yogurt for 2 quarts of milk or to substitute 1 pound of cheese and 1 quart of yogurt for 4 quarts of milk or to substitute 2 pounds of cheese for 6 quarts of milk.
• Soy-based yogurt substitute and soy-based cheese are authorized yogurt and cheese substitution options, respectively, for individuals with lactose intolerance, a milk allergy or who consume a vegan diet. Authorized soy-based yogurt and cheese must meet calcium and protein specifications (described later).

Rationale and benefit

• The retention of additional substitution options is intended to incentivize the fully breastfeeding food package.
• The rationale and benefits are comparable to those presented for the pregnant women's food package. See “Food Package V-A—Pregnant Women” for details.

Proposed revision Limit the whole grain bread option to 100% whole wheat bread; expand list of whole grain options that states may choose to authorize; provide a range of authorized sizes.

• Food packages VII recipients are prescribed 16–24 ounces of 100% whole wheat bread or authorized whole grain options per month.
• In addition to current whole grain options, states may authorize corn masa flour (nonwhole grain), cornmeal, teff, and buckwheat (specifications described later). States should authorize as many options as cost constraints allow.

Rationale and benefit Rationale and benefits of the revisions to the whole grain bread and associated substitution options are the same as for children. See “Food Package IV—Children Ages 1 to Less Than 5 Years” for details.

Proposed revision Prescribe legumes and peanut butter on a quarterly rotation; clarify authorized types of legumes.

• Food package VII recipients are prescribed 2 pounds (32 ounces of dry or 128 ounces canned [eight 15- to 16-ounce cans]) of legumes and 16 to 18 ounces of peanut butter on a quarterly basis. States may decide to issue 2 pounds of legumes in 1 month or spread the legumes over 2 months. Peanut butter may only be issued once per quarter.
• State agencies must authorize both dried and canned legumes.

Rationale and benefit The rationale and benefits are comparable to those presented for the pregnant women's food package. See “Food Package V-A—Pregnant Women” for details.

Proposed revision Reduce fish in the food package; modify specifications.

• Women receiving food package VII are prescribed 20 ounces of canned fish per month.
• Authorized canned fish may be packed in water or currently authorized sauces and flavorings. Oil packed is no longer authorized.

Rationale and benefit

• Fully breastfeeding women are prescribed the greatest quantity of fish on a monthly basis in order to incentivize the food package.
• The fish provision was slightly reduced from 30 ounces per month in the current food package to 20 ounces per month in the revised food package in order to achieve cost neutrality and allow for a monthly provision of fish in the partially breastfeeding package.
• Rationale and benefits for maintaining fish in food package VII are comparable to those presented for the pregnant women's food package. See “Food Package V-A—Pregnant Women” for details.

Proposed revision Increase the CVV. Food package VII recipients are prescribed a $35 vegetable and fruit CVV per month.

Rationale and benefit

• Provision of the largest monthly CVV compared to all other food packages is intended to incentivize the fully breastfeeding food package.
• Rationale and benefits of the increase in CVV are the same as for pregnant women. See “Food Package V-A—Pregnant Women” for details.

Other Provisions (Not Specific to a Single Food Package)

Proposed revision Modify specifications for milk. Only unflavored milk is permitted. All other specifications remain unchanged.

Rationale and benefit

• The proposed revision aligns the milk offering with Child and Adult Care Food Program (CACFP) provision of milks to children less than 5 years of age. The specification reduces the amount of added sugars that can be provided through the WIC food packages.
• At present, flavored milk is offered in 6 percent of states and 40 percent of Indian Tribal Organizations (ITOs), which together cover 3 percent of WIC participants (USDA/FNS, 2015b). At least one ITO is removing flavored milk from its food list to align with CACFP policy (personal communication, D. Tipton, Chickasaw Nation WIC, July 2016). Therefore, the recommendation is not expected to cause a significant disruption in administration of food packages nationally.

Proposed revision Increase federal minimum vegetable stocking requirement; increase number of vegetable and fruit forms states must authorize.

• Require WIC vendors to stock a minimum of three varieties of vegetables and two varieties of fruits.
• States must authorize fresh and at least one additional form (frozen, canned, and/or dried) of vegetables and fruits.

Rationale and benefit

• The committee foresees the need to provide participants with a greater variety of options, given the larger CVVs and opportunities to substitute juice and jarred infant food vegetables and fruits with CVVs.
• The proposed revision seeks to enhance the amount and forms of vegetables and fruits available in WIC authorized stores, while minimizing burden on small vendors.
• The increased vegetable requirement is intended to encourage participants to prioritize the use of the CVV for vegetables.

Proposed revision Increase soy substitution options; specify nutrient profiles of soy options.

• Soy-based yogurt and cheese are authorized yogurt and cheese substitution options, respectively, for individuals with lactose intolerance, a milk allergy, or who consume a vegan diet.
• Soy-based yogurt must contain at least 250 mg of calcium and 6.5 grams of protein per 8 ounce serving.
• Soy-based cheese must contain at least 250 mg of calcium and 6.5 grams of protein per 1.5-ounce serving.
• In addition to current standards for authorized soy-based beverages, the total sugars content should be as low as possible, not to exceed 12 grams per 8-ounce serving.
• Authorized tofu must contain a minimum of 200 milligram of calcium per 100 grams of tofu. Calcium-set is no longer part of the specification. Authorized tofu may not contain added fats, sugars, oils, or sodium.

Rationale and benefit

• The soy substitutions for yogurt or cheese are intended to meet the needs of individuals with lactose intolerance, a milk allergy, or who consume a vegan diet. The soy-based options in the food packages serve as milk substitutions. As such, the revised specification ensures that items in the food packages provide an amount of calcium as close to the amount in a serving of milk as reasonable, considering marketplace options.
• Sugars in soy-based beverages are 100 percent added; added sugars intakes are excessive in the WIC population, therefore the committee considered it important to apply a limit that considers nationwide availability of these products.

Proposed revision Create a range of authorized yogurt sizes; reduce the total sugars limit.

