Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 1 of 36 Oct 1, 2025 Legend: P = pregnant, B = breastfeeding postpartum, N = non-breastfeeding postpartum, I = infant, C = child 100 Risk Series: Anthropometric USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 101 Underweight (Pregnant/Postpartum) P – I B – I N – VI Pregnant: Prepregnancy BMI < 18.5 Non-breastfeeding postpartum: Prepregnancy or current BMI < 18.5 Breastfeeding postpartum: • < 6 months postpartum: prepregnancy or current BMI < 18.5 • ≥ 6 months postpartum: current BMI < 18.5 No 103 Underweight or At Risk of Underweight (Infants/Children) I – I C – III Underweight Birth to < 24 mo: weight-for-length ≤ 2.3rd percentile Child 2-5 yrs: BMI-for-age ≤ 5th percentile At Risk of Underweight Birth to < 24 mo: weight-for-length > 2.3rd percentile and ≤ 5th percentile Child 2-5 yrs: BMI-for-age > 5th percentile and ≤ 10th percentile Yes For under weight only 111 Overweight (Pregnant/Postpartum) P – I B – I N – VI Pregnant: Prepregnancy BMI ≥ 25 Non-breastfeeding postpartum: Prepregnancy BMI ≥ 25 Breastfeeding postpartum: • < 6 months postpartum: prepregnancy BMI ≥ 25 • ≥ 6 months or more postpartum: current BMI ≥ 25 No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 2 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 113 Obese (Child 2-5 Yrs) C – III Child 2-5 yrs: ≥ 95th percentile BMI or weight-for-stature Yes 114 Overweight or at Risk of Overweight (Infants/children) I – I C – III Overweight Child 2-5 yrs: BMI-for-age or weight-for-stature ≥ 85th & < 95th percentile At Risk of Overweight Infant: • Biological mother with BMI ≥ 30 at time of conception or at any point in the first trimester of pregnancy • Biological father with a BMI ≥ 30 at time of certification Child ≥ 12 months • Biological mother with BMI ≥ 30 at time of certification • Biological father with BMI ≥ 30 at time of certification No 115 High Weight for Length I-I, C-III (<24 mo) Birth to < 24 months: weight-for-length ≥ 97.7th percentile No

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Revised California WIC Policy and Procedure Manual Page 3 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 121 Short Stature or At Risk of Short Stature I – I C – III Short Stature Birth to < 24 months: length-for-age ≤ 2.3rd percentile 2-5 years old: stature-for-age ≤ 5th percentile At Risk of Short Stature Birth to < 24 months: length-for-age > 2.3rd percentile and ≤ 5th percentile 2-5 years old: stature-for-age > 5th percentile and ≤ 10th percentile No 131 Low Maternal Weight Gain P – I 1. A low rate of weight gain in the 2nd or 3rd trimesters for singleton pregnancies. • Underweight individuals: < 1 lb/wk • Normal weight individuals: < 0.8 lbs/wk • Overweight individuals: < 0.5 lbs/wk • Obese individuals: < 0.4 lbs/wk 2. Low weight gain at any point in pregnancy using the Institute of Medicine (IOM)-based weight gain grid. No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 4 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 133 High Maternal Weight Gain P – I B – I N – VI Pregnant: 1. A high rate of weight gain in the 2nd or 3rd trimesters for singleton pregnancies: • Underweight individuals: > 1.3 lbs/wk • Normal weight individuals: > 1 lbs/wk • Overweight individuals: > 0.7 lbs/wk • Obese individuals: > 0.6 lbs/wk 2. High weight gain at any point in pregnancy using the IOM-based weight gain grid. Breastfeeding/non-breastfeeding postpartum: Total gestational weight gain exceeding the upper limit of the IOM’s recommended range based on BMI for singleton pregnancies. No 134* Failure to Thrive I – I C – III A serious growth problem with the following potential indicators that a physician might use for diagnosis: • Weight consistently below 3rd percentile for age • Weight less than 80% of ideal weight for height/age • Progressive fall-off in weight to below the 3rd percentile • A decrease in expected rate of growth along the child’s previously defined growth curve irrespective of its relationship to the 3rd percentile Yes

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Revised California WIC Policy and Procedure Manual Page 5 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 135 Slowed/Faltering Growth Pattern I – I (≤ 6 mo) Infants birth to 2 weeks: Excessive weight loss after birth, defined as ≥ 7% birth weight. Infants 2 weeks to 6 months of age: Any weight loss. Use two separate weight measurements taken at least 8 weeks apart. Yes 141 Low Birth Weight or Very Low Birth Weight I-I, C-III (<24 mo) Low Birth Weight: Birth weight ≤ 5 pounds 8 ounces (≤ 2500 g), for infants and children < 24 months Very Low Birth Weight: Birth weight ≤ 3 pounds 5 ounces (≤ 1500 g), for infants and children < 24 months Yes For infants only 142 Preterm or Early Term Delivery I-I, C-III (<24 mo) Preterm: Delivery of an infant born ≤ 36 6/7 weeks gestation. Early Term: Delivery of an infant born ≥ 37 0/7 and ≤ 38 6/7 weeks gestation. No 151* Small for Gestational Age I-I, C-III (<24 mo) Birth weight less than 10th percentile for gestational age, as diagnosed by a physician or as self-reported by applicant/participant. No 152 Low Head Circumference I-I, C-III (<24 mo) Head circumference-for-age ≤ 2.3rd percentile. No 153* Large for Gestational Age I – I Birth weight ≥ 9 pounds (≥ 4000g); or as diagnosed by a physician or as self-reported by applicant/participant. No

