USHBC Coalition: WIC Online Access

To whom it may concern,

Comments submitted on behalf of the United States Hispanic Business Council (USHBC), Hispanic Chamber of e-Commerce, Statewide Hispanic Chamber of Commerce of New Jersey, Florida State Hispanic Chamber of Commerce, Irving Hispanic Chamber of Commerce and Utah Hispanic Chamber of Commerce in response to the United States Department of Agriculture’s (USDA) and Food and Nutrition Services’ (FNS) Federal Register publication titled Special Supplemental Nutrition Program for Women, Infants, and Children: Online Ordering and Transactions and Food Delivery Revisions to Meet the Needs of a Modern, Data-Driven Program [FNS–2022–0015].

I submit these comments in my role as the President and CEO of the United States Hispanic Business Council (USHBC). We are a 501(c)6 nonprofit organization credited as the leading advocate for fair representation of Hispanics in business, media, and politics. 

The Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) in our nation is a critical tool to ensure the survival of disadvantaged families. In fact, over 6 million Americans are enrolled in the WIC program. Looking further, 3 million (almost half) of them are of Hispanic descent. Suffice it to say, the WIC program is a beneficial program to the Hispanic community and others. However, we believe that potential changes could increase the effectiveness of the program, as seen with the online SNAP sales pilot program.

The USHBC is encouraged by some of the changes being considered by the USDA’s effort to streamline and modernize the WIC program. We also believe that an imperative part of rolling out this change is creating a national eligibility framework and adopting Minimum Stocking Requirements specific to online grocers. Implementing these reforms will have far-reaching benefits for vulnerable populations and contribute to the overall improvement of public health and consumer options by increasing accessibility for millions of disadvantaged families and small businesses.

Expanding WIC benefits to online retailers would greatly enhance access to nutritious food for participants, particularly single mothers, people residing in food deserts or those facing transportation, health, or weather challenges. With the increasing prevalence of online shopping, incorporating online retailers into the WIC program would provide an additional avenue for eligible families to access food. For example, online grocery shopping has grown over 45% nation-wide in the past few years. In the Hispanic community specifically, 54% of consumers now buy groceries online. It’s clear that like most Americans, Hispanics are shifting to online grocery shopping. The programs they rely on for their basic nutritional needs should remain in lockstep with these changes. 

The rapid growth of online shopping coupled with online eligibility for WIC products also presents abundant economic opportunities for the small business for which we advocate. Nationally, consumers already spend $6.5 billion a month on online groceries. Allowing small businesses to participate in WIC online sales will undoubtedly increase this amount. Additionally, authorizing online WIC transactions will level the playing field between small and big businesses, by eliminating the competition for finite shelf space. By embracing online retailers, we can bridge the gap between technology and social welfare, fostering inclusivity and improving the lives of countless individuals, families and businesses.

However, with the authorization of online WIC transactions, a new hurdle will present itself; the plethora  of state offices operating in separate, yet concurrent, jurisdictions with unique requirements and guidelines. Online retailers would be required to apply to 89 different offices nation-wide in order to ensure compliance with the program and allow customers from any jurisdiction to purchase their product. As a result, the benefits of introducing online WIC transactions will be mute. By requiring online retailers to apply to 89 different offices, all with varying requirements, small businesses will be cut out of the marketplace and made vulnerable to exorbitant compliance costs. Given this environment, the small business community asks for a national authorization framework that addresses the needs of online retailers serving all states.

Part of the varying requirements of these 89 offices are the Minimum Stocking Requirements (MSR). As you know, these require eligible retailers to have a minimum amount of each product in order to qualify as a “Full-Service Grocery Store”. However, when it comes to online retailers, many specialize in just one or two products. For example, under current guidelines an online retailer that specializes in just cheese or milk must also stock cereal, fruits and vegetables, meat and more. While this may prove effective in ensuring that brick and mortar stores are what they say they are, the landscape for online grocers is vastly different. In online marketplaces, while one retailer may only offer dairy products, the marketplace itself is filled with retailers offering the other products required for eligibility. We see value in allowing online retailers, whether full grocers or niche producers, to offer any WIC-eligible product to any customer in a given WIC jurisdiction, regardless of whether they meet the full set of existing stocking standards. 

In conclusion, the proposed measures of expanding WIC benefits to online retailers would have numerous positive outcomes for the Hispanic community, small businesses and other populations in the WIC ecosystem. However, we believe creating national eligibility criteria and reforming stocking requirements for online retailers is imperative to success. Together, these changes would increase accessibility, improve convenience, and promote equity within the program, leading to enhanced food security, better nutrition, and improved overall health for vulnerable populations. 

We are grateful for USDA’s work to expand access and increase efficiency for WIC participants, and stand ready to provide insight, feedback and strategy on your mission.

Sincerely,