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Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
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Access to WIC Services During Natural Disasters/Emergencies
Policy: This Colorado WIC disaster plan is intended to minimize the negative impact of program disruptions to WIC operations and services and ensure the availability of authorized supplemental foods to the extent feasible during an emergency/disaster. WIC clinics must make options available for clients who cannot come to regularly scheduled appointments.
Regulation: CFR 246.4(a)(23), USDA Guide to Coordinating WIC Services During Disaster
Procedure/Additional Guidance: Emergencies, natural disasters and, extreme weather, can prevent either clients or local staff from traveling to the clinic. As clinics consider WIC accessibility, it is important to ensure WIC services are accessible by offering the following:
● Reschedule client’s appointment to the next available time slot within the same month if they miss their scheduled appointment. If rescheduling, due to clinic appointment availability, would result in delayed or missed food benefits, agencies should issue enough monthly food benefits to ensure there are no gaps in the client’s benefits until their next scheduled appointment whenever possible. ● Certify as soon as possible or within 10 days of their request for WIC benefits. ● Offer remote appointments to provide flexibility and convenience. o In times of disaster, clients may not be able or interested in completing nutrition education via phone or wichealth.org. In such cases, provide the nutrition education at the next visit. If contacting currently scheduled clients to issue benefits, document in the Care Plan that the reason nutrition education was not provided is due to a disaster. ● Set aside weekly or monthly time slots for clients to make up missed appointments. ● Offer same day or extended hours including lunchtime, weekends, and evenings, if possible. ● Extend an infant’s or child’s certification period when possible. ● If a client is coming from out-of-state, ask for a Verification of Certification (VOC). For those without a VOC, staff should attempt to obtain one to use as proof of both income and nutritional risk eligibility. For a list of state VOC contacts click this link: https://www.fns.usda.gov/wic/wic- contacts. ● Upon certification, provide Colorado WIC VOC information to help with the continuation of benefits when the client returns to their home State. ● Families affected by disaster may temporarily move in with another household. The displaced individuals may be considered homeless and treated as a separate household or economic unit. If families are unable to provide the required proof of identity, income and/or address, they may use the affidavit option.
Formula Issuance and Replacement During an emergency/disaster, obtaining medical documentation may be challenging. In such cases, medical authorization for formulas can be accepted over the phone for up to 1 month, instead of the standard 2 weeks. Written documentation is required for the issuance of medical formulas and nutritionals beyond 1 month. For clients who were previously on WIC in another state, staff should make an effort to obtain the VOC. However, clinics may issue one month of benefits of any special formula or medical food that the client states they were previously receiving before evacuating. ● Formula Replacement: During a disaster, Colorado WIC may replace infant formula and nutritionals that were destroyed. Only formula/nutritionals purchased in the current benefit month can be replaced. State agency staff will provide specific guidance on formula replacement specific to the situation through normal Colorado WIC communication channels, including email, staff newsletters, and director meetings.
o For individual emergencies including but not limited to house fires, floods, and theft, please review the Exchange and Replacement of Benefits policy for guidance.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
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● Formula Delivery: Local agency staff should use all available options to ensure clients can obtain the necessary formula during a disaster. If formulas are not available at grocery stores or if clients are unable to travel to stores due to a disaster, staff should place orders using the Ordering Instructions for Products Not on Retail Shelves procedure. o During a presidentially declared disaster, formula may be delivered to homes by Colorado WIC specialty pharmacies without obtaining State Office permission. Local agency staff should continue to follow standard procedures for placing formula orders.
For any formula-related issues or concerns during a disaster, local agency staff should email cdphe.wicformula@state.co.us. Please note this email address is for WIC staff use only, and should not be provided to WIC clients. WIC clients and external partners should use askwic@state.co.us for inquiries.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
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Adjunctive Eligibility
Policy: Colorado WIC accepts current participation in Health First Colorado (Colorado Medicaid) or any of Colorado’s other Medicaid Programs (e.g. Health First Colorado Limited/Emergency Medicaid, Transitional Medicaid, etc.), Temporary Assistance to Needy Families (TANF - referred to as Colorado Works Program), or the Supplemental Nutrition Assistance Program (SNAP)/Food Distribution Program on Indian Reservations (FDPIR) as evidence of financial eligibility for participation in WIC. This also includes participants who are presumptively eligible for Health First Colorado (Medicaid). This is referred to as adjunctive eligibility or automatic WIC income eligibility.
An individual enrolled in one of the above public assistance programs is adjunctively income eligible for WIC even if their income exceeds the WIC Income limits Eligibility Guidelines.
Participation in CHP+ or the Behavioral Health Administration Benefit DOES NOT qualify a client for Adjunctive Eligibility.
Regulation: 7 CFR 246.7(d)(2), WIC Policy Memo 94-28
Procedure/Additional Guidance: All applicants and participants must be screened at certification and recertification for participation in one of the programs that would make them adjunctively or automatically income eligible for WIC.
Colorado Medicaid Programs (Regular, Emergency, Transitional Medicaid Program, Presumptive Eligibility, etc.) will be referred to as Health First Colorado/Medicaid within the policy.
Health First Colorado/Medicaid Participation ● Verify the participant is a current Health First Colorado/Medicaid participant. o Determine current participation by one of the following: ▪ Phone verification: Call the Colorado Medical Assistance Program Provider Assistance Telephone number: 1-833-468-0362 and enter the following information when prompted: ● Colorado WIC’s non-billing provider number: 83037331. ● Participant’s Member ID (Health First Colorado/Medicaid number) or social security number and date of birth. ● Health First Colorado/Medicaid Provider Portal using the local agency provider number (not available to all local agencies). ▪ Award letter with the dates of eligibility. The WIC certification/recertification date must be within the enrollment dates listed on the Health First Colorado/Medicaid Award letter. ▪ Colorado PEAK system or the Colorado Benefit Management System (CBMS). o If verified, enter the proof in the Adjunct Eligibility field in Compass and the Health First Colorado/Medicaid number in the ‘MA ID’ field. ● While proof of gross income is not required when proof of adjunctive or automatic eligibility has been established, to meet federal data collection requirements staff must ask the participant to self-report their household’s gross income o Enter the amount in the Income Determination field of Compass with “See Proof” as the Source and Medicaid/SNAP/TANF/FDPIR as the Proof. Once the participant is determined to be currently participating on Health First Colorado/Medicaid, SNAP, or TANF, no other proof of income is required. ● If Health First Colorado/Medicaid cannot be verified and no other proofs of income are available, but the participant brought proof of identity and address, staff may provisionally certify the participant. The participant must return within 30 days with acceptable proof of income. ●
Supplemental Nutrition Assistance Program (SNAP) Participation ● Verify the participant is a current SNAP by ensuring the participant’s name is listed on the SNAP Award Letter.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
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o The WIC certification/recertification date must be within the enrollment dates listed on the SNAP Award Letter, through the Colorado PEAK system or CBMS. o If the participant’s name is not on the SNAP Award Letter, another proof of income must be supplied. ● If verified, check the SNAP box in the Adjunct Eligibility field next to each participant’s name who is listed on the SNAP Award Letter and select “Award letter” from the dropdown in the Proof field. ● Staff must ask the participant to self-report their household’s gross income. ● Enter the amount in Compass in the Income Determination field with “See Proof” as the Source and Medicaid/SNAP/TANF/FDPIR as the Proof.
Food Distribution Program on Indian Reservations (FDPIR), or Temporary Assistance for Needy Families (TANF) Participation: ● Verify the participant is a current, FDPIR or TANF participant. o The WIC certification/recertification date must be within the enrollment dates listed on the /FDPIR or TANF Eligibility Notice, through the Colorado PEAK System or the CBMS. ● If verified, check the TANF box in the Adjunct Eligibility field and select the proof from the dropdown in the Proof field. ● Staff must ask the participant to self-report their household’s gross income. ● Enter the amount in Compass in the Income Determination field with “See Proof” as the Source and Medicaid/TANF/FDPIR as the Proof.
Adjunctive income eligibility applies to other household members when: ● Anyone in the household has FDPIR or TANF benefits. ● A pregnant woman or infant has Health First Colorado/Medicaid. o Note: When a newborn's mother has Health First Colorado/Medicaid benefits, that infant is automatically eligible to receive Health First Colorado/Medicaid until one year of age as a result of the Needy Newborn Health First Colorado Coverage legislation. If the newborn's WIC certification occurs prior to the infant being assigned a Health First Colorado/Medicaid number, enter “Pending” for the infant in the MA ID field in Compass and update the record once the Health First Colorado/Medicaid number is known.
See the chart below to help determine who else in the family may be covered by the adjunct eligibility of one family member. Applicant/Participant Medicaid TANF SNAP* FDPIR Pregnant woman Entire household Entire household The woman only Entire household Infant Entire household n/a (infants and children would not receive benefits individually)
The infant only Entire household Child The child only The child only Entire household Postpartum woman The postpartum woman only Entire household The postpartum woman only Entire household Foster Infant or Child The foster infant/child only n/a The foster infant/child only n/a Any other household member (example: father) n/a Entire household n/a Entire household *For SNAP, only those participant’s names who appear on the SNAP Award Letter may use SNAP for adjunctive eligibility.
Adjunctive income eligibility does not apply to other household members when:
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
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● A child has Health First Colorado/Medicaid. o In the instance where a child presents an active Health First Colorado/Medicaid card as proof of income and other family members are categorically eligible but do not have proof of income, complete the Adjunct Eligibility link for the child with Health First Colorado/Medicaid and leave the Income Determination box blank. Next certify the child and provisionally certify the remaining participants in the household. ● A foster child (even if an infant) has Health First Colorado/Medicaid. o A foster child can never confer adjunctive income eligibility to other household members since WIC considers the foster child a one-person household. ● A postpartum woman has Health First Colorado/Medicaid. Please see the note for Needy Newborn Medicaid Coverage Legislation Coverage for the infant exception. ● Not all family members have SNAP.
Colorado WIC Program Policies and Procedures Section 11: Civil Rights
Revised: 10/01/2018
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Administrative Review Policies and Procedures for Local Agency Appeals
Policy: The State agency must provide full administrative reivews to local agencies that appeal specific adverse actions.
Regulations: 7 CFR 246.18
Procedures/Additional Guidance: Administrative Review Procedures allow affected local agencies, who file an appeal concerning one of the actions listed in Subsection B of this policy, an opportunity to have a formal hearing by an impartial Administrative Hearing Official (hearing officer) at the State level. Hearings will be conducted in accordance with the Administrative Procedures Act, §24-4-105 and §24-4-106 C.R.S., Code of Federal Regulations 7 Part 246 and WIC policy and procedures.
These procedures provide a mechanism to ensure that: Local WIC Agencies (agency) have an objective and impartial avenue of redress when they feel they have been denied authorization, treated unfairly, or have had an adverse action taken against them by the State WIC Program (Program). Program standards, policies, procedures and regulations are being applied without prejudice.
Actions subject to Administrative Review The following actions are subject to an Administrative Review: Denial of local agency’s application; Disqualification of a local agency; and Any other adverse action that affects a local agency’s participation.
Actions not subject to Administrative Review The following actions are not subject to an Administrative Review: Expiration of an agreement; Denial of a local agency application if the State WIC Program’s selection is subject to the procurement procedures applicable to the Colorado Department of Public Health and Environment (Department).
Procedures for an Administrative Review Notification of Action When the adverse action is denial of a local agency’s application, such denial is effective immediately, and no advance notice will be issued. For all other adverse actions, the Program will provide the local agency with a written notice of the adverse action at least sixty (60) calendar days prior to the effective date of the action. The notice of the adverse action shall include the action being taken, the cause(s) for the action, the effective date of the action, and the right to appeal the action. A copy of the Administrative Review Procedures will also be provided. Appealing an Action Within thirty (30) calendar days of the receipt of the notice of action, the local agency must submit a written request for an Administrative Review to the State WIC Program. The written request should include the local agency name, action(s) being appealed, and the date of the request. A request for a hearing will be denied or dismissed if:
- the request is not received within thirty (30) calendar days from the date the notice is received by the local agency; - the request is withdrawn in writing by the local agency or representative; and/or - the local agency or representative failed, without good cause as determined by the hearing officer, to appear at the scheduled hearing. Appealing an action does not relieve a local agency, permitted to continue in the Program while its appeal is in process, from the responsibility of continued compliance with the terms of the contract. The adverse action affecting a participating local agency shall be postponed until a hearing decision is reached. Administrative Review Hearing - General Rules and Procedures
Colorado WIC Program Policies and Procedures Section 11: Civil Rights
Revised: 10/01/2018
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Upon receipt of the appeal request, the Program shall notify the local agency, in writing, that it has received the request. An explanation of the hearing procedures will be sent with the notice. The local agency will receive a minimum of ten (10) calendar days’ advance written notice of the time and place of the hearing. At the time of the written notice the State WIC Office will notify the local agency of their right to: - examine, prior to or during the hearing, the documents and records presented to support the decision under appeal; - be assisted or represented by an attorney or other persons; - bring witnesses; - advance arguments without undue interference; - question or refute any testimony or evidence, including an opportunity to confront and cross-examine adverse witnesses; and - submit evidence to establish all pertinent facts and circumstances in the case. The Department will provide a hearing officer, an impartial decision maker, whose decision as to the validity of the action shall rest solely on the evidence presented at the hearing, the federal regulations and the Program’s policies and procedures. The local agency shall have the opportunity to present its case and at least one opportunity to reschedule the hearing date upon request. The hearing shall be conducted in accordance with the provisions of §24-4-105 C.R.S. Administrative Review Decision Within sixty (60) calendar days of the receipt of the request for a hearing, the hearing officer must issue an initial Administrative Review Decision (decision) providing a summary of the facts of the case, specifying the reasons for the decision, and identifying the supporting evidence and the pertinent regulations or policy. The initial decision of the hearing officer shall be submitted, in writing, to the Executive Director of the Department. A copy of the decision will also be provided to the State WIC Program and the local agency. The local agency or Program may file a written appeal of the initial decision with the Department’s Executive Director within fifteen (15) calendar days of receipt of the initial decision. The Executive Director may affirm, modify, or reverse the initial decision in accordance with C.R.S. 24-4-105. If an appeal is not received within fifteen (15) calendar days, the initial decision of the hearing officer will be adopted by the Executive Director and shall constitute the final action. If the decision is in favor of the local agency and authorization was denied the local agency will be authorized on receipt of the administrative review decision. If the decision regarding repayment of funds by the local agency is in favor of the Program, efforts to collect the funds will resume immediately. Immediately upon receipt of notice of the initial decision, the Program shall comply with the decision unless an appeal is filed pursuant to §24-4-105 C.R.S. After an unsuccessful appeal, the local agency and/or Program shall comply with the decision. The effective date of the action is the date the local agency receives the decision. Withdrawal or Default of an Appeal A withdrawal of an appeal occurs when the local agency states, in writing, that it no longer wishes a hearing. A default occurs when the local agency fails to appear at the hearing without good cause, or the local agency cannot be located through the last address of record.
Judicial Review If the Department’s final decision is rendered against the local agency, judicial review may be pursued in accordance with §24-4-106 C.R.S.
§ 24-4-105. Hearings and determinations & § 24-4-106. Judicial review Links are more effective using Google Chrome
Colorado WIC Program Policies and Procedures Section 11: Civil Rights Revised:10/01/2020
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Administrative Review Policy and Procedures for Retailer Appeals
Policy: Policies and procedures must be in place that provide a mechanism to ensure that: Retailers have an objective and impartial avenue of redress when they feel they have been denied authorization, treated unfairly, or have had an adverse action taken against them by the State WIC Program (Program) and/or Local WIC Agency (Agency); and Program standards, policies, procedures and regulations are being applied without prejudice.
Regulations: 7 CFR 246.12 Food delivery methods (6) Actions subject to administrative review and review procedures.)
Procedures/Additional Guidance: Administrative Appeals Procedures for food vendors are detailed in the Retailer Handbook.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2025
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Anthropometric and Blood Screening
Policy: Appropriate procedures and equipment will be used to obtain participant weight, length/ height, and hemoglobin measurements when taken in WIC clinics. Every effort should be made to obtain measurements and hemoglobins/ hematocrits as required by policy. Measurements and hemoglobins may be gathered in the WIC clinic or from alternative trusted reliable sources (e.g. health care provider, community health center or program, health department, Head Start, etc.) or delayed. Heights and weight measurements may be delayed 60 days and hemoglobin 90 days. Only one repeat attempt is necessary for gathering heights, weights, and hemoglobins. Participants will not be terminated for failure to provide heights, weights, or hemoglobins.
Regulation: 7 CFR 246.7(e)(1)(i)(A) and (B), 7 CFR 246.7(e)(1)(ii)(B), 7 CFR 246.7(e)(1)(ii)(A), 7 CFR 246.7(e)(2)(i)(A) Memo 92-10 Bloodwork Protocols, 2001-2 Bloodwork
Procedures/Additional Guidance: The ongoing collection of accurate medical/nutritional data for participants allows WIC to provide nutrition education, appropriate referrals to other health services, determine nutrition risk factors and assign the appropriate food packages.
Options for Gathering Heights/Weights and Hemoglobins Heights/lengths, weights and hemoglobins may be gathered in a number of ways. Some options include: • Obtain in the WIC clinic heights, weights and hemoglobins measurements on a different day than the WIC appointment (cert/recert) by using the “Anthro/Hgb Only” appointment type or allowing walk-ins. • Obtain heights/weights in the WIC clinic at the same time as the WIC appointment (cert/recert). • Participant verbally reports the anthros/hemoglobin taken at a trusted reliable source (e.g. health care provider, etc) o Note: A measurement taken at home is not allowed.
WIC staff must enter the date when the measurement was taken in the Anthropometric panel (for heights/weights) or Blood panel (for hemoglobins) in Compass.
Refer to the Anthropometric and Blood Screen Schedules below for information on when measurements must be obtained.
Gathering Heights/Weights and Hemoglobins From A Trusted Reliable Source (e.g. healthcare providers, community health center or program, health department, Head Start, etc.) Medical data may be obtained from outside the WIC Program such as through a health care provider, public health nurse, or other public health program. Local WIC clinics are encouraged to obtain information from other sources to prevent repeated measurements, especially repeat hemoglobin measurements.
Anthropometric Measurements: Height and weight measurements from other sources may be used to determine WIC eligibility if the measurement is no more than 60 days old (from the date of actual WIC certification). Weight measurements for women should also reflect the physiological state for which she is being certified. For example, a postpartum woman’s weight should be from the time that she is postpartum and not from when she was pregnant. • In order to differentiate between anthros taken in the WIC clinic vs. those reported from a trusted reliable source, staff need to check the “Inaccurate Reason” check box, and choose “Reliable Source/Health Provider” from the drop down. Although the measurements may be accurate from a trusted reliable source, documenting the measurements in this way allows WIC staff to see which measurements were taken at the WIC clinic vs. the measurements taken at another location.
Hemoglobin Measurements: There is no time limit on how old a hemoglobin value can be when certifying a WIC participant as long as the measurement meets the following criteria:
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2025
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• For a woman: The hemoglobin value must correspond with the participant’s category for which she is being certified/recertified. For example, for a pregnant woman, the hemoglobin must have been performed at some time during the current pregnancy for which she is being certified. For a breastfeeding or postpartum woman, the hemoglobin must have been performed after the end of the woman’s most recent pregnancy. • For an infant or child: The hemoglobin must have been performed between 9-12 months of age, again between 15-18 months of age, and at least yearly after 18 months of age if the previous hemoglobin value was normal. If the previous hemoglobin value is abnormal, the hemoglobin should be repeated every 6 months until a normal value is obtained and then yearly thereafter.
If the anthropometric or hemoglobin measurement was taken on a day other than the day certification occurs, the WIC staff must enter the date when the measurement was taken in the Anthropometric panel in Compass.
Repeat Hemoglobin Measurements Taken At The WIC Clinic: WIC funds may be used for only one repeat hemoglobin measurement within a certification period.
When A Participant Reports Anthros or Hemoglobins ThatSeem Inaccurate: Use your best judgement. If a participant verbally reports weights/heights or hemoglobins from a trusted reliable source that appear inaccurate, enter the information in to the Anthropometric panel or Blood panel of Compass and make note of this issue in the Care Plan.
Delaying Anthropometrics and Hemoglobins Anthropometrics Delayed (60 days): Measurements may be delayed for up to 60 days. Since the height and weight field is required in Compass, you will need to do the following based on whether or not the participant has had a previous WIC anthropometric record: • Participant has had a previous WIC anthropometric record: Go back to the previous measurement record and note the measurement date, height and weight. In the Anthropometric panel of Compass, enter the previous Measurement Date, weight and height and choose “Delayed up to 60 days” from the Inaccurate Reason drop down. • Participant does not have a WIC anthropometric record: In the Anthropometric panel of Compass, enter the Measurement Date of today (the system defaults to this) and take a verbal on the participant’s weight and height. Then choose “Delayed up to 60 days” from the Inaccurate Reason drop down.
Hemoglobin Delayed (90 days): The hemoglobin screening may be delayed for up to 90 days. In the Blood panel of Compass, click “No” in the Blood Work Taken field, and choose “Delayed up to 90 days” from the No Test Performed Reason drop down.
Hemoglobin Exemptions Exemption - The only reasons which exempt an applicant/participant from hemoglobin testing are:
Religious: If an applicant/participant’s religious beliefs won’t allow him or her to have blood drawn, staff must choose “Religious” from the No Test Performed Reason drop down in the Blood panel in Compass.
Medical Reasons: If an applicant/participant has a medical condition (e.g. hemophilia, fragile bones (osteogenesis imperfecta, or serious skin condition) in which the hemoglobin screening procedure could cause harm to the applicant/participant, documentation from the health care provider of the medical condition must be submitted to WIC and scanned into Compass. If the noted condition is considered treatable, such as a serious skin condition, a new statement from the health care provider would be required for each recert. If the condition is considered “life long” such as hemophilia, a new statement from the health care provider is not necessary for the next recert.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2025
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An unknown hemoglobin/hematocrit CANNOT be used as a qualifying risk factor for WIC participation. Participants refusing a hemoglobin/hematocrit screening for religious or medical reasons must qualify for WIC using another nutritional/medical risk factor.
Hemoglobin Non-compliant/Refusal If the staff is unable to obtain a hemoglobin in the clinic due to the participant being non-compliant (e.g. child may harm staff or themselves during hemoglobin procedure), staff may delay the hemoglobin for 90 days, document the situation and attempt at a later date. In Compass, click “No” for Blood Work Taken and “Noncompliant/Refused” in the No Blood Work Reason drop down. If the participant is non-compliant at a later date again, document the second attempt in the participant’s record.
If a participant refuses to have a hemoglobin screening performed and the reasons are not for religious or medical, review the importance of the screening and explore with the participant the possibility of obtaining the information at a later date at the WIC clinic or from their health care provider.
When staff are unable to obtain the hemoglobin due to noncompliance or refusal, in the Blood panel of Compass, mark “No” in the No Text Performed Reason and mark “Noncompliant/Refused”.
One Repeat Attempt is Required for Anthropometrics and Hemoglobins When the initial attempt to gather the height, weight, or hemoglobin is unsuccessful for whatever reason, only one repeat attempt is required. If the one repeat attempt is unsuccessful, the missed appointment is sufficient documentation to show the one repeat attempt. If there is no appointment or the client attends the appointment but doesn't provide the missing measurement, then the one repeat attempt must be documented in the Care Plan.
Anthropometric and Blood Screen Schedules Pregnant Women At each certification visit: Hemoglobin or Hematocrit Weight Height. Nutrition Interview. It is best practice to gather a weight measurement during each trimester for pregnant women at the follow-up prenatals visits, although it is not required. -For women who are seeing a healthcare provider for their pregnancy, gather the weight from the woman that was taken at her most recent doctor’s appointment or you can offer an in-person appointment to obtain her weight in the clinic. -When a pregnant woman has no health care provider, you can schedule an in-person WIC appointment to obtain the weight. If there is hardship coming into the clinic (travel, disability, or a health condition) and the client is unable to come into the clinic, benefits should not be withheld. This weight is not a requirement, but a best practice.
Postpartum Non-Breastfeeding Women At each certification visit: Weight. Height (for recertifications, a height needs to be taken for women less than 18 years of age only). Hemoglobin or Hematocrit. Nutrition Interview.
Breastfeeding Women At initial certification visit after delivery: Breastfeeding Support. Weight. Height (for recertifications, a height needs to be taken for women less than 18 years of age only). Hemoglobin or Hematocrit.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2025
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Nutrition Interview.
Infants and Children: Weights and heights are to be taken at the cert/recert appointments. For infants, it is recommended that weights and heights are obtained at the mid-cert and and follow-upappointments, though it is not required.
A hemoglobin must be performed between 9-12 months of age, again between 15-18 months of age, and at least yearly after the 15-18 month hemoglobin if the value was normal. If the hemoglobin value was abnormal, the hemoglobin should be repeated every 6 months until a normal value is obtained and then yearly thereafter. After the 15-18 months hemoglobin, clinic staff may wish to do the next hemoglobin at the recert appointment (6 months later) regardless of whether the hemoglobin was normal or abnormal in order to sync the hemoglobin schedule with the recert schedule.
Immunization Screening: Staff members are required to ask endorsers to bring immunization records to all certification, recertification, and mid-cert visits for participants less than 25 months of age. If the record is available in the Colorado Immunization Information System (CIIS), agencies with access may use the CIIS electronic record instead of obtaining the immunization information from the caregiver. These records must be assessed for DTaP shots. If the information is not available in CIIS and the endorser does not bring their immunization records to the visit, the records cannot be assessed and staff should select "no" to the Compass question (Nutrition Interview, Immunization section, question 2a) "Can we look over your child's shot record today?" In those situations, staff must ask if the infant or child is up-to-date on their immunizations and document the caregiver’s verbal report in the Nutrition Interview or Care Plan. Endorsers/participants cannot be required to bring the participant’s immunization record to WIC visits. Once a child has received their four DTaP immunizations, WIC staff no longer need to ask about the child's immunization status.
Lead Screening: Local WIC Programs must ask if every child, starting at their one-year certification appointment or upon enrollment beginning at 12 months of age, has had a blood lead screening test. If the child has not been tested, they must be referred to their doctor or another program where the test can be obtained during each certification, recertification, and mid-certification. Document lead screening referrals in the Nutrition Education Panel by selecting "Referred for Lead Screening" under child standard counseling. Once a lead test is performed and documented in the Blood panel in Compass, staff no longer need to ask about lead testing or provide a referral during subsequent recertifications and mid-certifications. The Lead Level Measurement field in the Blood panel in Compass can be left blank.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 03/01/2026 Page 1 of 6
Breastfeeding Peer Counseling Program: Allowable Costs
Policy: Breastfeeding Peer Counseling (BFPC) funds that USDA Food and Nutrition Services (FNS) distributes to State agencies are to be used to develop or expand activities necessary to sustain a peer counseling program based on the FNS WIC Breastfeeding Model Components for Peer Counseling. The primary purpose of the funds is to provide direct breastfeeding support services through peer counseling to WIC participants. The use of BFPC funds for expenditures that are not supported by the WIC Breastfeeding Model Components for Peer Counseling are not authorized.
Funding for peer counseling is provided to local agencies (LAs) through a separate grant based on state resources. Allowable costs are defined by the USDA. LAs must monitor breastfeeding peer counseling program expenditures to assure they are correctly reported in a timely manner.
