NYHealth Responds to USDA Request for Information

April 9, 2026

Ms. Nisha Murray
Economic Research Service
1400 Independence Avenue SW
Mail Stop 1800, Washington, DC 20250-1800

RE: Request for Information on Opportunities, Challenges, and Emerging Areas in Statistical Data, Analysis, and Research at the U.S. Department of Agriculture (ERS-2026-0001)

Dear Ms. Murray,

The New York Health Foundation (NYHealth) appreciates the opportunity to comment on the United States Department of Agriculture's (USDA) Request for Information on Opportunities, Challenges, and Emerging Areas in Statistical Data, Analysis, and Research.

NYHealth is a private, independent foundation that works to improve the health of all New Yorkers. Our Healthy Food, Healthy Lives program seeks to advance policies and programs that connect New Yorkers with the food they need to thrive, with the goal of improving food security across the State. Core strategies of our work include maximizing participation in federal nutrition programs like the Supplemental Nutrition Assistance Program (SNAP) and the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC) and increasing access to healthy and high-quality food in public institutions like schools.

Despite critical efforts, USDA data show that food insecurity has increased across the United States (U.S.), rising from 11.2% of households in 2020-2022 to 13.3% in 2022 -2024.[1] While federal nutrition programs-including expanded SNAP emergency benefits, the Child Tax Credit, and free school meals-helped drive meaningful reductions in food insecurity during the COVID-19 pandemic, these gains were temporary. As these programs expired, food insecurity rates increased steadily nationwide, surpassing early pandemic levels by 2024.[2] In New York, rates exceed the national average: 14% of households experienced food insecurity in 2022-2024, up from 10.8% prior to the COVID-19 pandemic.

Our grantmaking and research have given us deep knowledge of the federal data infrastructure needed to identify solutions and assess progress. Effective program development, resource

Our comments below respond to Questions 1-7 in the USDA Request for Information regarding Economic Research Service (ERS), National Agricultural Statistics Service (NASS), and Office of the Chief Economist statistical and research products.[3]

Response to Question 1: Which NASS or ERS data are most valuable to your work, and why?

The Food Security Supplement to the Current Population Survey (CPS-FSS) is one of the most valuable federal datasets for understanding food security and evaluating nutrition policy in the United States (U.S.).[4]

The Household Food Security Survey Module was developed through extensive research and validation by USDA researchers and collaborators. The module is widely recognized as the gold standard for measuring food insecurity in the U.S.[5]

Because the CPS-FSS includes large annual samples, it enables robust national and state-level estimates that are not possible with other datasets. Specifically, it offers a combination of methodological strengths that no other federal dataset replicates[6] :

• Thirty years of continuous time series data, enabling long-term trend analysis.
• Large, nationally representative sample size, allowing statistically reliable national and state-level estimates.
• State-level identifiers, enabling geographic analysis and policy evaluation.
• The full 18-item Household Food Security Survey Module measures the full severity spectrum of food insecurity among both adults and children.
• Detailed contextual variables, including food expenditures, minimum necessary food spending, and participation in public benefit programs like SNAP and WIC.

Response to Question 2: What gaps exist in the agricultural data produced?

Discontinuing the well-established CPS Food Security Supplement would create a significant gap in the federal government's ability to monitor food insecurity, and no existing federal dataset can fully replace the CPS-FSS for comprehensive national monitoring. While some federal surveys collect limited information on food security, the CPS-FSS remains a uniquely comprehensive data source.

USDA itself acknowledged this limitation in its most recent Information Collection Request approved by the Office of Management and Budget, noting that other surveys "do not provide suitable data for timely and reliable monitoring of the prevalence and severity of food insecurity in the Nation's households and in critical subpopulations."[7]

Response to Question 3: What new topic areas should USDA prioritize for data products?

USDA should prioritize strengthening national food security surveillance rather than reducing it. At a time of rapidly changing federal policy-including newly implemented SNAP eligibility rule changes and work reporting requirements that could affect millions of Americans[8],[9]-the need for routine, reliable, and timely food security data has never been greater. Reliable federal statistics are essential for informing policy decisions, evaluating economic conditions, and ensuring accountability in federal programs.

Maintaining this dataset is also consistent with federal statistical policy. Under the Foundations for Evidence-Based Policymaking Act of 2018 and the Office of Management and Budget's Statistical Policy Directives, federal statistical agencies are required to produce data that are objective, reliable, timely, and relevant to policy evaluation.[10] The CPS-FSS meets these standards. In addition to maintaining the CPS-FSS, other priority research areas include:

• Analysis of food insecurity among rural populations, older adults, households with disabilities, communities of color, the LGBTQI+ community, and immigrant communities.
• Research on the relationship between food insecurity and health outcomes, housing instability, and broader economic hardship.
• Evaluation of federal nutrition programs, including SNAP and WIC, and their impact on household food security.

Surveys that include food security questions alongside health, housing, or education variables are complementary rather than duplicative. These data allow researchers to examine how food access interacts with broader social and economic conditions.

However, additional complementary research and surveys cannot replace the CPS-FSS, which serves as the national benchmark dataset for food insecurity prevalence.

Response to Question 4: How often should data be released or updated?

Food security data should continue to be collected and released annually and reported by the USDA, as is currently done through the CPS Food Security Supplement. Annual data collection is necessary to:

• Monitor trends in food insecurity;
• Detect emerging hardship during economic disruptions; and
• Evaluate the impact of federal policy changes on household food security-including the effects of recent changes to SNAP eligibility, benefit levels, and administrative requirements.

Infrequent, irregular, or modified surveys cannot provide the timely monitoring required for effective policy evaluation.