• At the discretion of the state agency, the yogurt quart substitution may range from 30 to 32 ounces to accommodate the smaller container sizes (approximately 5 ounces).
• In addition to the current specifications, authorized yogurts must contain no more than 30 grams total sugars per 8-ounce serving (≤3.75 grams total sugars per ounce).

Rationale and benefit

• The yogurt container sizes commonly available in the marketplace vary in total ounces, especially the single serving sizes. The proposed range of ounces of yogurt that substitutes for 1 quart of milk would allow for smaller container sizes to be authorized as a state option. State agencies would need to determine if provision of the smaller containers is within cost-containment parameters.
• The availability of yogurts that contain 30 grams or less of total sugars per 8-ounce serving has expanded substantially in recent years. The reduced total sugar limits for yogurt is more closely aligned with the DGA.

Proposed revision Modify the bread specifications; expand the list of state options for substitutions; specify specific nutrient parameters.

• Whole grain bread is no longer permitted; only 100% whole wheat bread is permitted.
• In addition to current whole grain options, states may authorize corn masa flour (nonwhole grain), teff, and buckwheat (specifications described later). States should authorize as many options as cost constraints allow.
• Cornmeal (including blue) meeting the FDA standard of identity (21 C.F.R. 137.260) and that is in alignment with USDA specifications for cornmeal in School Meal Programs (USDA-CNP-01-2008) may also be added as an option.
• Once available in the marketplace, states are encouraged to offer folic acid fortified corn masa flour and tortillas made with folic acid-fortified corn masa flour.

Rationale and benefit

• Very few states offer whole grain bread options other than 100% whole wheat. From the participant's perspective, identification of suitable whole grain breads (more than 50 percent whole grain) is challenging. As such, restricting to 100% whole wheat bread aligns with most current state WIC authorized food lists.
• Culturally appropriate alternatives are provided as state options. The selected options correspond to nutritionally appropriate items that participants and WIC staff expressed an interest in adding to the food packages. The expanded list allows state agencies to tailor their offerings to better accommodate the cultural needs and personal preferences of WIC clientele.

Proposed revision Changing whole grain specification of authorized breakfast cereals.

• In addition to meeting current nutrient specifications, all ready-to-eat cereals on a state agency's authorized food list must adhere to the “whole grain-rich” criteria as outlined by USDA-FNS for the School Lunch Program (USDA/FNS, 2014c).

Rationale and benefit

• The committee's analysis of NHANES data indicated that intakes of whole grains continue to be poor and intakes of refined-grains excessive across the WIC subgroups studied. Focusing on whole grains in the WIC food packages may also improve acceptability of whole grains for the longer term. This change increases the amount of whole grains in the food packages. This change also aligns WIC specifications with those of CACFP (USDA/FNS, 2014c).
• Whole grain cereal options have expanded substantially since the last review of the WIC food packages, removing marketplace availability as a barrier to access. Launches of whole grain products including cereal (wheat and other grains) doubled between 2006 and 2011 (Oldways, 2015).
• Two large national manufacturers of RTE breakfast cereals produce at least 14 different types of RTE cereals that meet the current WIC whole grain criteria (which is similar to the whole grain rich criteria), including 4 gluten-free whole grain varieties.
• The previous committee to review WIC food packages (IOM, 2006) recommended that all breakfast cereals provided through WIC be whole grain (that is, the grain component is at least 50 percent whole grain) to align with the 2005 DGA. Since 2005, the DGA have consistently specified that at least half of grain intake should be from whole grains. The DGA specifically state that intake of refined grains should be limited, although individuals (particularly women capable of becoming pregnant) who consume all grains as whole should include some sources fortified with folic acid as a means of preventing neural tube defects. RTE, fortified whole grain cereals are an example such a source (USDA/HHS, 2016).

Proposed revision Modify the specifications for canned fish.

• Authorized canned fish may be packed in water. Pack may include bones or skin. Added sauces and flavorings, such as tomato sauce, mustard, lemon, are authorized at the state agency's option. May be regular or lower in sodium content. Oil-packed is no longer authorized.

Rationale and benefit

• Water-packed varieties are more nutrient dense because water-packed fish is lower in energy but contains the same levels of key nutrients per serving.
• Few states currently offer oil-packed fish. The effect of this specification, therefore, is expected to have little effect on participant choice.

Unadjusted Estimates of Food Costs and Total Cost Differences

Table U-3 presents unadjusted food cost estimates for the current and revised food packages. The total unadjusted food costs from FY2018 through FY2022 are estimated to be $17.7 billion (averaging $3.93 billion per year) for the current food packages and $17.4 billion (averaging $3.87 billion per year) for the revised food packages. Over the course of FY2018 through FY2022, the proposed revisions are projected to lead to a total unadjusted cost savings of $263 million, as compared to the current food packages.

TABLE U-3

Estimated Unadjusted Food Costs of the Current and Proposed Food Packages, FY2018 Through FY2022.

Phased-in Cost Differences

Table U-4 presents the phased-in cost differences between the current and revised food packages, from FY2018 through FY2022. Assuming phased-in implementation across the WIC program inherently decreases the projected total cost savings. The total phased-in cost savings for FY2018 through FY2022 are approximately $42 million less than the total unadjusted cost savings ($220.4 million versus $262.8 million). The estimated cost differences not only reflect changes to the type and quantity of items in the specific food packages, but also the proportion of participants who are prescribed each food package. The cost savings in food package I in FY2021 and FY2022, for example, is driven by the anticipated 5 percent shift of fully formula-fed mother–infant dyads to the partially (mostly) breastfeeding participant categories, due to the incentives incorporated in to the revised food packages (see the “Participation” subsection in the section “Cost Estimate Methodology” for additional details about this assumption).

TABLE U-4

Estimated Phased-in Cost Differences of the Proposed Revised Food Packages as Compared to the Current Food Packages, FY2018 Through FY2022.