Regulations: USDA FNS WIC Breastfeeding Curriculum: Peer Counselor Management; USDA FNS WIC Breastfeeding Curriculum (Levels 1 & 2); USDA FNS WIC Nutrition Services Standards – Standard 9; USDA FNS WIC Breastfeeding Policy and Guidance (July 2016); USDA FNS Allowable Costs for Breastfeeding Peer Counseling Funds (March 2024).
Procedure/Additional Guidance: The table on the following page defines allowable BFPC program costs based on USDA criteria.*
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Allowable Costs for Breastfeeding Peer Counseling Programs The table below helps to identify allowable BFPC costs. (Note: This is not an exhaustive list of allowable costs.) Item or Service Allowable Costs Comments Durable Goods and Space Furniture, desktop computers/laptops/tablets, and office equipment used to provide peer counseling services and training Yes
Phone lines, internet service, cell/smartphones, pagers and answering machines for contacts between peer counselors and mothers Yes
Portable baby scales to weigh infants outside of the WIC clinic or scales marketed for pre- and post- breastfeeding weight checks No Nutrition Services and Administration (NSA) funds may be used to purchase scales for clinical assessment for use by staff other than peer counselors. Space and lease costs for peer counselors to provide services
Yes
Incentives and Educational Materials to Promote Breastfeeding Breastfeeding educational materials for mothers No NSA funds may be used to purchase participant educational material. Breast pumps and breastfeeding aids for mothers
Breast pumps and breastfeeding aids for demonstration purposes by peer counseling staff
No
Yes Refer to Breastfeeding: Breast Pump Issuance Policy for more information on breast pumps and allowable breastfeeding aids. Incentive items distributed to WIC participants to encourage breastfeeding (e.g., breast pumps, breastfeeding aids, breastfeeding promotion and support incentive items, written materials, etc.)
No NSA funds may be used to purchase participant incentive items.
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Item or Service Allowable Costs Comments Personnel and Compensation Salaries and compensation for peer counseling staff: peer counselors, designated peer counselor coordinators, and WIC Designated Breastfeeding Experts (DBE) Yes. BFPC funds may be used to fund staff to provide oversight/management of peer counseling programs and/or supervision, mentoring and referral expertise for peer counselors.
BFPC funds may be used to pay for DBE time if a peer counselor refers a WIC mother to a DBE for problems that are outside of the peer counselor’s scope of practice. The DBE may be compensated using BFPC funds if the mother continues to be supported by the peer counselor and remains part of the peer counselor’s caseload. BFPC funds cannot be used to disproportionately hire WIC DBEs versus peer counselors.
NSA funds must be used for consultations for WIC mothers who are not referred by peer counselors and are not part of a peer counselor’s caseload.
Refer to the Nutrition Services Standards for DBE qualifications, roles, and responsibilities. Salaries and compensation for dual-role staff (e.g., part-time WIC Nutrition Assistant and part-time peer counselor or part-time CPA and part-time DBE) Yes, but costs must be allocated between the two positions held. BFPC funds may be used for the portion of time spent as a peer counselor or the DBE. See FNS Breastfeeding Policy and Guidance document for additional information on dual-role staff.
Males as breastfeeding peer counselors
No. The definition of peer counselor in the WIC Breastfeeding Model for Peer Counseling is based on research demonstrating the benefit of hiring peer counselors from WIC’s target population of WIC-eligible women
Personnel and Compensation Father-to-Father Breastfeeding Support Group No Fathers are valuable partners of breastfeeding promotion and support in WIC. However, father- led activities are outside of those defined by the WIC Breastfeeding Model for Peer Counseling. See FNS Peer Counseling Management Curriculum for additional information. Virtual Breastfeeding Support Groups (i.e., Facebook, Zoom) Yes, only for PC/DBE staff hours for monitoring and engaging with WIC participants in a Virtual Support Group that provides breastfeeding support services.
BFPC funds cannot be used for breastfeeding support to non-WIC participants.
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Item or Service Allowable Costs Comments Recruitment of peer counselors and related staff Yes
Milk Banks/Depots No. BFPC funds cannot be used for services related to milk banks/depots.
Drop In Breastfeeding Groups Yes. BFPC/DBE time may only be used for WIC participants. BFPC/DBE time may not be counted toward nutrition education contacts. Staffing and expenses related to WIC Peer Counselor support to the Buddy Program Yes. Duties such as matching buddy pairs, responding to buddy requests/inquiries, following up on buddy interactions, prompting discussions with conversation starters, and other duties as assigned by the peer counselor supervisor.
Staffing and expenses related to WIC Peer Counselor support to breastfeeding hotlines and call centers Yes. BFPC funds may be used to fund peer counselors to answer calls to a WIC breastfeeding hotline if the peer counselor: 1) meets the definition of peer counselor; 2) receives the appropriate training and supervision as outlined in the WIC Breastfeeding Model for Peer Counseling; and 3) does not provide services to non-WIC participants. Other expenses related to the hotline/call center (e.g., rent, phone lines, equipment, etc.) are allowable for any portion of those expenses that are for the purpose of a WIC peer counselor providing WIC participant contacts through the hotline/call center. BFPC funds cannot be used for breastfeeding hotline support to non-WIC participants. Staff Training and Resources Travel for WIC State-required training of peer counselors/DBE and peer counseling staff/managers Yes, only for the FNS Breastfeeding trainings or WIC State-developed approved comparable training.
NSA funds may be used for attendance at a state/national breastfeeding conference. Travel for home and hospital visits by peer counseling staff Yes, for visits to WIC participants; peer counselors may not provide services to non-WIC participants.
Continuing education for DBEs Yes, if it relates to servicing peer counseling programs (e.g., mentoring, serving as a referral, etc.)
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Item or Service Allowable Costs Comments Breastfeeding resources for peer counseling staff
Breastfeeding resources for WIC staff not related to peer counseling Yes, if the resources are related to peer counseling (e.g., training materials for peer counselors and DBE).
No Training materials/education must be within scope of a peer counselor (i.e., basic breastfeeding information and support). NSA funds may be used to purchase general breastfeeding resources for WIC staff. Training and coursework for peer counselors to become International Board-Certified Lactation Consultant (IBCLC) or Certified Lactation Counselor (CLC) No. NSA funds may be used for CLC or IBCLC training and coursework. The priority use of BFPC funds is to hire and train peer counselors to provide breastfeeding peer counseling services to WIC participants. Staff with advanced lactation training are not considered peer counselors.
Research recommends that peer counselors be provided career path training options. CLC or IBCLC exam, renewal, or membership fees No At the WIC State agency’s (SA) discretion, NSA funds may be used for CLC or IBCLC training, exam fees, renewal and/or association membership fees. The SA must determine if it is necessary and of benefit to the WIC Program for the person in a particular job position to have the certification. SAs must also determine whether the cost fits within its WIC NSA grant budget. Peer Counseling Program Advertising and Promotion Media outreach (e.g. bus placards, paid social media and digital ads to advertise BFPC programs) Yes. Media outreach using BFPC funds are allowed if directly recruiting peer counselors or informing WIC participants about the PC program, including the Buddy Program, as a WIC breastfeeding benefit. FNS would not expect to see a disproportionate amount of the BFPC funds spent on advertising the program at the expense of direct services to participants.
BFPC funds may not be used for ads that promote breastfeeding in general but NSA funds may be used for this purpose. Name badges, buttons and similar low-cost items that identify peer counselor staff Yes
Pamphlets and similar materials to promote the peer counseling program Yes
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Item or Service Allowable Costs Comments Miscellaneous Indirect costs (e.g., personnel, accounting, or information technology services, etc.) Yes, but only those that are related to providing a WIC peer counseling program.
Second nutrition education contacts No. BFPC funds are for activities that are in addition to current required WIC activities. NSA funds provide for at least two nutrition education contacts; therefore, BFPC funds may not be used for the “second” contact.
In addition, the 1/6th nutrition education requirement and breastfeeding target must be met with regular NSA funds. Childcare No
Cribs or other materials and equipment for infants of peer counselors who bring their babies to work No
Monitoring and tracking of program effectiveness Yes. Funds may be used to monitor and track program components (e.g., contacts, referrals, training, etc.) to determine effectiveness and where improvements are needed.
Evaluation studies may not be paid for using BFPC funds. Miscellaneous Peer counseling services to non- WIC participants No. Peer counselors should refer WIC- eligible women to WIC to apply for WIC benefits. Peer counselors should refer women who are not WIC-eligible to appropriate non-WIC resources.
Breastfeeding coalitions No BFPC funds can only be used for services and activities related directly to peer counseling. *Updated March 2024. This is not an exhaustive list of allowable costs. Refer to the FNS Regional Office for questions about allowable cost and to the Breastfeeding Policy and Guidance.
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Breastfeeding Peer Counseling Program Cell Phones & Text Message Policy
Policy: The Breastfeeding Peer Counselor (BFPC) can perform peer counselor related business using personal cell phones or agency-issued phones. The BFPC will abide by all policies established by the local agency (LA) operating the BFPC Program as well as those specified below.
Regulations: USDA FNS WIC Breastfeeding Curriculum: Peer Counselor Management; USDA FNS WIC Breastfeedign Curriculum; USDA FNS WIC Nutrition Services Standards – Standard 9; USDA FNS WIC Breastfeeding Policy and Guidance (July 2016); USDA FNS Allowable Costs for Breastfeeding Peer Counseling Funds (January 2024).
Procedure/Additional Guidance: Cell phones and texting enhance the BFPC’s ability to communicate in a manner that is both timely and acceptable to the client.
Procedure: BFPCs can call and text clients as a means of communication in accordance with the following procedures: It is strongly encouraged that BFPC use agency purchased cell phones for communication with the client. When purchasing a cell phone to be used by the BFPC, consider the following: o Phones should require use of a pass code to access the phone. o Cell phone database can be remotely deleted if lost or stolen. o Ask about government grade security options. o Consider a hands free device to allow easy typing or writing while talking to avoid neck strain. o Return agency-issued cell phone upon termination of employment. If the agency has not issued cell phones and the BFPC is using a personal cell phone, the following guidelines apply: o Phones should require use of a pass code to access the phone. o Clients contact information should not be stored on the phone. o Cell phone database can be remotely deleted if lost or stolen. BFPC must report the loss or damage of a cell phone to the BFPC Coordinator immediately. If needed, the BFPC Coordinator ensures the database is deleted.
Prior to texting the client: Obtain the client’s preferred methods of communications upon enrollment (e.g.: texting, phone calls, or email.) Inform clients to opt-out of text communication, text the word “STOP” to incoming BFPC texts. The BFPC will ask clients their preferred methods of communication. BFPC informs clients of their work hours and availability, including on their outgoing voicemail message. BFPC must inform the BFPC Coordinator when they are unable to receive texts or calls due to illness, etc Use common abbreviations. Use text messages only for simple, quick notes to check in with a client. If she has questions or concerns, discuss by phone or in person. Do not use text messaging to perform a breastfeeding assessment, explain breastfeeding concepts, or collect personal health information. Inform clients not to text photos of body parts. If they have a specific concern, refer client to the LA BFPC Coordinator, DBE, WIC High Risk Counselor, or to their health care provider. For purposes of confidentiality: - Do not allow program cell phones to be visible by others. - Delete text messages and phone numbers after documentation in Compass is complete.
Documentation protocols: Document all text messages and phone calls as “Telephone Support” in Compass (and the BFPC Contact Log, if used). Voicemail messages, missed calls and text messages should be returned the same day if possible, or within 24 hours.
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If a client does not respond to a text or phone call within 24 hours, this will be documented as “No Answer”. If delayed dialogue occurs (e.g., it takes 2 days to finally connect), this is considered one contact and should be documented on the day the concern is addressed. Conversations by text over the course of two days on the same topic may be documented as two separate contacts if there was an initial conversation and a follow-up conversation. If you receive a text one day and could not respond until the following day, this will be documented as one contact. In the comment section, document that: “Client sent text on (date) ’quote text’ and BFPC responded on (date).” If text messaging is used to invite the client to a group class, mothers’ group or event, this will be documented as a “Mailing” and as it not a “two-way communication”. Short texts to check in to see how breastfeeding is going and to offer support (such as a client who recently delivered) are counted as a contact even if the new mother responds that everything is fine. Document any follow up activities related to the texting conversation (such as emailing educational materials, links, or referrals), as “Mailing” and enter actual materials shared. These types of follow up activities cannot be counted as a contact.
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Breastfeeding Peer Counseling Program Requirements
Policy: To implement and administer a Breastfeeding Peer Counseling (BFPC) Program, local WIC agencies (LA) receiving state BFPC Program grants are required to follow guidance specified in the LA’s BFPC Program contract and in the FNS WIC Breastfeeding Curriculum: Peer Counselor Management. Additionally, they are expected to provide training to BFPC staff using the WIC Breastfeeding Curriculum.
Regulations: USDA FNS WIC Breastfeeding Curriculum: Peer Counselor Management; USDA FNS WIC Breastfeeding Curriculum; USDA FNS WIC Nutrition Services Standards – Standard 9; USDA FNS WIC Breastfeeding Policy and Guidance (July 2016); USDA FNS Allowable Costs for Breastfeeding Peer Counseling Funds (January 2024).
Procedure/Additional Guidance: Program Description The BFPC Program is based on the FNS WIC Breastfeeding Model Components for Peer Counseling. The program utilizes breastfeeding peer counselors (BFPCs) to encourage and support pregnant and breastfeeding clients to breastfeed their infants via mother-to-mother support. BFPCs are paid paraprofessionals within WIC and are trained and supported by WIC breastfeeding experts. BFPCs are able to extend the Colorado WIC Program’s reach with breastfeeding promotion, education, and support by helping women initiate and continue exclusive breastfeeding through offering peer support during critical weeks after delivery outside of normal WIC clinic operating hours. Services provided by BFPCs are not counted toward nutrition education contact requirements.
Program Coordination The Colorado WIC BFPC Program is coordinated at the state and local level.
State Level To qualify as the COWIC BFPC Program Coordinator, the individual must have experience in program management, demonstrated expertise in breastfeeding management and promotion, training in advanced lactation management, and a minimum of one-year experience counseling breastfeeding individuals.
The State BFPC Program Coordinator describes the BFPC Program in the annual state plan, develops the standards for the program and provides support to the LA implementing the program.
Standards include establishing policies and procedures that: Define the responsibilities (job descriptions) of individuals involved with the BFPC program; Define program standards (management, training, continuing education and evaluation); and Describe the use and tracking of the BFPC program funds.
Support includes: Securing funds and materials annually; Providing training, resources and program materials (e.g., annual training, forms to document BFPC to mother contact, forms to monitor BFPC work performance); Providing ongoing technical support; and Incorporating an evaluation process as a part of each BFPC LA’s management review.
Local Level LAs that receive BFPC funding must designate a BFPC Coordinator. The LA BFPC Coordinator develops, manages, and oversees the LA’s BFPC Program procedures and may directly supervise the BFPC. In most cases, the LA’s Breastfeeding Coordinator fills this role; however, the agency may select an alternate person. The individual must have experience in program management, demonstrated expertise in breastfeeding management and promotion, training in lactation management, and a minimum of one-year experience counseling breastfeeding individuals.
Supervision includes:
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Weekly contacts (e.g., by phone or in person) with BFPCs during the first two months on the job (after initial orientation and training is complete); thereafter contact can be less often as determined by supervisor. Reviewing BFPCs weekly contacts with clients. Weekly spot check calls to mothers during the BFPCs first two months and monthly thereafter for up to six months to monitor performance and to ensure BFPCs are responding appropriately to mothers’ needs. Evaluating BFPCs performance at the completion of a three month period. Coordinators should identify strengths and give recognition, identify additional training needs and incorporate skill development into the BFPC’s work schedule, or may choose to dissolve employment.
BFPCs will be paid at least minimum wage and either an hourly rate or a salary rate depending on the preference and feasibility of each LA (evaluation of liability coverage will be done at each agency). LAs are encouraged to pay a salary commensurate with that of a WIC Educator. Compensation and reimbursement of BFPCs will be paid through LA employment systems or by contract with the LA. If the BFPC receives benefits, it will be in accordance with the LA’s policies. BFPCs will also be reimbursed for travel in situations where they are expected to make trips to the hospital or outside meeting areas from the WIC clinic. BFPC training expenses and communication resources (e.g., laptop, cell phone) specific to peer counseling will be covered by the LA.
Please refer to the Colorado WIC Policies & Procedures Manual, Local Staffing policy for BFPC Program Coordinator and BFPC job descriptions. LA must submit a BFPC job description if it differs from the job description defined in the Colorado WIC Policies & Procedures Manual prior to hiring.
Training
State and LA BFPC Program Coordinators must receive training on how to manage BFPC programs and train BFPCs through the FNS WIC Breastfeeding Curriculum: Peer Counselor Management and the WIC Breastfeeding Curriculum (Levels 1 & 2).
The LA is responsible for planning and overseeing BFPC staff training which is divided into new employee training and continuing education. New employee training for BFPCs, includes but is not limited to the following activities: Completes standard LA orientation and training (e.g., policies, confidentiality, work standards) and reviews COWIC breastfeeding policies. Receives BFPC-specific training FNS WIC Breastfeeding Curriculum (Levels 1 & 2). Completes COWIC training modules as listed on the BFPC Orientation checklist. Shadows WIC Educators, High Risk Counselors, and BFPCs for 40 hours to observe and understand WIC Program services and expectations re: professionalism, communication, work ethics and standards. Shadow a WIC DBE or other lactation expert assisting a WIC client with breastfeeding in the hospital or WIC clinic. Continuing Education: The BFPC will be invited to attend all WIC breastfeeding trainings, including all sessions held at state meetings and regional workshops. As funding allows, the BFPC will be encouraged to attend other breastfeeding training opportunities held within the state. The BFPC will be encouraged to participate in regular WIC staff meetings and in-services to promote their linkages with the WIC staff.
The State and LA ensures that BFPCs receive adequate program support that includes: Timely access to the LA BFPC Coordinator, DBE, or staff with advanced lactation training for assistance with problems outside their scope of practice. Regular, systemic contact with, and adequate supervision and monitoring by the LA BFPC Coordinator. Participation in clinic staff meetings and breastfeeding in-services as part of the WIC team. Opportunities to work with more experienced BFPCs to facilitate mentoring and to meet regularly with other BFPCs. Adequate compensation and reimbursement for expenses. Training with a standardized curriculum.
Community Partnerships
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The WIC Program encourages LAs to use the expertise of IBCLCs and other qualified lactation experts in order to serve as resources for clients who need additional lactation consultation. Colorado has an active statewide breastfeeding coalition. Several community breastfeeding coalitions exist around the state. When BFPC and WIC High Risk Counselors are unable to respond to the lactation concerns of the client, these lactation experts can serve as a reimbursable resource. The LAs’ BFPC contract funds can be used to pay for visits with lactation consultants. Agencies are expected to identify lactation resources in their communities and establish methods to make referrals to these resources. If necessary, methods of payment will be established by each LA. LAs are encouraged to establish relationships with the mother-baby units of their local hospitals, community health centers, health care provider clinics, and La Leche League groups.
LA Policy and Procedures Referral protocols - The referral process may be unique for each LA; however, agencies shall have a system in place for the following situations: A system for staff to refer a pregnant woman or new mother to the BFPC individually or to a group session facilitated by the BFPC. A system for the BFPC to refer a pregnant woman or new mother to the LA BFPC Coordinator, DBE, staff with advanced lactation training, or a community lactation expert or health care provider. Note: If referrals to the LA BFPC program need to be suspended for caseload management, the LA BFPC Coordinator should inform clinic staff. Clinic staff should then skip the BFPC support question in the Nutrition Interview. Confidentiality - BFPCs must follow confidentiality policies of the COWIC Program and their LA. BFPCs will be expected to receive training on confidentiality and sign an agreement of understanding and compliance with WIC client confidentiality. Breach of confidentiality is grounds for discharge. In some LAs, the BFPC will operate in the WIC clinic, and other LA may allow the BFPC to work from home. BFPC will provide peer contacts through various methods, including: prenatal/postpartum visits at the clinic (individual and group), at the hospital, in the community, in the client’s home, video conferencing, and by phone/text. LAs that incorporate hospital visits as a method of contact for the BFPC may need to establish a written agreement with the hospital identifying permission for the BFPC to visit with the mother, where the visits can take place (e.g., bedside, other room), and codes of conduct (e.g., does the BFPC need to check in/out, is there a length of time she can visit). LAs that incorporate home visits as a method of contact for the BFPC must have policies to address BFPC: Process for making home visits, including, but not limited to: scheduling, verifying location, and providing phone or text reminders prior to the appointment time. Safety within the client’s home. This must include coverage of liability insurance through the LA for home visits by BFPCs. BFPC must check in with their BFPC Coordinator/supervisor upon arrival at the client’s home and upon departure. Travel to and from the client’s home. This should include mileage reimbursement and require that BFPCs provide proof of valid car insurance or use of LA employee vehicle. Confidentiality of the client when in the home to maintain client privacy. LAs that incorporate video conferencing as a method of contact for the BFPC will provide for installation and maintenance of the equipment necessary for the video call. Additionally, LA must have written procedures detailing: How to schedule video conferences; Video conference platform information with instructions provided to the client how to access the conference; Where the conferencing call can occur, in an environment that promotes effective communication between the BFPC and the client and ensures that both are actively involved in the interaction; and Client confidentiality while on the call. The video conferencing should occur on a confidential video conferencing platform and the BFPC should host the call in a private location to protect client privacy. LA must have a process/protocol describing how the BFPC program provides breastfeeding assistance/support to clients beyond normal WIC clinic operating hours at their LA.
Contact Recommendations for Breastfeeding Peer Counselors While each LA will vary on types and frequency of contacts based on their WIC population needs, the following are recommendations for basic services provided by the COWIC Program:
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Contact Recommendations for Breastfeeding Peer Counselors Category Contact Time Frame Comments Prenatal Women Within 30 days of enrollment Encourage monthly contact through Support Groups and educational text messages
Contacts initiated by clients may be more frequent Once a trimester until within 2 weeks of Estimated Delivery Date (EDD) Weekly within 2 weeks of EDD Postpartum Women Weekly during the first month following delivery
Follow-up 3 days after breastfeeding problems (e.g., latch) or yield a breastfeeding complication (e.g., jaundice) Can be a phone call, text message, or in person. If problems don’t resolve within 24 hours, BFPC yields and refers to lactation management specialist, CLC or IBCLC 1-2 weeks before returning to work/school
Encourage Support Group attendance
Contacts initiated by clients may be more frequent
*Note: When BFPC caseload exceeds full-time equivalent (FTE) capacity, LAs should prioritize BFPC support for clients in their third trimester of pregnancy and the first month postpartum.
Documentation Each agency will define how the BFPC will be able to contact mothers (e.g., by text, phone, email). All contacts (two-way interactions) and attempted contacts must be documented in the Compass BFPC Documentation panel. Contacts should be entered within 5 business days but best practice to to document within 24-48 hours. Documentation for two-way interactions should be a brief summary and include: Partipant’s questions/concerns (if applicable) Topics/education discussed Yields or referrals made Next steps
The Compass BFPC Contacts Summary Report aggregates detailed information about the type and frequency of contacts made by the BFPC during a selected date range.
Compass BFPC Contact Categories *No Answer – Phone message left or text sent without a response from the client within 24 hours. Clinic Visit – Visit with the client in the WIC clinic. Home Visit – Visit with the client at their home or in the community. Hospital Visit – Visit with the client at the hospital during pregnancy or postpartum. Telephone Support – Phone call or text during which breastfeeding concerns are addressed and education or referrals are provided. Peer Support Group – Client attends peer support group. *Mailing – Email or US mail sent to the client in an attempt to contact, provide educational materials, or invite to breastfeeding support groups or classes. *Other - Social media, Facebook, Twitter, or when additional BFPC documentation is needed but no contact or attempted contact was made. *Note: No Answer, Mailings, and Other should not be used when documenting two-way interactions.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 03/01/2026 Page 1 of 3 Breastfeeding: Assistance, Aids and Contraindications Policy: Local agencies shall provide education, assistance and breastfeeding aids to directly support the initiation and continuation of breastfeeding. Regulations: CFR 246.11 c, e, CFR 246.14 c (10), USDA FNS WIC Breastfeeding Policy and Guidance (July 2016), Colorado WIC Policy Procedure/Additional Guidance: Assistance with Breastfeeding Technique and Assessment WIC staff can assist clients with breastfeeding techniques, positioning and latch within the following guidelines: ● Ask permission from the client to observe a breastfeeding session to assess positioning, latch and breastfeeding technique. (“Would you like me to offer some help on latching your baby?”) ● Verbally direct, use a doll to model, or a video to demonstrate/show various positions and latch techniques. ● If a client requests direct, hands-on assistance, staff shall use their hands to manipulate or place the baby. An effort should be made not to directly contact the client’s breast. Health First Colorado (Medicaid) Reimbursement for Lactation Services Federal policy prohibits individuals and organizations from receiving reimbursement and/or compensation from more than one federal funding source for the same time block (unit), including both individual and group session reimbursement. ● WIC staff may not be compensated/reimbursed from both Health First Colorado and the Colorado WIC grant for lactation services offered at the same time (block/unit). ● WIC staff may only bill for Health First Colorado reimbursement for lactation services provided outside of WIC paid FTE/time. ● WIC staff with advanced lactation credentials, who also provide lactation services reimbursed by Health First Colorado outside of WIC paid FTE/time, may do so if: ○ Health First Colorado reimbursement is not impeding upon WIC staff duties or services provided to WIC clients; and ○ Documentation for Health First Colorado reimbursements is kept separate from WIC’s Management Information System and stored on a separate charting platform, as data sharing between platforms is not allowed. Test Weights ● WIC staff (High Risk Counselors, Educators, Breastfeeding Peer Counselors, WLS, DBE, CLC, CLE and IBCLC) should not perform test weights on infants to determine if the client’s milk is transferred. This procedure does not fit within routine or high risk WIC visits in that it requires a more thorough assessment (including feeding history, elimination patterns, breast variables, infant health status, duration of feeding problem, etc.) than time permits. WIC staff should refer infants who are not gaining weight well to their healthcare provider. ● WIC staff can weigh infants and offer clients to weigh their infants on a regular basis when the purpose is to assure the parent that their infant is growing. Breastfeeding Aids Breastfeeding aids describe items that directly aid in the removal of human milk from the breast and/or provide human milk to the infant. Breastfeeding aids that directly support the initiation and continuation of breastfeeding are an allowable WIC Program cost. See the Breastfeeding: Breast Pump Issuance policy and WIC Lactation Specialist (WLS) Training Series for more information. ● Breastfeeding aids and pumps can only be ordered on a quarterly basis through the State Office (see Breastfeeding: Breast Pump Ordering and Maintenance policy). Other allowable breastfeeding aids may be purchased with funds available in the local agency budget. (Note: Funds cannot be used to purchase breast pumps or pump supplies, as purchasing such supplies outside of state ordering/contracts is not permitted). ● Breastfeeding aids should be provided to WIC postpartum clients based on individual need and requested support, not as an inducement to consider or to continue breastfeeding.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 03/01/2026 Page 2 of 3 ● When breastfeeding aids are provided to clients, the State’s Breast Pump/Aid Release Form must be reviewed with the client and a signature captured in the Compass computer system per policy outlined in Breastfeeding: Breast Pump Issuance policy. ● Liability – please see the Breastfeeding: Breast Pump Issuance policy. ● Only aids listed under the following table “Allowable Aids” are allowed for purchase with WIC funding by local agencies. Allowable Aids Non-Allowable Aids ● Milk storage bags ● Breast pumps/pump supplies outside of state ordering/contracts ● Nipple shells ● Nipple shields ● Supplemental Nursing Systems (SNS) ● Topical creams, ointments, vitamin E, other medicinal ● Nursing bras and pads ● Foot stools ● Nursing pillows or clothing ● Baby bottles Nipple Shields WIC staff cannot issue and should not place nipple shields on clients (not to be confused with breast shields or flanges used with a breast pump). The WIC clinic and scheduling does not provide adequate timing and resources to perform the necessary support and follow up. If use of a nipple shield is warranted, clients should be referred to a lactation consultant in the community. Nipple Shells WIC staff trained in lactation management (WLS, DBE, CLC, CLE, IBCLC) can provide nipple shells to clients as needed. Nipple shells can be used for: o Sore nipples: worn over the nipples between feeds to minimize contact with clothing and allow healing. o Flat or inverted nipples: worn to press around the base of the nipple to cause the nipple to protrude. ✔ Prenatal use: worn in the last month of pregnancy. Clients wearing shells prenatally MUST get permission from their obstetric care provider as shells can trigger contractions of the uterus. ✔ Postpartum use: worn approximately 30 minutes before each feeding. Supplemental Nursing Systems (SNS): WIC staff trained in lactation management (WLS, DBE, CLC, CLE, IBCLC), ideally those with advanced skills only (IBCLC), may provide supplemental nursing systems to clients as needed. Typically, SNS are only issued after first prescribed by the hospital/healthcare provider. SNS can be used for: o Underweight breastfed infants. o Low milk supply. o Re-lactating clients. o Clients attempting to lactate for an adopted infant. o Infants with ineffective suck or latch due to medical concerns/issues. Contraindications There are very few medical reasons when a client should not breastfeed. Identify contraindications that may exist for the client. See WIC Lactation Specialist (WLS) Training Series for additional details. Breastfeeding is contraindicated when: o The infant is diagnosed with classic galactosemia, a rare genetic metabolic disorder. o The client has tested positive for HIV (human immunodeficiency virus) or has acquired immune deficiency syndrome (AIDS). o The client has tested positive for human T-cell lymphotropic virus type I or type II (HTLV-1/2). o The client is using illicit street drugs, such as PCP (phencyclidine) or cocaine (exception: narcotic- dependent individuals who are enrolled in a supervised methadone program and have a negative screening for HIV and other illicit drugs can breastfeed).
