SEPARATION OF DUTIES WPPM #1000-80 ALTERNATE PROCEDURE May 1, 2023 California WIC Policy and Procedure Manual Page 1 of 2 Local Agency Name/Number: Site Number(s) using Alternate 1: Site Number(s) using Alternate 2: PROCEDURES: Alternate 1: Site with one staff person • A staff person (an individual that has the authority to change an eligibility determination and not directly related to the certification) must conduct: o A post review of certification records for all infants receiving any amount of infant formula. o A post review of a 20 percent random sample of the remaining certification records within 2 weeks of the certification date. • Documentation of the review must be maintained on file at the local agency for review during program monitoring visits. • It is recommended that staff is rotated on a regular basis so that the same staff person is not the only one known to the participants. Alternate 2: Site with multiple staff and only one staff performing all eligibility and certification functions, including issuing the WIC Card and food benefits. • Complete the justification section (page 2) to explain how the separation of duties requirement presents a hardship to the site. • A staff person (an individual that has the authority to change an eligibility determination and not directly related to the certification) must conduct: o A post review of certification records for all infants receiving any amount of infant formula. o A post review of 20 percent random sample of the remaining certification records within 2 weeks of the certification date. o The WIC LA director or designee must conduct an additional review of 10 percent of each clinic’s certification records every six months. • Documentation of the review must be maintained on file at the local agency for review during program monitoring visits. Submitted by: Date:

SEPARATION OF DUTIES WPPM #1000-80 ALTERNATE PROCEDURE May 1, 2023 California WIC Policy and Procedure Manual Page 2 of 2 Justification for Alternate 2 Instructions: Briefly explain how the separation of duties requirements presents a hardship to the site.