BREASTFEEDING PROMOTION & SUPPORT WPPM #630-10 Subject: Breastfeeding Peer Counseling Program Item: Program Overview and Administrative Requirements

Revised California WIC Policy and Procedure Manual Page 1 of 4 April 11, 2025 PURPOSE: To provide information on requirements for the WIC Breastfeeding Peer Counseling (BFPC) Program and guide local agencies (LAs) to implement effective BFPC services. POLICY: I. LAs that implement BFPC Programs must comply with the United States Department of Agriculture’s (USDA’s) WIC Breastfeeding Model Components for Peer Counseling. II. BFPC Program funds are restricted specifically for the BFPC Program and must be used in a manner consistent with the requirements in the WIC Breastfeeding Model Components for Peer Counseling. The primary purpose of BFPC funds is to provide direct breastfeeding support services through peer counseling to WIC participants. III. LAs are allowed to fund their BFPC Program using a source other than the USDA BFPC grant. However, the LA’s program must still follow BFPC Program policies regardless of funding source. IV. BFPC staff must meet appropriate BFPC Program qualifications and work within their allowed scope of practice. Refer to WPPM 630-11 and 630-12. V. Peer counseling services must be available to BFPC Program participants outside the usual WIC site environment and usual hours of operation. Refer to WPPM 530-10. PROCEDURES: I. BFPC Program Operations A. LAs that operate a BFPC Program must: 1. Follow BFPC Program policies in the WPPM and develop LA-specific BFPC policies and procedures. a. Develop a written process for referring participants to the BFPC Program and train all direct service WIC staff on this process. b. Follow established procedures to ensure non-BFPC Program staff can easily identify BFPC Program participants and their assigned PC. c. Ensure that LA-developed policies and procedures are written and standardized. 2. Provide a physical location where PCs can provide services. The workstation must include equipment needed for the job, such as a desk,

BREASTFEEDING PROMOTION & SUPPORT WPPM #630-10 Subject: Breastfeeding Peer Counseling Program Item: Program Overview and Administrative Requirements

Revised California WIC Policy and Procedure Manual Page 2 of 4 April 11, 2025 telephone/cell phone, office equipment, and computer/laptop with internet and access to the CDPH/WIC approved management information system to document contacts. 3. Provide PCs with adequate compensation and reimbursement for expenses. 4. Submit a signed Memorandum of Understanding (MOU) with the Annual Program Profile to CDPH/WIC if partnering with another LA or other program to meet program needs. 5. Plan and oversee BFPC Program training to ensure that PCs receive initial and ongoing training on breastfeeding, peer counseling, documentation, and referrals. Refer to WPPM 1000-30. The LA must maintain documentation of all trainings as described in WPPM 190-00. II. BFPC Program Services A. PCs must work within their scope of practice and provide breastfeeding support services that are focused on supporting normal breastfeeding. Refer to WPPM 630-12 for PC duties and responsibilities. B. The LA must not count classes taught by PCs as a nutrition education contact (NEC) in the WIC Web Information System Exchange (WIC WISE) unless: 1. The PC is partially funded as a WIC Nutrition Assistant (WNA), and 2. The class meets the requirements for NECs as described in the WPPM 400 Series: Nutrition Education Requirements. C. The LA may allow BFPC Program staff to assist non-BFPC Program participants for a limited amount of time, in situations where BFPC and non- BFPC participants are together (e.g., attending the same class). The LA must not allow on-going USDA-funded BFPC services for participants who are not enrolled in the BFPC Program. III. BFPC Program Staffing A. LAs with BFPC Programs must: 1. Recruit and hire women who meet the appropriate qualifications of a WIC PC. Refer to WPPM 630-12. 2. Designate a PC Supervisor/International Board-Certified Lactation Consultant (IBCLC) to oversee the BFPC Program and provide breastfeeding counseling to BFPC Program participants with issues

BREASTFEEDING PROMOTION & SUPPORT WPPM #630-10 Subject: Breastfeeding Peer Counseling Program Item: Program Overview and Administrative Requirements

Revised California WIC Policy and Procedure Manual Page 3 of 4 April 11, 2025 beyond the PC scope of practice. LAs who want to have separate IBCLC and PC Supervisor positions must submit a justification to CDPH/WIC. Refer to WPPM 630-11. B. Dietetic interns and women without personal breastfeeding experience do not meet the definition of PC (a paraprofessional who has breastfed at least one infant) and cannot be hired using BFPC Program funds. C. LAs using the PC/WNA model must use non-BFPC Program funds to fund time spent working as a WNA. IV. Use of BFPC Program Funds A. BFPC Program funds are restricted specifically for the BFPC Program. LAs must use the majority of the funds to hire and train PCs to provide direct breastfeeding peer counseling services to participants. B. LAs are only allowed to use BFPC Program funds for expenditures permitted by the USDA Allowable Costs for BFPC Funds. LAs must adhere to WPPM 1000-07 for procurement requirements and WPPM 1000-08 for subcontract requirements. C. LAs must reimburse PCs for approved telecommunication and travel expenses. D. LAs are allowed to use BFPC Program funds for advertising the BFPC Program, but the amount cannot be disproportionate nor come at the expense of direct services to participants. For ads that promote breastfeeding in general, LAs are allowed to use Nutrition Services and Administration (NSA) funds. E. LAs are not allowed to use BFPC Program funds to meet the 1/6th nutrition education spending requirement or the breastfeeding promotion and support minimum expenditures requirement. These requirements must be met with regular NSA funds. V. BFPC Program Budget and Reports A. The LA must: 1. Have an approved WIC Local Agency Agreement that includes a BFPC Program budget on file with CDPH/WIC. 2. Submit invoices showing expenditures in each line item to CDPH/WIC. Refer to WPPM 1000-12. 3. Report BFPC Program expenditures in the Report of Actual Expenditures (RAE) packet and submit to CDPH/WIC no later than December 15. Refer to WPPM 1000-13.

BREASTFEEDING PROMOTION & SUPPORT WPPM #630-10 Subject: Breastfeeding Peer Counseling Program Item: Program Overview and Administrative Requirements

Revised April 11, 2025 California WIC Policy and Procedure Manual Page 4 of 4

4. Ensure that dual-role staff (e.g., part-time WIC Nutrition Assistant (WNA) and part-time PC) complete continuous time reporting and/or time studies. 5. Adhere to all reporting requirements in the current WIC Local Agency Agreement. AUTHORITY: WIC Breastfeeding Model Components for Peer Counseling Allowable Costs for Breastfeeding Peer Counseling Funds, USDA Nutrition Services Standard 9 USDA Breastfeeding Curriculum RESOURCE: California WIC Breastfeeding Peer Counseling Program Guidance Manual California WIC Breastfeeding Program Administrative Manual WIC Breastfeeding Support CROSS REFERENCE: WPPM 190-00 Staff Training WPPM 530-10 Site Hours of Operation WPPM 630-11 Peer Counseling Supervisor/IBCLC: Requirements and Responsibilities WPPM 630-12 Peer Counselors: Requirements and Responsibilities WPPM 630-16 Fiscal Requirements WPPM 1000-07 Procurement Requirements WPPM 1000-08 Subcontract Requirements WPPM 1000-12 Invoicing and Payment WPPM 1000-13 Report of Actual Expenditures WPPM 1000-30 Required Trainings for Employees Job Aid