Cost Difference of Each Food Package Item

To determine the source(s) of the projected cost savings of the revised food package, the committee evaluated the total costs of each food package item category within the current and revised food packages. The total costs of each of the food items presented in Table U-5 include assumptions about substitutions and allowable options within each category and assumptions about changes in redemption rates (see “Cost Estimate Methodology” for additional details). Across the food package items, the total cost savings are larger than the total added costs, resulting in estimated total cost savings of the revised food packages as compared to the current food packages. Two major sources of cost differences between the current and revised food packages are juice and the CVV. In the current food packages, all women and children are prescribed juice. The reduction of total juice in the revised food packages results in a total phased-in cost savings of approximately $627 million over the course of FY2018 through FY2022, as compared to the current food packages. In contrast, increasing the value of the CVV for all women and children in the revised food package leads to an estimated total phased-in cost increase of approximately $780 million over the course of FY2018 through FY2022.

TABLE U-5

Phased-in Total Food Cost and Cost Differences (FY2018 Through FY2022) Between the Current and Revised Food Packages by Food Package Item Category, in Descending Order of Additional Costs.

Major Cost Differences of Food Package Items Within Each Food Package

To further explore the sources of the cost differences, the committee evaluated the total phased-in cost differences of each food package item within each food package. Table U-6 presents each food package item revision that resulted in a total phased-in cost difference of at least $25 million in cost saving or increases over the course of FY2018 through FY2022, as compared to the total cost of the corresponding item in the current food packages. The major total cost differences summarized in the table not only reflect the specific revisions to the items and the quantity prescribed, but also the distribution of participants across the different food packages. Because food package IV-B comprises the largest participant group (approximately 36 percent of food package recipients), relatively small changes lead to more drastic cost differences. For example, the CVV in the revised food package IV-B would increase by $3 per month compared to the current food package,⁸ leading to an estimated $246 million increase in estimated total phased-in costs, as compared to the current food package. In contrast, the CVV for fully breastfeeding women (food package VII)—who comprise approximately 3 percent of food package recipients—would increase by $24 per month in the revised food packages, and would only lead to an estimated $200 million increase in estimated phased-in costs.

TABLE U-6

Revisions to Food Package Items That Lead to Major Total Phased-in Cost Differences from FY2018 Through FY2022, by Food Package.

Cost Differences of Food Package Items Over Time

The preceding sections broadly evaluate the cost implications of each food package item, summed across all projected years. As presented in Table U-7, the phased-in costs differences are not static over the course of FY2018 through FY2022 and reflect assumptions of the analysis. Cost differences in FY2018 and FY2019 are markedly lower than in subsequent years, for example, because they reflect the phased-in implementation of the revised food package. The values for these 2 years are one-third of the unadjusted value. The cost differences for FY2018 are further reduced, because the values only encompass a 6-month period.

TABLE U-7

Phased-in Cost Differences Between the Current and Revised Food Packages by Food Package Item Category, by Fiscal Year.

Some of the variations in cost differences over time are solely due to assumptions regarding participation. In FY2021 and FY2022, infant formula is projected to cost less and eggs are projected to cost slightly more in the revised food packages as compared to the current food packages. The analysis does not assume changes in quantities or percent redeemed between the current and revised food packages for either food package item. Instead, the cost differences result from the 5 percent shift in fully formula-fed mother–infant dyads to partially (mostly) breastfeeding food packages that the committee projects to take place in FY2020 for the revised food packages. The slight increase in egg costs in the revised food packages is attributed to the women shifting from being classified as partially (minimally) breastfeeding at more than 6-months postpartum (i.e., receiving food package N/A) to partially (mostly) breastfeeding (i.e., receiving the revised food package V-B).

Most of the projected variations in cost differences over time are the result of a complex interplay among several factors. The CVV serves as a prime example. The proposed revisions add value to the CVV across all food packages for women and children. In FY2020 and FY2022, the CVV for women in the revised food package VII is projected to be adjusted for inflation by $1, increasing to $36 and $37 per month, respectively. Similarly, an inflation adjustment of $1 is projected for the revised food package V-B (for partially [mostly] breastfeeding women), increasing the CVV to $26 per month. Also during FY2021, the committee anticipates a 5 percent shift of fully formula-fed dyads to partially (mostly) breastfed food packages, which would shift a portion of postpartum women to the larger CVV in the revised food package V-B (as compared to the revised food package VI CVV). These adjustments and assumptions in the revised food packages do not have a dramatic effect on total cost differences because participants in food packages VII and V-B make up a small proportion of the total WIC population. In FY2022, however, the trajectory of the cost difference for the CVV changes, decreasing from +$230 million in FY2021 to +$215 million in FY2022. This is the result of a $1 inflation adjustment that is projected to affect all food packages for women in the current food packages. Although the revised CVV values result in positive cost differences (i.e., cost increases) as compared to the CVV values in the current food packages for each fiscal year assessed, the difference across the years is not consistent. Assumptions regarding the CVV are detailed in the “Cost Effect Methodology” section that follows. Alternative assumptions and their effects on total cost differences are tested in the “Uncertainty” section later in this appendix.

Participation

The WIC Participation and Program Characteristics 2014: Food Package Report (USDA/FNS, 2016a) and average participation by participant category from administrative data posted on FNS's website¹⁰ (USDA/FNS, 2016b) both describe WIC program participation by food package. While each provides a slightly different portrait of participation, neither directly provides the number of individuals who claim each specific food package type (outlined in Table U-1). The committee used both data sources to estimate the average number of participants who are actually issued a food instrument each month.