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Revised California WIC Policy and Procedure Manual Page 6 of 36 Oct 1, 2025

200 Risk Series: BIOCHEMICAL USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 201 Low Hematocrit Low Hemoglobin P – I B – I N – VI I – I C – III Hemoglobin (Hb) or Hematocrit (Hct) less than the 5th percentile of the distribution of Hb concentration or Hct in a healthy reference population based on age, sex, and stage of pregnancy. See cut-off values: Pregnant/postpartum (non-smoking, living at altitude of 0-2999 ft) No content Trimester 1 Trimester 2 Trimester 3 Postpartum > 15 yrs old Hgb 11 10.5 11 12 Hct 33 32 33 36 Infant and Children (living at altitude of 0-2999 ft) No content 6-12 months 1-2 years 2-5 years Hgb 11 11 11.1 Hct 33 33 33

No 211 Elevated Blood Lead Levels P – I B – I N – III I – I C – III Blood lead level of ≥ 3.5 μg/deciliter within the past 12 months. Yes

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Revised California WIC Policy and Procedure Manual Page 7 of 36 Oct 1, 2025 300 Risk Series: CLINICAL / HEALTH / MEDICAL USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 301* Hyperemesis Gravidarum P – I Severe and persistent nausea and vomiting during pregnancy, which may cause more than 5% weight loss and fluid and electrolyte imbalances. This nutrition risk is based on a chronic condition, not single episodes. It is a clinical diagnosis, made after other causes of nausea and vomiting have been excluded. Yes 302* Gestational Diabetes P – I Any degree of glucose/carbohydrate intolerance with onset or first recognition during pregnancy. Yes 303* History of Gestational Diabetes P – I B – I N – VI History of diagnosed gestational diabetes mellitus (GDM). No 304* History of Preeclampsia P – I B – I N – VI History of diagnosed preeclampsia. Yes For PG only 311 History of Preterm or Early Term Delivery P – I B – I N – IV History of preterm and/or early term delivery: • Preterm: Delivery of an infant born ≤ 36 6/7 weeks gestation. • Early Term: Delivery of an infant born ≥ 37 0/7 and ≤ 38 6/7 weeks gestation. No

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Revised California WIC Policy and Procedure Manual Page 8 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 321 History of Spontaneous Abortion, Fetal or Neonatal Loss P – I B – I N – VI Pregnant: Any history of fetal/neonatal death or ≥ 2 spontaneous abortions Breastfeeding: Most recent pregnancy in which there was a multifetal gestation with ≥ 1 fetal/neonatal deaths but with ≥ 1 infants still living Non-breastfeeding: spontaneous abortion (SAB), fetal death, or neonatal death in most recent pregnancy • Spontaneous Abortion (SAB): spontaneous termination of a gestation at < 20 weeks or of a fetus weighing < 500 grams. • Fetal Death: spontaneous termination of a gestation at ≥ 20 weeks. • Neonatal Death: death of an infant within 0-28 days of life. No 331 Pregnancy at a Young Age P – I B – I N – III Conception at ≤ 20 years of age. Applies to current pregnancy for pregnant individuals and most recent pregnancy for postpartum individuals. Yes 332 Short Interpregnancy Interval P – I B – I N – VI Interpregnancy interval of less than 18 months from the date of a live birth to the conception of the next pregnancy. Applies to current pregnancy for pregnant individuals and most recent pregnancy for postpartum individuals. No 334 Lack of/Inadequate Prenatal Care P – I Prenatal care beginning after the 1st trimester, or based on the Inadequate Prenatal Index (Kessner et al): • 14-21 wks gestation = 0/Unknown • 22-29 wks gestation = 1 or fewer prenatal visits • 30-31 wks gestation = 2 or fewer prenatal visits • 32-33 wks gestation = 3 or fewer prenatal visits • 34 or more wks gestation = 4 or fewer prenatal visits No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 9 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 335 Multi-Fetal Gestation P – I B – I N – VI More than one (> 1) fetus in a current pregnancy (for pregnant individuals) or the most recent pregnancy (for postpartum individuals). No 336* Fetal Growth Restriction P – I Usually defined as a fetal weight < 10th percentile for gestational age. Yes 337* History of Birth of a Large for Gestational Age Infant P – I B – I N – VI Pregnant: any history of giving birth to an infant weighing ≥ 9 lbs. (4000 grams). Breastfeeding/Non-breastfeeding: Most recent pregnancy, or history of giving birth to an infant weighing ≥ 9 lbs. (4000 grams) No 338 Pregnant Woman Currently Breastfeeding P – I Pregnant person who is currently breastfeeding. No 339* History of Birth with Nutrition Related Congenital or Birth Defect P – I B – I N – VI A person who has given birth to an infant who has a congenital or birth defect linked to inappropriate nutritional intake, e.g., inadequate zinc, folic acid, excess vitamin A. Applies to any history of birth with nutrition-related congenital or birth defect for pregnant individuals and most recent pregnancy for postpartum individuals. No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 10 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 341* Nutrient Deficiency or Disease P – I B – I N – III I – I C – III Any currently treated or untreated nutrient deficiency or disease. May include, but are not limited to: Protein Energy Malnutrition, Scurvy, Rickets, Beriberi, Hypocalcemia, Osteomalacia, Vitamin K Deficiency, Pellegra, Xerophthalmia, and Iron Deficiency. Yes 342* Gastrointestinal Disorders P – I B – I N – III I – I C – III Diseases and/or conditions that interfere with the intake or absorption of nutrients. May include, but are not limited to: Gastroesophageal reflux disease (GERD), peptic ulcer, post-bariatric surgery, short bowel syndrome, inflammatory bowel disease, including ulcerative colitis or Crohn’s disease, liver disease, pancreatitis, biliary tract disease. Yes 343* Diabetes Mellitus P – I B – I N – III I – I C – III A group of metabolic diseases characterized by inappropriate hyperglycemia resulting from defects in insulin secretion, insulin action or both. Yes 344* Thyroid Disorders P – I B – I N – III I – I C – III Thyroid dysfunctions that occur in pregnant and postpartum participants, during fetal development, and in childhood are caused by the abnormal secretion of thyroid hormones. Include, but are not limited to: hyperthyroidism, hypothyroidism, congenital hyperthyroidism, congenital hypothyroidism, postpartum thyroiditis. Yes