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 03/01/2026 Page 3 of 3 Breastfeeding may be temporarily contraindicated when (clients should be provided breastfeeding support and a breast pump, if eligible, and may resume breastfeeding after consulting with a physician to determine when their breast milk is safe for their infant and should be provided with lactation support to establish and maintain a milk supply): o The client is infected with untreated brucellosis. o The client has an active herpes simplex virus (HSV) infection with lesions present on the breast. o The client is undergoing diagnostic imaging with radiopharmaceuticals. o The client is taking certain medications or illicit drugs. Direct breastfeeding may be temporarily contraindicated and the client should be temporarily isolated from their infant(s) (should be provided breastfeeding support and a breast pump, if eligible) but expressed breast milk can be fed to the infant(s) when: o The client has untreated, active tuberculosis (TB) (may resume breastfeeding once they have been treated for approximately two weeks and is documented to be no longer contagious). o The client has active varicella (chicken pox) infection that developed within the five days prior to delivery to the two days following delivery.
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Breastfeeding: Breast Pump Issuance
Policy: Local agencies shall provide breast pumps to WIC clients when appropriate, along with appropriate education to directly support the initiation and continuation of breastfeeding.
Regulations: CFR 246.11 c, e, CFR 246.14 c (10), USDA FNS WIC Breastfeeding Policy and Guidance (July 2016), Colorado WIC Policy
Procedure/Additional Guidance: Breast pumps and breastfeeding aids that directly support the initiation and continuation of breastfeeding are an allowable WIC program cost. Research shows milk expression in the first few weeks postpartum, by hand or pump, can assist individuals in creating a good milk supply. However, it is important to note that breastfeeding directly at the breast provides many other benefits beyond that of only feeding breast milk by bottle. Additionally, providing pumps regardless of need may give clients the impression that special equipment is necessary to breastfeed, may contribute to feelings of inadequacy and lack of confidence, and may interfere with breastfeeding. ● Generally, pumps are issued to clients who are: ● Having difficulty establishing or maintaining an adequate milk supply due to maternal/infant illness; ● Parent/infant separation (e.g. hospitalization, return to work or school); and/or ● Parent temporary breastfeeding problems or medical need (e.g. severe engorgement). ● Pumps may not be issued to clients: ● As an inducement to consider or to continue breastfeeding. ● Prenatally to pregnant clients. ● Who are donating all their breast milk to a milk bank or other source. (To issue a pump, clients must be providing their own breast milk to their infant.) ● Liability: ● Staff providing breast pumps or aids must be adequately trained in lactation management (WLS, DBE, CLC, CLE, IBCLC) and/or in breast pump issuance procedures to provide clients with the appropriate information and follow-up. ● Clients must receive instruction from staff at the time of issuance on proper pump assembly, usage, cleaning, storage and maintenance. ● The Breast Pump/Aid Release Form must be reviewed with the client, and the client’s signature (or verbal acknowledgement) must be captured in the Compass computer system or on the printed form that must be uploaded into Compass. A print/electronic copy of the form must be offered to the client at the time of issuance. ● Local agency WIC Breastfeeding Coordinator will: ● Authorize and train local agency staff to appropriately assess and issue breast pumps to clients. ● Oversee breast pump inventory and order new breast pumps and accessories as needed from the State Office (see Breastfeeding: Breast Pump Ordering and Maintenance policy). ● Ensure all hospital-grade multi-user loaned breast pumps have a WIC asset tag adhered to the pump and are added to and tracked in the serialized inventory in Compass. ● Local agency staff must: ● Ask each client if they have received a breast pump or aid from another source (e.g., Medicaid, private insurance, health care provider, etc.). Options to obtain pumps and aids from Medicaid, health insurers, etc., should be considered before a pump or aid is provided through WIC. o If the client has a pump or aid from another source, WIC staff can provide education, support, and compatible pump supplies (e.g., breast shields/flanges) for its use. o WIC staff should limit issuing additional pumps or aids unless there is a need as determined by the staff’s clinical judgement. ● Assess each client needing/requesting a pump to determine the best pump for their situation. Breast pumps shall only be provided after a thorough breastfeeding assessment to ensure that a pump is the appropriate intervention. Assessments can be completed virtually, by phone, or in person. Staff may use the Breast Pump Questionnaire, as needed.
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● Document in Compass required client education (check boxes in Nutrition Education Covered and/or Care Plan) on: o The proper use, assembly/disassembly, cleaning, storage, and maintenance of the pump and associated collection kit/supplies issued; o Their responsibilities for handling and returning loaned, multi-user pumps. o Safe handling and storage of expressed breast milk. o Hand expression (to relieve normal engorgement and assist women in handling situations when they are without their infant and need to express milk - written materials and instructional videos are available). ● Review the Breast Pump/Aid Release Form with the client (virtually, by phone or in person) and capture the client’s signature or verbal acknowledgment in Compass to ensure the client accepts responsibility before accepting any type of pump. If a signature cannot be captured in Compass during an in-person appointment, upload a scanned copy of the signed Breast Pump/Aid Release Form into Compass. Provide the client with a copy of the Breast Pump/Aid Release Form that includes contact information for questions and the return date of loaned multi-user pumps, if applicable. The Breast Pump/Aid Release Form must be reviewed and a copy provided to the client each time any type of pump is issued. ● Document the type of pump issued and the reason for issuance in the Breastfeeding Equipment panel in Compass. ● Contact clients provided with any breast pump within 24-72 hours of issuance. Schedule a “Breast Pump Follow-up (remote)” appointment within this timeframe. During follow-up, answer questions, assess whether the initial issues/reasons for providing a pump have resolved, and provide referrals to lactation services or community support, as needed. o For clients with a loaned, multi-user pump, follow up at least monthly to assess ongoing need and provide lactation support. o Document all follow-up attempts in the Compass Scheduler using the “Breast Pump Follow- up (remote)” appointment type: ● If the client is reached, mark the appointment as “Seen” and complete a Care Plan, noting “Pump follow-up” in the Subjective section. ● If the client is not reached, mark the appointment as “No Show”. A Care Plan is not required. Marking as a “No Show” satisfies follow-up documentation requirements. o Note: Only one documented follow-up attempt is required per timeframe (24-72 hours for all pumps and monthly for multi-user pumps). Multiple contact attempts within the same month are not required. ● As best practice, refer a client requesting formula or an increase in formula after a pump is issued to the WIC High Risk Counselor who will assess the need for formula and follow the formula issuance guidance in the Breastfeeding: Definition, Promotion, Education and Support Standards policy.
*Note: Breastfeeding Peer Counselors (BFPC) not designated as WIC Lactation Specialists (WLS) cannot issue breast pumps and aids. BFPC should refer clients who may benefit from supplies or need assistance using supplies to appropriate staff (see Breastfeeding Scope of Practice policy). BFPC designated as WLS can only issue pumps and aids, as well as perform required pump follow-up contacts, to BFPC clients and must document contacts in the Client Care Plan.
Breast pumps and related pump supplies may only be purchased through the State Office ordering program. Only the additional breastfeeding supplies listed under the “Allowable Aids” indicated in the Breastfeeding: Breast Pump Ordering and Maintenance policy are allowed for purchase with WIC funding by local agencies. For breastfeeding aid issuance, see the Breastfeeding: Assistance, Aids and Contraindications policy.
Guidelines for Loaned Hospital-Grade Multi-User Electric Pumps Hospital-grade multi-user electric breast pumps are superior to single-user pumps because of a stronger motor, gentler suction options and capabilities that more closely mimic a baby at the breast for improved breast milk removal. Priority of hospital-grade multi-user pumps are provided to clients who have a medical need, whose infants have a medical need, or a breastfeeding challenge to maintain milk supply, including but not limited to: ● Infants with an ineffective suck or unable to breastfeed directly at the breast because of prematurity, respiratory or cardiac problems affecting endurance, and/or disorders of the oral or gastrointestinal structures. ● Latch on problems/breast rejection.
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● Severe feeding problems. ● Mastitis or breast infection. ● Mother on short-term medication(s) contraindicated for breastfeeding. ● Separation from infant (i.e., parent or infant hospitalized or ill) or mother is returning to work or school. ● Parent of multiples. ● Premature infant. ● Acute severe or recurrent engorgement not resolved with standard treatment (i.e., increased feedings, warm soaks, manual expression). ● Severely sore or cracked nipples. ● Abrupt weaning.
*Note: This list is not inclusive of all potential breastfeeding challenges and, therefore, the conditions for which a pump is loaned are left up to the decision of the local agency staff.
Issuance: Hospital-Grade Multi-User Electric Pumps Hospital-grade multi-user breast pumps should only be loaned to clients who have demonstrated reliability and can be located, if necessary. Multi-user breast pumps may only be issued in person and may not be mailed to clients. Multi-user breast pumps are prioritized for individuals with a medical need, and best practice is to issue a multi-user pump for the first 1-3 months, with the client’s expectation that a single-user pump would be issued, if needed, thereafter. In addition to the above requirements, staff must: ● Ask each client if they currently have a loaned multi-user breast pump from another source (e.g., Medicaid, private insurance, hospital loan, etc.). There should not be a need for an individual to have more than one multi-user loaned pump at one time. o If the client has a multi-user loaned pump from another source, WIC staff can provide education, support, and compatible pump supplies (e.g., breast shields/flanges) for the successful use of the pump. o WIC staff should limit issuing any additional pump while the client is loaning a multi-user pump from any source, unless there is a need determined by staff’s clinical judgement. ● At issuance, WIC staff shall inform participants that multi-user pumps are issued for temporary use to address specific breastfeeding or medical needs, such as resolving challenges or establishing milk supply. Participants must be advised that the pump should be returned once the need is resolved, typically within one to three months, and should transition to a single-user breast pump, if necessary. ● Complete the Breastfeeding Equipment panel. ● Review the Breast Pump/Aid Release Form with the client and document 2-3 individuals to contact in case the pump is not returned. ● Log each pump’s loan status, including the contact/return date, the date returned (once applicable) and at least two alternative contacts, including name and phone number or email address in Compass on the Breastfeeding Equipment panel. ● Inform clients that the double-pumping accessory/collection kits for the hospital-grade multi-user pump may not be loaned or shared with others, due to the possibility of cross-contamination. ● Use the Breastfeeding Equipment Due report in Compass to track loaned pumps. Pumps are visible on the report if the contact/return date is the current month or past due. ● Once a pump is returned, record the date returned and reason(s) for return (e.g., problem resolved) on the Breastfeeding Equipment panel. ● If a pump is kept longer than the expected return date, staff should follow up with the client, review the pump need and, if applicable, update the return date in Compass on the Breastfeeding Equipment panel and document follow-up in the Client Care Plan. ● Depending on the local agency inventory and because of the limited number of pumps, hospital-grade multi- user pumps used solely for medical problems or supply issues should be returned as soon as the need is resolved. If a pump is still necessary and a client qualifies, a single-user pump may be issued as a replacement (see qualifications below). ● Local agencies cannot withhold or deny WIC benefits or services from a client who has not returned a breast pump and/or not attended a pump follow-up appointment.
Clients with a loaned pump who transfer to another local WIC agency: ● Allow clients to have access to an electric pump when deemed necessary.
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● Preferred situation is for a mother to return the pump to the original clinic and staff work with the new clinic to quickly provide her with the same type of pump on arrival. ● If a mother transfers to a new clinic and does not return a loaned pump to the original clinic, the new clinic should exchange the pump with a pump from the new clinic and return the original pump, via transportation or mail, to the original clinic where it was issued.
Guidelines for Single-User Electric Pumps Single-user electric breast pumps are ideal for breastfeeding women who need help maintaining a milk supply and who have expressed genuine interest in breastfeeding exclusively for a goal of one year (use the WIC Breast Pump Questionnaire to aid in decision making). Single-user breast pumps may be provided in person or may be mailed via certified mail to clients. Primary reasons for issuing a single-user pump are: ● To help maintain adequate milk supply so that no formula is needed for the infant. ● To reduce the time and cost of WIC staff to follow up on loaned pumps for lower-risk situations.
*Note: This list is not inclusive of all reasons/needs for a single-user pump, therefore, the conditions for which a pump is loaned are left up to the decision of the local agency staff.
Single-user pumps are not as effective in removing milk as a hospital-grade electric pump due to weaker motors. Hospital-grade multi-user pumps are used to help establish and/or increase milk supply and are evidence-based ways to increase milk expression volume. This is one reason why WIC prefers clients already have a well-established milk supply before receiving a single-user pump.
While WIC strongly promotes exclusive breastfeeding for parents and children to receive the most benefits, WIC also understands and supports partial breastfeeding, as any breast milk is better than no breast milk.
Issuance: Single-User Electric Pumps Providing breast pumps to clients who do not need them may interfere with breastfeeding and result in unnecessary waste. Single-user pumps should only be provided to clients who: ● Have a well-established milk supply and are committed to continued breastfeeding. ● Are not receiving or have not received a single-user pump from another source (e.g., Medicaid, private insurance, health care provider, etc.). ● Are at least 4-6 weeks postpartum. (Supply is most effectively established in the first few weeks postpartum with the infant breastfeeding directly at the breast or by use of a hospital-grade multi-user loaned pump.) ● Are receiving an exclusive/fully breastfeeding food package, or the partially breastfeeding food package which has been individually tailored to meet the client’s needs. This is designed to provide for the supplemental nutrition needs of the breastfeeding pair, provide minimal formula supplementation to help mothers maintain milk production and provide incentives for continued breastfeeding by way of a larger variety and quantity of food. ● Are not currently borrowing a hospital-grade multi-user electric breast pump: o From WIC - Single-user pumps can be issued upon return of the loaned WIC pump. o From another source (e.g., Medicaid, private insurance, hospital rental, etc.) – Single-user pumps can be issued when the client states they have returned the loaned pump to the issuing agency, unless there is a need as determined by the WIC staff’s clinical judgement. ● Have a circumstance that warrants the issuance of a single-user pump, including: o Separation from infant(s) at least 6 consecutive hours on a regular basis (i.e., returning to work or school, custody sharing of the infant). o Parent of multiples. o Parent of infant(s) with physical or neurological impairment (i.e., weak suck, uncoordinated suck/swallow pattern, inability to suck, or inability to latch onto the breast). o Medical issue is resolved and the parent no longer needs hospital-grade pump, but is still interested in pumping on a regular basis for supply or separation from infant.
*Note: This list is not inclusive of all potential reasons for which a single-user pump can be issued and issuance is left up to the decision of the local agency staff.
In addition to the general pump issuance guidance above, staff must:
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● Encourage clients to save the breast pump for possible future infants. ● Not issue another single-user breast pump to a client for a future infant unless there are special circumstances warranting an exception to this guideline. The expectation is that a single-user pump can be used with all subsequent infants. Parents can receive additional collection kits and breastfeeding aids as needed with future WIC infants. ● Encourage clients to complete the manufacturer’s warranty registration. WIC clients are responsible for contacting the pump manufacturer themselves for repair or pump issues. ● Explain and remind WIC clients that single-user breast pumps are for one user only and should not be sold, lent to, or shared with others. Single-user pumps have an open motor system that cannot be removed, replaced or fully sterilized. When the client is finished with the single-user pump, it should be discarded or recycled by a pump manufacturer recycling program, not sold or given away. ● Label each single-user pump with a “not for resale” and “single-user only” statement (e.g., written in permanent marker on the bottom).
Guidelines for Manual/Hand Pumps Manual or hand breast pumps are ideal for breastfeeding clients who need a pump for convenience, short-term use, or to help alleviate a minor problem. If used regularly, manual pumps are typically not effective enough to maintain a client’s milk supply in the long term. Manual breast pumps may be provided in person or may be mailed via certified mail to clients. Reasons for issuing a manual pump include: ● Normal engorgement. ● Occasional separation from infant (e.g., meetings, social events). ● Working or in school with a flexible schedule and limited separation from the infant.
*Note: This list is not inclusive of all reasons/needs for a manual pump; therefore, the conditions for which a pump is loaned are left up to the decision of the local agency staff.
Formula Education When a breastfeeding client requests formula for her breastfed infant, staff must follow the formula procedures outlined in the Breastfeeding: Definition, Promotion, Education and Support Standards policy.
Loaning Breast Pumps to Partner Organizations If loaning/providing WIC breast pumps to partner organizations, a formal agreement must exist between the local agency and partner organization. See the Breastfeeding: Breast Pump Partnerships policy.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 03/01/2026 Page 1 of 3 Breastfeeding: Breast Pump Ordering and Maintenance Policy: Local agencies shall appropriately manage breast pumps provided to clients, including the ordering of pumps through the state purchasing program and maintaining breast pump inventories. Regulations: CFR 246.11 c, e, CFR 246.14 c (10), USDA FNS WIC Breastfeeding Policy and Guidance (July 2016), Colorado WIC Policy Procedure/Additional Guidance: Breast pumps and breastfeeding aids that directly support the initiation and continuation of breastfeeding are an allowable WIC program cost. Ordering ● Local agencies are responsible for maintaining an inventory of pumps and pump accessories, and for tracking items and quantities that need to be reordered. ● Breast pumps (multi-user, single-user, manual), collection kits and breastfeeding aids (e.g., breast shields/flanges, pump supplies) can only be ordered on a quarterly basis through a centralized process at the State WIC Program. o Local agency representatives complete the online Pump Order Form on or before the due date outlined in the reminder email sent to local agency pump representatives. o Each order requires the local agency WIC Director approval. o Pumps and pump accessories ordered are shipped directly to the local agency. o Local agency WIC funds cannot be used to purchase breast pumps or pump supplies, as purchasing such supplies outside of state ordering/contracts is not permitted. ● Other allowable breastfeeding aids may be purchased with funds available in the local agency budget (see the Breastfeeding: Assistance, Aids and Contraindications policy for allowable aids). ● Breast pumps and breastfeeding aids purchased with WIC funds should be provided at no cost to the client. ● Upon receipt, breast pumps and other items must be inspected for damage, ensuring the correct type and quantity ordered are received. ● After the type and quantity of ordered pumps and supplies are verified, local agency staff must send a confirmation of receipt to the State WIC Office fiscal officer. Tracking and Inventory ● Local agencies must maintain a serialized inventory of all hospital-grade multi-user loaned breast pumps in the Compass computer system. ● Upon receipt, each new pump must be added to the clinic’s inventory. Hospital-grade multi-user electric pumps must be added to the Serialized Inventory section in Compass under Operations. Enter the serial number provided by the pump manufacturer on the pump. ● All breast pumps must be kept in a locked cabinet or locked room at the clinic, and off the floor when not loaned. Electric breast pumps are costly, and careful attention must be given to maintaining, securing, and inventorying of all equipment. ● Hospital-grade multi-user electric loaned breast pumps must have an asset tag affixed to the pump for tracking purposes. The asset tag includes a unique identifying number and the State WIC telephone number. Asset tags are ordered through the State WIC Office fiscal office. ● Hospital-grade multi-user electric-loaded breast pumps must have a contact label securely affixed to each pump case stating who to contact if the pump is found. The WIC agency’s name, address, and telephone number should be included on the label (e.g., consider using mailing labels sealed with packing tape). ● Hospital-grade multi-user electric loaned breast pumps must have a Pump Cleaning Insert (available to order on the WIC materials order form) securely affixed to each pump case (via packing tape). ● Use the Breastfeeding Equipment Due report in Compass to track loaned pumps. Pumps are visible on the report if the due date/next contact date is the current month or past due. ● Once a pump is returned, record the date and reason(s) for return (e.g., problem resolved) on the Breastfeeding Equipment panel and Client Care Plan.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 03/01/2026 Page 2 of 3 ● If a pump is kept longer than the expected return date, staff should follow up with the client, review the pump need, and, if applicable, update the return date in Compass on the Breastfeeding Equipment panel and document follow-up in the Client Care Plan. Maintenance ● Loaned hospital-grade multi-user breast pumps and cases must be cleaned when returned to the clinic after being loaned to a client. Clean pumps as described by the manufacturer: o Ensure the pump is unplugged while cleaning. o Wear gloves. o Freshly mix the standard 1:10 bleach cleaning solution: 1 part bleach and 9 parts water. This solution is not stable and must be mixed fresh each day and discarded after use. o Apply the cleaning solution with a soft cloth to the pump and case. Leave the solution on for 30-60 seconds and rinse thoroughly with clean water using a soft cloth. ● If a pump is returned and contamination and/or insect infestation is suspected, do not re-issue the pump to another client and follow the instructions below under the Repair section. ● Loaned hospital-grade multi-user breast pumps must be checked for performance upon return and before reissuing to another client. Check pump functions properly and vacuum suction is adequate. ● All pumps must be stored in a secure, locked location and off the ground, away from electronic equipment, such as TVs, DVD players. Motors in electronic equipment can attract insects and could result in pump infestation. ● Educate on and ensure, upon issuance of all breast pumps, that each client understands proper cleaning and storage of breast pumps and supplies. Repair Multi-User Electric Breast Pumps ● If a hospital-grade multi-user electric breast pump needs repair or cleaning, contact the State WIC Office to verify warranty status. o Note: Warranty begins from the date of purchase and typically is a three year warranty. ● It is the responsibility of the local agency to track the repair and return of “warranty” pumps. ● Pumps Under Warranty – as deemed by the State WIC Office: o Contact the pump manufacturer's customer service by phone or email to request a warranty repair return authorization number and instructions. o Ship the pump, as instructed by the manufacturer to the factory for cleaning and repair. o Ship all pumps for repair without the cases. If a pump is believed to be contaminated or infested with insects, follow the manufacturer’s specific shipping instructions (manufacturers have specific instructions for shipping pumps contaminated or infested) and ship in the case. If a case is not returned by the manufacturer, the local agency may order a replacement case. ● Pumps Not Under Warranty: o Contact the State WIC Office fiscal unit to request prior approval for repair. A Purchase Request will need to be approved at the State level prior to contacting the pump manufacturer. o Upon approval from the State WIC Office, contact the pump manufacturer's customer service by phone or email to request a repair return authorization number. A request can be made at this time to provide an estimate of costs prior to work being completed. o Notify the State WIC Office fiscal unit upon receipt of the repaired pump. ● Pumps determined to be too damaged to repair or in need of disposal will be disposed of or recycled by the local agency. Check the pump manufacturer for recycling information and programs. Single-User Electric Breast Pumps ● It is the responsibility of the client to register the pump with the pump manufacturer and work with the pump manufacturer for warranty-related issues/pump malfunctions. It is not the WIC staff's responsibility to assist clients with the warranty process. WIC staff are not allowed to share client information with pump manufacturers, including the date of issuance, as it is a violation of data sharing/client privacy. o Note: Single-user breast pumps typically have the date of issuance to the client. Missing Pumps and Recovery* ● Hospital-grade multi-user electric breast pumps are costly and should be carefully maintained, tracked and secured. Such pumps should only be loaned to clients who have demonstrated they are reliable and who can be located, if necessary.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 03/01/2026 Page 3 of 3 ● WIC benefits cannot be denied to a client for failing to return a breast pump. If a loaned pump is not returned or cannot be located, staff should: o Attempt to reach the client and relatives/friends (contacts/referrals) listed on the Breastfeeding Equipment panel in Compass and/or Breast Pump/Aid Release Form. o Document all attempted contacts in Compass under Comments/Alerts of the client’s file. o Contact the State WIC Office with the pump serial number to obtain the depreciated value of the pump. ✔ If the missing pump is determined to have no monetary value (pump depreciated over 6 years), it is up to the agency/clinic to determine if pursuit of the pump should be continued. ✔ If the missing pump has a depreciated value near purchase price, it is cost effective for an agency/clinic to continue to pursue the missing pump. ● If contacts with the client are unsuccessful, send a certified letter to the client and attempt to call the client’s contacts listed in Compas and/or on the Breast Pump/Aid Release Form. Notify them if the pump is not returned promptly local authorities may be contacted. ● Depending on the pump’s depreciated value, the agency/clinic can determine whether to request assistance from local law enforcement. However, not all local law enforcement will act on requests for assistance. ● If the pump’s depreciated value is still at or near purchase price and cannot be recovered, contact the State WIC Office for further instructions. ● If the pump is not returned, the client may not be eligible for a breast pump (loaned or single-user) in the future. *Note: Breast pumps are a WIC benefit and it is a participant violation if a client is found to sell or offer to sell WIC breast pumps - see Participant Violation policy for full details.
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Breastfeeding: Breast Pump Partnerships
Policy: Local agencies may formally partner with community organizations to ensure WIC clients have easy access to breast pumps and related pump supplies.
Regulations: CFR 246.11 c, e, CFR 246.14 c (10), USDA FNS WIC Breastfeeding Policy and Guidance (July 2016), Colorado WIC Policy
Procedure/Additional Guidance: Breast pumps and breastfeeding aids that directly support the initiation and continuation of breastfeeding are an allowable WIC cost. Partnering with community organizations to provide WIC breast pumps assists in providing early and easy access to pumps for WIC clients. This can help WIC clients to initiate and maintain breastfeeding, increasing the likelihood both parent and child receive health benefits associated with breastfeeding. Partner organizations include, but are not limited to: hospitals, health care provider clinics, local public health agency programs (e.g., Nurse Family Partnership).
