Review of WIC Food Packages Improving Balance and Choice: Final Report (2017) / Chapter Skim
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Appendix U: The Regulatory Impact Analysis (Complete)
Appendix U: The Regulatory Impact Analysis (Complete)
Pages 869-988
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From page 869... ...
Unless otherwise noted, cost differences describe how much more the revised food packages would save or cost program-wide, as compared to the current food package.
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Cost Differences • Current food costs subtracted from the revised food costs -- Negative values (−) indicate that the revised food packages costs less than the current food packages.
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. The committee used this monthly per participant cost to assess the cost neutrality of the revised food packages, because it reflects current regulations.
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Accordingly, the phased-in cost differences between the current food packages and proposed revised food packages are 33.3 percent of the unadjusted cost differences for FY2018 (6 months) and FY2019 (12 months)
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From page 873... ...
In implementing the proposed revisions, it may be decided to consolidate the two food packages and align the naming structure across the infant food packages (i.e., I-BF/FF-A for infants ages 0 to less than 4 months, I-BF/FF-B for infants ages 4 to less than 6 months)
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breastfeeding women,b up to 1-year postpartum V-A V-A Revised Pregnant women
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breastfeeding women,e up to 6-months postpartum VII VII Current, revised Fully breastfeeding women, up to 1-year postpartum N/A N/A Current, revised Partially (minimally) breastfeeding women, more than 6-months postpartume a Despite revised food packages I-BF/FF-A and I-BF/FF-B having the same maximum ("up to")
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From page 876... ...
This projected partici pant shift includes women more than 6-months postpartum. ACTION Nature This RIA was conducted by the Committee to Review WIC Food Packages as part of a National Academies of Sciences, Engineering, and Medicine (the National Academies)
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From page 877... ...
DGA.4 To accomplish this, USDA-FNS asked the National Academies to recommend revisions to the food packages to align with current research and dietary guidance, be culturally suitable to the increasingly diverse WIC population, be relatively cost-neutral compared to current food packages, be efficient for nationwide distribution, and be nonburdensome to state and local agencies that administer the program. Affected Parties The proposed changes to the food packages affect a broad range of individuals and entities associated with the WIC program, including, but not limited to, USDA-FNS; the 90 agencies that administer WIC and their associated staff; authorized vendors; food producers, manufacturers, and distributors; and program participants.
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From page 878... ...
A decade has passed since the first set of recommended changes to the WIC food packages. In that time, the WIC population has changed in
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From page 879... ...
The food package revisions recommended in this report reflect the consensus of an expert committee. Compared to the current food packages, the proposed revisions do the following: • Provide supplemental quantities of foods across food packages.
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From page 880... ...
To support the DGA's recommendation to increase seafood intake, the revised food packages include fish in all children's and women's food packages. Furthermore, DGA analyses also indicate that while most age groups' consumption of total grains is within the recom mended intake ranges, average refined grain consumptions exceeds 5 One of the challenges the committee faced in developing revised food packages that provided supplemental quantities of foods was the standard container sizes of products currently available on the market.
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The pro posed revisions to the food packages are intended to encourage breastfeeding. Revised food packages V-B and VII are enhanced to support and incentivize both partial (mostly)
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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.
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• Similar to food package I, across all infant food packages, the max imum formula quantities should be considered "up to" amounts. All formula prescribed to infants should be tailored to the indi vidual needs of the infant.
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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.
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• Redemption of jarred infant food meat is particularly low; pub lished 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.
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From page 886... ...
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.
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. Rationale and benefit • Milk in the current food packages provides what the committee considered a greater than supplemental amount of dairy (e.g.,
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• 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)
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• 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 maxi mum of 24 ounces in the revised food package. This slight reduc tion helps to offset the cost of offering the range of bread sizes across food packages.
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From page 890... ...
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 prefer ences.
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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.
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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.
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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 bet ter 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)
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From page 894... ...
• 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 prefer ences. 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.
