Comment on FR Doc # 2013-05496

Document ID: FNS-2013-0014-0014
Document Type: Public Submission
Agency: Food And Nutrition Service
Received Date: May 07 2013, at 12:00 AM Eastern Daylight Time
Date Posted: May 8 2013, at 12:00 AM Eastern Standard Time
Comment Start Date: March 8 2013, at 12:00 AM Eastern Standard Time
Comment Due Date: May 7 2013, at 11:59 PM Eastern Standard Time
Tracking Number: 1jx-8575-kazl
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1. The information being requested from local agencies, while of interest, does not provide a full picture of WIC breastfeeding (BF) support, since it focuses only on those agencies/clinics that provide breastfeeding peer counseling (BFPC). A focus solely on agencies with BFPC gives only a partial view of the effective and comprehensive WIC breastfeeding support provided by CPAs and IBCLCs within WIC agencies. To truly assess BF effectiveness, all components of WIC BF support efforts must be considered and included in determining recognition for BF efforts. 2. The burden of the proposed collection of information is greater than indicated to identify and acknowledge agencies providing exceptional BF support. There would need to be a short and streamlined application or form for local agencies to use, and clear and easy to implement evaluation guidelines for the state offices. For Oregon alone, the estimate of 6.74 applications underestimates by at least 50% the number of the agencies that would apply and need to be evaluated. 3. As indicated above, an easy to complete, short application format with clear evaluation criteria, preferably on-line, would enhance the quality, utility and clarity of information collected. 4. We encourage FNS to explore ways to streamline the application process and the information collected, otherwise only the most “successful” and highly motivated agencies will send in their information and we won’t be able to identify those agencies that are improving and might benefit from this recognition to move their BF support efforts to the next level.

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