Requirements ● A formal written agreement between the local WIC agency and partner organization must be in place (see below), reviewed and dated by both parties annually, and renewed with new signatures from both parties at least every two or three years, as indicated in the written agreement. ● WIC breast pumps may only be provided to individuals verified to be currently active on WIC (see below) and are eligible to receive a pump. ● WIC breast pumps cannot be issued to clients prenatally. ● A completed and signed Breast Pump/Aid Release Form must be provided to the local WIC agency for every pump issued to WIC clients for documentation purposes (recorded/uploaded into Compass). If issuing a multi-user loaned pump, the partner organization must obtain 2-3 individual contacts from the WIC client to be used if the pump is not returned. ● Information must be provided by the partner on proper assembly, usage, cleaning and maintenance of the pump and related supplies, as well as proper breast milk storage and who to contact for support. ● Multi-user breast pumps may be loaned to partner organizations to provide to verified WIC clients in- person, as deemed necessary for multi-user breast pump issuance within the Breastfeeding: Breast Pump Issuance policy. ● Single-user and manual breast pumps may be provided to partner organizations to give to verified WIC clients, as deemed necessary based on the issuance guidance within the Breastfeeding: Breast Pump Issuance policy. ● Either party can terminate the agreement at any time and request the pumps and related supplies be returned to the local WIC agency as soon as possible.
Formal Written Agreement In order for a partner organization to provide WIC pumps, the local WIC agency must create a formal written agreement renewed every two or three years, as indicated in the agreement, that is signed by both the local agency director and partner organization detailing the required procedures and requirements. Such documents may be in a memorandum of understanding (MOU), memorandum of agreement (MOA), interagency agreements, specialty services agreements, etc. The written agreement must contain: ● Full contact information for the local WIC agency and the partner organization. ● Purpose of the agreement and effective dates (start and end dates – must not exceed three years in length - and annual review dates). ● Responsibilities of each party in the agreement should include, but are not limited to: o How the partner organization obtains pumps, associated collection kits, etc., from the local WIC agency. o How the pumps will be stored in a secure location at the partner organization. o How the partner organization verifies the individual is currently active on WIC (see below) and is eligible to receive a pump. o A prohibition on issuing WIC breast pumps prenatally.
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o Required duties the partner organization must complete when issuing a pump (e.g., Breast Pump Release Form signatures, using and maintaining/cleaning the pump, human milk storage, etc.). o Communication requirements between the local WIC agency and partner organization. o Client follow-up responsibilities after a pump is issued. ● Make and model of the pumps provided to the partner organization. ● Serial numbers of the pumps provided to the partner organization (optional - if designated pumps are assigned for the partner organization’s specific use). ● Signatures of both parties.
The local WIC agency must inform the State Office Nutrition Consultant and State Breastfeeding Coordinator and provide a copy of the signed agreement. The agreement must be reviewed annually and renewed every two or three years (with new signatures and dates) by both parties. If loaning multi-user breast pumps to the partner organization, the pumps issued must: ● Be in the local WIC agency’s serialized inventory in Compass; ● Have a WIC asset tag affixed to the pump; ● Have WIC contact information written on/affixed to the pump; ● Have a cleaning insert adhered to the inside of the pump case; and ● The local agency must document the serial numbers of the specific pumps loaned to the partner organizations and track the pumps.
WIC Client Verification For a partner organization to issue a breast pump, they must first verify the individual is currently an active WIC client. Due to data-sharing restrictions in place to protect and respect the privacy of clients, WIC staff may not provide information on individual clients to partner organizations. WIC clients can provide verification of their current WIC status to share with the partner organization by: ● Calling their WIC agency in the presence of the partner organization and requesting WIC staff to share their current WIC status; ● Showing the partner organization their current benefits available via the WICShopper; and/or ● Provide a printed copy of the verification of enrollment that the client obtained previously from WIC staff.
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Breastfeeding: Definition, Promotion, Education and Support Standards Policy: Local agencies shall provide breastfeeding promotion, education and support to participants and designate a Local Agency Breastfeeding Coordinator. Regulations: CFR 246.11 c(2),(5),(7)(i)-(iv), CFR 246.2, CFR 246.10 e, USDA FNS WIC Breastfeeding Policy and Guidance (July 2016), Colorado WIC Policy Definitions: Breastfeeding Recommendations: Human milk is the optimal food for infant growth and development. The American Academy of Pediatrics (AAP) recommends exclusively breastfeeding for the first 6 months after birth, and supports continued breastfeeding for 2 years or as long as desired. Exclusive Breastfeeding: An infant does not receive any additional foods or fluids other than breast milk unless medically recommended. Breastfeeding Woman: Refers to women up to one year postpartum who are providing their breast milk to their own infant(s), including: ● Women who are providing any amount of breast milk to their infant(s) via breastfeeding (exclusively or partially). ● Women who are providing any amount of breast milk to their infant(s) by expressing the breast milk by hand or pump and feeding the expressed breast milk to the infant. ● Women who are providing any amount of breast milk to infant(s) to whom they did not give birth and for whom she has legal responsibility. Examples include foster mothers, adoptive mothers, and female partners in the same household. A non-birth breastfeeding woman may receive WIC services if she meets eligibility criteria and the infant receiving her breast milk is a WIC participant. Breastfeeding Descriptions Definitions*: • Exclusively Breastfeeding (“Excl BF”): Infant fed only human milk, vitamins, minerals, and/or medications. Infant receives no food package from WIC. • Primarily Exclusive/No Food Pkg (“Prim Excl/No F Pkg”): Infant fed something other than human milk, vitamins, minerals, and/or medications on rare occasions, or has received a limited-time (not routine) feeding of infant formula, human milk fortifier, cow’s milk, juice, sugar water, rehydration solution, baby food, or anything else. Includes infants whose exclusive breastfeeding is interrupted because of special circumstances, such as acute illness, hospitalization, or caregiver misinformation. Infant receives no food package (no infant formula) from WIC. • Primarily Exclusive/Complimentary Foods (“Prim Excl/Comp”): Infant fed any complimentary food in addition to only being fed human milk, vitamins, minerals, and/or medications. These complimentary foods are provided on a routine or ongoing basis, regardless of the amount. Infant receives age- appropriate food packages with no WIC infant formula. • Partially Breastfeeding In Range (“Part BF – in range”): Infant fed human milk and something other than human milk, such as complementary foods, infant formula (non-WIC supplied or from WIC up to the maximum provided for a mostly breastfeeding infant - described in Table 1 of 7 CFR 246.10). • Partially Breastfeeding Out of Range (“Part BF Woman – out of range”): Infant fed human milk and receives more than the maximum amount of infant formula from WIC provided for a mostly breastfeeding infant, but less than the amount provided for a non-breastfeeding infant. • No Longer Breastfeeding (“No Longer BF”): Infant was breastfeeding at some point in time, but has now discontinued. • Never Breastfed (“Never BF”): Infant was never breastfed. Should only be used if breastfeed was never initiated. • Breastfeeding Child (“BF Child”): Child greater than or equal to 12 months of age continuing to receive human milk.
*Note: does not include clients providing breast milk to infants only by donating their breast milk to a milk bank or other source.
Colorado WIC Program Policies and Procedures Section: Nutrition Services Revised: 03/01/2026 Page 2 of 4 Procedure/Additional Guidance: Promotion of Breastfeeding Colorado WIC will promote and support breastfeeding. ● Each local agency program will designate a staff person to serve as the Breastfeeding Coordinator to provide leadership to the local WIC agency on breastfeeding promotion, education and support matters. ● All agency staff exhibits a positive attitude toward breastfeeding and, depending on their position, be expected to encourage, educate on, promote and support breastfeeding and make referrals for breastfeeding services beyond WIC. See Breastfeeding Roles in Colorado WIC Clinic in the Breastfeeding: Scope of Practice policy. Staff Training Federal regulations require local agency staff to have a basic knowledge of breastfeeding and understand their unique role in supporting breastfeeding as the standard method of infant feeding. All staff have a valuable role in supporting breastfeeding women in WIC. ● The local agency Breastfeeding Coordinator helps train staff in the provision of breastfeeding support services and serves as a mentor for new and existing staff. ● All new staff must complete at a minimum the online WIC Lactation Specialist (WLS) training series Modules 1-3, as well as additional task-appropriate breastfeeding training as determined by the local agency Director and/or Breastfeeding Coordinator. ● State office will provide in-service training and technical assistance on the promotion and management of breastfeeding to staff at local agencies. Clinic Environment All local agencies must develop policies and create a clinic environment that endorses breastfeeding as the preferred method of infant feeding. A positive breastfeeding clinic environment demonstrates to mothers the importance WIC places on breastfeeding and enhances staff efforts in promoting breastfeeding. ● Encourage staff to communicate a positive attitude toward breastfeeding. ● All printed materials (e.g., handouts, pamphlets, posters), audiovisual materials and social media messages used will use positive breastfeeding messages and images and be free of infant formula product names or manufacturer information or logos. ● Ensure infant formula, bottles, feeding supplies and related materials are out of the sight of participants and the public. ● Office supplies (e.g., cups, calendars, pens, note pads, etc.) must be free of infant formula product and manufacturer/sponsor names and information. ● Refuse free gifts and samples from infant formula representatives for use by local agency staff. ● Encourage and support local agency staff to breastfeed their children. ● Support breastfeeding in clinics and provide private space (other than a toilet stall) for staff and participants to breastfeed and/or express breast milk. ● Develop a mechanism to incorporate positive peer influence into the clinic. This could include a breastfeeding affirmation bulletin board where pictures and statements from breastfeeding moms and infants are displayed (from staff and participants), and/or classes or support groups where breastfeeding women and/or peer counselors talk to pregnant women. Education and Support Breastfeeding education and support are provided throughout the prenatal and postpartum period, particularly at critical times when the mother is most likely to need assistance. All women should be educated on the benefits of exclusive breastfeeding. Prenatal Education Prenatal education and breastfeeding intention prior to delivery is one of the best predictors of a woman’s breastfeeding success. Every opportunity should be taken during a woman’s pregnancy to educate on the importance of breastfeeding, address breastfeeding concerns and questions, and provide encouragement to initiate and continue breastfeeding as long as possible. • The local agency will use prenatal breastfeeding education protocols which: ✔ Integrate breastfeeding promotion into the continuum of prenatal nutrition education. ✔ Include an assessment of participant knowledge, concerns, attitudes and support networks related to breastfeeding.
Colorado WIC Program Policies and Procedures Section: Nutrition Services Revised: 03/01/2026 Page 3 of 4 ✔ Provide initial and follow-up breastfeeding education sessions to each participant and include breastfeeding education at every prenatal participant visit and interaction. ✔ Are comprehensive, up-to-date, and culturally appropriate. ✔ Include information on the benefits of exclusive breastfeeding and practical strategies to combat potential challenges. ✔ Include information to prepare mothers to communicate effectively with hospital staff of her decision to breastfeed. ✔ Include information to prepare mothers to communicate effectively with her employer/school as she prepares for maternity leave. • Staff must invite all pregnant women to a breastfeeding/infant feeding class or provide comparable education one-on-one with participants. • Staff will follow local agency systems in place to refer pregnant women to the Breastfeeding Peer Counseling program. Postpartum Education The first few weeks postpartum are critical time periods in helping mothers build a milk supply and confidence. Research shows mothers with early and continued breastfeeding support are the most likely to succeed and breastfeed for longer durations. • Staff will make efforts to schedule mothers who intend to breastfeed for subsequent certification as soon after delivery as possible in order to provide timely breastfeeding support. • Inform participants that WIC helps mothers establish a successful breastfeeding relationship with their infant(s) and provides support to build their milk supply. • All postpartum contacts provide positive reinforcement for the continuation of breastfeeding. • Staff will document a mother’s plan for breastfeeding in her nutrition education record and provide education and support to help her achieve her breastfeeding goals. • Staff will develop a plan to assure that women have access to locally available support programs/services early in the postpartum period (when infant is 0-2 weeks of age). • Local agencies will invite women to a WIC support group or refer women to a community breastfeeding support group. • Staff will provide and/or identify education and support services for breastfeeding women returning to work or school. • Local agencies collaborate with other programs/groups that provide breastfeeding education/support. • Staff will follow local agency systems in place to refer new mothers and breastfeeding women to the Breastfeeding Peer Counseling program. Formula When a breastfeeding woman requests formula for her breastfed infant, the first priority is to help the woman achieve her breastfeeding goals. Staff must: ● Perform a nutrition assessment and use participant centered approaches to understand each mother’s individual request for formula supplementation and determine the appropriateness of supplementation. ● Ask open-ended questions to understand the reasons behind the infant formula request and assess a mother’s understanding of the potential impact of formula on milk supply and breastfeeding. ● Continue to affirm, encourage and support any amount of breastfeeding. ● Inform the mother that her food package will change based upon how much she is breastfeeding. ● Document a mother’s plan for breastfeeding, formula use and education provided in her nutrition education record. ● When formula is issued to a breastfed infant: o Provide only the minimum amount to meet, but not exceed the infant’s nutritional needs. Remember that WIC is a supplemental program and mothers will have greater breastfeeding success if they continue to breastfeed and/or express their milk regularly. o Provide powdered formula as a supplement because it can be prepared in as small a quantity as needed. o Determine the amount of supplement necessary that meets but does not exceed the infant’s nutritional needs and assign the appropriate food package. A breastfeeding infant who receives any formula from WIC is no longer in the fully breastfeeding category and needs to be adjusted
Colorado WIC Program Policies and Procedures Section: Nutrition Services Revised: 03/01/2026 Page 4 of 4 appropriately. o Adjust the mother’s food package appropriately based upon her level of breastfeeding and amount of infant formula issued. A woman over six months postpartum and determined to be in the “some breastfeeding” category will not receive a food package, however can still receive all other WIC services. o Document appropriately in the Compass computer system. o Provide regular follow up with the mother at least monthly to continue to support breastfeeding success as able. Banked Human Milk Banked human milk is not a WIC-eligible supplemental food (as defined by 7 CFR 246.10) and WIC federal funds cannot be used for the purposes of collecting, storing, purchasing, or disseminating banked human milk. WIC staff may inform parents about banked human milk, refer clients to human milk banks, and inform parents about donating their milk. Additionally, WIC clinics can serve as a human milk depot in partnership with another organization/human milk bank. Prior to serving as a milk depot, a Memorandum of Understanding (MOU) is required between the WIC agency and human milk bank/organization to clearly define the roles and responsibilities of each organization and explicitly state that banked human milk is not a WIC benefit, nor is the milk depot sponsored by WIC.
Colorado WIC Program Policies and Procedures Section: Nutrition Services Revised: 06/01/2025
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Breastfeeding: Human Milk Fortifier
Policy: Local agencies may issue human milk fortifier (HMF) to participants with proper medical documentation to promote and support continued breastfeeding.
Regulations: CFR 246, 79 FR 12273 C (5)(f), USDA FNS WIC Breastfeeding Policy and Guidance (July 2016), Colorado WIC Policy
Procedure/Additional Guidance: Human milk fortifier (HMF) is predominantly a protein and mineral supplement, that when added to human milk boosts the calories and nutrition to better meet the needs of very premature infants. Studies have shown the addition of HMF is associated with improved growth, bone mineralization and neurologic outcomes. HMF is initiated in the hospital and may be maintained after discharge with proper medical oversight and documentation. • HMF is classified as an exempt infant formula by USDA. • For clients with Medicaid insurance, WIC staff should refer to a Medicaid Durable Medical Equipment (DME) provider to obtain requested HMF. Medicaid is the first payer for HMF in Colorado. • For clients who do not have Medicaid insurance, issuance of HMF through WIC is allowed with monthly authorization by the infant’s health care provider (provided on the Physician Authorization Form – PAF). • WIC participant must have access to a breast pump (either from or outside of WIC). • WIC participant must be provided with breastfeeding support and continued, regular follow up (ideally weekly). • Breastfeeding definition guidance: o If receiving HMF not from WIC (from other sources only – e.g., Medicaid): If the infant is not receiving any HMF/formula from WIC, the infant's BF Description can be “Prim Excl/No Food Package”. The infant must be marked as receiving something other than breast milk and marked as receiving formula rarely (record the date HMF or any formula was started) in the nutrition interview. Choosing rarely to formula (while not entirely accurate) will allow for correct data collection of HMF start date and allow a fully breastfeeding food package to be issued. Add HMF issuance in the notes/care plan in Compass. Mother may be considered fully breastfeeding and receive the appropriate food package. o If receiving HMF from WIC: Since USDA classifies HMF as formula, the infant must receive a Breastfeeding Description of “Part BF” and be marked as receiving formula regularly in the nutrition interview. The mom's food package is based on the infant's BF Description. Therefore, mom will get a Part BF Food Package. Once HMF from WIC is discontinued, the infant’s BF Description can be changed to “Prim Excl/No Food Package” and the mother can be transitioned back to the fully breastfeeding package. • Infant must be monitored closely by their health care provider (thus require monthly PAF submitted). • HMF is most often discontinued prior to discharge and is not necessary or healthy to receive on a long-term basis. HMF must discontinue once the infant is 12 weeks post-discharge from the hospital or as indicated by the health care provider. • HMF cannot be reconstituted/fed on its own as an infant formula to provide proper nutrition, it must be added to human milk. • HMF cannot be added to formula or used in conjunction with formula “sprinkles” to fortify human milk. HMF is the preferred source of fortification for human milk as research indicates fortification of human milk with formula is inferior nutritionally to HMF. • HMF cannot be issued with other infant formula. HMF is authorized for use when a mother is, or is attempting to be, exclusively breastfeeding.
For questions or more information, refer to the Colorado Guidelines for Health Care Professionals for Human Milk Fortifier after NICU Discharge (plus mixing instructions) available on the Colorado WIC website.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 01.01.2023
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Breastfeeding: Scope of Practice
Policy: WIC regulations require the roles and responsibilities be defined for all staff in the support and promotion of breastfeeding.
Regulations: CFR 246.3e, USDA FNS WIC Breastfeeding Policy and Guidance (July 2016), Colorado WIC Policy
Procedure/Additional Guidance: The core competencies of staff as defined by USDA include: • Recognize own beliefs and attitudes regarding breastfeeding and the impact of those beliefs and attitudes on WIC participant decisions. • Know the benefits of breastfeeding for infants, mothers, families, community and environment, and apply to daily clinic activities. • Self-identify as part of the WIC “Team” that promotes, protects and supports breastfeeding. • Understand how the WIC food packages for the breastfeeding dyad support breastfeeding. • Understand how to assist mothers to overcome common barriers to initiation of, exclusive and continued breastfeeding. • Develop rapport and foster open dialogue to successfully communicate with pregnant women and mothers. • Identify factors that can impact breastfeeding during the prenatal assessment process. • Identify physiological factors that impact breastfeeding. • Understand optimal breastfeeding practices that help mothers initiate and maintain breastfeeding. • Recognize common breastfeeding concerns and protocols for obtaining additional assistance for mothers. • Assist women who are employed or in school with tailored strategies for continuing to breastfeed after returning to work or school. • Apply knowledge of lactation to supporting breastfeeding in varied situations. • Understand the role of clinic and community support for breastfeeding. • Collaborate with other programs/groups that provide breastfeeding education and support in the community.
Staff Training • Staff can receive breastfeeding education to meet the above core competencies by completing the Level II Colorado WIC Breastfeeding Module. • Staff can become WIC Lactation Specialists (WLS) [and/or Designated Breastfeeding Experts (DBE)] by attending a Colorado WIC training specifically designed to equip staff with knowledge to counsel women and infants with nutrition risk factors (NRFs) related to breastfeeding complications (NRFs 602 & 603). • All WIC Directors and High Risk Counselors are required to have advanced lactation training by becoming a WLS (by attending the training and passing the exam within one year of hire), DBE, and/or obtaining advanced lactation credentials (e.g., Certified Lactation Counselors (CLC), Certified Lactation Educators (CLE), International Board Certified Lactation Consultants (IBCLC)). • Educators are invited to participate in WLS trainings and must successfully pass the exam and observations of participant interactions to become WLS and perform initial counseling on high risk breastfeeding complications. • Breastfeeding peer counselors (BFPCs) with at least 12 months of work experience, or per the discretion of the LA BFPC Coordinator, may participate in WLS trainings and must successfully pass the exam and observations of participant interactions to become WLS. • Staff who have advanced lactation credentials are not required, but recommended, to attend the WLS training, regardless of their WIC title. Observations of participant interactions are not required.
The table on the following page defines general roles which staff with various training, education and credentialing can practice.
*Note: WIC agencies with staff who are RN, IBCLCs and who also perform public health nursing positions which require greater technical expertise may have expanded scope of practice beyond that described in this policy.
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Breastfeeding Roles in the Colorado WIC Program
Roles
(BF=breastfeeding) Basic Lactation Training WIC Lactation Specialist (WLS) Advanced Lactation Credentials (CLC/CLE/DBE/IBCLC) Clerical staff BFPC Educator
BFPC WLS Educator WLS RD/RN WLS Educator CLC,CLE RD/RN CLC,CLE DBE, IBCLC Provides info on benefits of BF and WIC services X X X X X X X X X Aids in or conducts BF promotion projects in the clinic X X X X X X X X X Creates and sustains a clinic environment supportive of BF X X X X X X X X X Refers clients to community BF resources X X X X X X X X X Conducts BF support groups X X X X X X X X Conducts BF education classes X X X X X X X Refers moms to appropriate staff for pumps and BF aids X X X X
Assesses need and issues appropriate pump and/or BF aids. Instructs on use, milk collection and storage X* X X X X X Contacts participants 24-72 hours after pump issuance and monthly thereafter. X* X X X X X Provides basic BF information through counseling and support calls
X X X X X X X X Assesses and provides counseling on common BF problems (e.g. sore nipples, latch, weaning)
X X X X X X X X Assesses and provides counseling on complex BF problems X X X X X X Provides high risk counseling on BF Complications risk factors (NRFs 602 & 603) X**
X X X X Mentors Educator and BFPC WLS staff
X
X X Serves as agency’s or clinic’s BF coordinator X X X X X Serves as agency’s BFPC program coordinator X X X X Serves as agency’s breastfeeding expert X
*BFPC WLSs can only issue pumps and complete follow-up calls for BFPC clients and must document contacts in the Participant Care Plan.
**When Educator WLSs provide the initial high risk counseling for NRFs 602 & 603, which is required within 24 hours of risk assignment, a high risk follow up appointment should be scheduled with a High Risk Counselor, DBE, or Educator Advanced Lactation Credentials (CLC, CLE, or IBCLC) within two weeks of the risk assignment.
Colorado WIC Program Policies and Procedures Section 4: Organization and Management Revised: 03/01/2026
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Central File Requirements
Policy: The local agency must maintain central files of specified documents according to retention policies as noted in the Retention of WIC Records and Reports policy.
Regulation: Colorado WIC State Policy
Procedure/Additional Guidance The local agency will maintain the following central files: ● Vendor Reports ● Ward Road Pharmacy/Sentido Health special formula signed invoices ● Equipment Maintenance and Calibration Logs (scales, measuring boards, and hemoglobin analyzers) ● Formula Disposal Log ● If USDA determines that a civil rights violation occurred, the local agency must document the corrective action taken and all follow-up activities in the Civil Rights Complaint Tracking Log provided by the State Office. (see Customer Service Complaint Processing policy for details)
Note: See the Retention of WIC Records and Reports policy for retention requirements.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 10/01/2018
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Certification Periods
Policy: All eligible participants will be certified in the WIC Program according to their category for the length of time allowed by USDA regulations.
Regulation: 7CFR 246.7(g)
Procedure/Additional Guidance: Pregnant Woman Apregnant woman is certified at time of entrance into the Program for the duration of her pregnancy and for up to the last day of the month in which her infant turns six weeks old or the pregnancy ends. Within the 6 weeks postpartum period, she may be recertified as: o A non-breastfeeding woman up to the last day of the sixth month after her baby is born or the pregnancy ends. For example, the pregnant woman can be recertified as a non-breastfeeding woman within 6 weeks of delivery. If she is recertified during this time period she receives postpartum food benefits. If the recertification is late (i.e., not done within 6 weeks), a woman can still be recertified as a non- breastfeeding and her new certification ends 6 months from the termination of her pregnancy.
OR o A breastfeeding woman for up to the last day of the month in which her infant turns one yearold, or until she stops breastfeeding, whichever occurs first.
Non-Breastfeeding/Postpartum Woman A non-breastfeeding woman may be certified within 6 months of termination of pregnancy and is certified for up to the last day of the sixth month after her baby is born or the pregnancy ends.
Breastfeeding Woman To be considered a breastfeeding woman, a woman must bebreastfeeding her infant on average of at least once a day. A breastfeeding woman may be certified at any time during the one-year postpartum period. A breastfeeding woman is certified for up to the last day of the month in which her infant turns 1 year old or until she stops breastfeeding, whichever happens first. A breastfeeding womans eligibility will endno later than 1-year postpartum. If a breastfeeding woman stops breastfeeding before 6-months postpartum, staff must change her category to postpartum/non-breastfeeding (refer to Section 8: Certification, Elilgibility and Coordination, Ineligible Applicants and Participant Terminations policy). If a woman is partially breastfeeding her infant that is older than 6 months who is receiving an out of range amount of formula, she remains eligible to receive all WIC Program benefits (e.g., breastfeeding support, nutrition education, etc.) except food benefits.
Infant The eligibility period for infants entering the Program from birth through 5 months of age begins on the date of certification into the Program until the last day of the month of his/her first birthday. An infant who is 6 months up to 12 months of age may be certified for 6 months. Category change from Infant to Child automatically occurs at the first recertification following their first birthday.
Child The eligibility period for a child begins on the date of certification into the program and ends the last day of the month of a 12 month period. A child may continue to receive WIC food benefits through the last day of the month of their 5th birthday.
Priority Levels & Certification Periods Local WIC programs will serve all priorities unless approval is given by the state office for restriction of priorities served. When an agency is approved to NOT serve priority 6 participants, (which includes postpartum, non- breastfeeding women at nutritional risk who do not qualify as a higher priority) the following apply:
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• A breastfeeding woman who stops breastfeeding before 6-months postpartum will be issued a minimum of 15-days benefits and then may no longer receive WIC benefits. • If benefits expire less than 15 days in the future, staff must issue the next month of benefits to ensure a 15- day notification period. • If the benefits expire in more than15 days in the future (redeemed or not), no additional benefits should be issued.
Shortening or Lengthening a Certification Period Federal regulations allow a participant to be recertified one-month prior or one month after their scheduled termination date. This flexibility allows the issuance of one month of food benefits beyond the certification period for certain categories of participants: Children who have not reached 5 years of age. Infants (certification may be extended up to, but not beyond, the 13th month of age).
If the participant has a valid reasonfor not being subsequently certified and meets a requirement for being extended, the termination date can be extended by one month. The participant's termination date cannot be extended if the participant has already been terminated or if the termination date has already been extended. If the termination date has been reached, the participant must be recertified (refer to Section 8: Certification, Eligibility and Coordination, Access to WIC Services policy).
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2022
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Certification Policy and Procedures
Policy: WIC staff will screen WIC applicants for eligibility based on the certification requirements and document each applicant’s eligibility and required information in Compass.
Regulation: 7 CFR 246.7, 7 CFR 246.26
Procedure/Additional Guidance: WIC staff must perform the following steps in order to certify a participant:
1) Obtain and enter Intake information on the New Member/Proxy screen in Compass: Endorser name. Participant first name and last name. Date of birth. Sex (for infants and children). Participant Category. Hispanic/Latino (yes/no). Mother’s name (for infants and children if on WIC) -or- Mother not on WIC. Race. Expected DOB (date of birth) (for infants and children). Although Compass allows the user to by-pass, this field must be completed in order for Compass to calculate gestational age. Foster Care (for infants and children who are in foster care).