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From page 895... ...
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]
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• 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)
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. Proposed revision Align milk prescription across women's food packages; specify substitution options.
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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.
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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.
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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.
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. Therefore, the recommendation is not expected to cause a significant disruption in administration of food packages nationally.
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The soy-based options in the food packages serve as milk substitutions. As such, the revised specifica tion 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.
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• 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.
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, including 4 gluten-free whole grain varieties. • The previous committee to review WIC food packages (IOM, 2006)
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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. Phased-in Cost Differences Table U-4 presents the phased-in cost differences between the current and revised food packages, from FY2018 through FY2022.
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food benefit. security for women who Breastfed infants can be food packages is expected Management Information may try to breastfeed in prescribed up to 364 fl oz to largely offset additional Systems will need to be the immediate postpartum of infant formula during costs of the infant updated.
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From page 907... ...
It is package, the amount month costs elsewhere in the cereal containers; not anticipated to affect provided is more food packages. some state agencies stocking requirements.
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may result in slight intended to provide fully recipients are prescribed and fruit issuance to Management Information reductions in jarred infant breastfed infants with a 256 oz of jarred infant fully breastfed infants, Systems will need to be food vegetable and fruit supplemental quantity food vegetables and fruits the option for CVV updated, but overall it sales to WIC participants, of infant food vegetables per month. All other substitution is expected will improve Management but it may increase fresh, and fruits, in the absence food package II recipients to lead to an increase Information Systems frozen, and/or canned of definitive guidance on receive 128 oz of jarred in redemption, thereby efficiency by authorizing vegetables and fruits recommended intake.
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Ten canned fish is currently greater flexibility in this oz of canned fish can less expensive per oz than food category. be substituted for 4 jars jarred infant food meat, (10 oz)
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From page 910... ...
their nutrition needs, as determined by the participant's health care professional. Proposed revision: Participants with a qualifying condition in which a WIC formula is not medically necessary are still eligible to receive appropriate supplementary foods through food package III.
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From page 911... ...
package VI) of juice from the food packages also Proposed revision: allowed for larger CVVs Children, pregnant across all food packages women, partially (mostly)
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From page 912... ...
milk can be substituted Systems will need to be may be purchased by for 1 lb of cheese, with updated. WIC participants under the maximum amount the revised substitution of cheese being 1 lb options, as 1 and 2 qt for food packages IV, substitution options are V, and VI and 2 lb for allowed.
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From page 913... ...
No more than a total of 6 qt of milk may be substituted for a combination of cheese, yogurt, or tofu for women in food package VII. Proposed revision: Food package IV-A recipients are prescribed 12 qt of milk per month.
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From page 914... ...
Current rule: The proposed revisions The expanded list of The range of whole WIC participants will Food packages V and VII are expected to decrease whole grain options that wheat bread sizes may benefit by allowing whole recipients are prescribed food package costs. The states can authorize are lead to the elimination wheat breads that are 1 lb of whole wheat expanded list of whole intended to better meet of the 16 oz bread size readily available in the
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From page 915... ...
WIC staff, vendors, and WIC-eligible breads and participants will need to grains. Proposed revision: be trained on new sizes Food packages IV, V, and options.
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From page 916... ...
to identify authorized The burden is expected canned fish products. Proposed revision: to be relatively minor, as Food packages IV, V-A, all food packages would and VI recipients are be authorized the same prescribed 10 oz of fish canned fish.
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Current rule: Reduction of the amount States and local agencies Sales of legumes and This change brings Food packages IV and VI of legumes and peanut will need to educate peanut butter to WIC children's and women's recipients have the option butter prescribed in food participants about the participants using their food packages in better of being prescribed 1 lb packages IV through legume and peanut butter food instrument will alignment with the dried legumes (or 64 oz VII will result in a cost rotation patterns for decrease. Market effect is concept of supplemental of canned legumes)
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From page 918... ...
slightly increase for a dollar amount allows The monthly CVVs for Management Information vendors that meet the participants flexibility and food packages IV, V-A, Systems will need to current federal minimum choice to meet cultural V-B, VI, and VII are $12, be updated. States and stocking requirement for needs and personal $15, $25, $15, and $35, local agencies will need vegetables.
