ADMINISTRATIVE POLICIES AND PRACTICES WPPM #140-10 Subject: Program Integrity Item: WIC Services for Employees and Relatives

PURPOSE: To ensure that no conflict of interest exists and to prevent staff fraud and abuse. POLICY: Local Agency (LA) employees are prohibited from participating in any component of the certification process and issuing food instruments (FI) to themselves, their relatives or close friends. PROCEDURE(S): I. Only the LA director, site supervisor or designee (an individual selected by the LA director or site supervisor to act on their behalf) is authorized to: A. Determine WIC eligibility for LA employees, their relatives, and close friends. B. Process the certification, provide appropriate nutrition education contacts, prescribe and issue FIs. II. The LA director, site supervisor, or designee must: A. Restrict access to the applicant/participant WIC Management Information System (WIC MIS) record by designating it “confidential”. B. Secure and file the applicant/participant paper records separately from the general paper files. C. Maintain separation of duties. If separation of duties is not achieved, a different staff person (an individual that has the authority to change an eligibility determination and not directly related to the certification) must conduct: 1. A post review of all such certification records within 2 weeks of certification. 2. Documentation of the review(s) must be maintained on file at the LA for review during program monitoring visits. AUTHORITY: 7 CFR §246.4(a)(27) CROSS REFERENCE: WPPM 210-16 Separation of Duties WPPM 970-10 Glossary Revised California WIC Policy and Procedure Manual Page 1 of 1 January 10, 2018