Optional Intake information: Additional endorser name. Proxy name. Middle name. Suffix. Special needs.
2) Search for possible dual participation Click the “Show Hidden Members” in the “View” drop down to ensure a thorough check. Prior to enrollment, conduct an Advanced search which can be done by name, date of birth, zip code or home phone number To ensure a thorough check, especially when some of the identifying factors may be questionable, enter the first part of a name followed by the “%” sign (i.e., “Gon%”) to search for various spellings of Gonzales or Gonzalez. During enrollment, search within the Dual Participation Search pop-up within the New Member/Proxy screen. Discontinue adding the applicant if found to be already enrolled in another clinic, and transfer into the new clinic if appropriate.
3) Collect and document demographic information on the Family Intake Branch. The following fields must be completed: Family panel: o Mother’s Education Level. Enter the mother’s completed years of education. If the child is not in the care of his/her mother (i.e., child in foster care), enter the education level of the caregiver. o Printouts Language. o Preferred Language Spoken. Leave the field within the Family panel blank when the participant speaks English. Enter the language spoken when any language other than English is preferred o Referred to WIC by. Identity panel: o Proof of Identity. o Physically Present. o Other Program Participation. If the participant does not receive Medicaid, SNAP or TANF, “None” must be checked.
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Contact/Address panel: o Primary Phone Number. (Check appropriate box to identify if landline, cell/mobile) o Alternate Phone Number (optional). Check appropriate box to identify if landline or cell/mobile) o Alternate Phone Owner (optional). o Ask and check appropriate box for approval to allow call and allow texts. o Email Address (optional and recommended) o Privacy Information (as requested). o Record Dates. o Proof of Residence. o Physical Address. o Mailing Address (if different from physical address). Income panel: o Household Size. o Income Determination. Voter Registration panel: o Refers to whether or not the endorser or woman participant is registered to vote where they currently live or completed a voter registration form that day. o Staff are required to complete the voter registration panel at every participant certification and recertification visit, and whenever a client changes an address.
4) Complete and document health assessment on the Assessment branch. The following fields must be completed: Pregnancy panel: o The Expected Delivery Date and Last Menstrual Period dates are required fields for pregnant women. Update these fields if the due date changes during the pregnancy. The Last Menstrual Period and Expected Due Date are used to calculate a woman’s weeks’ gestation and her Certification End Date. o Pre-Pregnancy Weight: Required field to document the woman’s weight before her current pregnancy began. If pre-pregnancy weight is unknown, estimate the woman’s pre-pregnancy status (normal, low, high) by considering her current height and weight. From the pre-pregnancy weight determination and weeks gestation, identify the expected weight gain (use the lower line of the weight gain range). Subtract that value from current weight and enter as pre- pregnancy weight. o Multifetal Gestation and number of Expected Babies (if applicable). o Infants Born from this Pregnancy: Required field to link the mother and baby. Baby must have previously been added to the “New Member/Proxy” field in order for his/her name to appear in the drop down panel. o Postpartum information to be completed after delivery Actual Delivery Date. Weight Gained this Pregnancy. Pregnancy termination with no live birth (if applicable). Number of live infants from this pregnancy. o Anthropometrics panel: Measurement Date: If height and weight measurements are from another source (i.e., a physician’s office), enter the actual date the measurements were taken. o Birth Measurement: Required field for all infants and children. Check the “unknown” check box when measurements are not known. Blood panel: o Record Date: If hemoglobin or hematocrit values are from another source (i.e., physician’s office), enter the actual date the blood screening was done. If the values indicate severe anemia, staff must select “severely low hemoglobin/hematocrit” from the risk panel, as this risk factor is not automatically identified when the user selects “determine risk.” o Print Notice:
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2022
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Staff should select “print notice” to print a referral to the physician when a participant has abnormal blood iron results. o Blood Lead Measurement: Required field to record lead level screening information for children.
5) Complete and document a thorough Nutrition Interview.
6) Assign applicable risks Determine Risk o User clicks the “Determine Risk” button to pull forward all known risk factors in order to determine the participant’s risk status.
7) Complete the certification Staff must notify participants of the certification period. The endorser’s signature must be captured on the electronic signature pad for the Rights and Responsibilities form (R&R).
8) Referral Referrals must be documented.
9) Provide and document nutrition education Staff must complete the Nutrition Education and Care Plan panels
10) Assign food packages and issue benefits Staff must assign the appropriate food package, taking into consideration the participants category, breastfeeding level, and food preferences. Staff must verify the endorser’s proof of identity and record the type of ID in Compass. The endorser’s signature must be captured on the electronic signature pad for the receipt of food benefits. No endorser signature is required if food benefits are remotely issued.
11) Schedule and document next appointment
12) Complete the following if required for certification: Verification of Certification: For transfers who are currently certified, enter the VOC information in the New Member/Proxy section and any supplied information (risks, measurements, etc.) in the appropriate Compass fields Physician Authorization Form (PAF) completed and signed by a prescriptive authority. High risk counselor must review, sign and date, complete medical documentation in Food Package section and scan into Compass.
Colorado WIC Program Policies and Procedures Section 11: Civil Rights Revised: 01.01.2021
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Civil Rights Complaints Processing
Policy: Local agency staff members are required to understand the procedures for processing civil rights complaints.
Regulations: 7 CFR 246.8, FNS Instructions 113-1
Procedure/Additional Guidance: Specific procedures for local agency handling of all civil rights complaints follow:
Right to File a Complaint: Any person alleging discrimination based on race, color, national origin, sex, age, or disability has a right to file a complaint within 180 days of the alleged discriminatory action. (Under special circumstances this 180-day time limit may be extended by the Office of Adjudication and Compliance.) Complaints received after 180 days should also be investigated and resolved.
Acceptance: Local and State WIC staff must accept all written and verbal Civil Rights complaints and instruct complainants on how to file a complaint. In addition, Civil Rights complaints must be documented in the Customer Service Log in Compass. Staff must check the “Civil Rights” check box and complete the “Referred To” drop-down box within the screen, noting whether the complaint was forwarded to the director/supervisor, state office, or USDA. A copy of the civil rights complaint must be forwarded to the Colorado WIC Program Civil Rights Coordinator within 2 days of initial report and to the USDA within 5 days of initial report. Complainants may choose to submit complaint forms themselves. All of the required information must be collected so that USDA is able to determine validity of the complaint, and to contact the person with a reply. Note that all forms or letters must be signed by the complainant or authorized representative.
Complaint Filing: Complainants or their authorized representative should be directed to complete the USDA Program Discrimination Complaint Form found online at https://www.usda.gov/oascr/how-to-file-a-program- discrimination-complaint or at any USDA office, or call (866) 632-9992 to request the form. They may also write a letter containing all of the information requested in the form (see copy of form in this section). The completed, signed complaint form or letter may be mailed, faxed, or emailed to USDA at the addresses below:
Mail U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, DC 20250-9410 Fax (202) 690-7442 E-mail program.intake@usda.gov
For help filling out the form, instruct the complainant to call any of these telephone numbers: (202) 260-1026 Local area (866) 632-9992 Toll-free Customer Service (800) 877-8339 Local or Federal relay (800) 845-6136 Spanish relay (866) 377-8642 Relay voice users
Verbal Complaints: In the event a complainant makes verbal allegations, such as through a phone conversation, and is not inclined to place the allegations in writing, the person’s name to which the allegations are made and the details of the complaint shall be documented in the Compass Customer Service Log Description text box. Every effort must be made to collect sufficient information and to reread the statement back to the complainant to verify completeness and accuracy of the information recorded. The complainant is instructed on how to file a complaint with USDA.
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Tracking Complaints: Once a complaint is documented, immediate and appropriate follow up is required. Staff member documents the follow up plan in the Compass Customer Service Log Resolution text box. Follow up can include any of the following actions: Local agency WIC Director is notified of the complaint. Local agency WIC Director meets with local staff to develop a plan for corrective action as needed. Local agency WIC Director consults with State Nutrition Consultant, Retailer Coordinator, and/or Civil Rights Coordinator to develop a plan for corrective action (e.g., staff training on customer service, policy clarification, staff monitoring). When State Office staff receive the complaint, the CO WIC Nutrition Consultant and/or Civil Rights Coordinator contacts the local agency WIC Director to discuss the complaint and appropriate follow up.
Follow-up Plan: Staff documents the follow-up plan in the Compass Customer Service Log Resolution text box. Additional follow-up or documentation may be entered by editing the original record. Once the complaint has been resolved, WIC staff should close the record by recording the date in the Closed Date field.
If USDA determines the local agency to be noncompliant, the plan for corrective action and follow-up activities should be tracked on a Civil Rights Complaint Tracking Log (WIC #81) and entered into the Compass Customer Service Log Resolution text box. Documenting follow up on the tracking form and in Compass enables WIC staff to track problems, as well as identify any repeated occurrences. The USDA will notify the state office within 90 days when an agency is found in non-compliance. Once 90 days has passed the Compass Customer Service Log “Closed Date” may be noted, however no earlier than 90 days from date the complaint was sent to USDA. State and local agencies must keep records of Civil Rights complaints in a Civil Rights file. Complaints against a retailer must also be kept in the retailer file at both the state and local level.
Colorado WIC Program Policies and Procedures Section 11: Civil Rights Revised: 03/01/2026
Page 1 of 1 Civil Rights Monitoring and Compliance Reviews
Policy: Biennially, each local WIC agency will be reviewed for Civil Rights Compliance. Local agencies are required to understand the procedures for Civil Rights Compliance and Enforcement information.
Regulations: 7 CFR 246.6 (b)(10), 7 CFR 246.8 , FNS Instructions 113-1, Title VI Civil Rights Act of 1964.
Procedure/Additional Guidance: Pre-award reviews will be conducted on all applicant agencies to determine if they comply with the Title VI Civil Rights Act of 1964. Biennially, each local WIC agency will be reviewed for Civil Rights Compliance. This review will be accomplished during Program monitoring visits and will include the determination of the following items: ● Do all persons have an equal opportunity to participate in the Program regardless of race, color, national origin, sex, age, or disability? ● Have case records been coded by racial/ethnic origin? ● Has the local agency conducted civil rights training for its staff? ● Do project areas display the USDA WIC nondiscrimination poster or an FNS WIC-approved poster? ● Is program information being provided to applicants, participants, grassroots organizations, or similar minority groups? ● Is the nondiscrimination statement being included on all printed materials, such as applications, pamphlets (other than nutrition education), forms, or any other materials distributed to the public? ● Are civil rights complaints being handled in accordance with complaint processing procedures? (see Complaint Processing section) ● Has the local agency corrected all past substantiated civil rights problems or noncompliance situations? ● Are appropriate staff members, volunteers, or other translation resources available in areas where a significant proportion of non-English or limited English-speaking people reside?
In addition, local agencies are required to: ● Record completion of the required annual civil rights training in Compass under Staff Training. ● Log all civil rights complaints and related actions in the Compass Customer Service Log.
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Civil Rights Training
Policy: All new employees must complete Civil Rights training as a standard component of new employee training. All Employees must complete annual training in the following Civil Rights-related areas: Collection and use of civil rights data Effective public notification systems Complaint procedures Compliance review techniques Resolution of noncompliance Requirements of reasonable accommodations of persons with disabilities Requirements for language assistance Conflict resolution Customer service
Regulation: FNS Instruction 113-1
Procedure/Additional Guidance: Within 3 months of hire all new employees must complete Civil Rights training as part of the Level I Orientation Module, and document the completion in Compass under Operations – Staff – Staff Training.
Annually, all staff complete the required Civil Rights training and document the completion in Compass – Staff – Staff Training.
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Colorado WIC Allowable Foods
Policy: The state WIC program is responsible for selecting foods for the Colorado WIC Food List & Shopping Guide in accordance with the federal regulations and state policies. Authorized foods are provided through food packages according to the category and nutritional needs of the participant.
Regulations: 7 CFR 246.10 (c), 21 CFR 101.95
Procedure/Additional Guidance: WIC staff issue Colorado WIC approved foods to women, infants and children enrolled in WIC.
Colorado WIC Food List & Shopping Guide (Effective March 2023; Updated April 2025) The list of Colorado WIC Foods can be viewed at: https://www.coloradowic.gov/wic-foods-list
Unauthorized Foods in the Colorado WIC Program Infant Formula Any formula not specified on the Colorado WIC Physician Authorization Form. Baby Food Fruit and Vegetables With added sugar, starch or salt Infant Cereal
Cera Meal Wet Pack (jars) Dry Pack with fruit or sweeteners Dry Pack with formula - Milupa Cereals Any hot or cold cereal except those specified on Colorado WIC Food List and Shopping Guide Fruit Juice
Fruit Punch Tang Hi-C Fruit Punch Non-fortified fruit juices (except orange, grapefruit, and orange-grapefruit blend) Hawaiian Punch Fruit Nectars Lemonade Sweetened Juice Fruits and Vegetables Dried fruits or vegetables Fruits or vegetables with added sugars, fats, oils, sauces, o any added ingredients (i.e. salad dressing, croutons, chees nuts, meat, pasta, rice, noodles) Items from deli or salad bar Any herb or spice not on the Colorado WIC List of Allowed Herbs and spices Decorative fruits and vegetables Milk Raw milk or non-pasteurized milk Half and Half Hot Chocolate Mix Chocolate Drink Chocolate Milk Powdered Buttermilk Milnot Sweetened condensed Milk Cheese Deli cheese Individually wrapped cheese (except string) Cheese foods Cheese spreads Cheese products Flavored cheese Cream cheese Cottage cheese Imported cheese
Canned Beans With added sugar, fat, oil or meat Baked beans, refried beans or chili beans Soup or soup mix Baby Food Meat With added sugar or salt
Colorado WIC Program Policies and Procedures Section 11: Civil Rights Revised: 03/01/2026 Page 1 of 1 Customer Service Complaint Processing Policy: The State Office must have procedures to document the handling of complaints by participants, parents or caretakers of infant or child participants, proxies, vendors, farmers, and home delivery contractors. Regulations: 7 CFR 246.12, 7 CFR 246.8(b) Procedure/Additional Guidance: The specific procedures for handling customer service complaints follow: ● Right to File a Complaint: Any person alleging mistreatment has a right to file a customer service complaint. ● Acceptance: All customer service complaints, written or verbal, shall be accepted and documented by local or state WIC staff. Complaints elevated to the WIC clinic supervisor and/or state office must be documented in the Compass Customer Service Log. When possible, signed written statements from the complainant should be scanned into Compass. For vendor-related complaints, local agency staff should collect information, including the vendor’s name, details of the complaint, and the date and time the issue occurred. Once this information is gathered, Local agency staff should forward the complaint details to their Local Agency Retailer Coordinator (LARC). The LARC will then elevate the complaint and report it to the State Benefit Delivery Unit (BDU) for further review. ● Verbal Complaints: In the event a complainant makes verbal allegations, such as through a phone conversation, and is not inclined to place the allegations in writing, the person receiving those allegations must document them in the Compass Customer Service Log. Every effort should be made to capture the full complaint; staff members are encouraged to reread the statement back to the complainant to verify the accuracy of the information recorded. ● Tracking Complaints: Once a complaint is documented, immediate and appropriate follow-up is needed. Document the follow up plan in the Compass Customer Service Log resolution text box. Follow-up may include any of the following items. ✔ Agency WIC Director or staff supervisor clarifies the complaint with the complainant, if needed. ✔ Local agency staff consults with the agency WIC Director to develop a plan to resolve the situation. ✔ Local agency WIC Director consults with State Nutrition Consultant, BDU Coordinator, and/or Civil Rights Coordinator to develop a plan for corrective action (e.g., staff training on customer service, policy clarification, staff monitoring). ✔ State Nutrition Consultant and/or Civil Rights Coordinator contacts local agency WIC Director to discuss the complaint, if complaint is received at State WIC Office. ✔ Plan for follow-up with the complainant and the staff, as appropriate. ● Follow-up Plan: Staff documents the follow-up plan in the Compass Customer Service Log Resolution text box. Local Agencies are encouraged, but not required, to keep a written tracking log of all customer service related complaints. This tracking log enables local agencies to track problem resolution, as well as identify any repeated occurrences. Copies of customer service complaints against specific vendors should be kept on file at both the state and local levels.
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Data Collection and Reporting
Policy: Local agency WIC staff will collect and document racial and ethnic data in Compass in order to meet the responsibilities of compliance and enforcement. The collected Information is maintained on file at both the state and local level for three and a half years.
Regulations: 7 CFR 246.6 (b)(10), 7 CFR 246.8, FNS Instruction 113-1, Title VI of the Civil Rights Act of 1964 and USDA Regulations 7 CFR 15
Procedure/Additional Guidance: The following designations are used for the collection of racial/ethnic categories:
Ethnic categories: - Not Hispanic/Latino - A person of Cuban, Mexican, Puerto Rican, South or Central American, or other Spanish culture of origin regardless of race. The term “Spanish origin” can be used in addition to “Hispanic or Latino.”
Racial categories: - White: A person having origins in any of the original peoples of Europe, Middle East, or North Africa. - Black: A person having origins in any of the Black racial groups of Africa. Terms such as “Haitian” or “Negro” can be used in addition to “Black or African American. - Asian: A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and Vietnam. - American Indian or Alaskan Native: A person having origins in any of the original peoples of North and South America (including Central America), and who maintains tribal affiliation or community attachment. - Native Hawaiian or Other Pacific Islander: A person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
Use of Data The participant characteristics from the minimum data set are sent to USDA biennially. This information is compared to state and county racial/ethnic breakdown percentages to determine the effectiveness of WIC to reach potentially eligible populations, identify areas where additional outreach may be needed, and assess cultural diversity and sensitivity of the WIC staff.
Required Steps for Collections of Racial/Ethnic Data Local agency staff must: - Explain to the individual that the data collection is for statistical purposes only and that it is a USDA requirement as part of the certification process. - Inform the individual that it does not affect their eligibility for the program. - Request that the participant self-identify their racial/ethnic background. Participants may choose only one ethnicity but more than one racial category. - Use visual identification to determine the participant’s racial and ethnic categories if a participant chooses not to self-identify a race and/or ethnicity. When performing a visual identification, selection of one or more races is acceptable. - Not second guess, change or challenge a self-declaration made by the applicant as to his or her race or ethnic background unless such declarations are patently false. - Enter the participant’s ethnic and racial data in Compass.
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Data Use Policy: Process to Request Participant and Applicant Data
Policy: WIC staff, state and local, direct all requests for the disclosure of individual-level, identifying WIC participant information (i.e., any non-aggregated data) to the Data Manager at the Colorado WIC State Program Office.
Regulation: 7 CFR 246.26, 7 CFR 246.7(i)(11), 7 CFR 246.3(h)(3)
Procedure/Additional Guidance:
Introduction and Background State agencies administering the WIC program are responsible for the management and protection of confidential WIC applicant and participant information. The Colorado WIC State Program carries out these responsibilities according to state agency policies that ensure compliance with Federal regulations. The USDA grants state agencies the authority to determine with whom confidential WIC applicant and participant information will be shared and for what purposes within the limitations and allowances established in Federal regulation.
Colorado WIC Program policy requires that non-WIC partners may only use PII with participant consent for the following reasons: 1) to follow up on referrals and provide additional services to participants and their families. 2) under a data use agreement to support evidence-based or promising practices that increase WIC enrollment and/or retention. 3) reporting known or suspected child abuse or neglect.
The intent of this request process is to guide public partner organizations who desire use of confidential personal information for meaningful projects that benefit WIC applicants/participants or the Colorado WIC Program. Completion of this request will provide the Colorado WIC State Program Office sufficient information to assess whether the data use purpose meets Federal regulations and upholds program data use values. Expected time for review is within 10 business days. The Colorado WIC Program Director has the authority to approve or decline this request. If a request for data use is approved, additional information about data elements and timelines may be needed to create a data use agreement with all approved parties for approved uses.
In addition to compliance with Federal regulations, the Colorado WIC Program makes decisions regarding data use according to Program policies and values. The Colorado WIC State Program Office intends to support innovation proposed by state and local partners with these values in mind:
The protection of confidential participant and applicant data is the highest level of priority for the Colorado WIC Program to build and maintain public trust that personal data is protected. The Colorado WIC Program holds the interests, desires, and well-being of the public, WIC participants, and WIC applicants at the center of any data use decision. The Colorado WIC Program will ensure that any data use allowed within Federal regulations provides benefit to program participants, applicants and/or to the Colorado WIC Program as a whole. Racial and ethnic equity will be preserved by ensuring that no data use agreements result in any type of harm to people or communities of color or any people or communities impacted by public charge. The Colorado WIC Program will ensure that only the minimum necessary protected information is provided through data use agreements. Robust protections of personal data by the recipient organization will be ensured by the Colorado WIC Program before approving data use agreements. Data use requests will be balanced with capacity and resource constraints of the Colorado WIC Program, as the Program does not typically receive additional funding for these purposes.
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Request Process Please answer the following questions to request confidential personally-identifiable information (PII) from the Colorado WIC Program:
What effort or intervention does your organization plan to execute using Colorado WIC Program data? In your response, please describe how your proposal meets at least one of these state requirements for use of PII with participant consent by non-WIC partners: ○ to follow up on referrals and provide additional services to participants and their families. ○ under a data use agreement to support evidence-based or promising practices that increase WIC enrollment and/or retention. ○ reporting known or suspected child abuse or neglect.
What evidence demonstrates that this effort or intervention has a promising or proven impact for Colorado WIC Program participants?
Has your organization conducted engagement work with Colorado WIC Program participants to understand their perspective about your effort or intervention? If yes, please answer the following: ○ In what ways has participant engagement informed your planned effort or intervention? ○ What has the engagement work revealed about participants’ perceived benefit of this proposal? ○ What has your community engagement revealed about participants' level of comfort for the Colorado WIC Program using their personal data for these purposes?
If your organization hopes to streamline administrative procedures and minimize staff burden, have you engaged Colorado WIC Program (state or local) staff for their perspective about the proposal? If yes, what do they perceive as the benefit to their administrative roles?
What interventions do you hope to do differently based on the availability of this data? How may this change if this request is denied?
During or after your effort or intervention, what findings would you share with the Colorado WIC Program about the outcomes, impacts, and discoveries of your work that could benefit the future direction of the Program statewide?
What specific additional value does PII data provide that cannot be met by available sources of aggregate data provided by the Colorado WIC Program?
Data Security: ○ If this request is approved, who specifically will see and/or utilize Colorado WIC Program data? Please include names, titles, a description of their roles, the name of the entities for which they work, and a description of where they appear in an organizational chart (division, unit, and which positions they report to). ○ Where and how would data from the Colorado WIC Program be stored? ○ What is your planned destruction method for sensitive data? When and would the data from the Colorado WIC Program be destroyed? ○ How can the Colorado WIC Program audit the handling of the data to ensure proper use? ○ What safeguards do you have in place to ensure Colorado WIC Program data will not be used in any way that might harm the individuals represented in the data?
What long term or future work is planned that relates to this work and the Colorado WIC Program data used for this immediate project?
Have you gotten permission from your organization to enter into a data use agreement with the Colorado WIC Program, if needed? If so, who would sign the agreement for your organization or program (include name, title, contact information)?
Please submit your data request electronically to the WIC Data Manager, cdphe_nsbdata@state.co.us.
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Data Use Policy: Use of Program Participant and Applicant Data
Policy: WIC staff, state and local, direct all requests for the disclosure of individual-level, identifying WIC participant information (i.e., any non-aggregated data) to the Data Manager at the Colorado WIC State Office. The following policy is used to assess the ability to fulfill data requests.
Regulation: Federal:7 CFR 246.26, 7 CFR 246.7(i)(11), 7 CFR 246.3(h)(3) State: § 24-74-102(1), C.R.S. and § 24-74-103 CRS
Procedure/Additional Guidance: This data use policy clarifies when and how Colorado WIC State Program participant data will be shared with state, local, and external entities while protecting participant confidentiality.
Aggregated Data Aggregated data arise from processing individual records into summary form in order to track information across populations, organizations, time and other variables of interest. State and local Colorado WIC Program staff may access aggregated data via WIC Data Central (WDC) and Compass reports. Requests for additional aggregated data not available on WDC or within Compass reports shall be directed to the Data Manager.
Maintaining Statistical Stability Aggregated WIC data sometimes describe rare events and/or small populations, which may compromise statistical stability. Therefore, when possible, aggregated data produced by the Data Manager shall include a description of the variability of the data (i.e., confidence intervals, relative standard error). Additionally, the Data Manager will recommend the requester interpret any counts of less than 30 with caution given the small sample size.
Maintaining Confidentiality When data use occurs outside of state and local Colorado WIC Program staff, rare events and small populations may also endanger participant confidentiality. Counts of 20 or less will be censored when producing tables that will be viewed outside of state or local WIC staff to maintain confidentiality. The Data Manager also uses caution when sharing aggregate data with populations of less than 500, and producing multiple tables from the same dataset. Should there be concern about a possible breach of confidentiality when sharing outside of state and local WIC staff, the Data Manager will take steps to limit this risk through strategies such as: combining alike groups, producing a courser analysis, and omitting tables unlikely to contain information that would inform public health efforts.
Personally Identifying Information (PII) Per Federal regulations (§246.26), PII includes any information that individually identifies an applicant, participant, and/or family member(s) that was obtained or created during the course of an individual(s) WIC referral, application, or program participation. This includes but is not limited to: name; WIC participant number; contact information (may include address, phone, email); health data; the fact that a person was referred, applied, and/or participated in WIC; date of birth; health insurance number; source of income; status as a recipient of public assistance; race; ethnicity; gender identity; physical, intellectual and/or developmental disability.
In accordance with Federal regulation §246.7(i)(11), WIC applicants and participants acknowledge in the Participant Rights & Responsibilities form through the following language that their PII may be shared for these allowed purposes: ● “WIC respects my privacy. Information I give is used to verify if I qualify and to provide me with services. My information may be shared only with programs directly connected with WIC and for reports and audits as approved by the Colorado WIC Data Use Policy. Any other sharing of information must be approved by me with a signed or verbal consent.” ● “WIC staff are mandatory reporters. They are required to report suspected child abuse or neglect.”
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The local Colorado WIC agency must permit applicants and participants to refuse to sign/acknowledge the Rights & Responsibilities statement but must also notify the applicants and participants that signing/acknowledging the form is a condition of program eligibility and participation. These forms must be signed/acknowledged only after the certification is complete.
A verbal acknowledgment is allowed instead of a signature for those participants who are participating in a remote appointment.
Prior to PII disclosure for the allowed purposes listed below, the state WIC agency requires a completed data request process. If the request is approved, a data use agreement is created to include: a) Specific PII to be shared, why PII is critically necessary, the intended purpose of PII, time frame of PII use, specific individuals with access to PII, plan for safekeeping and timely destruction of PII, and assurance that the partner will not use the information for any other purpose or disclose the information to a third party. b) Approval of the Colorado WIC director, the director of the CDPHE Office of Legal & Regulatory Compliance, and CDPHE Privacy Officer. c) Signature of the Executive Director of CDPHE. d) Amendment to the WIC State Plan in accordance with federal regulation §246.3(h)(3).
The Colorado State WIC Program provides only the PII reasonably necessary to accomplish the approved purpose(s). The initiation of a data request does not compel the Colorado WIC Program to provide PII to the requestor. The Colorado State WIC office will make every attempt to use aggregated data in lieu of disclosing PII in meeting the needs of a requestor. If a request cannot use aggregated data and does not present a clear benefit to applicants/participants or the Colorado State WIC program as a whole, the request will be denied.