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indicate that the revised food packages result in cost savings as compared to the current food packages. Positive values (+)
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All other state agencies are assumed to implement the proposed revisions as of FY2020. a Cost differences were calculated by subtracting the estimated food costs for the current food packages from the estimated food costs for the revised food packages.
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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.
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The estimated phased-in total food costs reflect assumptions about redemption, substitutions, prices, and program participation. c Cost differences were calculated by subtracting the estimated phased-in food costs for the current food packages from the estimated food costs for the revised food packages.
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The major total cost differences not only reflect the specific revisions to the items and the quantity prescribed, but also the distribution of participants across the different food packages. Food packages that represent a smaller proportion of WIC participants generally have fewer major cost differences.
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From page 924... ...
indicate that the revised food packages result in cost increases compared to the current food packages. b This analysis assumes the incentives in the proposed revisions will result in a 5 percent shift of fully formula-fed mother–infant dyads to the partially (mostly)
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Cost differences include assumptions about substitutions and selection of allowable options within each category. b Cost differences were calculated by subtracting the estimated phased-in food cost for each item in the current food packages from the estimated food costs of the corresponding item in the revised food packages.
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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)
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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 dur ing the month of April of the assessment year, regardless of whether the food benefits were claimed.
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while most did not report a food package. 12 This statement specifically pertains to Table C.1 in the Food Package Report, "Food Packages Assigned by Participant Category (2014)
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To account for this in the RIA, the follow ing 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.
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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.
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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
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From page 932... ...
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)
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From page 933... ...
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)
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From page 934... ...
breastfed II-BF/FF 105,953 107,224 107,331 107,439 107,546 Fully formula-fed II-FF 694,815 703,153 703,856 704,560 705,264 Subtotal 912,606 923,558 924,481 925,406 926,331 Participants with qualifying conditions Infants Alla 184,436 186,649 186,836 187,023 187,210
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Bureau of Labor Statistics, and projections were based on projected unemployment from the Federal Reserve. a Food package III recipients are prescribed food packages appropriate for their age and physiological state.
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From page 936... ...
breastfed II-BF/FF 105,953 107,224 107,331 142,667 142,809 Fully formula-fed II-FF 694,815 703,153 703,856 669,332 670,001 Subtotal 912,606 923,558 924,481 925,406 926,331 Participants with qualifying conditions Infants Allb 184,436 186,649 186,836 187,023 187,210 Children Allb 62,184 62,930 62,993 63,056 63,119 Women Allb 1,197 1,211 1,213 1,214 1,215 Subtotal 247,817 250,791 251,042 251,293 251,544
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From page 937... ...
breastfeeding categories includes women who are more than 6-months postpartum. Accordingly, 5 percent of women who did not qualify for a food package under the current food packages are anticipated to qualify for food package V-B under the proposed revisions.
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From page 938... ...
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.
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From page 939... ...
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.
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From page 940... ...
FF-B, I-BF/FF-C, FF-B, I-BF/FF-C, I-FF-A, I-FF-B, I-FF-A, I-FF-B, II-BF/FF, II-FF II-BF/FF, II-FF Infant cereal 47f II-BF, II-BF/FF, 57g,h II-BF, II-BF/FF, Increased because the amount prescribed is reduced II-FF II-FF and the amount provided in the current food packages exceeded recommended amounts.
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From page 941... ...
59j VI Used the implied redemption rated and increased it by 3 percentage points because of the additional yogurt 68j VII substitution option. Whole grains 53a IV-A, IV-B, V, 60 IV-A, IV-B, V-A, Increased because of the increased options and allowable VII V-B, VII size range; redemption set to redemption of breakfast cereal in the current food packages.