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Revised California WIC Policy and Procedure Manual Page 11 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 345* Hypertension and Prehypertension P – I B – I N – III I – I C – III Hypertension: high blood pressure which may eventually cause health problems and includes chronic hypertension during pregnancy, preeclampsia, eclampsia, chronic hypertension with superimposed preeclampsia, and gestational hypertension. Prehypertension: at high risk for developing hypertension, based on blood pressure levels. Yes 346* Renal Disease P – I B – I N – III I – I C – III Any renal disease including pyelonephritis and persistent proteinuria, but excluding urinary tract infections (UTI) involving the bladder. Yes 347* Cancer P – I B – I N – III I – I C – III Current cancer; treatment or condition affects nutritional status. Yes

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Revised California WIC Policy and Procedure Manual Page 12 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 348* Central Nervous System Disorders P – I B – I N – III I – I C – III Conditions which affect energy requirements, ability to feed, or alter nutritional status metabolically and/or mechanically. Includes, but are not limited to: epilepsy, cerebral palsy (CP), neural tube defects (NTD) (e.g., spina bifida), Parkinson’s disease, and multiple sclerosis (MS). Yes 349* Genetic and Congenital Disorders P – I B – I N – III I – I C – III Hereditary or congenital condition at birth that causes physical or metabolic abnormality. Current condition must alter nutrition status metabolically, mechanically, or both. May include, but are not limited to: cleft lip/palate, Down’s syndrome, thalassemia major, sick cell anemia (not sickle cell trait), and muscular dystrophy. Yes 351* Inborn Errors of Metabolism P – I B – I N – III I – I C – III Gene mutations or gene deletions that alter metabolism in the body. May include, but are not limited to: amino acid disorders, urea cycle disorders, organic acid metabolism disorders, carbohydrate disorders, fatty acid oxidation disorders, peroxisomal disorders, lysosomal storage disorders, and mitochondrial disorders. Yes 352a* Infectious Diseases - Acute P – I B – I N – III I – I C – III Diseases of relatively rapid onset and short duration (must be present within the past 6 months). May include, but are not limited to: hepatitis A/E, pneumonia, meningitis (Bacterial/Viral), parasitic infection, bronchitis (3 episodes in last 6 months), or listeriosis. An extensive listing of infectious diseases can be found on the NIH website Infections: MedlinePlus. Yes

