-

USDA

Food and
Nutrition
Service
Park Office
Center
3101 Park
Center Drive
Alexandria
VA 22302

United States Department of Agriculture

JUN 08 2016
Ms. Bethany Hamm
SNAP Director
Maine Department of Health and Families
Office of Family Independence
19 Union Street
# 11 State House Station
Augusta, Maine 04333-0011
Dear Ms. Hamm:
Thank you for your March 9, 2016, response to the Food and Nutrition Service (FNS)
questions about Maine's sugar-sweetened beverage/candy demonstration waiver request.
We appreciate the detailed and specific responses to our questions. However, we
continue to have significant concerns relative to the evaluation.
While Maine has proposed a thorough process evaluation to document how the restriction
was implemented by both the State and retailers, the proposed impact evaluation is not
adequate to provide sufficient assurance of credible, meaningful results with respect to
the consumption of sweetened beverages or candy or the impacts on obesity or other
weight-related diseases. There are several key issues with the evaluation:
•

Since the restriction would be implemented statewide, the study design does not have
a counterfactual to show what would have happened in the absence of the restriction.

•

There is no pre- and post-implementation data collection to compare SNAP
household purchases before and during the demonstration. The data will be collected
through retrospective surveys at one month and six months after implementation
asking participants if their food purchases changed during the demonstration.

•

The impact evaluation relies on SNAP participants accurately reporting, in retrospect,
how their purchases of sweetened beverage and candy have changed during the
demonstration. Self-reported data is subject to bias as respondents may not remember
their purchases six months ago or may be influenced by the statewide restriction and
accompanying messaging.

It is possible that some of these concerns could be addressed by obtaining retailer data
from a significant portion of SNAP-authorized stores to analyze item-level purchases to
determine if households use cash or other tender to purchase sweetened beverages and
candy when making a SNAP EBT purchase.

An Equal Opportunity Provider and Employer

 Ms. Bethany Hamm
Page 2
This would also require obtaining item-level purchase data for SNAP households when
an EBT card is not used in the transaction. Maine doubted that small retailers would be
able to provide this data, but was hopeful that large chains will cooperate and provide this
data. However, the waiver request does not indicate that Maine has agreement from any
retailers, or has even begun conversations with retailers about obtaining this data. The
absence of retailer data in the evaluation plan significantly limits the feasibility of
determining the impact of the restriction on consumption patterns or health outcomes for
SNAP participants in Maine.
Should you have clarifying details or more information relative to these key evaluation
issues, please do not hesitate to contact me.
We would note again that FNS appreciates Maine's desire to address proactively obesity.
There is no question that the obesity epidemic in America, especially among our children,
is a national health crisis, with obesity estimated to cost almost $150 billion in direct
medical costs. The Administration has recognized and responded to this crisis with
unprecedented action. The President's Task Force on Childhood Obesity developed a
comprehensive set of recommendations, including improved access to healthy and
affordable food, significant changes to the school meals and the school nutrition
environment, and increased opportunities for physical activity. The Healthy, HungerFree Kids Act of 2010 put the Nation on the right path, for the first time in decades, to
make real improvements to food served at school and child care settings. USDA has
increased the opportunities for SNAP participants to make healthy purchases at farmers'
markets, launched Food Insecurity Nutrition Incentive grants to increase the purchase
healthy foods, and restructured SNAP nutrition education to focus more tightly on
evidence-based and outcome driven strategies that prevent obesity.
We also appreciate your interest in pursuing innovative approaches to promote healthful
diets and healthy weight. Given the challenges in developing a comprehensive and
robust evaluation, we might suggest that Maine consider alternatives such as restrictions,
limits, or disincentives on purchases on a demonstration basis that can be applied
equitably to SNAP participants and other consumers.

 Ms. Bethany Hamm
Page 3
In addition to these evaluation challenges, we must also note that, given the many other
challenges Maine currently faces, including the advanced warning due to chronic
timeliness problems, media reports indicating that the State is dealing with a backlog of
claims for State-caused errors totaling approximately $2 million, staffing issues and other
general Program issues, at this time, FNS would need to take these into consideration
before agreeing to move forward with such a demanding demonstration project.
We stand ready to further discuss all these items you consider next steps.
Sincerely,

                   

   

Director
Retailer Policy and Management Division