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From page 942... ...
d The committee used the redemption rates in the current food packages and the distribution of redemption shares (full, partial, nonredeemers) provided in a 2014 report from Altarum to calculate an implied redemption rate under the proposed revisions.
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APPENDIX U 943 TABLE U-12 Estimated Average Amount Redeemed for Each Food Package Item Food Package Type, Current Food Packages Estimated Monthly Average Food Package Maximum Amount Type Foods Package Item Unit Allowance Redeemeda Food package I: Infants, 0 to less than 6 months I-BF-A Infant formula Prepared fl oz 0 0 I-BF-B Infant formula Prepared fl oz 0 0 I-BF/FF-A Infant formula Prepared fl oz 104b 98 I-BF/FF-B Infant formula Prepared fl oz 424b 399 I-BF/FF-C Infant formula Prepared fl oz 510b 479 I -FF-A Infant formula Prepared fl oz 861b 809 I -FF-B Infant formula Prepared fl oz 948b 891 Food package II: Infants, 6 to less than 12 months II-BF Infant cereal Ounces 24 11 Jarred infant food vegetables Ounces 256 131 and fruits Jarred infant food meat Ounces 77.5 24 II-BF/FF Infant formula Prepared fl oz 371b 349 Infant cereal Ounces 24 11 Jarred infant food vegetables Ounces 128 66 and fruits II-FF Infant formula Prepared fl oz 683b 642 Infant cereal Ounces 24 11 Jarred infant food vegetables Ounces 128 66 and fruits Food package III: Participants with qualifying conditions IIIc Food package IV: Children, 1 to up to 5 years IV-A Cash value voucher Voucher ($) 8 6 Juice Ounces 128 90 Milk, whole Quarts 16 12 Breakfast cereal Ounces 36 22 Whole wheat bread 16 oz 2 1 Legumes or peanut butterd 16 oz/18 oze 1 0.5 Eggs Dozen 1 0.8 continued
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From page 944... ...
breastfeeding women, up to 6-months postpartum VI Cash value voucher Voucher ($) 11 9 Juice Ounces 96 67 Milk, reduced-fat Quarts 16 9 Breakfast cereal Ounces 36 22 Legumes or peanut butterd 16 oz/18 oze 1 0.5 Eggs Dozen 1 0.8 Food package VII: Fully breastfeeding women, up to 1-year postpartum VII Cash value voucher Voucher ($)
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From page 945... ...
The 94-percent redemption rate was then applied to those quantities and used in cost estimates. Because the quantity of infant formula did not change in the revised food package, this assumption is not expected to affect the estimated cost difference between the food packages.
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From page 946... ...
946 REVIEW OF WIC FOOD PACKAGES TABLE U-13 Projected Average Amount Redeemed for Each Food Package Item Under the Proposed Revisions, by Food Package Type Projected Monthly Average Food Package Maximum Amount Type Foods Package Item Unit Allowance Redeemeda Food package I: Infants, 0 to less than 6 months I-BF-A Infant formula Prepared fl oz 0 0 I-BF-B Infant formula Prepared fl oz 0 0 I-BF/FF-A Infant formula Prepared fl oz 104b,c 98 I-BF/FF-B Infant formula Prepared fl oz 424b 399 I-BF/FF-C Infant formula Prepared fl oz 510b 479 I -FF-A Infant formula Prepared fl oz 861b 809 I -FF-B Infant formula Prepared fl oz 948b 891 Food package II: Infants, 6 to less than 12 months II-BF Infant cereal Ounces 16 9 Jarred infant food vegetables Ounces 128 83 and fruits Jarred infant food meat Ounces 40 17 II-BF/FF Infant formula Prepared fl oz 371b 349 Infant cereal Ounces 8 5 Jarred infant food vegetables Ounces 128 83 and fruits II-FF Infant formula Prepared fl oz 683b 642 Infant cereal Ounces 8 5 Jarred infant food vegetables Ounces 128 83 and fruits Food package III: Participants with qualifying conditions IIId Food package IV: Children, 1 to up to 5 years IV-A Cash value voucher Voucher ($) 12 9 Juice Ounces 64 50 Milk, whole Quarts 12 10 Breakfast cereal Ounces 36 20 Whole wheat bread 24 ozf 1 0.6 Legumes and peanut butter 16 oz/18 oze 0.7g 0.4 Eggs Dozen 1 0.8 Canned fish Ounces 3.3h 2.3
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From page 947... ...