If the data requested requires matching or may involve research, Colorado State WIC follows the Prevention Services Division procedure related to these types of requests.
In alignment with USDA Food and Nutrition Service (FNS) Instruction 800-1, State WIC does not allow the use of universal consents which give an agency unlimited authority to release applicant or participant information, or to take the place of sharing agreements with health and welfare organizations detailed in the regulations. Such open- ended release forms could result in inappropriate sharing of information and reduce the protection of applicant/participant PII.
Disclosure to WIC staff for WIC Purposes State WIC provides access to PII to state and local WIC staff who administer WIC programming through the data management information system, Compass. Only authorized users are allowed access to this information; no non-WIC staff can be authorized for this access. Notification must be provided as to how the data may be used or shared.
Disclosure to Participant’s Healthcare Provider Participants may consent or deny consent to disclosure of personal information to their healthcare providers. This consent or denial of consent is recorded in Compass in the Nutrition Interview and a signature is captured when the participant signs the Colorado WIC Rights & Responsibilities document. The Colorado WIC Rights & Responsibilities states, “I have been asked about disclosing my confidential healthcare information with my provider. That information can be found in the Nutrition Interview.” Prior to documenting a participant’s preference (Yes or No) for disclosing information to their healthcare provider, the participant must be notified that their answer (consent or denial) is not a condition of their eligibility, and the possible reasons why information may be shared with their provider.
Any information shared with the healthcare provider should be minimum necessary. Minimum necessary means only the relevant information needed to accomplish the task can be shared.
Limited Disclosure to Non-WIC Partners for Approved Purposes Limited disclosure is a one-time release of information and does not include back and forth data sharing. The approved purposes for limited disclosure are listed below.
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● Non-WIC partners may only use PII with individual, documented participant consent to follow up on referrals and provide additional services to participants and their families. ● Non-WIC partners may use PII under a data use agreement to support evidence-based or promising practices that increase WIC enrollment and/or retention.
Note: Local WIC MOUs with partners that include sharing of WIC data are not allowed.
Disclosure Related to Subpoenas Per Federal regulation (§246.26), local WIC agencies receiving subpoenas shall immediately do the following; 1) Immediately notify the Colorado WIC Program State Office; 2) Notify local legal counsel, however local legal counsel cannot authorize release of PII. CDPHE legal counsel determines this. 3) If the requested information is PII, CDPHE legal will attempt to quash the subpoena unless CDPHE legal counsel determines that disclosing the PII is in the best interest of the Colorado State WIC Program. a) The decision to disclose PII without attempting to quash a subpoena should be made rarely and the Colorado State WIC Program should inform the receiving party that the requested information is confidential, provide only the specific information requested in the subpoena and no other information, and limit, to the greatest extent possible, public access to the disclosed PII. This may require a signed data sharing agreement at the discretion of the Colorado WIC Program Director and Data Manager.
Disclosure Related to Court Orders Local WIC agencies presented with a court order shall do the following: 1) Immediately notify the Colorado WIC Program State Office. The State Office will consult with CDPHE legal for direction.
Disclosure Related to Judicial Search Warrants A judicial search warrant is a court order signed by a judge/magistrate based on probable cause for criminal investigations, authorizing forced entry. In responding to a judicial search warrant for PII, the local Colorado WIC Program agency shall do the following: 1) Immediately notify the Colorado State WIC Program Director. 2) Immediately notify local legal counsel. 3) Comply with the judicial search warrant, but inform the individual(s) serving the judicial search warrant that the information being sought is confidential. 4) Seek to limit the disclosure by: a) Providing only the specific information requested in the judicial search warrant and no other information; and b) Limiting public access to the confidential information disclosed.
Disclosure to US Department of Agriculture (USDA)/FNS State and local WIC and contractors must cooperate in studies and evaluations conducted by or on behalf of the USDA, related to programs authorized under the Richard B. Russell National School Lunch Act and the Child Nutrition Act of 1966 (42 U.S.C. 1786).
Release of WIC Records to Endorser The Colorado State WIC Program releases applicant/participant records to the current initial and/or additional endorser(s) only for the period of time they personally are the endorser. The Colorado State WIC Program is only required to release information that was provided by the applicant/participant, except as required by federal, state or local law. The endorser(s) must show proof of identification (as defined by Colorado WIC Program proof of identity standards) to obtain the records and may only be provided with the portion of the record for which they were the endorser(s).
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Records Not Released Colorado WIC Program records shall not be released to the federal government or third parties, including the Department of Social Services (DSS), without written approval from the Colorado WIC Program or the endorser. Records of a child in foster care may only be released to DSS for that time while the child was in foster care. Requests for records from proxies, past or interim endorsers, relatives, or nonlegal guardians shall not be released. Requests for records for immigration or immigration administration purposes shall not be released. Records requests and releases shall be documented in each participant's care plan.
Direct questions or concerns about this policy to the Colorado WIC Program Director or the Data Manager.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 04/01/2026 Page 1 of 5
Determining Income Eligibility
Policy: Local WIC program staff shall determine income eligibility for all WIC applicants and participants at certification and recertification appointments.
Regulation: 7 CFR 246.7 (d)(2)(ii), 7 CFR 246.7 (d)(2)(iv)
Procedure/Additional Guidance: Staff must first assess for adjunctive eligibility. See Adjunctive Eligibility policy. If an applicant/participant is not adjunctively eligible, staff must assess the household’s income situation and determine the most appropriate method for determining the household’s income.
Income Sources to be Included in Determining Income Eligibility: Income means gross income before deductions for income taxes, employee's social security taxes, insurance premiums, bonds, etc. WIC regulations do not allow a household’s income to be reduced for hardships, high medical bills, child care payments, taxes, child support, alimony, insurance, or other deductions. Income includes the following:
● Monetary compensation for services, including wages, salary, commissions, or fees, including active military payments. ● Social Security, Social Security Disability. ● Dividends or interest on savings or bonds, income from estates or trusts, or net rental income. ● Public assistance or welfare payments, foster care payments (SNAP benefits are not counted as income). ● Unemployment Compensation. ● Government civilian employee or military retirement, pensions, or veteran's payments. ● Private pensions or annuities. ● Alimony or child support payments. ● Military clothing allowance. ● Military Basic Allowance for Subsistence (BAS). ● Military foreign duty pay. ● Any Cost-Of-Living Allowance (COLA) provided to military personnel on duty in designated high-cost areas within the 48 contiguous states of the United States. This allowance is referred to as the continental United States (CONUS) COLA. ● Regular contributions from persons not living in the household. ● Net royalties. ● Other cash income, including, but not limited to, cash amounts received or withdrawn from any source, including savings, investments, trust accounts, or other resources which are readily available to the family (See Lump Sum Payments below). ● Education grants and loans are considered income when determining WIC eligibility, dependent on the source of the grant or loan (see Income and Benefits Exclusion List). Money received from the G.I. Bill for educational purposes is considered income. ● Lump sum payments may be considered income depending on their classification. Lump sum payments are classified as either "new money" or "reimbursements" for lost assets or for injuries. ✔ Lump sum payments that represent "new money" intended to be used as income should be considered as "other cash income" and counted as income for WIC income eligibility determinations. Examples of "new money" include: gifts, inheritances, lottery winnings, workers' compensation for lost income, and severance pay. ✔ Lump sum payments that represent reimbursements should not be counted as income. Examples of lump sum payments as "reimbursements" that do not count as income include: mileage reimbursements, amounts received from insurance companies (home or auto) for loss or damage of real or personal property incurred by a household, such as payment of medical bills resulting from an accident or injury. ✔ Lump sum payments may not fall easily into the categories of "reimbursements" or "new money" but may in fact represent both. Examples include legal or medical settlements that provide reimbursement for lost property and medical expenses, as well as compensation for tangible or intangible physical or
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mental injury. In the case that a lump sum payment falls into both categories, the payment should be treated in a way that most accurately reflects the economic situation of the household.
✔ For those lump sum payments that are considered as income, the lump sum should be counted as annual income or divided by 12 to estimate a monthly income.
Income Sources NOT to be Included in Determining Household Eligibility ● Any Basic Allowance for Housing (BAH) received by military service personnel for residing off base or as payments for privatized on-base housing. ● Any Cost-Of-Living Allowance (COLA) provided to a member of a uniformed service who is on duty outside the contiguous states of the United States. This allowance is referred to as the Overseas Continental United States (OCONUS) COLA. Some members of a military family may remain stateside and apply for WIC while a family member on duty overseas receives the OCONUS COLA. ● Combat pay is an additional payment (Chapter 5 of Title 37 of the United States Code) received by the household member who is deployed to a designated combat zone. Combat pay received by service members is normally reflected in the entitlements column of the military Leave and Earning Statement (LES). Family Separation Hardship (FSH), Hardship Duty Pay (HDP) are also exclusions. Combat pay, Hardship Duty Pay, and Family Separation pay are excluded from WIC income eligibility determination when: ✔ Received in addition to the service member’s basic pay; and ✔ Received as a result of the service member’s deployment to or service in an area that has been designated a combat zone; and ✔ Not received by the service member prior to his/her deployment to or service in the designated combat zone. ✔ Received as Deployment Extension Incentive Pay (DEIP)/Deployment Extension Stabilization Program (DESP) pay. DEIP/DESP payments are given to active service members who agree to extend their military service by completing deployment with their units without re-enlisting. This exemption to income applies until the service member returns to a military installation within the United States. (Note: Any additional DEIP or DESP payment received by the service member while serving within the United States must be counted as income for WIC eligibility determination purposes.) ● The value of in-kind housing and other in-kind benefits (e.g. divorced woman has full custody of child and her ex-husband pays child care expense directly to childcare provider. ● Reimbursements from the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 (Pub. L. 91-646, sec. 216, 42 U.S.C. 4636). ● Any payment to volunteers under Title I (VISTA and others) and Title II (RSVP, foster grandparents, and others) of the Domestic Volunteers Service Act of 1973 (Pub. L. 93-113, sec. 404(g), 42 U.S.C. 5044(g)) to the extent excluded by that Act. ● Payment to volunteers under section 8(b)(1)(B) of the Small Business Act (SCORE and ACE) (Pub. L. 95-510, sec. 101, 15 U.S.C. 637(b)(1)(D)). ● Income derived from certain sub marginal land of the United States, which is held in trust for certain Indian tribes (Pub. L. 94-114, sec. 6, 25 U.S.C. 459e). ● Payments received: Job Training Partnership Act (Pub.L. 97-300, sec. 42(b),29.S.C. 1552(b)); ● Income derived from the disposition of funds to the Grand River Band of Ottawa Indians (Pub. L. 94-540, sec 6). ● Payments received under the Alaska Native Claims Settlement Act (Pub. L. 100-241, sec. 15, 43 U.S.C. sec. 1626(c)). ● The value of assistance to children or their families under the National School Lunch Act, as amended (Pub. L. 94-105, sec. 9(d), 42 U.S.C. sec. 1760(e)), the Child Nutrition Act of 1966 (including free or reduced-price lunches or breakfasts, and meals or supplements in the Child and Adult Care Program and Summer Food Service Program) (Pub. L. 89-642, sec. 11(b), 42 U.S.C. sec. 1780(b)), and the Food Stamp Act of 1977 (Food Stamp Program, including Food Distribution Program on Indian Reservations) (Pub. L. 95-113, sec. 1301, 7 U.S.C. sec 2017(b)). ● Payments by the Indian Claims Commission to the Confederate Tribes and Bands of the Yakima Indian Nation or Apache Tribe of the Mescalero Reservation (Pub.L.95-433,sec.2,25USC609c-1). ● Payments to the Passamaquoddy Tribe and the Penobscot Nation or any of their members received pursuant to the Maine Indian Claims Settlement Act of 1980 (Pub. L. 96-420, sec. 6, 9(c), 25 U.S.C 1725(I), 1728(c)).
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● Payments under the Low-income Home Energy Assistance Act, as amended (Pub. L. 99-125, sec. 504(c), 42 U.S.C. sec. 8624(f)). ● Student financial assistance received from any program funded in whole or part under Title IV of the Higher Education Act of 1965, including the Pell Grant, Supplemental Educational Opportunity Grant, State Student Incentive Grants, National Direct Student Loan, PLUS, College Work Study, and Byrd Honor Scholarship programs, which is used for costs described in section 472 (1) and (2) of that Act (Pub. L. 99-498, section 479B, 20 U.S.C. 1087uu). The specified costs set forth in section 472 (1) and (2) of the Higher Education Act are tuition and fees normally assessed a student carrying the same academic workload as determined by the institution, and including the costs for rental or purchase of any equipment, materials, or supplies required of all students in the same course of study; and an allowance for books, supplies, transportation, and miscellaneous personal expenses for a student attending the institution on at least a half-time basis, as determined by the institution. The specified costs set forth in section 472 (1) and (2) of the Act are those costs which are related to the costs of attendance at the educational institution and do not include room and board and dependent care expenses. ● Payments under the Disaster Relief Act of 1974, as amended by the Disaster Relief and Emergency Assistance Amendments of 1989 (Pub. L. 100-707, sec. 105 (I), 42 U.S.C. sec. 5155(d)). ● Effective July 1, 1991, payments received under the Carl D. Perkins Vocational Education Act, as amended by the Carl D. Perkins Vocational and Applied Technology Education Act Amendments of 1990 (Pub. L. 101- 392, sec. 501, 20 U.S.C. sec. 2466d). ● Payments pursuant to the Agent Orange Compensation Exclusion Act (Pub. L. 101-201, sec.1). ● Payments received for Wartime Relocation of Civilians under the Civil Liberties Act of 1988 (Pub. L. 100-383, sec. 105 (f)(2), 50 App. U.S.C. sec. 1989b-4(f)(2). ● Value of any child care payments made under section 402(g)(1)(E) of the Social Security Act, as amended by the Family Support Act (Pub. L. 100-485, sec. 301, 42 U.S.C. sec. 602 (g)(1)(E)). ● Value of any “at-risk” block grant child care payments made under section 5081 of Pub.L. 101-508, which amended section 402(I) of the Social Security Act. ● Value of any child care provided or paid for under the Child Care and Development Block Grant Act, as amended (Pub. L. 102-586, sec. 8(b), 42 U.S.C. 9858q). ● Mandatory salary reduction amount for military service personnel, which is used to fund the Veteran’s Educational Assistance Act of 1984 (GI Bill), as amended (Pub L. 99-576, sec. 303(a)(1), 38 U.S.C. sec. 1411 (b)). ● Payments received under the Old Age Assistance Claims Settlement Act except for per capital shares in excess of $2000 (Pub. L.98-500, sec. 8, 25 U.S.C. sec. 2307). ● Payments received under the Cranston-Gonzales National Affordable Housing Act, unless the income of the family equals or exceeds 80 percent of the median income of the area (Pub. L. 101-625, sec. 522(I)(4), 42 U.S.C. sec.1437 (nt). ● Payments received under the Housing and Community Development Act of 1987, unless the income of the family increases at any time to no less than 50 percent of the median income of the area (Pub. L.100-242, sec. 126(c)(5)(A), 25 U.S.C. sec. 2307). ● Payments received under the Sac and Fox Indian claims agreement (Pub. L. 94-189, sec 6). ● Payments received under the Judgment Award Authorization Act, as amended (Pub. L. 97-458, sec. 4, 25 U.S.C. sec. 1407 and Pub. L. 98-64, sec. 2(b), 25 U.S.C. sec. 117b(b)). ● Payments for the relocation assistance of members of Navajo and Hopi Tribes (Pub. L. 93-531, sec. 22, U.S.C. sec. 640d-21). ● Payments to the Turtle Mountain Band of Chippewas, Arizona (Pub. L. 97-403, sec.9 ). ● Payments to the Blackfeet, Grosventre, and Assiniboine tribes (Montana) and the Papago (Arizona) (Pub. L. 97-408, sec. 8(d)). ● Payments to the Assiniboine Tribe of the Fort Belknap Indian community and the Assiniboine Tribe of the Fort Peck Indian Reservation (Montana) (Pub. L. 98-124, sec. 5). ● Payments to the Red Lake Band of Chippewas (Pub. L. 98-123, sec. 3). ● Payments received under the Saginaw Chippewa Indian Tribe of Michigan Distribution of Judgment Funds Act (Pub. L. 99-346, sec. 6(b)(2)). ● Payments to the Chippewas of Mississippi (Pub. L. 99-377, sec. 4(b). ● Payments received under the Medicare Prescription Drug, Improvement, and Modernization Act of 2003 through the prescription drug discount program must not be treated as income.
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● Earned Income Tax Credit (EITC) refund/payments. ● National Flood Insurance program payments (USDA Policy Letter WC-06-02-P). ● Treatment of Family Subsistence Supplemental Allowance (FSSA)(USDA Policy Letter WC-06-03-P). ● Loans, not including amounts to which the applicant has constant or unlimited access. ● Filipino Veterans Equity Compensation Fund payments (Public Law 111-5, Sections 1002(c) and 1002(g).
Any benefit that is of value, but which is not provided in the form of cash, is considered an in-kind benefit and is not counted as income. Example: A divorced woman has full custody of a child, and her ex-husband pays child care expenses directly to the child’s day care center. Those payments are considered an in-kind benefit and are not included in her income. However, if the ex-husband pays the money directly to the divorced woman, who then pays the day care, then the money is included as income. Another example includes a person who receives housing without cost as part of their job. The value of in-kind housing is not considered income. If a person receives a housing allowance (money), then it is considered income.
Special Income Situations/Considerations
Current Income versus Annual Income Current income is defined as all income received by the household during the month (30 days) before the date they apply for WIC benefits. When income received in the prior 30 days does not accurately reflect the household’s current circumstances, income expected to be received in the next 30 days may be used instead. Staff may use either income from the past 30 days or income expected in the next 30 days, whichever best represents the household’s current financial situation. ● Examples of Using Current Income: ○ If an individual’s income increases and this increase is expected to continue (such as a raise in salary), the increased pay must be used for income determination. ○ If an individual’s income decreases and the decrease is expected to continue (for example, if a person lost a higher-paying job and transitions to a lower-paying job), the reduced pay must be used for income determination. ○ When adult household members are unemployed, income determination should be based on the income they are currently receiving or expect to receive in the next 30 days (such as unemployment benefits), if applicable. ○ Households experiencing temporary low-income situations must be assessed using current income based on either the past 30 days or the next 30 days, whichever best reflects the household’s present financial circumstances. Temporary low-income situations may include, but are not limited to: ● Construction or seasonal workers. ● Seasonal agricultural workers, including farmers (see Self-Employed Individuals policy for how income must be calculated). ● Teachers paid for fewer than 12 months of the year. ● Individuals on extended leave due to childbirth or illness. ● Furloughed individuals. Annual income is defined as income received during the past 12 months. Lump sum payments must be counted as annual income or be divided by 12 to estimate a monthly income for eligibility purposes. ● Lump sum payments include one-time or irregular payments, such as, but not limited to: ○ Bonuses (e.g., reenlistment bonuses, hazardous duty pay) ○ Other one-time income payments considered countable that are listed under the Income Sources to be Included in Determining Income Eligibility.
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Self-Employed Individuals For self- employed farm and non-farm individuals, WIC income eligibility must be determined using net income, not gross income.
WIC agencies are encouraged to use the applicant’s most recently completed Internal Revenue Service (IRS) tax returns as a basis for calculating net income for both self-employed farm and non-farm individuals. State and local agencies should use the adjusted net income figure shown on the completed Federal tax return. It is not the responsibility of the local WIC staff to challenge or recalculate that amount.
When tax documents are not available, staff must review the list of acceptable proofs of income. Staff may then use either income from the past 30 days or income expected in the next 30 days, whichever best represents the household’s current financial situation. If no other proof of income is available, an affidavit may be used.
Participants Declaring Zero Income When an applicant declares zero income for their household, staff should question how basic living necessities such as food, shelter, medical care, and clothing are obtained. Given WIC’s definition of economic unit (a group of related or unrelated persons sharing financial and other resources), some WIC participants may incorrectly report having zero income. ● For example, an unemployed pregnant woman may report zero income even though she lives with a friend who provides housing, water, electricity, and/or food. In this example the pregnant woman is actually part of the larger household and must report the income of her friend (and any other household members).
Income Ineligibility and Disqualification If the participant is found to be over income and not adjunctively eligible, all members of their household should be disqualified from WIC even if they are currently within a certification period. Participants found to be over income and are within their certification period should be issued 15 more days of food benefits, made ineligible, and be given a Notice of Ineligibility. Exception is when 90 days or less remain in the certification period, the remainder of the food benefits may be issued through the current certification period.
Income Eligibility Complaints Any time a Local WIC program receives a complaint against a participant about questionable income eligibility, either verbally or in writing, local staff shall determine if any further investigation or action is needed to address the reported complaint.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 07/01/2026 Page 1 of 2 Education Documentation Policy: A minimum of two nutrition education contacts must be documented in the participant’s WIC record for each 6-month certification period. For breastfeeding women, infants and children certified for more than six months, contacts must be offered on a quarterly basis. Actively participating breastfeeding women of an infant older than 6 months of age receiving out of range formula do not receive food benefits but a nutrition education contact is still required. Regulation: 7 CFR 246.11(e) Procedure/Additional Guidance: The purpose of documentation is to record information provided to and from the participant during a WIC visit. Quality documentation ensures continuity of care and enables staff to review plans from previous visits, follow up on participant goals, and reinforce nutrition education messages. Participant Care Plan information must be entered no more than 10 days after a visit. The following are required components of nutrition education documentation in Compass: ● Completion of the Nutrition Education panel including: o Selecting Nutrition Education Topics Covered, o Documenting any pamphlets provided in the Pamphlets Provided field, o Checking the High Risk Follow Up Appointment check box if a high risk visit is performed by the high risk WIC counselor or IBCLC/CLC. ● Completion of the Participant Care Plan including: o Participant comments, objective information, assessment, nutrition education, pamphlets, goals, referral and follow-up plan as appropriate and as described below. o At least one goal the participant identified documented (exception, low-risk participants who complete a wichealth.org lesson or those that complete a nutrition education contact via a Nutrition Education class). Documenting High Risk: When a WIC educator identifies a participant to be high risk and the WIC High Risk Counselor provides high risk counseling that day, both WIC staff enter a separate education note. Only one education note is required when the WIC High Risk Counselor completes both the certification/recertification/follow up and high risk counseling in one visit. Documenting Group Education: In order for a group education session to be counted as a nutrition contact, a class outline must be on file that specifies the topics covered, materials used, and the class title. Nutrition education class topics are chosen when a class is created in the Compass scheduler. When a parti cipant completes a class, those topics are transferred to their nutrition education record. A care plan is not required. Creating A Care Plan: The Care Plan – Participant panel is where all subjective, objective, assessment, counseling and plan, goals and referral information is located. Here are lists of possible items within each section: ● Subjective: is information obtained directly from the participant, the participant's family, or a healthcare professional. ✔ Participant comments will pull into the Subjective area from the text boxes in the current Nutrition Interview. ✔ Staff may add additional information in the white text box under Subjective such as: o Additional participant comments related to: medical, growth and iron, nutrition practices, lifestyle and/or personal factors. o Reason why a staff-assigned risk factor was assigned. o Other needs identified. o Comments related to follow up on previous goals. o Comments related to follow up on previous referrals. o Additional subjective information that was not collected during the Nutrition Interview can be added to the open text boxes.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 07/01/2026 ✔ Objective: is information from measurable facts such as a tests, physical measurements, etc. Participant information such as category, age, blood work, height, weight, week’s gestation, and growth percentile data entered in previous Compass panels will pull into the objective area of the care plan. Additional objective information such as special dietary needs, special formulas, and tailored food packages can be added to the open text boxes. ● Assessment: ✔ Compass risk factors added in previous Compass panels will pull into the assessment area of the Care Plan. In the white text box under Assessment, WIC staff members may add their assessment. An example of an assessment would be “diet high in sugar sweetened beverages” or “participant has gained x amount of weight in x days/weeks.” Agencies that use the Nutrition Care Process, (Problem, Etiology & Signs/Symptoms) PES statements may be added here also. Staff are not required to write an assessment, but may do so if they choose. ● Counseling/Plan/Pamphlets: ✔ Selected counseling topics and pamphlets from the Nutrition Education Panel automatically populate into these text boxes when a new Participant Care Plan is selected. ● Counseling/Education: ✔ Additional counseling and nutrition education information can be entered into the text box to clarify or enhance the topics and counseling points entered in the Nutrition Education Panel. ● Goals: ✔ What the participant states will be their next step or what they will work on or do (based on their stage of change). ✔ One goal is required and should be participant centered, specific and time sensitive. ● Referrals: ✔ Each agency has a list of organizations that is entered into Compass for outreach and referral purposes. Referrals provided to participants are pulled from those documented on the Referral- Participant panel in the Family/Intake area of Compass. ● Plan: The plan is a place to record information to be covered at the next visit or additional measures to take. A plan is entered for future visits such as a referral to the WIC High Risk Counselor, the items that need to be completed for the next visit or additional referrals. If applicable, the WIC High Risk Counselors should enter when to schedule the next high risk visit with the WIC High Risk Counselor. Elements of Quality Nutrition Services Documentation: Consistent: Follows protocols set by Colorado WIC Clear: Precisely stated and easily understood by any reader Organized: Follows a logical order that minimizes duplication Complete: Creates a picture of the participant, the services provided over time, and outlines a plan for future services Concise: Contains relevant information Documentation of Other Contacts: WIC staff should document other visits or contacts in the participant’s care plan when education or information is exchanged or goals are set. Note: For appointments such as the Anthro/Hgb Only appointment, where staff are only gathering height, weight or hemoglobin (either in-person or remotely) and no information is exchanged, staff do not need to create a Care Plan. Editing WIC Records: A participant care plan cannot be edited more than 3 days after it was created. If more information needs to be entered in Compass for a participant after 3 days, a new education note must be created. In this case you would not need to enter a new record in the Nutrition Education panel as you have already created a nutrition education contact for this visit. Create a new record in the Participant Care Plan panel and note the date of the original education note in the new note. Page 2 of 2
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Eligibility Requirements
Policy: To be certified as eligible for WIC Program benefits, an applicant must meet required criteria for category, residence, income, and nutritional risk.
Regulations: 7 CFR 246.7
Procedure/Additional Guideance:
Eligibility Criteria
Categorical: The individual must be a pregnant, postpartum or breastfeeding woman, or an infant or child under five years of age.
Category Definition PREGNANT WOMAN* Woman determined to have one or more fetuses in utero. NON-BREASTFEEDING, POSTPARTUM WOMAN A woman up to six months after termination of pregnancy. Termination of pregnancy may occur with delivery of an infant or be due to miscarriage or therapeutic abortion. BREASTFEEDING WOMAN A woman up to one year postpartum who is breastfeeding her infant on the average of at least once a day. INFANT A person under one year of age (has not yet reached their first birthday). CHILD A person who is one year of age but who has not reached their fifth birthday.
*Proof of Pregnancy No local agency may require proof of pregnancy as a condition of eligibility for WIC services. Requiring confirmation of an applicant’s pregnancy can act as a barrier to intervention and enrolling women in WIC as early as possible in their pregnancy. Agencies may ask women for proof of pregnancy in cases of suspected dishonestywhen there is reasonable doubt the pregnancy exists; however, the agency may not withhold services, disqualify, or terminate the participant if they refuse to provide proof. In cases of suspected dishonesty, participants When reasonable doubt exists of a pregnancy, may be reminded that they have signed a form stating that all information they have presented to determine eligibility is truthful.