The 2014 Food Package Report is the only data source that provides insight into the distribution¹¹ of participants across the 27 specific types of food packages. While the data used for the Food Package Report are the most comprehensive available on the topic of specific food package assignments, there are limitations including, but are not limited to:

• The dataset captured all individuals certified to receive benefits during the month of April of the assessment year, regardless of whether the food benefits were claimed. The total number of participants in the Food Package Report's analyses, therefore, is higher than average monthly participation counts derived from other sources of administrative data, which generally reflect those that claimed benefits from the WIC agency.
• The food package type variable in the dataset is still considered to be in the testing phase. Because of this, the Food Package Report notes: “Findings should be treated as suggestive rather than definitive” (USDA/FNS, 2016a).
• The dataset only includes WIC participants in Puerto Rico; Washington, DC; and 48 states.¹² Louisiana and New Mexico did not provide information on specific food package assigned to participants. Furthermore, other territories and Indian Tribal Organizations were not included in the dataset. As such, the distributions of the food packages within the participant categories approximates, but may not necessarily represent, that which exists across all participating agencies.
• The dataset had variable levels of missing data. The Food Package Report notes that “the information provided by state agencies on food package types is not entirely complete or reliable” (USDA/FNS, 2016a).
• In the data received from states, participants were recorded as being part of one of five certification categories: pregnant women, breastfeeding women, postpartum women, infants, and children. The breastfeeding category encompasses fully breastfeeding women (intended to be food package VII); partially (mostly) breastfeeding women up to 1-year postpartum (intended to be food package V); partially (minimally) breastfeeding women up to 6-months postpartum (intended to be food package VI); and partially (minimally) breastfeeding women, 6- to 12-months postpartum (no food package). In the analyses performed in the Food Package Report, the breastfeeding certification category was separated into fully and partially breastfeeding women by dichotomizing the participants based on prescription of food package VII. Food package VII, however, can also be assigned to women pregnant with or partially (mostly) breastfeeding multiples, so this approach to subgrouping can only closely approximate the number of fully breastfeeding women in the dataset. Furthermore, partially (minimally) breastfeeding women more than 6-months postpartum are eligible for WIC services but do not receive a food package. Agencies differed in their approach to reporting the food package associated with these participants. Some reported a null food package (food package “N/A”) while most did not report a food package.
• Some participant categories appeared to be assigned discordant food packages. A small fraction of participants were reportedly assigned a food package that did not correspond with their participant category (e.g., an infant receiving food package IV-A). Some of the discrepancy is attributed to how age was calculated in the dataset (e.g., an infant aged into the children's food package during the month of April may still be counted as an infant). Another potential source of the discrepancies is that agencies may prescribe an updated food package without recertifying the participant when their status changes. Women, for example, may take up to 6-weeks postpartum to recertify based on breastfeeding status. During this period, such women would continue to receive the prenatal food package V despite being postpartum.

The distributions presented in the 2014 Food Package Report were applied to the average monthly national participation for FY2015, to arrive at participation estimates that reflect individuals issued food benefits in a given month. Because the Food Package Report and administrative data posted on FNS's website assess participation levels differently, the following adjustments and assumptions were made:

• The data used in the 2014 Food Package Report are collected on a biennial basis, and are the most current portrait of specific food package prescription distributions. The committee presumed that the food package distributions would not be substantially different between FY2014 and FY2015.
• Due to rounding, not all food package distributions within each participant category presented in the 2014 Food Package Report summed to 100 percent. To account for this in the RIA, the following was done:
  • Specific food packages assigned “<0.1 percent” were set to zero for pregnant women, partially breastfeeding women, infants, and children, as the distributions within each of the participant categories summed to 100 percent without accounting for such values.
  • The three food package types assigned a “<0.1 percent” for postpartum women were replaced with a value of 0.03 percent, so the distribution for the participant category summed to 100 percent rather than 99.9 percent.
  • All values ≥0.1 percent in the infant participant category were divided by 1.001 to scale the distribution for the participant category to 100 percent rather than 100.1 percent.
• The percent of a participant group assigned a “Missing” food package type in the Food Package Report was assumed to represent certified WIC participants who did not claim benefits in a given month. This type of participant is represented in the Food Package Report dataset, but not in the administrative totals presented on FNS's website. To arrive at food package distributions representing only participants claiming their food instrument, the percent assigned “Missing” were removed from each participant category, and the remaining food package distributions were scaled to 100 percent within each participant category. Scaled distributions were then applied to the FY2015 administrative participation data, by participant category. This assumption has implications particularly for the partially breastfeeding women participant category. Since not all states used a null food package (“N/A”) to report on partially (minimally) breastfeeding women more than 6-months postpartum (i.e., a participant group that does not receive a food instrument), the slightly higher rate of missing food package assignments for the partially breastfeeding woman participant category could be due to this subgroup being inadequately captured in the data. The extent to which this occurred, however, could not be determined or accounted for in this analysis.
• The Food Package Report includes a null food package (“N/A”) which is noted to be assigned to minimally breastfeeding women more than 6-months postpartum who do not receive food benefits but still participate in WIC. According to FNS, this type of WIC participant is captured in the administrative dataset. Because the goal of this analysis is to assess costs related to the food benefit, participants assigned the “N/A” food package were not included in the cost profiles for the current food package (see “Cost Estimate Methodology” for additional details). The final participant count used in this RIA is therefore slightly lower than the total average participation derived from the administrative data.
• Discordance between the food package and the participant category were largely disregarded for the purposes of this analysis, since the primary goal was to determine the number of participants prescribed as specific food package. However, assumptions had to be made for food package V. In the Food Package Report, more than 1 percent of women in the postpartum participant category were assigned food package V, which is intended for pregnant and partially (mostly) breastfeeding women. It was presumed that these participants were women who had given birth within the previous 6 weeks and were still receiving the prenatal food package, and would therefore receive food package V-A (pregnant) in the revised food package structure. This assumption had minimal effect on overall cost, as postpartum women represented less than 1 percent of participants receiving food package V.

The integration of the 2014 Food Package Report and average participation by category from FNS administrative data allowed the committee to estimate the number of participants actively being issued each of the specific food packages in FY2015. This served as the base for both the current and proposed cost estimates.

Estimating participation for FY2018 through FY2022 The forecasted levels of WIC participation through FY2022 are an extrapolation of FY2015 WIC participation levels based on the relationship between WIC participation and the general economy. During and following the economic recession of 2008–2009, WIC participation grew. As that recession waned, WIC participation declined. As the general economy is forecasted to moderately improve and then stabilize, the committee expects that WIC participation levels will decrease initially, then slightly increase and stabilize through FY2022.