25 19 Juice Ounces 64 51 Milk, reduced-fat Quarts 13 11 Breakfast cereal Ounces 36 20 Whole wheat bread 24 ozf 1 0.6 Legumes and peanut butter 16 oz/18 oze 1i 0.5 Eggs Dozen 1 0.8 Canned fish Ounces 10 7 Food package VI: Nonbreastfeeding postpartum women and partially (minimally) breastfeeding women, up to 6-months postpartum VI Cash value voucher Voucher ($)
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From page 948... ...
Accord ingly, the committee assumed the redemption estimates in the current food packages and corresponding redemption projections applied to all participants categorically eligible to be prescribed the food item (i.e., a child prescribed food package III was assumed to be prescribed all of food package IV foods)
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From page 949... ...
Because the quantity of infant formula did not change in the revised food package, this assumption is not expected to affect the estimated cost difference between the food packages. e The 16 oz corresponds to the size of the dried legumes.
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From page 950... ...
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.
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From page 951... ...
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, indicat ing a single price for fluid milk could not be used for this analysis.
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From page 952... ...
a or 0.186 0.314 0.500 Legumes and peanut butter are 18 oz peanut butter both provided, so are equally weighted; canned beans account for 37.2% of legume purchases while dried legumes account for 62.8%b Revised IV-A and 1 lb legumes (64 oz canned) 0.211 0.289 0.500 Legumes and peanut butter are IV-B and 18 oz peanut butter both provided in a 3-month cycle, prescribed over the course of 3 so are equally weighted; canned monthsc beans were assumed to account for 42.2% of legume purchases while dried legumes account for 57.8%d
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From page 953... ...
It was therefore assumed that the ratio reflected the current state of authorized options for legumes. c Under the proposed revisions, legumes, peanut butter, and canned fish are each prescribed once in a 3-month rotation.
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From page 954... ...
For the revised food packages, the committee weighted the maxi mum cheese and yogurt substitution options. Table U-15 summa rizes the weighting scheme used to calculate composite prices for the milk food package item category.
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From page 955... ...
Food package VII recipients can also substitute 2 lb of cheese for 6 qt of milk. Substitution schemes for revised food packages average the substitution options unless otherwise noted.
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From page 956... ...
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.
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From page 957... ...
b,f 1.00369c 2.650 24 oz Eggs 1.15757 2.169 Dozen Fish, cannedb,g 1.01228 0.202 Ounce Calculated Food Package Composites Infant formulah 0.066 Prepared fl oz, postrebate Infant food, meat (revised) i 0.353 Ounce Legumes and peanut butterj Food packages IV-A, IV-B, V, VI 2.370 Per one allotmentk and VII (current)
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From page 958... ...
d In the current food packages, cheese is prescribed to food package VII recipients as a sepa rate item. In both the current and revised food packages, cheese is offered as a substitution option for milk.
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From page 959... ...
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.
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From page 960... ...
Table U-19 presents the effect of the CPI projections on the CVVs for the current and revised food packages. UNCERTAINTIES The estimated costs of the current food packages and proposed revised food packages are sensitive to key assumptions made in the preceding sections.
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From page 961... ...
g Initial values of the CVV prescribed when substituted for all jarred infant food vegetables and fruits under the proposed revisions. h Initial values of the CVV prescribed to food packages V-B under the proposed revisions.
