This public comment letter addresses the proposed rule for modernizing the ways families can access food through the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC). The proposed rule would allow online ordering and internet-based transactions and would support future innovations, such as allowing families to house WIC benefits in their mobile wallets. The public comment letter draws on insights from prior Urban research related to applying principles of equity and inclusion and the implementation of potential future technologies for SNAP.

We recommend that the same equity and inclusion principles we have identified for SNAP apply to WIC. In the previous work on SNAP, we define an overarching equity principle that beneficiaries should have access to the same customer experience as consumers using other forms of payment and an overarching inclusion principle that all beneficiaries should be able to access food without stigma, regardless of where they live. We argue that for any new technology to be adopted, policymakers and regulators would need to develop guidelines that maintain equitable and inclusive access to SNAP and WIC benefits.

In addition, we strongly encourage the Food and Nutrition Service (FNS) to directly engage a diverse group of WIC participants in decisionmaking about modernizing benefit delivery and designing new technology. No program modifications should be advanced without significant client input.