To extrapolate WIC participation into the future, the committee quantified the relationship between WIC participation levels and economic conditions, using regression analysis. The number of unemployed persons served as a measure of economic conditions. Regression analysis showed a strong correlation between the number of unemployed persons and WIC participation. This correlation was used to predict WIC participation based on the Federal Reserve's forecast of unemployment rates and the Bureau of Labor Statistics's forecast of the civilian labor force (BLS, 2013). Based on these data and the relationship between WIC participation and unemployment, the committee forecasts WIC participation to decline by 2.2 percent between FY2015 and FY2018. From FY2018 to FY2022, the committee forecasts WIC participation to increase by 1.5 percent. The FY2022 participation levels are forecasted to be 0.7 percent lower than the FY2015 levels. The relative changes in participation used in this RIA are summarized in Table U-8. The committee assumed the relative change would be experienced the same across all participant categories. Projected participation for the current food packages, by food package type, is presented in Table U-9. These values served as the participant multipliers for estimating costs of the current food packages.

TABLE U-8

Forecasted Relative Change in Total Participation.

TABLE U-9

Projected Participation by Food Package Type, Current Food Packages.

Anticipating a Shift in Fully Formula-Fed Mother–Infant Dyads Under the Proposed Revisions

Participation projections are identical between the current and proposed revised food packages, with one exception. The committee anticipates the proposed revision to the categorization of partial (mostly) breastfeeding dyads in the first month will result in a shift of 5 percent of formula-fed infants (food packages I-FF-A, I-FF-B, and II-FF), 5 percent of postpartum and partially (minimally) breastfeeding women less than 6-months postpartum (food package VI recipients), and 5 percent of women classified as receiving the N/A food package to their respective partially (mostly) breastfeeding categories. The shift of women assigned the food package N/A to V-B slightly increases the total number of participants issued food benefits under the proposed revisions, as compared to the projections for the current food packages. The 5-percent shift was selected based on data presented in USDA/FNS (2011) that indicated the 2009 food package resulted in an approximately 8 to 11 percent shift of women out of the partially breastfeeding food package. The shifts were largely due to the fully formula-feeding food packages. The 5 percent value used in this analysis was therefore considered a conservative estimate for the number of participants that would shift back to the partially (mostly) breastfeeding category. The committee anticipates that the shift will take place after all the revisions have been implemented in all states and will be sustained but not recur in subsequent years. Accordingly, the shift has been incorporated in FY2021 participation estimates, which corresponds to the year after full implementation under the phased-in assumption. Projected participation under the proposed revisions by specific food package is presented in Table U-10. These values served as the participant multipliers for estimating food package costs under the proposed revisions.

TABLE U-10

Projected Participation Under the Proposed Revisions, by Food Package Type.

Redemption

Three sources of data were used to estimate and project redemption for each item in the current and revised food packages: (1) anonymized redemption data provided by FNS (hereafter referenced as the FNS redemption dataset), (2) redemption data provided by six individual WIC agencies, and (3) a 2014 Altarum report detailing redemption in Kentucky, Michigan, and Nevada as they transitioned to EBT (USDA/ERS, 2014).

Redemption data provided by FNS USDA-FNS provided the committee with 12 months (August 2013 through July 2014) of WIC redemption data from a convenience sample of 6 WIC state agencies, representing five of the seven regions of the country (the FNS redemption dataset). The identities of the states were not known to the committee. The states were diverse in terms of size and did not include Indian Tribal Organizations or territories.¹³

For each state, each month's worth of data included the following information: a description of the main food package item category (e.g., “legume”); the subcategory of food (e.g., “canned beans,” “dry beans”); size and measure of the container purchased (e.g., 16 ounces); number of containers redeemed; average price for the container; and the total amount paid by WIC for that specific item (see the “Prices” section for use of the cost data). Because states agencies varied in their reporting approach—some providing specific descriptions of the items purchased (e.g., “soft corn tortilla”), while others only provided general descriptions (e.g., “whole grains, all types”)—redemption estimates collectively describe the main food package item category, rather than individual food items. To arrive at redemption estimates from the FNS redemption dataset, the following steps were taken for each state:

• The number of units purchased in a given month was standardized by multiplying the container size by the number of containers redeemed, summing the total amount purchased across the various container sizes, and, where applicable, dividing by a food package-appropriate unit size. For example, ounces of fish purchased in the month was determined across all container sizes (3.75 to 20 ounces), summed, and divided by 30 to arrive at number of 30-ounce units purchased.
• The number of standardized units purchased in a given month was then averaged across the 12 months for each food package item category.
• The average number of standardized units purchased in a month was divided by the number of participants expected to receive the food item and accounted for differences in monthly maximum allowances by food package (e.g., the equation used to estimate juice redemption accounted for the different maximum amounts prescribed children and the various food packages for women). To keep the identity of the state agencies anonymous, FNS inputted average monthly participation by participant category for each state into a spreadsheet that contained the redemption equations created by the committee, and returned the overall unweighted average redemption across the state agencies per food package item.¹⁴ Through this process, FNS identified one of the six states as a clear outlier, and removed it from the averages (personal communication, K. Castellanos-Brown, USDA-FNS, June 22, 2016). As such, redemption estimates are calculated from five of the six state agency datasets provided by FNS.

Redemption estimates based on the FNS data have both strengths and limitations for the purposes of estimating and projecting costs associated with the food benefit. One of the strengths is that the data reflect actual purchases made by WIC participants with their food instrument. The data capture the range of container sizes that participants chose to purchase, and also include state-specific options for substitutions. Using redemption data, rather than making assumptions based on average quantity prescribed to participants, has the potential to better reflect the actual food costs. Limitations of the existing data, however, affect generalizability. The data only provide insight into the total number of units purchased in a given month or over the course of the year and were not currently reported in a way that could be used to see how redemption differed across specific food packages when an item was not unique to a single food package (e.g., breakfast cereal redemption may not be the same for children as it is for women). Furthermore, the FNS data could also not be used to arrive at redemption estimates for certain food package items. Redemption of milk and cheese, for example, could not be determined because cheese is offered not only as a separate food item provided in food package VII, but also as a substitution option for milk across children's and women's food packages. The data also predated the authorization of yogurt as a milk substitution option.