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From page 962... ...
The proposed revisions allow for a CVV to be a substitution options for juice and jarred infant food vegetables and fruits. Given the CVV's increased prominence in the revised food packages, it is paramount to evaluate different aspects of the assumptions underlying the primary cost analysis.
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From page 963... ...
indicate that the assumption scenario costs more than the current food packages. c Describes the increases or savings of the base assumption as compared to the uncertainty scenario.
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From page 964... ...
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. Another CPI inflation scenario assumption is the baseline year to which all subsequent years are compared in the revised food packages.
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From page 965... ...
of additional savings, as compared to the base assumption of no substitution in the revised food packages. Under the proposed revisions, a $3 CVV can be substituted for the 64 ounces of juice prescribed in children's and women's food packages.
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From page 966... ...
966 TABLE U-21 Projected Phased-in Cost Difference of WIC Food Package Revisions, Assuming Different Consumer Price Index Inflation Rates Used to Inflate the Revised CVV Relative Change in CPI Used to Inflate Revised Phased-in Cost Differences of the Revised Food Packages CVV Assumptions, Inflation Ratea Compared to Current Food Packages ($, millions) b Total Difference, FY2018 Through Scenario FY2018 FY2019 FY2020 FY2021 FY2022 FY2018 FY2019 FY2020 FY2021 FY2022 FY2022 Base assumptionc 1.015 1.015 1.015 1.015 1.015 −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 1c 1.050 1.015 1.015 1.015 1.015 −6.4 −14.8 −64.7 −82.0 −86.6 −254.5 Cost difference of base 0.0 0.0 +17.0 +17.1 0.0 +34.1 assumption as compared to uncertainty scenario 1d Base assumptionc 1.015 1.015 1.015 1.015 1.015 −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 2c 1.015 1.050 1.050 1.050 1.050 −6.4 −13.6 −45.8 −62.3 −49.8 −177.9 Cost difference of base 0.0 −1.2 −1.9 −2.7 −36.8 −42.6 assumption as compared to uncertainty scenario 2d Base assumptionc 1.015 1.015 1.015 1.015 1.015 −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 3c 1.050 1.050 1.050 1.050 1.050 −6.4 −19.3 −45.8 −62.3 −66.8 −200.6 Cost difference of base 0.0 4.5 −1.9 −2.7 −19.7 −19.8 assumption as compared to uncertainty scenario 3d
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From page 967... ...
c Describes the increases or savings of the base assumption or uncertainty scenario ("assumption scenario") as compared to the current food packages.
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From page 968... ...
968 TABLE U-22 Projected Phased-in Cost Difference of WIC Food Package Revisions, Changing the Base Comparison Year for CVV Inflation Phased-in Cost Differences of the Revised Food Packages Compared to Current Food Packages ($, millions) a Base Year for CVV Total Cost Difference, Inflation in the Revised FY2018 Through Scenario Food Packages FY2018 FY2019 FY2020 FY2021 FY2022 FY2022 Base assumptionb FY2018 −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 1b FY2015 −5.8 −13.6 −31.1 −8.6 −32.4 −91.6 Cost difference of base −0.6 −1.2 −16.6 −56.4 −54.1 −128.8 assumption as compared to uncertainty scenario 1c Base assumptionb FY2018 −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 2b FY2016 −6.4 −14.0 −46.5 −62.6 −72.3 −201.8 Cost difference of base 0.0 −0.8 −1.2 −2.3 −14.3 −18.6 assumption as compared to uncertainty scenario 2c
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From page 969... ...
indicate that the assumption scenario costs more than the current food packages. c Describes the increases or savings of the base assumption as compared to the uncertainty scenario.
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From page 970... ...