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Revised California WIC Policy and Procedure Manual Page 13 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 352b* Infectious Diseases - Chronic P – I B – I N – III I – I C – III Conditions likely lasting a lifetime and require long-term management of symptoms. May include, but are not limited to: HIV, AIDS, and Hepatitis B/C/D. An extensive listing of infectious diseases can be found on the NIH website Infections: MedlinePlus. Yes 353* Food Allergies P – I B – I N – III I – I C – III Adverse health effects arising from a specific immune response that occurs reproducibly on exposure to a given food. This risk only applies to food allergies and should not be assigned to those who have non- immunologic adverse reactions to food. Yes 354* Celiac Disease P – I B – I N – III I – I C – III Also known as: Celiac Sprue, Gluten-sensitive Enteropathy, Non-tropical Sprue. An autoimmune disease precipitated by the ingestion of gluten (a protein in wheat, rye, and barley), resulting in damage to the small intestine and malabsorption of the nutrients from food. Yes 355* Lactose Intolerance P – I B – I N – VI I – I C – III The syndrome of one or more of the following: diarrhea, abdominal pain, flatulence, and/or bloating, that occurs after lactose ingestion. No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 14 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 356* Hypoglycemia P – I B – I N – III I – I C – III Presence of hypoglycemia. Hypoglycemia can occur as a complication of diabetes, as a condition in itself, in association with other disorders, or under certain conditions such as early pregnancy, prolonged fasting, or long periods of strenuous exercise. Yes 357 Drug Nutrient Interactions P – I B – I N – III I – I C – III Use of prescription or over-the-counter drugs or medications that have been shown to interfere with nutrient intake, absorption, distribution, metabolism, or excretion, to an extent that nutritional status is compromised. Yes 358* Eating Disorders P – I B – I N – III Eating disorders are characterized by severe disturbances in a person’s eating behaviors and related thoughts and emotions. Eating disorders include, but are not limited to: anorexia nervosa (AN), bulimia nervosa (BN), and binge-eating disorder (BED). Yes 359* Recent Major Surgery, Trauma, Burns P – I B – I N – III I – I C – III Major surgery (includes C-sections), physical trauma or burns severe enough to compromise nutritional status. Yes

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Revised California WIC Policy and Procedure Manual Page 15 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 360* Other Medical Conditions P – I B – I N – III I – I C – III Diseases or conditions with nutritional implications that are not included in any of the other medical conditions. Current condition, or treatment for the condition, must be severe enough to affect nutritional status. May include, but are not limited to: juvenile ideopathic arthritis (JIA), systemic lupus erythematosus (SLE), polycystic ovary syndrome (PCOS), cardiovascular disease, persistent asthma (moderate or severe) requiring daily medication, cystic fibrosis. Yes 361* Mental Illnesses P – I B – I N – VI Presence of mental illnesses where the current condition, or treatment for the condition, may affect nutrition status. These include, but are not limited to: depression, post-traumatic stress disorder (PTSD), personality disorders, schizophrenia, anxiety disorders, obessive-compulsive disorder (OCD), bipolar disorders, attention-deficit/hyperactivity disorder (ADHD). Note: For mental illnesses related to eating disorders (e.g., anorexia nervosa, bulimia nervosa and binge-eating disorder), please see risk #358 Eating Disorders. No 362 Developmental, Sensory, or Motor Disabilities Interfering with Ability to Eat P – I B – I N – III I – I C – III Developmental, sensory, or motor disabilities interfering with ability to eat, restricting the ability to chew or swallow food, or requiring tube feeding to meet nutritional needs. May include, but are not limited to: minimal brain function, feeding problems due to developmental delay, head trauma, brain damage or birth injury. Yes

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Revised California WIC Policy and Procedure Manual Page 16 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 363* Pre-Diabetes B – I N – III Impaired fasting glucose (IFG) and/or impaired glucose tolerance (IGT). Yes 371 Nicotine and Tobacco use P – I B – I N – VI Use of any product which contains nicotine and/or tobacco to include but not limited to cigarettes, pipes, cigars, electronic nicotine delivery systems (e.g. e-cigarettes, vaping devices), hookahs, smokeless tobacco (e.g. chewing tobacco, snuff, dissolvables), or nicotine replacement therapies (e.g. gums, patches). No 372 Alcohol and Substance Use P – I B – I N – III Pregnant Alcohol Use: Any alcohol use. Substance Use: • Any illegal substance use and/or abuse of prescription medications. • Any marijuana use in any form. Breastfeeding and Non-Breastfeeding: Alcohol Use: • High Risk: Routine drinking of ≥ 8 drinks/week or ≥ 4 drinks/day. • Binge: Routine consumption of ≥ 4 drinks within 2 hours. Substance Use: • Any illegal substance use and/or abuse of prescription medications. • Any marijuana use in any form (breastfeeding participants only). Yes

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Revised California WIC Policy and Procedure Manual Page 17 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 381* Oral Health Condition P – I B – I N – VI I – I C – III Includes but not limited to: tooth decay, periodontal disease, gingivitis, tooth loss, ineffectively replaced teeth or oral infections that impair the ability to ingest food in adequate quantity or quality. No 382* Fetal Alcohol Spectrum Disorders P – I B – I N – VI I – I C – III A group of conditions that can occur in a person whose mother consumed alcohol during pregnancy. Encompasses a range of possible diagnoses, including fetal alcohol syndrome (FAS), partial fetal alcohol syndrome (pFAS), alcohol-related birth defects (ARBD), alcohol-related neurodevelopmental disorder (ARND), and neurobehavioral disorder associated with prenatal alcohol exposure (ND-PAE). Yes For I and C only 383* Neonatal Abstinence Syndrome I – I A drug withdrawal syndrome that occurs among drug-exposed infants as a result of the parent’s use of drugs during pregnancy. Yes