Redemption data provided by individual state agencies From the data provided by FNS, the committee was able to estimate redemption for most of the standard items prescribed to children and women. Some redemption of estimates, however, could not be determined. In these instances, publicly available redemption data from individual state agencies were averaged and used in the analysis. The six agencies that provided redemption data included California (February 2015 through February 2016), the Chickasaw Nation (April 2015 through March 2016), Kentucky (November 2014 through May 2015), Massachusetts (March through August 2015), Texas (July and August 2015), and Wyoming (May 2015). Not all of the state agencies provided redemption estimates for all food items. Although the redemption estimates derived from these sources were WIC-specific, they were relatively limited in scope and not necessarily representative of WIC participants nationally.

Calculating Redemption for Current and Revised Food Package Items

The redemption rates derived from the data provided by FNS and the data provided by individual state agencies were applied to the current food packages and served as the base for the redemption projections under the proposed revised food packages. The committee used a 2014 report from Altarum (USDA/ERS, 2014), which provided insight into three types of redemption practices (full-, partial-, and nonredemption) to develop data-based assumptions for the redemption behaviors in the revised food packages (detailed in Appendix R). Redemption estimates that were based only on assumptions about full-, partial-, and nonredemption were considered “implied redemption rates.” Implied redemption rates, however, do not account for behavioral changes, such as those that might result from the offering of new substitution options. Accordingly, the committee made slight adjustments to account for such changes. Table U-11 outlines the redemption rates applied to the current and revised food packages.

TABLE U-11

Redemption Estimates and Projections for Food Package Items for Current and Revised Food Packages.

Applying redemption rates to the food packages The committee applied the calculated and projected redemption rates to the current and proposed monthly maximum allowances) for all food packages. Tables U-12 and U-13 summarize the estimated average amount redeemed for each food item for the current and revised food packages, respectively. The projected average amounts redeemed for each food package item serves as the quantity multipliers used in the estimation of total food costs.

TABLE U-12

Estimated Average Amount Redeemed for Each Food Package Item Food Package Type, Current Food Packages.

TABLE U-13

Projected Average Amount Redeemed for Each Food Package Item Under the Proposed Revisions, by Food Package Type.

Prices

As described in the preceding “Redemption” section, FNS provided the committee with 12 months' worth of anonymized redemption data from six state agencies (August 2013 through July 2014).¹⁵ The data included the number and sizes of containers purchased, the average price per container for each container size, and the total amount the WIC agency paid for each size of the food item. Given the range of container sizes purchased for each food package item, the number of units purchased was standardized by multiplying the container size by the number of containers redeemed, summing the total amount purchased across the various container sizes, and, where applicable, dividing by a food package-appropriate unit size. The total amount the agency paid for the food item (across all container sizes) was divided by the total number of standardized units purchased to arrive at a price per unit.

The FNS redemption dataset captures WIC shopping behaviors not readily quantifiable from other sources of food prices. For example, the data were presumed to encompass the range of approved vendors where participants choose to use their WIC food instruments. The prices themselves reflect the choices participants actually made while at the vendor. Prices are inclusive of the substitutions and state-authorized allowable options selected by participants. Although the extent to which the FNS redemption dataset was representative of program participants at large could not be determined, the committee prioritized its use owing to its specificity to the WIC population.

The FNS redemption dataset, however, could not be used to estimate prices for select food package items. Infant formula was not included in the FNS redemption dataset. The FNS redemption dataset also predated allowing yogurt as a substitution option for fluid milk. Finally, the FNS redemption dataset did not contain the range of whole wheat bread and allowable options being proposed for the revised food packages. For these items, prices were drawn from the 2014 IRI Consumer Network database.

Composite prices for the food items State agencies that contributed information to the FNS redemption dataset varied in the level of detail about the purchased item. Some provided specific descriptors of the subcategory (e.g., “nonwhole grain breakfast cereal”) while other only provided broad descriptions (e.g., “breakfast cereal: all types”). Because of this, the price estimates derived from the FNS redemption dataset collectively describe the main food package item category, which includes corresponding substitution and state-authorized allowable option selections made within that category. This approach, however, could not be used for five food package items: infant formula, infant food meat (revised food package only), milk, peanut butter and legumes, and whole wheat bread (revised food package only). For these items, the committee developed composite prices for each of the food package items, as outlined below:

• Infant formula prices were not included in the FNS redemption dataset. The committee, therefore, drew retail price data for liquid concentrate, powdered, and ready-to-feed infant formulas from the 2014 IRI Consumer Network database. The prices for unprepared infant formula were converted to prices per prepared fluid ounce. The average costs per prepared fluid ounce were weighted to reflect the distribution of infant formula types purchased through WIC. The weights were derived from the 2014 Food Package Report (USDA/FNS, 2016a): 0.78 (powdered), 0.12 (liquid concentrate), and 0.10 (ready-to-feed). Based on the FY2010 WIC Food Cost Report (USDA/FNS, 2013b), postrebate costs of infant formula are approximately 35 percent of prerebate costs. Given the rebate data were from 2010, the committee evaluated the stability of rebates between 2010 and 2015.¹⁶ With the exception of 2011, rebates between 2010 and 2015 were relatively stable. Accordingly, the postrebate cost to the agency was estimated to be approximately 35 percent of the weighted average price per prepared fluid ounce.
• Under the proposed revisions, fully breastfed infants ages 6 to less than 12 months are prescribed 40 ounces of infant food meat, with the option of 10 ounces substituted with canned fish. Given the relatively low redemption of infant food meat and feedback from the public regarding infant food meat, the committee assumed food package II-BF recipients would make use of the 10-ounce substitution option. The weights used to calculate the composite were 0.75 for infant food meat and 0.25 for canned fish. The redemption projection presented in Table U-11 was applied to this composite value.
• In both the current and revised food packages, legumes and peanut butter are prescribed to participant under two different schemes. Accordingly, the different food packages and food package versions needed different weights for calculating composite prices. The weights accounted for the two different forms of legumes that can be authorized (dried and canned). The 2015 WIC Food Package Policy Options II Final Report (USDA/FNS, 2015b) reported that 85 percent of WIC participants are served by state agencies that allow canned legumes as an allowable option. Under the proposed revisions, all state agencies would have to authorize canned legumes as an allowable option. Table U-14 summarizes the weighting scheme used to calculate composite prices for the legume and peanut butter category.
• Allowable options and substitutions in the milk category include milk,¹⁷ yogurt, cheese, soy beverage, and tofu. In both the current and revised food packages, children issued food package IV-A are prescribed whole milk, while all other food packages only prescribed the option of reduced-fat milk, low-fat milk, or nonfat milk. In the FNS redemption dataset, the cost of whole milk was slightly more than reduced-fat, low-fat, and nonfat milks, indicating a single price for fluid milk could not be used for this analysis. Milk prices are a weighted composite of the price of fluid milk, soy beverage, and lactose-free milk. Weights were based on redemption data provided by Texas and Wyoming. Tofu was redeemed for less than 1 percent of milk purchases in the available redemption data, and therefore was omitted from the milk composite price. Furthermore, because the quantity of milk prescribed differs across the food packages, and the maximum allowed substitutions differ for food package VII, a single weighting scheme of milk, yogurt, and cheese could not be applied. For the current food packages, the committee assumed maximum substitution of cheese and yogurt. For the revised food packages, the committee weighted the maximum cheese and yogurt substitution options. Table U-15 summarizes the weighting scheme used to calculate composite prices for the milk food package item category.
• Proposed changes to the specifications and allowable options in the whole wheat bread category necessitated new prices. Prices for 100% whole wheat bread (18- to 24-ounce sizes),¹⁸ corn tortillas (16 to 24 ounces), and oatmeal (16 to 24 ounces) were used in the cost estimates for the proposed revisions. While other allowable options for the whole wheat bread category exist (e.g., brown rice, bulgur, whole wheat pasta), nationally representative data on the distribution of redemption in context of the different options authorized by states were not available to the committee. Weights for the whole wheat bread (0.755), corn tortillas (0.185), and oatmeal (0.060) were estimated from redemption data from the Chickasaw Nation, Texas, and Wyoming.