−6.2 −14.7 −48.4 −66.8 −89.4 −225.6 Cost difference of base −0.2 −0.1 +0.7 +1.8 +2.9 +5.1 assumption as compared to uncertainty scenario 1d Base assumptionc 0 −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 2c 100 (partial) −6.0 −14.7 −49.1 −68.6 −92.3 −230.7 Cost difference of base −0.4 −0.1 +1.4 +3.6 +5.8e +10.3e assumption as compared to uncertainty scenario 2d Base assumptionc 0 −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 3c 50 (full)
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From page 971... ...
−6.1 −14.7 −48.8 −67.7 −88.6 −225.8 Cost difference of base −0.3 −0.1 +1.1 +2.7 +2.0 +5.4 assumption as compared to uncertainty scenario 5d NOTES: This table shows the phased-in cost difference between the revised and current food packages, along with the cost differences of different assumptions regarding jarred infant food vegetables and fruits substitution for CVV. All other assumptions in the primary analysis remain constant.
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From page 972... ...
indicate that the assumption scenario costs more than the current food packages. d Describes the increases or savings of the base assumption as compared to the uncertainty scenario.
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From page 973... ...
In Scenario 1, prescribing all infants in food package I-BF/FF-A the maximum "up to" amount of infant formula would result in approximately $20 million in additional costs in the revised food packages, over the course of FY2018 through FY2022, as compared to the base assumption used in the primary analysis. The revised food packages would still be projected to cost approximately $201 million less than the current food packages, over the course of FY2018 through FY2022.
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From page 974... ...
974 TABLE U-25 Projected Phased-in Cost Difference of WIC Food Package Revisions, Changing the Maximum Amount of Formula in Food Packages I and II Phased-in Cost Differences of the Revised Food Packages Compared to Current Rule ($, millions) a Total Cost Difference, Maximum Formula FY2018 Through Scenario Assumption, Amount Change FY2018 FY2019 FY2020 FY2021 FY2022 FY2022 Base assumptionc Identical to Current Food −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Packageb Uncertainty scenario 1c All I-BF/FF-A recipients −5.6 −13.1 −42.6 −58.8 −80.3 −200.5 prescribed maximum "up to" amount Cost difference of base −0.8 −1.6 −5.1 −6.1 −6.3 −19.9 assumption as compared to uncertainty scenario 1d Base assumptionc Identical to Current Food −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Packageb Uncertainty scenario 2c 95% of maximum "up to" −13.0 −28.5 −89.6 −105.9 −128.5 −365.5 amounts Cost difference of base +6.6 +13.7 +41.9 +41.0 +41.9 +145.1 assumption as compared to uncertainty scenario 2d
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From page 975... ...
indicate that the assumption scenario costs more than the current food packages. d Describes the increases or savings of the base assumption as compared to the uncertainty scenario.
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From page 976... ...
b Assumption, Percent of Fully Formula-Fed Total Cost Difference, Scenario Projected to Shifta FY2018 FY2019 FY2020 FY2021 FY2022 FY2018 Through FY2022 Base assumptionc 5 −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 1c 0 −6.4 −14.8 −47.7 −52.8 −74.0 −195.7 Cost difference of base 0.0 0.0 0.0 −12.1 −12.5 −24.7 assumption as compared to uncertainty scenario 1d Base assumptionc 5 −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 2c 3 −6.4 −14.8 −47.7 −60.1 −81.5 −210.6 Cost difference of base 0.0 0.0 0.0 −4.9 −5.0 −9.9 assumption as compared to uncertainty scenario 2d Base assumptionc 5 −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 3c 8 −6.4 −14.8 −47.7 −72.2 −94.1 −235.2 Cost difference of base 0.0 0.0 0.0 +7.3 +7.5 +14.8 assumption as compared to uncertainty scenario 3d
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From page 977... ...
c Describes the increases or savings of the base assumption or uncertainty scenario ("assumption scenario") as compared to the current food packages.
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From page 978... ...
Some of these alternatives and the committee's rationale for not including them in the revised food packages are outlined in the sections that follow. As with the uncertainty scenarios, the "primary analysis" refers to the set of base assumptions that led to a total phased-in cost savings of $220 million for the revised food packages as compared to the current food packages, over the course of FY2018 through FY2022.