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Revised California WIC Policy and Procedure Manual Page 18 of 36 Oct 1, 2025 400 Risk Series: DIET – Presumed Eligibility for Women and Children Ages 2-5 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 401 Failure to Meet Dietary Guidelines for Americans P – IV B – IV N – VI C – V Pregnant, breastfeeding, and non-breastfeeding participants and children age two to five years may be presumed to be at nutrition risk based on inability to meet Dietary Guidelines for Americans as defined by consuming fewer than the recommended number of servings from one or more of the basic food groups. This risk may only be assigned after a complete nutrition assessment has been performed and no other risks have been identified. No 411 Risk Series: DIET – Inappropriate Nutrition Practices for Infants USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 411.1 Routinely using a substitute(s) for human milk or for FDA approved iron- fortified formula as the primary nutrient source during the first year of life. I – IV Examples of substitutes: • Low iron formula without iron supplementation. • Cow’s milk, goat’s milk, or sheep’s milk (whole, reduced fat, low-fat, skim), canned evaporated or sweetened condensed milk. • Imitation or substitute milks (like rice- or soy-based beverages, non- dairy creamer), or other “homemade concoctions”. No

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Revised California WIC Policy and Procedure Manual Page 19 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 411.2 Routinely using nursing bottles or cups improperly I – IV • Using a bottle to feed fruit juice. • Feeding any sugar-containing fluids, such as soda/soft drinks, gelatin water, corn syrup solutions, and sweetened tea. • Allowing the infant to fall asleep or be put to bed with a bottle at naps or bedtime. • Allowing the infant to use the bottle without restriction (e.g., walking around with a bottle) or as a pacifier. • Propping the bottle when feeding. • Allowing an infant to carry around and drink throughout the day from a covered or training cup. • Adding any food (cereal or other solid foods) to the infant’s bottle. No 411.3 Routinely offering complementary foods or other substances that are inappropriate in type or timing I – IV • Adding sweet agents such as sugar, honey, or syrups to any beverage (including water) or prepared food, or used on a pacifier. • Introducing any food or beverage other than human milk or iron- fortified infant formula before 6 months of age, such as tea, rice water, or infant cereal. No

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Revised California WIC Policy and Procedure Manual Page 20 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 411.4 Routinely using feeding practices that disregard the developmental needs or stage of the infant I – IV • Inability to recognize, insensitivity to, or disregarding the infant’s cues for hunger and satiety (e.g., forcing an infant to eat a type and/or amount of food or beverage or ignoring hunger cues). • Feeding foods of inappropriate consistency, size, or shape that put infants at risk of choking. • Not supporting an infant’s growing independence with self-feeding (e.g., solely spoon-feeding an infant who is able and ready to finger- feed and/or try self-feeding with appropriate utensils). • Feeding an infant food with inappropriate texture based on his/her developmental stage (e.g., feeding primarily pureed or liquid foods when the infant is ready and capable of eating mashed, chopped or appropriate finger foods). No 411.5 Feeding foods to an infant that could be contaminated with harmful microorganisms or toxins I – IV Potentially harmful foods: • Unpasteurized fruit or vegetable juice. • Unpasteurized dairy products or soft cheeses such as feta, Brie, Camembert, blue-veined, and Mexican-style cheese. • Honey (added to liquids or solid foods, used in cooking, as part of processed foods, on a pacifier, etc). • Raw or undercooked meat, fish, poultry, or eggs. • Raw vegetable sprouts (alfalfa, clover, bean, and radish). • Deli meats, hot dogs, and processed meats (avoid unless heated until steaming hot). • Donor human milk acquired directly from individuals or the Internet. No

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Revised California WIC Policy and Procedure Manual Page 21 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 411.6 Routinely feeding inappropriately diluted formula I – IV • Failure to follow manufacturer’s dilution instructions (to include stretching formula for household economic reasons). • Failure to follow specific instructions accompanying a prescription. No 411.7 Routinely limiting the frequency of nursing of the exclusively breastfed infant when human milk is the sole source of nutrients I – IV Examples of inappropriate frequency of nursing: • Scheduled feedings instead of demand feedings. • Less than 8 feedings in 24 hours if less than 2 months old. No 411.8 Routinely feeding a diet very low in calories and/or essential nutrients I – IV Examples: • Strict vegan diet • Macrobiotic diet • Other diets very low in calories and/or essential nutrients No

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Revised California WIC Policy and Procedure Manual Page 22 of 36 Oct 1, 2025 411.9 Routinely using inappropriate sanitation in preparation, handling, and storage of expressed human milk or formula I – IV Limited or no access to a: • Safe water supply (documented by appropriate officials). • Heat source for sterilization. • Refrigerator or freezer for storage. Failure to properly prepare, handle, or store bottles or storage containers of expressed breast milk or formula; examples include: Human Milk • Thawing/heating in a microwave. • Refreezing. • Adding freshly expressed unrefrigerated human milk to frozen human milk. • Adding freshly pumped chilled human milk to frozen human milk in an amount that is greater than the amount of frozen human milk. • Feeding thawed refrigerated human milk more than 24 hours after it was thawed. • Saving human milk from a used bottle for another feeding. • Failure to clean breast pump per manufacturer’s instructions. • Feeding donor human milk acquired directly from individuals or the Internet. Formula • Failure to prepare and/or store formula per manufacturer’s or physician instructions. • Storing at room temperature for more than 1 hour. • Using formula in a bottle one hour after the start of a feeding. • Saving formula from a used bottle for another feeding. • Failure to clean baby bottle properly. No