Residence: The individual must live in Colorado. Income: The family's income must meet specified guidelines. Nutritional Risk: The individual must be determined to be at nutritional risk, as documented by a thorough nutritional assessment (growth, hemoglobin/hematocrit, health/medical, nutrition practices, lifestyle, personal factors, etc.).
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Fair Hearing Policy and Procedures for Applicant/Participant Appeals
Policy: The Colorado WIC Program and its contracting agencies must make a fair hearing available to any individual whose application for benefits or services has been denied, reduced, or terminated, or who is otherwise aggrieved by agency action. Participants must be advised of their right to a fair hearing and the procedure to follow to obtain a fair hearing.
Once requested, a fair hearing will be conducted in accordance with the Fair Hearing Procedures outlined below.
Regulations: 7 CFR 246.9, Colorado Administrative Procedures Act, 24-4-105 and 24-4-106 C.R.S.
Procedures/Additional Guidance:
Definition of a Fair Hearing A Fair Hearing (hearing) allows individuals, who file an appeal concerning one of the actions listed in Subsection B of this policy, an opportunity to have their case heard by an impartial Administrative Hearing Official (hearing officer).
These hearing procedures provide a mechanism to ensure that: Applicants/participants have an objective and impartial avenue of redress when they feel they have been denied benefits, treated unfairly, or have had an adverse action taken against them; Program standards, policies, procedures and regulations are being applied without prejudice; The services and benefits are being provided fairly; Certain services are retained pending the outcome of a hearing and; Certain services are restored based on the outcome of a hearing.
Actions Subject to Fair Hearing Applicants/participants may file an appeal when the following actions occur: Denial of participation; Termination of benefits due to ineligibility; Disqualification based on intentional program abuse as defined in the Participant Sanction Policy and/or; Claims that are assessed against an individual who has been improperly issued benefits or has improperly obtained benefits.
Procedures for a Fair Hearing Notification of Action Participants will be notified of an adverse action at least fifteen (15) days prior to the effective date of the action, unless the 15 days falls after the end of the participant’s certification period. If this period is less than 15 days, participants should be given benefits for the remaining days of their certification period. Participants may not receive benefits after the end of their certification period. Nor may participants receive benefits if the adverse action is denial of certification on the Program.
Written notification of adverse actions will be provided stating the action, cause(s) for the action, the effective date of the action, the right to file an appeal, and the method by which a hearing may be requested.
Appealing an Action An appeal is any clear expression by the individual, the individual’s parent, caregiver, or other representative, that he or she desires an opportunity to present his or her case to a higher authority. A request for an appeal can be made to the State WIC Program or local WIC agency. A disqualified or terminated participant must file an appeal within fifteen (15) calendar days of receiving the notice of action to continue receiving benefits until the hearing officer reaches a decision or the certification period expires, whichever occurs first. A participant whose certification period has expired cannot have benefits continue through the appeal. An applicant/participant must file an appeal within sixty (60) calendar days of the date the notice of action is mailed or provided to the applicant/participant.
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An appeal will be denied or dismissed if: - the appeal is not received within sixty (60) calendar days from the date the notice is mailed or provided; - the appeal is withdrawn in writing by the applicant/participant or representative; and/or - the applicant/participant or representative failed, without good cause (as determined by the hearing officer) to appear at the scheduled hearing.
The Hearing - General Rules and Procedures Upon receipt of an appeal, the State WIC Program shall notify the applicant/participant, in writing, that it has received the appeal. A copy of the hearing procedures and a confirmation notice will be sent to the applicant/ participant. This confirmation must be signed by the applicant/participant and accompanied by a list of the specific action (s) being appealed. The confirmation of appeal must be returned to the State WIC Program within seven (7) calendar days of receipt. The applicant/participant will receive a minimum of ten (10) calendar days’ advance written notice of the time and place of the hearing. At the time of the written notice the State WIC Office will notify the applicant/participant of their right to: - examine, prior to or during the hearing, the documents and records presented to support the decision under appeal; - be assisted or represented by an attorney or other persons; - bring witnesses; - advance arguments without undue interference; - question or refute any testimony or evidence, including an opportunity to confront and cross- examine adverse witnesses - submit evidence to establish all pertinent facts and circumstances in the case. Hearing will be held within twenty-one (21) calendar days from the date the State WIC Program or local WIC agency received the appeal. The Colorado Department of Public Health and Environment (Department) will provide a hearing officer, an impartial decision maker, whose decision as to the validity of the action shall rest solely on the evidence presented at the hearing, federal regulations and the Program’s policies and procedures governing the Program. The applicant/participant shall have the opportunity to present their case and at least one opportunity to reschedule the hearing date upon request. The hearing shall be conducted at the State level in accordance with the provisions of §24-4-105 C.R.S.
Fair Hearing Decision Within forty-five (45) calendar days of the receipt of the appeal, the hearing officer must issue an initial Fair Hearing Decision (decision) providing a summary of the facts of the case, specifying the reasons for the decision, and identifying the supporting evidence and the pertinent regulations or policy. The initial decision of the hearing officer shall be submitted, in writing, to the Executive Director of the Department. A copy of the decision will also be provided to the Program and the applicant/participant. The applicant/participant or Program may file a written appeal of the initial decision with the Department’s Executive Director within fifteen (15) calendar days of receipt of the initial decision. The Executive Director may affirm, modify, or reverse the initial decision in accordance with §24-4-105 C.R.S. If an appeal is not received within fifteen (15) calendar days, the initial decision of the hearing officer will be adopted by the Executive Director and shall constitute the final action pursuant to §24-4-105 C.R.S. If the final decision is in favor of the applicant/participant, and benefits were denied or discontinued, benefits shall begin immediately. If the final decision concerns disqualification, and is in favor of the Program, the participant will be terminated as soon as administratively feasible. If the final decision regarding repayment of benefits by the participant is in favor of the Program, efforts to collect the claim will resume immediately. The effective date of the action is the date the decision is issued to the applicant/participant.
Withdrawal or Default of an Appeal
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A withdrawal of an appeal occurs when the applicant/participant states, in writing, that he or she no longer wishes a hearing. A default occurs when the applicant/participant fails to appear at the hearing without good cause as determined by the hearing officer or the applicant/ participant cannot be located through his or her last address of record.
Judicial Review If the Department’s final decision is rendered against the applicant/participant, judicial review may be pursued in accordance with §24-4-106 C.R.S.
QUESTIONS AND ANSWERS ABOUT THE FAIR HEARING PROCEDURES FOR APPLICANT/PARTICIPANT
1. Where can I request a fair hearing? Requests for Fair Hearing may be made to the local agency administering the Program or directly to: Colorado Department of Public Health and Environment WIC Director 4300 Cherry Creek Drive South Denver, CO 80246-1530 2. Is there anything I should do prior to requesting a Fair Hearing?
You might find it helpful to discuss with your local or state program representative your feelings and any questions or concerns that you have before you make a decision to request a Fair Hearing. Questions or concerns can often be answered or addressed prior to a Fair Hearing. 3. Who pays for a Fair Hearing?
The Colorado Department of Public Health and Environment (CDPHE) will pay for the expenses of the hearing officer and, if necessary, the stenographer. The CDPHE will also pay for an interpreter if one is needed. 4. Where will the hearing be held?
The hearing must be held at a time and place convenient to the person making the request. 5. Who conducts the hearing?
A hearing officer who is not involved in the dispute will conduct the hearing. He or she will be designated and paid for by the CDPHE. 6. Who is to be at the hearing?
Besides the hearing officer and possibly a stenographer, the applicant or participant requesting the hearing or his or her representative, such as a relative, friend, legal counsel, or other spokesperson, witnesses, and State WIC staff. (Any person presenting material will be under oath or affirmation and all testimony will be recorded.) 7. How is the hearing conducted?
All hearings conducted in accordance with the provisions of Colorado Administrative Procedures Act §24-4-105 and the Code of Federal Regulations 7 Part 246.
Both the individual requesting the hearing and the representative of the local WIC agency or State WIC Program shall have the right to examine and present evidence, present and cross-examine any witness, make arguments, and question or refute evidence. The person requesting the hearing also has the right to examine all documents and records presented to support the decision under appeal prior to the hearing, to be assisted or represented by an attorney or other persons, and bring witnesses.
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QUESTIONS AND ANSWERS ABOUT THE FAIR HEARING PROCEDURES FOR APPLICANT/PARTICIPANT Continued 8. What are the responsibilities of an applicant/participant when requesting a Fair Hearing?
Applicants/participants are responsible for: Requesting assistance from CDPHE or the local agency in submitting a Fair Hearing request; Requesting the Fair Hearing, verbally or in writing, within the sixty (60) day period; or Requesting the Fair Hearing, verbally or in writing, within the fifteen (15) day period if services are to be considered for continuation; Requesting a translator when it is necessary to understand the participant in the Fair Hearing. Preparing for the Fair Hearing—examining all material, asking witnesses to be present, presenting testimony, etc.; Attending the Fair Hearing; OR Sending a written notice stating that a Fair Hearing is no longer desired. OR Calling in or sending a written reason explaining why they were not at the scheduled hearing; Keeping the CDPHE or the local agency informed of any address changes; If desired, submitting a request for appeal no later than twenty (20) days after the Fair Hearing decision becomes effective. 9. What are the responsibilities of the local agency when a participant/applicant requests fair hearing?
These responsibilities include: Informing individuals of their right to a fair hearing when application for Program benefits or services is made and informing individuals of the availability of a Program representative to discuss questions, concerns, and to provide further information; Informing individuals of denial, termination, suspension, or reduction in services, fifteen (15) days before the change in services occur, for the WIC Program; Assisting individuals in filing a request for a fair hearing and in completing the Acknowledgement and Confirmation of a Fair Hearing Request (if assistance is requested). Forwarding the request for a fair hearing to the CDPHE within twenty-four (24) hours; Supplying CDPHE with a written statement describing the reason why the person is requesting a fair hearing, the reason why services have been denied, terminated, or reduced, and any other material relevant to the request including copies of participant notices and other materials relevant to the request. Preparing and submitting background information on the request to the CDPHE; Providing the person requesting information with any information that was used in determining eligibility or in changing benefits; Assisting the CDPHE in finding a time and place convenient to the individual for a fair hearing; Being present and giving testimony at the fair hearing; Complying with the fair hearing decision.
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Fair Hearing Procedures Timeline and Flowchart
Colorado WIC Program Policies and Procedures Section 5: NSA Expenditures Revised: 01.01.2023
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Fiscal Overview & Reporting Requirments
Policy: Local WIC Agencies shall submit monthly expenditure reimbursement requests and shall submit monthly or quarterly time studies regarding
Regulation: 7 CFR §246.1, 2 CFR Part 200, subpart A_f, 2 CFR Part 400 and 415, Office of Management and Budget Circular A-130, State Agency and FNS Guidelines and Instructions, USDA FNS Allowable Costs for Breastfeeding Peer Counseling Funds (January 2022).
Procedure/Additional Guidance: WIC is a federally funded program through the United States Department of Agriculture (USDA) Food and Nutrition Services (FNS) with strong financial accountability, and strict rules attached to the use of WIC funds. The Colorado WIC program receives three distinct kinds of funds, for food benefits, for Nutrition Services and Administration (NSA), and for Breastfeeding Peer Counseling (BFPC).
Food funds are spent by WIC participants at the grocery store or pharmacy. Food funds come from the federal WIC grant and rebates received on bid infant formula bought by WIC participants. Breast pumps for participants may also be purchased using food funds.
NSA funds are spent at the state and local level for staff, rent, educational materials, equipment, overhead, and all other costs involved in delivering WIC services to participants. In Colorado, WIC program service funds come entirely from the federal grant and some local agencies’ general fund contributions.
Breastfeeding Peer Counseling funds are spent at the state and local level to continue to build up and expand breastfeeding and peer counseling efforts. The use of these funds for activities that are outside of approved breastfeeding peer couseling implementation plans or that are not supported by the WIC Breastfeeding Model Components for Peer Counseling is not authorized.
Financial Management Standards All local agencies must have a financial management system in place which, at a minimum, ensures the following: Accounting records are supported by source documents Records show the source and application of funds and contain information pertaining to reimbursement from Federal funds, authorizations, obligations, unobligated balances, assets, liabilities, outlays and income Accurate, current, and complete disclosure of the financial results of the Program, and effective control over, and accountability for all funds, property, WIC checks, and other Program assets to assure that they are safeguarded and used solely for authorized purposes Comparison of actual outlays with budgeted amounts A systematic method to assure timely and appropriate resolution of audit and/or monitoring findings and recommendations Records detailing all procurements made with WIC funds that assure that such procurements meet Federal and State procurement standards An accounting system that ensures that no other program costs are charged to WIC Adequate internal controls to assure separation of duties
Allowable WIC Costs – General All local Colorado WIC Agencies operate under the auspices of the CDPHE WIC Program. Local agencies perform under the jurisdiction of a State of Colorado contract with the WIC Program.
Federal funds are available to local agencies through contracts/agreements to provide for the following:
Cost of WIC food benefits Certification of WIC participants Nutrition education Breastfeeding Promotion Outreach General program administration
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Prior to entering into a formal contract, the State WIC Office allocates funds to each local agency through a funding formula. A formal contract, specifying the maximum administrative budget and effective time periods for that budget, is signed by the local agency, the State WIC Office, and the CDPHE. The contract specifies that administrative costs are reimbursed upon the basis of the maximum allocated amount or actual documented expenditures, whichever is less, and that costs will be reimbursed up to the allowed maximum.
Expenses in excess of the maximum will not be reimbursed. WIC contracts cannot be amended retroactively (i.e., if you need additional funds for June and do not request those additional funds until July, WIC will not be able to amend your contract).
If you have any questions regarding maximums or unexpected problems staying within those maximums, please call the WIC Fiscal Unit Manager.
All local agencies are required to follow Federal Regulations (7CFR Part 246 and 7CFR 3016), the State WIC Program Manual, and applicable OMB rules and regulations -2 CFR Chapter I, and Chapter II, Parts 200, 215, 220, and 230 Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards.
This provides guidelines for identifying allowable costs under grants to public entities and nonprofit organizations. It states that users should not construe the failure to mention a particular item of cost as an implication that such cost item is either allowable or unallowable. Users are instructed to determine the appropriate treatment of a cost item that is not expressly mentioned by relating it to the treatment of similar items that are mentioned. The general rule for determining the allowability of costs is the “reasonable and necessary” cost test.
Reasonable Costs: Provide the Program a benefit generally commensurate with the costs incurred, Are consistent with the costs of similar items from other vendors, Are in proportion to other program costs for the function that the costs serve, Are a priority expenditure relative to other demands on available administrative resources, and Have a proven or intuitive positive impact.
Necessary Costs: Are incurred to carry out essential program functions, and Cannot be avoided without adversely impacting program operations.
The State WIC Program has final authority over what constitutes reasonable and necessary costs.
The following categories of cost are allowable under WIC regulations: The amount of funding allocated for food costs is based on predicted caseload levels. Operational and administrative costs allowable costs are outlined as follows:
Colorado WIC Program Policies and Procedures Section 5: NSA Expenditures Revised: 01.01.2023
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Direct Costs Salaries and Wages Compensation of employees for actual time and effort devoted specifically to the WIC program, including fringe benefits. Time and effort (T & E) certification must be available at the local agency. These T & E forms must include the employee's and supervisor's dated signatures and a certification statement. Supplies Costs of materials acquired, consumed, or expended specifically for WIC, i.e., food models and samples; medical supplies such as Band-Aids; office supplies such as paper, pens; nutrition education materials and printing costs (see Nutrition Education below). Nutrition Education Nutrition Education and Breastfeeding Promotion expenses, i.e., costs related to individual or group educational sessions with participants; provision of nutrition education and/or breastfeeding promotion materials such as pamphlets, training and evaluation of education, and mailing education materials. These costs must be clearly identified on the Contract Reimbursement Statement. Equipment Equipment: Office equipment such as chairs, desks, filing cabinets, non-expendable medical equipment; blood analysis equipment, measuring boards, and scales. Equipment purchases must have prior approval from the Fiscal Unit Manager. Equipment is defined as an article of non-expendable, tangible personal property having a useful life of more than one year and an acquisition cost which equals or exceeds the lesser of the capitalization level established by the governmental unit for financial statement purposes or $5,000.
All equipment purchased with WIC funds becomes the property of the WIC Program. Per 7 CFR 3016.32(d)(1), property records must be maintained by the local agency that include a description of the property, a serial number or other identification number, the source of the property, who holds the title, the acquisition date, cost of the property, percentage of Federal participation in the cost of the property, the location, use and condition of the property and ultimate disposition data including the date of disposal and sale price of the property. No WIC equipment may be disposed of without State and/or USDA approval. The local agency will return WIC equipment if so requested.
A physical inventory of the equipment must be taken and the results reconciled with the property records bi-annually. All ADP equipment must have prior approval from USDA through the Fiscal Unit Manager or it will not be reimbursed. When equipment is billed to the State WIC Program during the last month of the fiscal year, causing the local agency to exceed their contract maximum, it will be processed as follows: When the equipment purchased was requested in the approved WIC budget, or approval has been received from the Fiscal Unit Manager, the amount of the equipment will be reimbursed (while other expenditures to the extent of the contract excess will not be reimbursed) and will become the property of WIC. When the equipment purchased was not requested in the approved WIC budget, or approval was not received from the Fiscal Unit Manager the amount of the equipment will be deducted (not allowed) from the reimbursable amount and the equipment will become the property of the local agency. Travel WIC personnel travel to and from clinic sites and travel necessary to fulfill WIC Program functions. All out-of-state travel, and travel other than within the agency service area or to State-sponsored WIC meetings must meet the generally accepted accounting criteria of “reasonable and necessary” and further the goals of the program. Mileage will be reimbursed at the local agency’s rate up to the maximum allowed by the IRS.
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Lab Fees Lab fees associated with certification. (Lab fees cannot be charged to participants, Medicaid or other third parties). Outreach Outreach costs, including advertising. Program Incentives Program incentive items. Reasonable and necessary costs that promote the specific Program purposes of outreach, nutrition education and/or breastfeeding promotion. Program incentive items are primarily intended for use by Program participants or potential participants. Occasionally, it may sometimes be appropriate to distribute Program incentive items to staff when those items present an outreach, nutrition education, or breastfeeding message. These items should be of nominal cost. Contact your nutrition consultant for more information. Physical Activity Elements of physical activity promotion as a part of nutrition education may be considered an allowable cost for the WIC Program. Examples of allowable costs include: educational materials that reinforce health benefits of physical activity, nutrition education classes that reinforce and contain physical activity messages, brief physical activity demonstrations, training for staff on the health benefits, promotion of physical activity, and how to promote behavior change in participants. (See Unallowable costs for examples of items that are not allowable.) Building Space & Related Facility Costs The rental cost of space in privately – or publicly-owned buildings used for the benefit of the Program is allowable subject to the following conditions: The total cost of space may not exceed the rental cost of comparable space and facilities in a privately owned building in the same locality The costs charged to WIC must be based on actual costs paid by the agency WIC’s share of the rental costs must be based on WIC’s share of the total space based on square footage studies
When the building is owned by the county and/or agency and no rent is paid, a usage fee or depreciation cost may be charged. These charges must be in accordance with the appropriate OMB fiscal guidelines. Purchase, Repair or Renovation of Buildings The purchase, repair or renovations of real property are capital expenditures that require prior approval from the USDA Regional Office. Only in areas where other options are not available, will USDA approve capital expenditures for the purchase, repair or renovation of buildings. Any local agency requests for prior approval must be submitted to the State WIC Office for submission to the USDA. Upkeep of grounds, necessary maintenance, normal repairs and alterations, and the like are allowable to the extent that they: keep property in an efficient operating condition, do not add to the permanent value of property or appreciably prolong its intended life, and are not otherwise included in rental or other charges for space.
Local agencies shall ensure that no claim is submitted for reimbursement of services already funded by other state or federal programs, or for costs which are not allowable.
Indirect Costs Indirect costs are those incurred for a common or joint purpose benefiting more than one cost objective and not readily assignable to the direct costs specified previously. Shared expenditures such as postage, phone, and administrative overhead in terms of salaries of administrators, accountants, nurses. Other shared expenditures such as building space, heating and lighting and printing or copying. Documentation must be submitted on a yearly basis (or as the rate changes) to CDPHE for approval. Costs included in the indirect cost pool cannot be charged as direct costs.
Questions concerning allowable costs should be directed to the State Fiscal Unit Manager. Effective January 1, 2015 changes in OMB circular guidance allows that agencies may submit indirect costs up to 10% per invoice without prior approval from CDPHE’s internal auditing department. No indirect rates exceeding 10% will be reimbursed without a CDPHE approved indirect rate. Rate changes occurring within a contract year must be reflected on contract reimbursement statements.
Colorado WIC Program Policies and Procedures Section 5: NSA Expenditures Revised: 01.01.2023
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Unallowable Costs Costs NOT Allowed Are Specified Below: Food costs may not be used as a basis for determining indirect cost rates. Bad debts any losses arising from uncollectible accounts and other claims and related costs. Contingencies, contributions to a contingency reserve or any similar provision for unforeseen events. Contributions and donations. Entertainment, costs of amusements, social activities and incidental costs relating thereto, such as meals, beverages, lodgings, rentals, transportation and gratuities. Fines and penalties costs resulting from violations of, or failure to comply with Federal, State and local laws and regulations. Governor's expenses, salaries and expenses of the Office of the Governor or the chief executive of a political subdivision are considered a cost of general State or local government. Interest and other financial costs, interest on borrowings (however represented), bond discounts, cost of financing and refinancing operations and legal and professional fees paid in connection therewith, are unallowable except when authorized by Federal legislation. Legislative expenses, salaries and other expenses of the State Legislature or similar local governmental bodies such as county supervisors, city councils, school boards, etc., whether incurred for purposes of legislation or executive direction. Under recovery of costs under grant agreements any excess of cost over the Federal contribution under one grant agreement is not allowable under other grant agreements. Implementation and maintenance of Health Insurance Portability Accountability Act (HIPAA) and National Smallpox Vaccination Program (NSVP). Biological Disaster Response Teams, unless all other sources of funds are exhausted. Physical activity items such as, fitness center dues or memberships, exercise equipment, exercise classes, incentive items. Contact the State Office with any questions.
This list is not all-inclusive. Questions concerning the allow ability of costs should be referred to the State Fiscal Unit Manager prior to purchase and/or expenditure.
Local Agency Retention of Records Full and complete records concerning program operations shall be maintained. These records shall include, but are not limited to: A copy of the contract with the State WIC Program. Information on the service area and financial eligibility standards used. Complete and accurate participant records documenting nutrition risk, certification information of applicants, foods prescribed, nutrition care, counseling, and referrals provided under the WIC Program. Complete, accurate, documented, and current accounting of all funds received and expended pursuant to the contract. Detailed inventory records including purchase date, acquisition cost, location, inventory number, and disposition information. Complete and accurate retail records documenting training, monitoring, and problems of each retailer. Racial/ethnic participation data. Fair hearing information. Participant abuse records.
All WIC Program records shall be retained for 3½ years following the end of the applicable Federal fiscal year. The USDA has reserved the right to require by written notice, retention of any records deemed by it to be necessary for resolution of an audit or any litigation. If any litigation, claim, or audit is started before the expiration of the 3½ year period, the records must be retained until all litigation, claims or audit findings involving the records have been resolved.Additionally, if the USDA deems any of the program information to be of historical interest, it may require the state or local agency to forward such records to the department whenever the state or local agency decides to dispose of them.
All WIC records shall be available during normal office hours for representatives of the Colorado Department of Public Health & Environment, The United States Department of Agriculture, The General Accounting Office of the United States, and State designated auditors to inspect, audit and copy, provided that medical case records of individual participants shall remain confidential.
Colorado WIC Program Policies and Procedures Section 10: Monitoring and Audits Revised: 01/01/2025
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Fiscal Monitoring
Policy: The US Department of Agriculture (USDA) Audit Guide specifies that the objective of a local agency financial audit is "to determine whether the local agency has adequate control over funds and an effective accountability system." The purpose of a WIC local agency fiscal monitoring is to ensure that the local agency is in compliance with State rules and Federal Regulations.
Regulation: 7 CFR 246.19 (b), 7 CFR 246.20, 7 CFR 3015 Implements OMB circulars, 7 CFR 3016 Implements OMB circulars, P.L. 89-642 Child Nutrition Act of 1966 17-62 (11/6/92, p 33) Biennial review requirement P.L. 98-502 Single Audit Act , OMB A-87 Cost principles for state and local governments, OMB A-102 Grants and cooperative agreements with state and local governments, OMB A-110 Grants and agreements with institutions of higher education, hospitals, and other nonprofit organizations , OMB A-122 Cost principles for nonprofit organizations, OMB A-128 Audits of state and local governments, OMB A-133 Audits of institutions of higher education and other nonprofit organizations
Procedure/Additional Guidance: The local agency financial monitoring is conducted in conjunction with the Colorado Department of Public Health and Environment (CDPHE) Financial Risk Management System (FRMS) team. The FRMS process was created within CDPHE to ensure standardization of the monitoring process across programs within the department and to eliminate duplication of efforts regarding information gathered at the local level during the fiscal monitoring visit. The result of this effort is a partnership between the department and the WIC program in evaluating each agency’s compliance with contractual fiscal requirements. FRMS applies to all Colorado local health agencies and some nonprofit agencies.
FRMS provides the department the ability to implement risk-based monitoring. The foundation for the system is a standardized assessment of a contractor’s financial management system and results in a risk rating of Low, Medium or High. The rating provides the WIC program with an understanding of how the contractor manages the funding received from the department and consequently what the potential is for noncompliance with fiscal requirements. The FRMS team conducts a thorough examination of each agency’s overall accounting practices via a site visit at least once every 24 months and a questionnaire every 12 months for agencies exhibiting low risk. That visitation schedule increases to once per year for agencies rating “high.” Areas reviewed include agency payroll and timekeeping efforts and policies and procedures among other topics. The results of this examination are maintained within CDPHE and the overall rating and recommendations for improvement (if applicable) are shared with the WIC program. A diagram of the FRMS process as well as a sample questionnaire is included with this manual.
The State Fiscal Unit Manager and/or WIC Fiscal Officer will perform an in depth fiscal monitoring of each local agency at least once every two years. In addition to using the information provided through the FRMS process, the WIC fiscal personnel will examination operational expenses specific to WIC reimbursement invoices, including supplies, equipment, travel, cost allocations specific to rent, phone, utilities, etc. If through the FRMS process, discrepancies are identified relating to personnel expenses charged to the WIC or the Breastfeeding Peer Counseling program, additional review of invoices may be necessary. Depending upon the size of the agency and the number of expenses to review, the fiscal monitoring visit will either be conducted on-site or through a desk audit process.
For those agencies that do not fall under the FRMS guidelines, the WIC fiscal officer will conduct a full monitoring, including a review of time and effort and payroll costs in addition to the operational costs mentioned above. The monitoring form for those agencies is listed at the end of this section.
An entrance interview conducted either in person or on the phone, will be held prior to the monitoring with appropriate local agency staff to explain the monitoring process. At least one local agency staff member must be available to answer questions. Due to the nature of a fiscal monitoring, this may involve staff members from various departments (i.e., personnel, accounting), as well as a WIC staff member.
An in-depth fiscal monitoring consists of the State staff member looking at the source documentation to back up all costs billed to WIC. The Contract Reimbursement Statements (CRTs) for the period of time being monitored will be compared to the source documents to assure that all costs are properly supported and allowable. A sample of the fiscal monitoring form is provided on page 3.