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From page 979... ...
Table U-29 shows the cost implications of maintaining the current whole wheat bread regulations as they exist in the current food packages. This alternative would cost an estimated $154 million more than the base assumptions for the revised food packages.
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From page 980... ...
b Milk Redemption Assumption, Total Cost Difference, Percent Point FY2018 Through Scenario Changea FY2018 FY2019 FY2020 FY2021 FY2022 FY2022 Base assumptionc d −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 1c +5 +4.3 +7.4 +20.4 +4.80 −15.1 +21.8 Cost difference of base assumption as −10.7 −22.2 −68.1 −69.8 −71.5 −242.2 compared to uncertainty scenario 1e Base assumptionc d −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 2c −5 −17.2 −37.0 −115.8 −134.7 −158.0 −462.7 Cost difference of base assumption as +10.7 +22.2 +68.1 +69.8 +71.4 +242.2 compared to uncertainty scenario 2e Base assumptionc d −6.4 −14.8 −47.7 −65.0 −86.6 −220.4 Uncertainty scenario 3c −10 −27.9 −59.2 −183.9 −204.5 −229.4 −704.9 Cost difference of base assumption as +21.5 +44.4 +136.2 +139.5 +142.9 +484.5 compared to uncertainty scenario 3e
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From page 981... ...
indicate that the assumption scenario costs more than the current food packages. d Base assumptions for the redemption rates of milk under the proposed revisions are as follows: IV-A (87.00 percent)
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From page 982... ...
indicate that the base assumption or alternative costs less than the current food packages. Positive values (+)
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From page 983... ...
per month Cost difference of base −6.8 −14.2 −43.4 −44.3 −45.3 −153.9 assumption as compared to alternativec NOTES: This table shows the phased-in cost difference between the revised and current food packages, along with the cost differences of alternative quantities of whole wheat bread prescribed to participants receiving food packages IV-A, IV-B, V-A, V-B and VII. All other assumptions in the primary analysis remain constant.
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From page 984... ...
NOTES: The food package item categories encompass substitutions and allowable options. Estimates for the revised food packages include the 5 percent participant shift from the fully formula-fed mother–infant dyads to partially (mostly)
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From page 985... ...
Based on the assumptions in the primary analysis, the committee estimated the total value of WIC sales for each food item using the quantities in the current and revised food packages for FY2015.21 Figure U-1 shows the estimated sales for each category prescribed in the current food packages 21 To reflect current regulations, women's CVV in this portion of the analysis is $11 for the current food package. The committee acknowledges that this inflation-based increase in CVV was not effective until FY2016.
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From page 986... ...
In the interim rule, sales of milk were estimated to be 4.4 percent of the retail milk market, and cheese sales were estimated to be 2 percent of the retail cheese market. While it is difficult to accurately gauge how sales of any individual product within that composite will be affected, data for the dairy products examined in the Interim Rule suggest that effects of the TABLE U-30 Estimated Percent of the Market Attributed to WIC Sales, as Presented in the Interim Rule Regulatory Impact Analysis Estimated WIC Percent of the Market of the Interim Rule Food Packages Calendar Year 2005 WIC Food Item Assuming No Substitutions Assuming Full Substitution Formula 65.5 56.3 Beans 8.9 9.5 Peanut butter 4.8 4.8 Milk 4.5 4.4 Adult cereal 4.1 4.1 Juice 2.0 2.0 Vegetables and fruits 2.7 2.7 Eggs 2.3 2.3 Cheese 2.0 2.0 Bread 0.5 0.6 Canned fish 0.6 0.6 SOURCE: 7 C.F.R.
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From page 987... ...
2006. WIC food packages: Time for a change.
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From page 988... ...
: Revisions in the WIC food packages; additional data for RIA. http://www.
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Key Terms
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