Response to Question 5: What geographic granularity best supports your work?

State-level data are essential for understanding geographic disparities in food insecurity and informing tailored policy decisions.

The CPS-FSS is uniquely capable of producing reliable state-level estimates, allowing policymakers to evaluate regional differences and target interventions. Most alternative datasets lack public state identifiers or have sample sizes too small to produce reliable state-level estimates. Sub-state data-at the county or metropolitan area level-would be valuable for targeting interventions, and USDA should explore whether expanded sample sizes or data linkages could support more granular geographic estimates over time.

Response to Question 6: Are there ERS or NASS data products that are duplicative or outdated?

The CPS Food Security Supplement has long been the national standard for food security data and is neither duplicative nor outdated.[11] Other surveys either: exclude children; use shortened food security modules; have significantly smaller sample sizes; lack geographic identifiers; or are no longer fielded.

These limitations make the CPS-FSS irreplaceable for measuring the prevalence and severity of food insecurity at the national and state levels.

Response to Question 7: Do you use non-USDA data to supplement USDA datasets?

Researchers frequently use non-USDA datasets to examine specific populations or policy contexts. However, these datasets are used in combination with CPS-FSS data rather than as substitutes.

The CPS-FSS serves as the national benchmark for measuring food insecurity, enabling researchers to contextualize findings from other surveys. Without the CPS-FSS, it would be significantly more difficult to interpret state-level trends in food insecurity or evaluate policy impacts.

Conclusion

Maintaining and enhancing the CPS-FSS is essential to USDA's mission and consistent with federal statistical standards requiring accurate, objective, timely, and policy-relevant data. It is the nation's most reliable and comprehensive dataset for measuring food insecurity. No other federal survey provides the same combination of annual data collection, large sample sizes, state-level estimates, and a full household food security module capturing both adult and child experiences.

For these reasons, NYHealth strongly urges USDA to continue and strengthen the CPS-FSS, and to expand analytic capacity to support disaggregated state-level estimates for historically underserved populations.

We appreciate your consideration of our comments and welcome the opportunity to discuss them further. Please feel free to contact Mary Ford at [email protected] with any questions or to discuss.

Sincerely,

David Sandman, Ph.D.

President and CEO
New York Health Foundation

References

[1] Request for Information on Opportunities, Challenges, and Emerging Areas in Statistical Data, Analysis, and Research at the U.S. Department of Agriculture, 91 Fed. Reg. (2026, February 23). https://www.federalregister.gov/documents/2026/02/23/2026-03497/request-for-information-on-opportunities-challenges-and-emerging-areas-in-statistical-data-analysis

[2] U.S. Department of Agriculture, Economic Research Service. (2026). SUPPORTING STATEMENT FOR EXTENSION OF OMB APPROVAL OF THE FOOD SECURITY SUPPLEMENT TO THE CURRENT POPULATION SURVEYhttps://www.reginfo.gov/public/do/DownloadDocument?objectID=150543902; Klein, M., Jarosz, B., Briefel, R., & Plata-Nino, G. (2025). Threats to food security data: Why the "redundancy" claim doesn't hold up. Food Research & Action Center. https://frac.org/blog/threats-to-food-security-data-why-the-redundancy-claim-doesnt-hold-up

[3] Jarosz, B., & Dick, C. (2025). Forsaking Food Security. America's Data Index. Dataindex.us. https://dataindex.us/newsletter/article/0e1a7dbb-47d1-4019-abb2-c1b7ef6c81f1

[4] Williams, K., & Pastoor, I. (2025, October 10). Measuring Food Security with U.S. Federal Data - Use It for Good. Popdata.org. https://blog.popdata.org/food-security-data-cps/

[5] U.S. Department of Agriculture, Economic Research Service. (2026). Food security in the United States: How do states compare?https://www.ers.usda.gov/topics/food-nutrition-assistance/food-security-in-the-us/interactive-charts-and-highlights#States

[6] Rabbitt, M. P., Reed-Jones, M., Hales, L. J., & Burke, M. P. (2025). Household food security in the United States in 2024 (Economic Research Report No. ERR-358). U.S. Department of Agriculture, Economic Research Service. https://www.ers.usda.gov/publications/pub-details?pubid=113622

[7] U.S. Department of Agriculture Economic Research Service. (2026). SUPPORTING STATEMENT FOR EXTENSION OF OMB APPROVAL OF THE FOOD SECURITY SUPPLEMENT TO THE CURRENT POPULATION SURVEY. Reginfo.gov. https://www.reginfo.gov/public/do/DownloadDocument?objectID=150543902

[8] U.S. Department of Agriculture, Food and Nutrition Service. (2025). SNAP provisions of the One Big Beautiful Bill Act: Information memorandum. https://www.fns.usda.gov/snap/obbb-implementation

[9] Bleich, S. N., & Plata-Nino, G. (2026). Changes to SNAP under HR 1 and the implications for food insecurity. JAMA Health Forum, 7(1), e260158. https://doi.org/10.1001/jamahealthforum.2026.0158

[10] Foundations for Evidence-Based Policymaking Act of 2018. (2020, October 27). https://www.govinfo.gov/content/pkg/COMPS-15356/pdf/COMPS-15356.pdf

[11] Klein, M., Jaroz, B., Briefel, R., & Plata-Nino, G. (2025). Threats to Food Security Data: Why the "Redundancy" Claim Doesn't Hold Up - Food Research & Action Center. Food Research & Action Center. https://frac.org/blog/threats-to-food-security-data-why-the-redundancy-claim-doesnt-hold-up