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Revised California WIC Policy and Procedure Manual Page 23 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 411.10 Feeding dietary supplements with potentially harmful consequences I – IV Examples of dietary supplements which, when fed in excess of recommended dosage, may be toxic or have harmful consequences: • Single or multi-vitamins • Mineral supplementations • Herbal or botanical supplements/remedies/teas. No 411.11 Routinely not providing dietary supplements recognized as essential by national public health policy when an infant’s diet alone cannot meet nutrient requirements I – IV • Infants who are 6 months of age or older who are ingesting less than 0.25 mg of fluoride daily when the water supply contains less than 0.3 ppm fluoride. • Infants who are exclusively breastfed, or who are ingesting less than 1 liter (or 1 quart) per day of vitamin-D fortified formula, and are not taking a supplement of 400 IU of vitamin D. No

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Revised California WIC Policy and Procedure Manual Page 24 of 36 Oct 1, 2025 425 Risk Series: DIET – Inappropriate Nutrition Care Practices for Children USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 425.1 Routinely feeding inappropriate beverages as the primary milk source C – V Examples of inappropriate beverages as primary milk source: • Non-fat or reduced-fat milks (between 12 and 24 months of age only) or sweetened condensed milk. • Goat’s milk, sheep’s milk, or unfortified or inadequately fortified substitute milks (such as unfortified rice, almond or soy based beverages, non-dairy creamer, or homemade concoctions). No 425.2 Routinely feeding a child any sugar- containing fluids C – V Examples of sugar-containing fluids: soda/soft drinks, gelatin water, corn syrup solutions, sweetened tea. No 425.3 Routinely using nursing bottles, cups, or pacifiers improperly C – V • Using a bottle to feed fruit juice, diluted cereal or other solid foods. • Allowing the child to fall asleep or be put to bed with a bottle at naps or bedtime. • Allowing the child to use the bottle without restriction (e.g., walking around with a bottle) or as a pacifier. • Using a bottle for feeding or drinking after 14 months of age. • Using a pacifier dipped in sweet agents (e.g., sugar, honey, syrups). • Allowing a child to carry around and drink throughout the day from a covered or training cup. No

