NCUIH Supports Tribal Proposal to Remove Urban Limitations in USDA Food Distribution Programs

On October 13, 2023, the National Council of Urban Indian Health (NCUIH) submitted written comments and requests to the U.S. Department of Agriculture (USDA) Food and Nutrition Service (FNS) in response to the August 14, 2023, request for comments regarding the Proposed Rule on Food Distribution Programs: Improving Access and Parity. NCUIH’s comments address food insecurity in urban American Indian and Alaska Native communities.

NCUIH recommended that FNS:

In its comments, NCUIH recommended that FNS:

  • Remove urban place requirements in Food Distribution Program on Indian Reservations (FDPIR)
  • Encourage Tribes and States to collaborate with urban Indian organizations (UIOs) on FDPIR expansion in urban areas.
  • Ensure data collection accounts for expanded FDPIR access in urban areas.

By removing the urban place requirements and encouraging tribal and state collaboration with UIOs, FNS can make significant steps toward eliminating food insecurity for urban American Indians and Alaska Natives. The FDPIR benefits would extend to these populations.

Background on the FDPIR

The FDPIR provides USDA Foods to income-eligible households living on Indian reservations, and to American Indian households residing in approved areas near reservations or in Oklahoma. Many households participate in FDPIR as an alternative to the Supplemental Nutrition Assistance Program (SNAP) because they do not have easy access to SNAP offices or authorized food stores. The FNS, an agency of the USDA, administers FDPIR at the federal level. The program is administered locally by either Indian Tribal Organizations (ITOs) or an agency of a state government. Currently, there are approximately 276 Tribes receiving benefits under FDPIR through 102 ITOs and 3 state agencies. Currently, per FDPIR regulations at § 253.4(d), any urban place outside of the reservation boundaries may not be served unless an ITO or State agency requests to serve the urban place with a justification.

Tribal leaders and the National Association of Food Distribution Programs on Indian Reservations Board have submitted multiple Resolutions to FNS to remove and/or adjust the definition of urban place to increase the population from 10,000. Resolutions have cited the nutritional needs of Tribal members, their preferences for FDPIR benefits over SNAP, access to FDPIR nutrition education which is more tailored to meet Tribal needs, and a desire to remain connected to Tribal services. The FDPIR community has expressed frustration with the administrative difficulties in applying for an “urban place waiver,” and with what is perceived to be an arbitrarily low population cap of 10,000.

Next Steps

NCUIH will continue to advocate to eliminate food insecurity in American Indian and Alaska Native communities, regardless of their location.