TABLE U-14

Weighting Schemes Used to Calculate Composite Prices for Legumes and Peanut Butter for Current and Revised Food Packages.

TABLE U-15

Weighting Schemes Used to Calculate Composite Prices for Milk for the Current and Revised Food Packages.

Inflating unit prices to FY2015 prices The two sources of price data encompassed different timeframes; the FNS redemption dataset values were from August 2013 through July 2014 and the IRI Consumer Network prices were from calendar year 2014. To create a common base year, prices were inflated to FY2015 prices using Bureau of Labor Statistics Consumer Price Index (CPI) adjustments.¹⁹ To accomplish this, the average item-specific CPI for FY2015 was divided by the average CPI for the time frame encompassed by the available unit price. The FY2015 prices were used to create the composite prices described in the preceding section. Table U-16 outlines the item-specific inflation rates and resulting FY2015 unit and composite prices for each food item used in this analysis.

TABLE U-16

FY2015 Price per Unit for Each Food Package Item and Calculated Composite Using Item-Specific Inflation Rates.

Projecting prices after FY2015 For years after FY2015, prices for items that are prescribed as a fixed quantity (e.g., 16 quarts of milk) were inflated using the Congressional Budget Office's March 2015 Baseline Thrifty Food Plan estimates (CBO, 2015) The inflation assumptions are presented in Table U-17.

TABLE U-17

Inflation Assumptions for Food Package Items Prescribed as a Fixed Quantity, FY2016–FY2022.

Inflating the cash value voucher The CVV does not inflate the same way as items prescribed as a fixed quantity. Instead, its inflation depends on an annual average of the CPI for fresh fruits and vegetables (7 C.F.R. § 246.16). Under the current rule, the average CPI for fresh fruits and vegetables from April 2006 through March 2007 is assigned to FY2008 and considered the baseline CPI. Each subsequent year follows the same pattern (e.g., FY2009 value is the average CPI from April 2007 to March 2008). To inflate the CVV, the average CPI for the fiscal year being considered is divided by the baseline CPI value and multiplied by the base values of each CVV ($8 for children, $10 for women). Participants only receive an increase in value when the inflated CVV crosses a $1 increment. Provision of the CVV in dollar increments, rather than prescribing the exact inflated value, is easier from an administrative perspective, as adjustments only have to be made periodically. It also decreases participant burden, as the benefit is provided in a round number and a consistent value month to month. This inflation approach was used for estimating the costs of the current food packages in this analysis.

Under the proposed revisions, all women and children receive a CVV of higher value. Had the committee kept FY2008 as the baseline CPI value under the proposed revisions, in FY2018 the $12, $15, $25, and $35 CVVs would already have been inflated to $13, $17, $28, and $39, respectively, because of the inflation that will have taken place in the decade between FY2008 and FY2018. Accordingly, the CVV under the proposed revision required a new inflation baseline, which was assumed to be the first year of implementation (FY2018).

The CPI values used in the inflation of the CVV encompass the 6 to 18 months prior to the fiscal year they describe. Accordingly, actual CPI values were used through FY2017 of this analysis. The committee could not identify forecasts for the retail price of fresh vegetables and fruits that extended to FY2022. A forecast for 2017 projected a 1 to 2 percent relative change in price from FY2016 (USDA/ERS, 2016). Therefore, a relative change in average CPI of 1.5 percent was used for FY2018 through FY2022. The CPI value assumptions and associated percent increase are summarized in Table U-18. The cost effect of using alternate baseline years for the CPI inflation values for the revised food packages are tested in the “Uncertainties” section of this analysis.

TABLE U-18

Consumer Price Index for Fresh Vegetables and Fruits: Assumptions for Inflating the CVV for Current and Revised Food Packages.

When the assessment year's CPI is divided by the baseline year value, it represents the percent increase relative to baseline. Because this percent is applied to the initial CVV value, larger CVVs will cross the $1 increment sooner than smaller CVVs. These differences become more pronounced with higher CVV values. Given this, in this analysis, the CVVs that are issued as substitution options (i.e., half of infant food vegetables and fruits for a $10 CVV; all infant food vegetables and fruits for a $20 CVV; all juice for $3 CVV) are not added to the participant's CVV value, but are instead inflated separately. Table U-19 presents the effect of the CPI projections on the CVVs for the current and revised food packages.

