CERTIFICATION WPPM #200-000 Subject: Maintaining Program Integrity Item: Separation of Duties Waiver

California WIC Policy and Procedure Manual Page 1 of 4 August 1, 2024 PURPOSE: To provide guidance on the Separation of Duties (SOD) waiver issued by the United States Department of Agriculture (USDA) Food and Nutrition Services (FNS) pursuant to waiver authority from the American Rescue Plan Act (ARPA). This policy temporarily waives the standard SOD requirement listed in 7 CFR 246.4(a)(27)(iii) and is effective until September 30, 2026, or as communicated by the California Department of Public Health, Women, Infants and Children Division (CDPH/WIC). POLICY: I. Local agency (LA) staff must maintain separation of duties (SOD) during initial certifications and recertifications by using one of the following two methods: A. The LA staff person who determines income eligibility cannot be the same staff person who completes the nutritional risk assessment for the participant. B. The LA staff person who determines eligibility for all certification criteria cannot be the same staff person who issues food benefits for the participant. II. All certifications that do not achieve SOD must be completed by a competent professional authority (CPA). A. A staff person that has the authority to change an eligibility determination and not directly related to the certification must conduct a post review of certifications that did not achieve SOD. Refer to Procedure II below. III. LA staff are prohibited from certifying themselves, family, or friends. Refer to WPPM 140-20. PROCEDURES: I. LAs must maintain SOD using either of the following two methods: A. Assign at least two staff persons when certifying/recertifying an applicant. 1. Staff person A must determine income eligibility during initial certification/recertification. Complete Family Information and Individual Information screens in the WIC Web Information System Exchange (WIC WISE). 2. Staff person B, the certifier, must be a CPA and determines if an applicant is at nutritional risk through a nutrition assessment. Complete all other certification screens starting with Cert Action in WIC WISE. 3. Staff person A, staff person B, or any other staff may issue the WIC Card and food benefits.

CERTIFICATION WPPM #200-000 Subject: Maintaining Program Integrity Item: Separation of Duties Waiver

California WIC Policy and Procedure Manual Page 2 of 4 August 1, 2024 B. Assign one staff person to complete the certification/recertification and other staff to issue food benefits. 1. Staff person A, the certifier, must be a CPA and determines eligibility for all certification criteria. Complete all certification screens in WIC WISE. 2. Staff person B must issue food benefits. 3. Staff person A, staff person B, or any other staff may issue the WIC Card. II. LAs must monitor for records that did not observe SOD and complete any necessary record reviews. A. LA staff must run the SOD report regularly and complete the required record review. Refer to the SOD Report & Monitoring User Guide for detailed instructions. The SOD report will not include certifications where the applicant was determined to be adjunctively income eligible, as these certifications will be considered to meet the SOD requirement. 1. A staff person (an individual that has the authority to change an eligibility determination and not directly related to the certification) must conduct: a. A post review of 100 percent of all infant certifications that are in WIC WISE categories Infant Non Breastfeeding (INB) and Infant Breastfeeding Partially some (IBPs) that did not meet SOD per LA site. b. A post review of a 10 percent random sample of the remaining certification records that did not meet SOD per LA site. c. Post review must be completed within two weeks of the certification date. 2. Documentation of the review must be maintained on file for three years for review during program monitoring visits.

CERTIFICATION WPPM #200-000 Subject: Maintaining Program Integrity Item: Separation of Duties Waiver

California WIC Policy and Procedure Manual Page 3 of 4 August 1, 2024 III. Example Procedures for Separation of Duties Method 1 Staff Person Staff Functions Person A Determines income eligibility: 1. Completes the Family Information screen which includes adding or verifying caretakers. 2. Completes Income Information screen and Individual Information screen. 3. Completes Self Declaration Statement for any missing eligibility documents, if applicable. 4. Issue the WIC Card, if applicable. 5. Places Alerts and/or Notes as needed. Person B (Competent Professional Authority) Determines medical or nutritional risk and completes certification/recertification: 1. Completes the Cert Action screen. 2. Completes nutrition assessment by completing the Breastfeeding (if applicable), Ht/Wt/Bloodwork, Health, and Nutrition screens. 3. Reviews and adds nutrition risk(s) manually, if identified. 4. Provides nutrition education. 5. Completes a Care Plan. 6. Documents a Nutrition Education Contact. 7. Provides and documents Referrals as needed. 8. Adds a food package. 9. Completes any applicable forms including Rights & Responsibilities. 10. Schedules next appointment. 11. Places Alerts and/or Notes as needed. Person A or B or C Issue Food Benefits: 1. Issues food benefits.

CERTIFICATION WPPM #200-000 Subject: Maintaining Program Integrity Item: Separation of Duties Waiver

California WIC Policy and Procedure Manual Page 4 of 4 August 1, 2024 Method 2 Staff Person Staff Functions Person A (Competent Professional Authority) Determines program eligibility and completes certification/recertification 1. Completes the Family Information which includes adding or verifying caretakers. 2. Completes Income Information screen and Individual Information screen in WIC WISE. 3. Completes Self Declaration Statement for any missing eligibility documents (if appropriate). 4. Issues the WIC Card, if applicable. 5. Places Alerts and/or Notes as needed. 6. Completes the Cert Action screen. 7. Completes nutrition assessment by completing Breastfeeding (if applicable), Ht/Wt/Bloodwork. Health & Nutrition screens. 8. Reviews and adds nutritional risk manually, if identified. 9. Provides nutrition education. 10. Completes Care Plan. 11. Documents Nutrition Education contact. 12. Provides and documents Referrals as needed. 13. Adds a food package. 14. Completes any applicable forms including Rights & Responsibilities. 15. Schedules next appointment. 16. Places Alerts and/or Notes as needed. Person B

Issue Food Benefits 1. Issues food benefits. AUTHORITY: 7 CFR 246.4(a)(27) WIC Policy Memorandum # 2016-5 RESOURCE: SOD Report & Monitoring User Guide CROSS REFERENCE: WPPM 140-10 WIC Services for Employees and Relatives WPPM 280-20 Criteria for Program Violation and Termination WPPM 970-10 Glossary WPPM 1000-70 Job Aid for Separation of Duties