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Revised California WIC Policy and Procedure Manual Page 25 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 425.4 Routinely using feeding practices that disregard the developmental needs or stage of the child C – V • Inability to recognize, insensitivity to, or disregarding the child’s cues for hunger and satiety (e.g., forcing a child to eat a certain type and/or amount of food or beverage or ignoring a hungry child’s requests for appropriate foods). • Feeding foods of inappropriate consistency, size, or shape that put children at risk of choking. • Not supporting a child’s need for growing independence with self- feeding (e.g., solely spoon-feeding a child who is able and ready to finger-feed and/or try self-feeding with appropriate utensils). • Feeding a child food with an inappropriate texture based on his/her developmental stage (e.g., feeding primarily pureed or liquid food when the child is ready and capable of eating mashed, chopped or appropriate finger foods). No 425.5 Feeding foods to a child that could be contaminated with harmful microorganisms C – V Examples of potentially harmful foods for a child: • Unpasteurized fruit or vegetable juice. • Unpasteurized dairy products or soft cheeses such as feta, Brie, Camembert, blue-veined, and Mexican-style cheese. • Raw or undercooked meat, fish, poultry, or eggs. • Raw vegetable sprouts (alfalfa, clover, bean, and radish). • Deli meats, hot dogs, and processed meats (avoid unless heated until steaming hot). No 425.6 Routinely feeding a diet very low in calories and/or essential nutrients C – V • Vegan diet • Macrobiotic diet • Other diets very low in calories and/or essential nutrients No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 26 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 425.7 Feeding dietary supplements with potentially harmful consequences C – V Examples of dietary supplements which, when fed in excess of recommended dosage, may be toxic or have harmful consequences include but may not be limited to: single or multi-vitamins, minerals supplements, herbal or botanical supplements/remedies/teas No 425.8 Not providing dietary supplements recognized as essential by national public health policy when a child’s diet alone cannot meet requirements C – V • Providing children under 36 months of age less than 0.25 mg of fluoride daily when the water supply contains less than 0.3 ppm fluoride. • Providing children 36-60 months of age less than 0.50 mg of fluoride daily when the water supply contains less than 0.3 ppm fluoride. • Not providing 400 IU of vitamin D if a child consumes less than 1 liter (or 1 quart) of vitamin D fortified milk or formula. No 425.9 Routine ingestion by child of nonfood items (pica) C – V • Ashes • Carpet fibers • Cigarettes or cigarette butts • Clay • Dust • Foam rubber • Paint chips • Soil • Starch (laundry and cornstarch No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 27 of 36 Oct 1, 2025 427 Risk Series: DIET – Inappropriate Nutrition Care Practices for Women USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 427.1 Consuming dietary supplements with potentially harmful consequences P – IV B – IV N – VI Examples of dietary supplements which, when ingested in excess of recommended dosage, may be toxic or have harmful consequences: • Single or multi-vitamins • Mineral supplements • Herbal or botanical supplements/remedies/teas • Cannabidiol (CBD), for Pregnant and Breastfeeding participants only (Products labeled as CBD with any form of THC should be a risk with 372) No 427.2 Consuming diets very low in calories/ nutrients; impaired intake/absorption after bariatic surgery P – IV B – IV N – VI • Low-calorie diet • Strict vegan diet • Any other diet restricting calories and/or essential nutrients No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 28 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 427.3 Compulsively ingesting non-food items (pica) P – IV B – IV N – VI • Dirt • Starch (laundry and cornstarch) • Large quantities of ice and/or freezer frost • Cigarette ashes • Baking soda • Burnt matches • Coffee grounds • Chalk • Uncooked rice • Clay • Paper No 427.4 Inadequate vitamin/mineral supplementation P – IV B – IV N – VI • Consumption of less than 27 mg of iron as a supplement daily by a pregnant participant. • Consumption of less than 150 mcg of supplemental iodine per day by pregnant and breastfeeding participants. • Consumption of less than 400-800 mcg of folic acid from supplements daily by pregnant, breastfeeding, and non-breastfeeding participants. No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 29 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 427.5 Pregnant woman ingesting foods that could be contaminated with pathogenic microorganisms P – IV Potentially harmful foods: • Seafood: Any raw or undercooked fish, or shellfish, or food containing raw or undercooked seafood, e.g., sashimi, found in some sushi or ceviche; Refrigerated smoked fish; Partially cooked seafood, such as shrimp and crab. • Raw or undercooked meat or poultry. • Hot dogs, luncheon meats (cold cuts), fermented and dry sausage and other deli-style meat or poultry products unless reheated until steaming hot. • Pâtés: Unpasteurized, refrigerated pâté or meat spreads. • Deli Salads: Deli Salads prepared without preservatives in a deli-type store or restaurant. • Unpasteurized milk or foods containing unpasteurized milk. • Soft cheeses made with unpasteurized milk such as feta, Brie, Camembert, blue-veined cheeses and Mexican style cheeses such as queso blanco or queso fresco. • Eggs: Raw or undercooked eggs or foods containing raw or lightly cooked eggs including certain salad dressings (Ceasar), cookie and cake batters, sauces, and beverages such as unpasteurized eggnog. • Raw sprouts (alfalfa, bean, radish, microgreens). • Unpasteurized fruit or vegetable juices. • Unwashed fruits and vegetables. No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 30 of 36 Oct 1, 2025 428 Risk Series: DIET – Presumed Eligibility for Infants and Children < 2 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 428 Dietary Risk Associated with Complementary Feeding Practices I – IV (>4 mo) C – V (<24 mo) An infant or child who has begun to or is expected to begin to: 1. consume complementary foods and beverages. 2. eat independently. 3. be weaned from breast milk or infant formula, or 4. transition from a diet based on infant/toddler foods to one based on the Dietary Guidelines for Americans. A complete nutrition assessment, including for risk #411, Inappropriate Nutrition Practices for Infants, or #425, Inappropriate Nutrition Practices for Children, must be completed prior to assigning this risk. No 500 Risk Series: OTHER RISKS – Miscellaneous USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 502 Transfer of Certification P – V B – V N – V I – V C – V Person with current valid Verification of Certification (VOC) card from another State agency. The VOC is valid through the end of the current certification period, even if the participant does not meet the receiving agency’s nutritional risk, priority, or income criteria, or the certification period extends beyond the receiving agency’s certification period for that category, and must be accepted as proof of eligibility for program benefits. No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 31 of 36 Oct 1, 2025 600 Risk Series: OTHER RISKS – Breastfeeding Mother/Infant Dyad USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 601 Breastfeeding Mother of Infant at Nutritional Risk P – I, II, or IV B – I, II, or IV A breastfeeding person whose breastfed infant has been determined to be at nutritional risk. No 602 Breastfeeding Complications or Potential Complications (Women) P – I B – I A breastfeeding person with any of the following: • Severe breast engorgement • Recurrent plugged ducts • Mastitis (fever or flu-like symptoms with localized breast tenderness) • Flat or inverted nipples • Cracked, bleeding or severely sore nipples • Age ≥ 40 years • Failure of milk to come in by 4 days postpartum • Tandem nursing (breastfeeding two siblings who are not twins) No 603 Breastfeeding Complications or Potential Complications (Infants) I - I A breastfeeding infant with any of the following complications or potential complications: • Jaundice • Weak or ineffective suck • Difficulty latching onto parent’s breast/chest • Inadequate stooling (for age, as determined by a physician or other health care professional), and/or less than 6 wet diapers per day. No