TABLE U-19

Projected Incremental Increases in Cash Value Vouchers for the Current and Revised Food Packages.

Different CVV Redemption Projections Under the Proposed Revisions

In the primary analysis, CVV redemption was estimated to be 77.2 percent in the current food packages and 75.0 percent in the revised food packages The cost implications of two alternative redemption scenarios are presented in Table U-20. Scenario 1 shows that increasing the redemption assumption to 85 percent for the revised food packages would result in the estimated $220.4 million savings projected in the primary analysis becoming $135.1 million in additional costs, as compared to the current food packages ($355.5 million in additional costs as compared to the base assumption). Similarly, scenario 2 shows that lower redemption of the revised CVV (65 percent redemption) results in an additional $355.5 million savings from FY2018 through FY2022, as compared to the base assumptions in the primary analysis. This lower redemption assumption for the CVVs in the revised food packages results in a total cost savings of approximately $580 million over the course of FY2018 through FY2022, as compared to the current food packages.

TABLE U-20

Projected Phased-in Cost Difference of WIC Food Package Revisions, Increase or Decrease in Redemption Assumption of Cash Value Voucher.

Different CPI Inflation Scenarios

The CVV inflation rate depends on the baseline CPI value to which all subsequent years are compared. In the primary analysis, actual inflation rates were available through FY2017; values thereafter are projections. The CPI value assigned to FY2018 has significant implications, as it is expected to serve as the new CVV inflation baseline for the revised food packages. Based on Economic Research Service forecast (USDA/ERS, 2016), the committee estimated a 1.5 percent relative change in average CPI from FY2017 to FY2018 and in each year thereafter.

Table U-21 presents the cost differences of changing these assumptions about relative change in CPI values.²⁰ In scenario 1, a higher relative change in just FY2018 (relative increase of 5 percent rather than 1.5 percent) leads to an additional $34.1 million in savings from FY2018 through FY2022, resulting in an estimated total cost savings of $255 million, as compared to the current food packages. When the base assumption inflation rate is maintained for FY2018, but increased to 5.0 percent in all subsequent years (scenario 2), the proposed revisions would decrease cost savings by $42.6 million over FY2018 through FY2022. Scenario 3 assumes a 5.0 percent inflation rate across all years, which would cost $19.8 million more than the total phased-in cost estimate of the primary analysis. In contrast, a 5.0 percent deflation from FY2017 to FY2018 followed by inflation of 1.5 percent in each subsequent year (scenario 4) would cost an additional $130 million compared to the base assumptions in the primary analysis, over the course of FY2018 through FY2022. Finally, when the initial deflation assumption is followed by a higher relative inflation rate (5 percent rather than 1.5 percent; scenario 5), the total costs are approximately $229 million more than the total costs of the base assumptions for the revised food packages. This is the only tested CPI inflation scenario that results in the proposed revisions costing more than the current food packages during FY2018 through FY2022.

TABLE U-21

Projected Phased-in Cost Difference of WIC Food Package Revisions, Assuming Different Consumer Price Index Inflation Rates Used to Inflate the Revised CVV.

Another CPI inflation scenario assumption is the baseline year to which all subsequent years are compared in the revised food packages. Table U-22 explores the cost differences associated with different CPI base years for the revised food packages. In scenario 1, changing the base year to inflate the revised CVV FY2015 would cost an additional $128 million over FY2018 through FY2022, as compared to using FY2018 as the base year. Both scenarios 2 and 3 demonstrate that there are relatively small costs effects of selecting either FY2016 or FY2017 as the base year for CVV inflation in the revised food packages.

TABLE U-22

Projected Phased-in Cost Difference of WIC Food Package Revisions, Changing the Base Comparison Year for CVV Inflation.

Different Levels of Substitution for CVV

Under the proposed revisions, food package II recipients can receive a $10 (“partial substitution”) or a $20 (“full substitution”) CVV in lieu of the 64 ounces and 128 ounces of jarred infant food vegetables and fruits, respectively. To maintain cost neutrality, the committee selected the dollar value of the CVVs based on estimated FY2015 prices of jarred infant food vegetables and fruits. The base assumptions in the primary analysis, however, project slightly higher redemption of CVVs compared to jarred infant food vegetables and fruits. Furthermore, jarred infant food vegetables and fruits inflate differently than the CVV. While jarred infant food vegetables and fruits are projected to progressively inflate between FY2018 and FY2022, the CVV value prescribed to participants does not adjust until FY2022, when the $20 CVV inflates to $21.

The base assumption in the primary analysis is that 0 percent of participants select the CVV substitution option. Table U-23 summarizes the cost effects of different levels of partial and full substitution of jarred infant food vegetables and fruits. Given the redemption and inflation assumptions, substitutions of jarred infant food vegetables and fruits with CVVs initially cost slightly more but eventually lead to additional cost savings beginning in FY2020. The net cost effect of substitution for CVVs in food package II are $5.1 million (scenario 1, 50 percent of infants selecting partial substitution) to $11.4 million (scenario 4, 100 percent selecting full substitution) of additional savings, as compared to the base assumption of no substitution in the revised food packages.

TABLE U-23

Projected Phased-in Cost Difference of WIC Food Package Revisions, Changing Assumptions About Substitution of Cash Value Vouchers for Jarred Infant Food Vegetables and Fruits.

Under the proposed revisions, a $3 CVV can be substituted for the 64 ounces of juice prescribed in children's and women's food packages. The CVV amount was the closest dollar increment to the estimated cost of 64 fluid ounces of juice based on FY2015 prices, which was estimated to be $3.15. In contrast to jarred infant food vegetables and fruits, the redemption rate of juice is projected to be slightly higher than the overall redemption rate of the CVV. The cumulative effect of the slightly lower price and projected redemption means that, under the assumptions of the analysis, substituting a CVV for the juice prescription would lead to increased cost savings (see Table U-24).

TABLE U-24

Projected Phased-in Cost Difference of WIC Food Package Revisions, Changing Assumptions About Substitution of Cash Value Vouchers for Juice.