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Revised California WIC Policy and Procedure Manual Page 32 of 36 Oct 1, 2025 700 Risk Series: OTHER RISKS – Infant of a WIC-eligible Mother USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 701 Infant up to 6 months old of WIC mother or of a woman who would have been eligible during pregnancy I – II (< 6 mo) An infant < 6 month of age whose parent was a WIC Program participant during pregnancy or whose parent’s medical records document that the person was at nutritional risk during pregnancy because of detrimental or abnormal nutritional conditions detectable by biochemical or anthropometric measurements or other documented nutritionally related medical conditions. No 702 Breastfeeding infant of woman at nutritional risk I – I or IV Breastfeeding infant of person at nutritional risk. No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 33 of 36 Oct 1, 2025 800 Risk Series: OTHER RISKS – Homeless/Migrant USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 801 Homelessness P – IV B – IV N – VI I – IV C – V A pregnant/postpartum individual, infant or child who lacks a fixed and regular nighttime residence; or whose primary nighttime residence is: • A supervised publicly or privately operated shelter (including a welfare hotel, a congregate shelter, or a shelter for victims of domestic violence) designed to provide temporary living accommodations. • An institution that provides a temporary residence for individuals intended to be institutionalized. • A temporary accommodation of not more than 365 days in the residence of another individual, or • A public or private place not designed for, or ordinarily used as, a regular sleeping accommodation. No 802 Migrancy P – IV B – IV N – VI I – IV C – V Categorically eligible pregnant, breastfeeding, and non-breastfeeding participants, infants, and children who are members of families which contain at least one individual whose principal employment is in agriculture on a seasonal basis, who has been so employed within the last 24 months, and who establishes, for the purposes of such employment, a temporary abode. No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 34 of 36 Oct 1, 2025 900 Risk Series: OTHER RISKS – Environmental USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 901 Recipient of abuse P – IV B – IV N – VI I – IV C – V An individual who has experienced physical, sexual, emotional, economic, or psychological maltreatment that may frighten, intimidate, terrorize, manipulate, hurt, humiliate, blame, injure, and/or wound the individual. The experience of abuse may be self-reported by the individual, an individual’s family member, or reported by a social worker, healthcare provider, or other appropriate personnel. Types of abuse relevant to the WIC population include, but are not limited to: • Domestic violence: abuse committed by a current or former family or household member or intimate partner. • Intimate partner violence (IPV): a form of domestic violence committed by a current or former intimate partner (i.e., spouse, boyfriend/girlfriend, dating partner, or ongoing sexual partner) that may include physical violence, sexual violence, stalking, and/or psychological aggression (including coercive tactics). • Child abuse and/or neglect: any act or failure to act that results in harm to a child or puts a child at risk of harm. Child abuse may be physical (including shaken baby syndrome), sexual, or emotional abuse or neglect of an infant or child under the age of 18 by a parent, caretaker, or other person in a custodial role (such as a religious leader, coach, or teacher). No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised California WIC Policy and Procedure Manual Page 35 of 36 Oct 1, 2025 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 902 Woman or infant/child of primary caregiver with limited ability to make feeding decisions and/or prepare food P – IV B – IV N – IV I – IV C – V Person (pregnant, breastfeeding, or non-breastfeeding) or infant/child whose primary caregiver is assessed to have a limited ability to make appropriate feeding decisions and/or prepare food. Examples may include a person or an infant/child of caregiver with the following: • Documentation or self-report of misuse of alcohol, use of illegal substances, use of marijuana, or misuse of prescription medications. • Mental illness, including clinical depression (diagnosed by a physician or psychologist, or as self-reported). • Intellectual disability (diagnosed by a physician or psychologist, or as self-reported). • Physical disability which restricts or limits food preparation abilities. • ≤ 17 years of age. No 903 Foster Care P – IV B – IV N – VI I – IV C – V Entering the foster care system during the previous six months or moving from one foster care home to another foster care home during the previous six months. Cannot be used for consecutive certifications while the child remains in the same foster home. It should be used as the sole risk criterion only if careful assessment of the applicant’s status indicates that no other risks based on anthropometric, medical or nutritional risk criteria can be identified. No

Nutritional Risks Criteria and Descriptions WPPM #960-01 Job Aid

Revised Oct 1, 2025 California WIC Policy and Procedure Manual Page 36 of 36 USDA Code Risk Criteria Category Priority Definition and Cutoff High Risk 904 Environmental Tobacco Smoke Exposure P – I B – I N – VI I – I C – III Exposure to smoke from tobacco products inside enclosed areas, such as the home, place of child care, etc. ETS is also known as passive, secondhand, or involuntary smoke. ETS definition also includes the exposure to the aerosol from electronic nicotine delivery systems. No *Condition diagnosed by a physician and self-reported by the applicant/participant/caregiver, or as reported or documented by a physician or someone working under a physician’s orders.