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The following types of records must be made available by the local agency at the time of the review: Original receipts, invoices, etc. for all items charged to WIC (supplies, utilities, etc.). Lease agreements (where applicable). Documentation of the methodology used for allocation of costs (where applicable). Travel expense forms.
An exit conference conducted either in person or on the phone, will be held with appropriate local agency staff to discuss results of the monitoring and any recommendations. A written summary of the monitoring visit will be sent to the local agency within 30 days. The local agency will respond with a written plan of action and target dates for resolution of problems not already corrected. After review of the local agency's response, the State agency will follow up as necessary. Any unallowable costs found during the monitoring will be reclaimed within the same fiscal year either through a check paid to the CDPHE or through a credit to a reimbursement invoice submitted within the same fiscal year as the unallowable expense. The replayment methodology shall be approved in advance by the WIC Fiscal Administrator.
All local agencies will ensure that the WIC Program is included in audits of the agency as required in the state/local agency contract.
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Colorado WIC Program Policies and Procedures Section 10: Monitoring and Audits Revised: 01/01/2025
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Colorado WIC Program Policies and Procedures Section 10: Monitoring and Audits Revised: 01/01/2025
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Colorado WIC Program Policies and Procedures Section 9: Food Delivery Accountability and Control Revised: 01/01/2020
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Food Benefit Redemption
Policy: WIC participants are provided with tools to assist them in redeeming food benefits.
Regulation: 7 CFR 246.12 Food delivery methods. Colorado WIC Program policy
Procedure/Additional Guidance: At the store the endorser/alternate shopper should: Ensure s/he has the eWIC card, the Colorado WIC Food List & Shopping Guide, and knows their WIC food balance. Select the appropriate WIC-allowed items. Separate non-WIC food items from WIC foods if required by store. Swipe the eWIC card and enter the PIN when asked. Swipe the eWIC card before all other forms of payment. Keep the receipt, which lists the remaining food benefit balance.
Note: No money is to be given to or paid by the WIC participant in exchange for WIC benefits. If an item doesn’t ring up as a WIC food, the cashier cannot change or override the item.
Customer Services WIC participants/endorsers may access a web portal (www.ebtedge.com) or a toll-free 24-hour automated telephone line (1-844-234-4950) to: Obtain current food balance information Obtain benefit expiration dates Set-up or change a PIN
Food balance information is also available from: Clinic: printed Family Food Benefits list. Shopping receipt: remaining balance prints at the bottom of the receipt. Store: request a benefit inquiry. Smartphone: WICShopper app
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 03/01/2026
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Exchange of Food Benefits & Replacement of Formula
Policy: Unredeemed food benefits may be exchanged for any participant for current or future months. Participants switching to a different formula may have their benefits exchanged. Formula can be replaced in certain emergency situations.
Regulation: 7 CRF 246.12, 7 CRF 246.10, USDA WIC Food Package Guidance
Procedure/Additional Guidance:
Exchanging Non-Formula Food Benefits ● Non-formula food packages may only be exchanged if no food items have been redeemed.
Unredeemed Formula Exchanges ● Contract Formula: If switching from one contract formula to another, benefits can be exchanged remotely (the endorser does not need to come to the clinic). ● Non-Contact/Exempt Formula: A completed Physician Authorization Form is required. Benefits can be exchanged remotely only if: ✔ The new prescription has been received by the clinic, and ✔ The WIC high risk counselor determines that the endorser does not need an in person visit for additional education or instructions on the use of the formula.
Redeemed Formula Exchanges ● Only unopened formula purchased in the current month may be exchanged. ● Unopened cans of formula must be returned to the clinic to be exchanged for the new requested formula. Compass calculates the amount that can be reissued based on the federal maximum allowable reconstituted ounces. o Before changing the food package, open the Foods branch and select “Returned Formula”. Note: Formula from the current month can still be returned even if a new food package is issued. o Document the returned formula on the Formula Disposal Log and save it in the clinic’s central files for program monitoring. ● Select the “Get Balance” button. The returned formula grid will display a row of the current month’s formula issued to the participant. ● Enter the quantity of formula returned into the grid and save. Compass will not allow an amount greater than what was purchased with the eWIC card for the current month. ● Compass automatically calculates the amount of formula allowed to be reissued.
Compass Steps for Food and Formula Exchanges ● Go to the Foods branch and select “Food Package”. Click “new” to create a new food package. ● Select a new model food package from the drop-down list and save. Staff may also tailor the food package or create a new package “from scratch.” ● Verify the appropriate issuance period (1, 2, or 3 months). ● Once verified, click the “Issue Benefits” button. Compass will automatically calculate the remaining food benefits for the participant. ● Obtain the endorser’s signature acknowledging receipt of food benefits. ● Review the Family Food Benefits printout with the endorser or proxy.
Formula Disposal ● Formula returned by a participant must be disposed of and cannot be reused, shared, donated, or given to another WIC participant (ie, for trial or sample), including food banks or animal shelters. ● Returned formula must be destroyed within two (2) days of receipt. ● WIC staff must record the destroyed formula on the Formula Disposal Log and save the log in the clinic’s central files. Formula Exchanges When Ordered from a Pharmacy
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● Formula ordered from a pharmacy that has not been issued to a participant (never left the clinic) may be issued to another WIC participant. It may be transferred between WIC clinics in one of the following ways: 1. Transferred by WIC Staff: The formula transfer must be approved by a supervisor or lead staff. The formula must be received the same day. 2. Shipped: The formula must be received by the clinic well in advance of the formula’s expiration date so that it may be used by the participant before it expires.
General Guidelines for Formula Exchanges ● Staff should never authorize the exchange of formula at a grocery store or pharmacy. ● Opened cans of formula cannot be exchanged. ● Stored formulas must be kept out of public view to avoid undermining breastfeeding promotion efforts. ● All formula exchanges must be documented in the participant's record.
Redeemed Formula Replacement
Redeemed formula issued during the current month can be replaced in certain individual emergencies. An individual emergency is a situation that affects one person or family; it is not a large-scale disaster or a presidentially or state-declared disaster. Examples of individual emergencies may include, but are not limited to: ● House fire. ● Flood. ● Theft. ● Fleeing domestic violence. ● Custody changes where the redeemed formula was not provided to the new caregivers.
To replace the redeemed formula, the client should provide proof of the emergency. Proof could include: ● A police report. ● A landlord statement (in the case of an apartment fire). ● A theft report from a store. ● A letter from a shelter (for domestic violence situations). ● A letter from a caseworker. ● If no formal proof is available, a signed statement from the participant or endorser is acceptable. The signed statement can be completed using the General Signature Document printed from Compass or as a written statement or provided in an email from the participant. It must include: ○ Number of cans that need to be replaced (current benefit month only). ○ Name of the formula. ○ Reason for the replacement. ○ The date. ○ The participant’s signature (typed signature is acceptable if submitted by email).
Procedure: To replace the redeemed formula, WIC staff should: 1. Gather information about the request, including the formula name, benefit month, number of cans, and reason for the replacement. 2. Review the Rights and Responsibilities with the participant, emphasizing that WIC benefits are intended for the individual participant and cannot be sold or exchanged. 3. Scan the proof document or signed statement into the participant’s Compass record. 4. Email the request and supporting documentation to cdphe.wicformula@state.co.us. State Office staff will issue the replacement and notify local agency staff once completed.
Additional Guidelines for Redeemed Formula Replacement: ● Local agencies must not return redeemed formulas in Compass for individual emergencies. All redeemed formula replacements for emergency situations are handled by the State Office. ● Redeemed formula can only be replaced once per participant in a 12-month period.
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Food Packages - Children
Policy: WIC staff shall select children’s food packages according to the participant’s age and nutritional needs.
Regulation: 7 CFR 246.10
Procedure/Additional Guidance: ● When an infant reaches one year of age, assign and issue a Toddler food package (containing whole milk). ● When a child’s age is between 12 through 23 months, assign and issue a Toddler food package (containing whole milk.) ● When a child’s age is between 24 through 59 months, assign and issue a Child food package (containing low-fat (1%) or fat free milk).
Child Food Package Food Toddler (12-23 months)
Child (24-59 months) Milk (gallons) 2 gal + 1 qt 3 gal + 1 qt Cheese (pounds)a 1 1 Eggs (dozen) 1 1 Juice (ounces) 64 64 Breakfast cereal (ounces) 36 36 Whole grains (pounds) 1.5 1.5 Dry beans and/or peanut butter 1 lb or 18 oz 1 lb or 18 oz Cash Value Benefit (CVB) $26 $26 a Staff must ensure clients are aware they may opt for either a cheese model food package OR a standard milk model food package including three additional quarts of milk. The model food package including cheese can only be assigned after nutrition assessment is completed and the client has expressly chosen a cheese model food package.
Food Package Allowances/Substitutions WIC staff may prescribe allowable alternatives and tailor the package according to additional participant needs and preferences. All substitutions are considered for client preference unless stated otherwise. If the reason for substitution was not simply client preference, the reason why a substitution was issued must be expressly documented. WIC staff may determine the issuance of the following foods: ● Alternate nut/seed butters. ✔ Following a nutrition assessment, alternative nut and seed butters may be substituted for peanut butter at a rate of 1:1 in situations that include, but are not limited to, allergy, religious or cultural reasons, or participant preference. Alternative nut/seed butters may also be substituted for peanut butter when peanut butter is substituted for eggs. ● Plant-based milk alternative or tofu as a substitution for milk. ✔ Following a nutrition assessment, plant-based milk alternatives may be substituted for milk in situations that include, but are not limited to, milk allergy, lactose intolerance, vegan diet, religious preference (i.e., kosher), or participant preference. The rate of exchange is 1 quart of plant-based alternative milk per 1 quart of fluid dairy milk. ✔ Following a nutrition assessment, tofu may be substituted for milk in situations that include, but are not limited to, milk allergy, lactose intolerance, vegan diet, religious preference (i.e., kosher), or participant preference. The rate of exchange is 1 lb of tofu per 1 quart of fluid dairy milk. ● Beans/Peanut butter as a substitution for eggs. ✔ Per participant preference, staff may substitute dry legumes (1 pound), canned legumes (64 ounces), and peanut butter (18 ounces) for each 1 dozen eggs when individually tailoring food packages. ● $3 CVB substitution for juice. ✔ Per participant preference, staff may substitute a $3CVB can be provided in place of 64 oz. of juice when individually tailoring food packages.
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● Reduced fat milks (2% 1% or fat free) for 1 year children for whom overweight or obesity is a concern. ✔ The WIC staff may issue reduced fat milks (2%, 1% or fat free) to one-year-old children (12-23 months) meeting these criteria: ▪ Overweight: Child’s weight for length is at or above the 98th percentile. ▪ Rapid weight gain: A child whose weight for length, initially at or above the 50th percentile crossed two percentile curves. For example, a child going from the 50th to the 90th percentile, or going from the 75th to the 95th percentile. ✔ Food packages containing reduced fat milk (2%, 1% or fat free) are accessed by selecting “Special Diet” from the Food Package screen in Compass. WIC staff must complete the Documentation box, noting “concern of overweight/obesity” as the medical diagnosis reason. The authorization period (“Rx Expiration Date”) may be up to the date in which the child turns two years old. Staff should add their name as both “Approved by” and “Authority.” A Physician Authorization form is not required.
When substantiated with proper and complete medical documentation and approval from the WIC High Risk Counselor, the following formulas can be issued to children: ✔ Primary contract brand infant formula. ✔ Exempt infant formula. ✔ WIC eligible nutritional. ✔ Infant cereals as a substitute for breakfast cereal. ✔ Infant fruits and vegetables as a substitute for the CVB. ● The WIC High Risk Counselor may approve issuance of the following foods: ✔ Supplemental foods for children receiving “special formulas.” ✔ Whole or 2% milk for >2-year-old underweight children receiving “special formula.”
Standard Issuance of yogurt. ● Whole or low-fat yogurt is the standard issuance for toddlers ages 12-23 months. Participants must be offered the choice of either whole or low-fat yogurt for 12-23 month old children at the time of issuance. ● Low-fat or nonfat yogurt is the standard issuance for children ages 24-59 months.
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Food Benefit Issuance
Policy: WIC staff prescribes monthly supplemental foods in quantities that do not exceed the regulatory maximums and are appropriate for the participant’s age, category, profile, and nutritional needs.
Regulation: 7 CFR 246.10
Procedure/Additional Guidance: WIC staff assign food packages based on the participant’s age, category, profile, and nutrition risk factors. Staff may choose a model food package which contains specific combinations of foods that are most frequently issued to participants. From the Food Package panel, staff members have the ability to: ● Assign one of the displayed model food packages –OR- ● Select a model and then tailor it -OR- ● Create a new food package.
The selected food package remains in effect until the user selects a different food package. In order to change a food package, the user must enter a new effective date. The food package effective date is the date the food package is first available for issuance. In Compass, the food package effective date defaults to today’s date. Compass functionality allows the user to set a future food package effective date. When selecting a new food package for the following month, make the effective date the first day of the following month. For example, on July 15 if a new food package will be needed for August, use the date selector to make the effective date of the new food package August 1. For benefits issued and then exchanged on the same day, the new food package effective date will be the same date as the previous effective date.
Note: Non-formula food packages may only be changed in the current month if none of the food items have been redeemed.
Issuance Cycle The majority of WIC participants are issued food benefits for three months at a time.
Automatic Food Package Update for Infants Compass automatically changes model food packages for infants at 4 months of age. When that happens, the word “Changed” is added to the name of the updated food package. Tailored food packages do not automatically update at milestones. WIC staff need to reassess at milestones and create new tailored packages if needed. WIC staff have the ability to over-ride the automatic changes. When a participant's category and age change, Compass displays new model food packages meeting the participant’s profile that can be assigned. Changing risk factors may prompt the need to change food packages. If a food package is inappropriate for a participant's age or category, or contains more than the maximum allotment of foods, Compass will not verify the package. Staff must correct the package before issuing food benefits.
Food Package Tailoring Nutrition tailoring is the process of modifying an individual food package to better meet the supplemental nutritional needs of each participant. It entails making substitutions, reductions, and/or eliminations to food types and physical food forms to accommodate special dietary needs, cultural practices, and/or personal preference. Offering a participant substitution is the first step before eliminating or reducing foods. Individual nutrition tailoring is allowed based on the WIC staff’s assessment of a participant’s supplemental nutrition needs. By federal regulation, the full maximum monthly allowance of all supplemental foods in all food packages must be made available to participants if medically or nutritionally warranted.The one exception is that breastfed infants who also receive supplemental formula should be provided the minimum amount of supplemental formula and offered counseling and support to ensure breastfeeding success. Tailoring the package to provide less than the full amount is appropriate only when: ✔ Medically or nutritionally warranted such as removing an item due to a food allergy ✔ A participant refuses or cannot use the maximum monthly amount
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✔ Quantities necessary to supplement another program’s contribution to fill a medical prescription are less than the maximum monthly amount. There are instances when issuance of a food package requires both medical documentation from a health care provider licensed to prescribe in Colorado and approval by the WIC High Risk Counselor.
Documentation of Food Package Tailoring All substitutions are considered for client preference unless stated otherwise. If the reason for substitution was not simply client preference, the reason why a substitution was issued must be expressly documented. Documentation is critical so that all staff providing follow up can readily see that a specific tailored food package was purposefully assigned.
Guidelines for Issuing Homeless Food Packages The WIC food package may be tailored to accommodate the unique needs and circumstances of homeless participants. Some of these adaptations may be necessary because of their living circumstances. Information regarding storage, transportation, ability to access the grocery store, and use of specific food items should be obtained when certifying the participant. If the person is residing in a shelter, the WIC food package must be kept separate from the general inventories and be used by the participant only. Below is a list of ways a food package may be tailored to meet the needs of homeless individuals: ● If proper refrigeration is not available, eggs and fluid milk, including evaporated, may not be issued to the participant. UHT or powdered milk should be issued instead. The participant should be instructed to mix one glass of milk at a time. Nonfat dry milk should not be used for children between 12-24 months of age. ● Hardboiled eggs should be issued instead of raw eggs if cooking facilities are not available but refrigeration is available. If neither refrigeration or cooking facilities are available, one 18-ounce jar of peanut butter may be substituted for 1 dozen eggs. ● Participants may be issued single serving containers of juice. If single serving containers of juice will not provide the maximum allowable ounces, participants should be counseled on this and offered the choice of whether they want to receive the 64 oz. container instead. ● Breastfeeding should be encouraged as the easiest and safest way to feed the infant. Formula-fed infants should receive powder formula, mixed one bottle at a time. Ready-to feed formula may be issued according to Colorado WIC Food Package Tailoring Guidelines. No exemptions or exceptions are allowed from the requirement for medical documentation to support the issuance of exempt infant formulas and WIC-eligible medical foods. ● Local agency WIC staff determine whether to provide monthly or tri-monthly food benefits. Factors to consider when determining food benefit issuance include: length of time the individual plans to stay in the area, length of time it is possible to stay in the shelter, nutritional risk factors, and access to transportation.
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Homeless Food Package Guidelines
For more information regarding certification of and providing services for homeless participants, see the Homeless Applicants policy in Section 8, Certification, Eligibility and Coordination
Hospitalized or Institutionalized Participants If a participant is in the hospital, long term care facility or an institution, a WIC food package cannot be provided until discharged, since the institution is responsible for feeding the patient.
Issuance of WIC food benefits WIC benefits may be issued remotely for all remote appointment types. A verbal acknowledgement of the food benefit issuance suffices since a signature cannot be captured on the signature pad. If the client is present in the clinic, benefits should be issued in the clinic and a signature must be captured on the signature pad. Food Package Sizes Most foods are available in a variety of sizes at local retailers and on the Colorado WIC Food List and Shopping Guide. It is allowed for participants to choose to purchase sizes that will provide less than the maximum allowable amounts per their preference. However, WIC staff must provide education on how to reach the maximum allowable amounts, and ensure participants are aware that picking other sizes may result in losing benefits.
WIC Food Refrigeration, dry storage, and cooking NO refrigeration and NO cooking facilities with dry storage Milk Same as regular food package whereby participant may choose to purchase fluid milk in quarts, half- gallons or gallons-or- powdered or evaporated milk Powder or UHT Cheese Substitute for milk -same as regular food package Substitute for milk-same as regular food package Eggs Same as regular food package Or can issued boiled eggs if refrigeration is available but cooking facilities are not Substitute peanut butter Juice
Same as regular package -or- issue single serving juice
Same as regular package - or- issue single serving juice
Breakfast cereal & infant cereal Same as regular package Same as regular package Whole grains Same as regular package Same as regular package Peanut butter and Beans Same as regular package whereby participant has a choice of peanut butter, dry or canned beans
Encourage purchase of peanut butter or canned beans Canned fish Same as regular package Encourage purchase of single serving size cans Fruit & Vegetable voucher Same as regular package Encourage purchase of items that do not require cooking or refrigeration such as apples, oranges, carrots, etc. Formula Powder or liquid conc. or ready-to- feed Powder
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Food Benefit Signature & proof of ID capture The endorser/participant/proxy shows proof of ID and electronically signs the signature pad to acknowledge receipt of food benefits. Staff records the proof of ID seen in the Proof of Identification drop down on the Signature Capture pop up in Compass.
No Signature Available If a signature is not available, staff must check the No Signature Available checkbox and select one of the following reasons: ● Remote Appointment – Verbal Acknowledgement. ● Equipment malfunction. ● Mailed. ● Refused. ● NE Class. ● Other (If selected, the reason must be documented in the participant’s file).
There are two ways to capture an electronic signature from those attending a NE class: ● Signature can be captured at the time benefits are issued. ● If benefits are issued while the participant is in the NE class, staff can capture the participant signature after the class by accessing the NE Class in Scheduler and clicking on the Signature button.
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SUMMARY OF COLORADO WIC FOOD PACKAGES
Food Category Infant 0-3 mo Infant 4-5 mo
Infant 6-11 mo
Excl BF a Infant 6-11 mo Child 1 year Child 2-4 yr Pregnant Partially BF (In Range) Postpartum/ Novel BF Woman Excl BF Woman b Excl BF Multiples
Infant Formula c 870 oz pwd 806 oz conc -or- 832 oz RTF 960 oz pwd 884 oz conc -or- 913 oz RTF 696 oz pwd 624 oz conc -or- 643 oz RTF
Infant Cereal
1, 8-oz boxes 2, 8-oz boxes
Baby Food Fruit/Veg.
32 4-oz jars -or- 16 (4-oz) jars FV + $11CVB -or- 0 (4-oz) jars + $22 CVB 32 4-oz jars -or- 16 (4-oz) jars FV + $11CVB -or- 0 (4-oz) jars + $22 CVB
Baby Food Meat
16 2.5-oz jars
Milk d, e,f
12qt. whole 14 qt. 1%/fat free 16 qt. 1%/fat free 16 qt. 1%/fat free 16 qt. 1%/fat free 16 qt. 1%/fat free 24 qt. 1%/fat free Cheese g
1 lb may replace 3 qt. milk 1 lb may replace 3 qt. milk 1 lb may replace 3 qt. milk 1 lb may replace 3 qt. milk 1 lb may replace 3 qt. milk 2 lb may replace 6 qt. milk 3 lb may replace 9 qt. milk Eggsh
1 dozen 1 dozen 1 dozen 1 dozen 1 dozen 2 dozen 3 dozen Juicei
1 64-oz container 1 64-oz container 1 64-oz container 1 64-oz container 1 64-oz container 1 64 oz container 1 64 oz container even, 2 64 oz containers odd j Breakfast Cereal
36 oz 36 oz 36 oz 36 oz 36 oz 36 oz 54 oz Whole Grains
24 oz 24 oz 48 oz 48 oz 48 oz. 48 oz 72 oz Dry Beans and/or Peanut Butterk, l
1 lb beans or 18 oz peanut butter 1 lb beans or 18 oz peanut butter 1 lb beans and 18 oz peanut butter 1 lb beans and 18 oz peanut butter 1 lb beans or 18 oz peanutbutter 1 lb beans and 18 oz peanut butter 1.5 lbs dry beans, or 96 oz. canned beans and 27 oz peanut butter
CVB F/V
$26.00 $26.00 $47.00 $52.00 $47.00 $52.00 $78.00 Canned Fish
6 oz. 6 oz. 10 oz. 15 oz. 10 oz. 20 oz. 30 oz. a Exclusively BF infants 0-6 months are counted as WIC participants even though they are not issued food benefits.
b Exclusively BF woman’s package also issued to women partially (mostly or “in range”) breastfeeding multiples from the same pregnancy, and pregnant women who are partially (mostly) breastfeeding singleton infants.
c Reconstituted ounces of infant formula. Formula amounts are considered “up to” amounts. Colorado WIC uses the Full Nutrition Benefit (FNB) for concentrate formula and the Maximum Monthly Allowance for powder and RTF formulas.
d Plant-based milk alternatives milk may be substituted for cow’s milk at the rate of 1 quart of plant-based milk alternative per 1 quart cow’s milk. Following a nutrition assessment, plant-based milk alternatives may be substituted for milk in situations that include but are not limited to milk allergy, lactose intolerance, vegan diet, religious preference, or participant preference.
e Tofu may be substituted for cow’s milk at the rate of 1 lb tofu per 1 quart milk Following a nutrition assessment, tofu may be substituted for milk in situations that include but are not limited to milk allergy, lactose intolerance, vegan diet, religious preference, or participant preference.
f Yogurt may be substituted for fluid milk at the rate of 1 quart yogurt per 1 quart milk. A maximum of 2 quarts of milk may be substituted. Additional amounts of yogurt are not authorized. Whole yogurt or low fat yogurt is the standard yogurt for issuance to 1-year-old children (12 through 23 months.) Non-fat yogurt may be issued to 1-year-old children for whom overweight and obesity are a concern. Low-fat or nonfat yogurts are the only types of yogurt authorized for children > 24 months of age and women.
g Maximum substitution of milk for cheese: Children: 3 quarts (maximum 1 pound cheese) Pregnant, Postpartum and Partially (Mostly) BF Women: 3 quarts (maximum 1 pound cheese) Exclusively BF Women: 6 quarts (maximum 2 lb cheese).
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Women Exclusively BF Multiples: 9 quarts (maximum 3 lb cheese)
h Beans or peanut butter can be substituted for eggs at the rate of 1 unit beans/peanut butter per 1 dozen eggs (1 unit = 1 lb dry beans, 18 oz peanut butter, or 64 ounces canned beans. This substitution is allowed in situations that include but are not limited to egg allergy, vegan diet, religious preference, or participant preference.
i A $3 CVB can be substituted for 64 oz.of juice.
j Foods can be divided into “even” and “odd” month packages to provide the full authorized amount of juice over a 2-month period.
k A combination of dry beans, canned beans, and peanut butter may be issued in order to provide the full authorization of beans and peanut butter.
l Following a nutrition assessment, alternative nut and seed butters can be offered in place of peanut butter in situations that include but are not limited to peanut allergy or participant preference.
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Additional Allowed Substitutions: ● Canned evaporated milk may be substituted for fresh at the rate of one 12-oz can per quart fresh milk. ● Powdered milk may be substituted for fresh at an equal reconstituted rate. ● Infant cereal (32 oz) may be substituted for 36 oz breakfast cereal for women and children receiving WIC eligible nutritionals (formulas). ● Jarred infant fruits and vegetables may be substituted for CVB for women and children receiving WIC eligible nutritionals (formulas). The rate of exchange is 6.25 oz infant fruits and vegetables for every $1 CVB. Standard milk types: ● Whole milk is the standard milk for one-year-old children (12-23 months). ● Low fat (1%) or fat free milk is the standard milk for women and 2-4-year-old children (24-59 months)
Issuing milk for overweight one-year old children Based on the WIC CWA’s determination (through individual nutritional assessment and consultation with the child’s health care provider if necessary) fat reduced milks (2%, 1% or fat free) may be issued to one-year-old children for whom obesity and overweight are a concern who meet these criteria: ● Overweight: Child’s weight for length is at or above the 98th percentile. ● Rapid weight gain: A child whose weight for length, initially at or above the 50th percentile crossed two percentile curves. For example, a child going from the 50th to the 90th percentile, or going from the 75th to the 95th percentile
Issuing milk for underweight women and 2-4-year-old children Based on the WIC High Risk Counselor determination (through individual nutritional assessment and consultation with the participant’s health care provider if necessary) whole or 2 % milk may be issued to women with insufficient weight gain and underweight 2-4-year-old children (24-59 months) only when participant is also receiving a special formula.
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Food Packages - Infants
Policy: WIC staff shall select infant’s food packages according to the infant’s age, breastfeeding status (Excl BF, Prim Excl/No F Pkg, Prim Excl/Comp, Part BF, No Longer BF, and Never BF), and nutritional needs.
Regulation: 7 CFR 246.10, Policy Memodandum #2025-3
Procedure/Additional Guidance: When certifying/recertifying a mother/infant pair, begin with entering infant data into Compass and then proceed with entering the mother’s data. WIC food packages can be promoted to incentivize and support clients to reach their breastfeeding goals. When appropriate, refer to local agency staff with advanced breastfeeding credentials to provide breastfeeding assessment and support.
Food Package Types/Categories for Infants: Exclusively Breastfeed Infants: An infant who is breastfed and receives no WIC formula. Fully Formula Fed or “Full Formula”: An infant who receives WIC formula and is not breastfed. Partially (Mostly) Breasfeeding Infant: An infant who is breastfed and receiving WIC formula. “Partial (Mostly) BF Within Range”: An amount of standard formula an infant can receive that allows mother to receive a partially breastfeeding food package for herself. “Partial BF Out of Range”: An amount of standard formula greater than what is allowed for mother to receive a partially breastfeeding food package for herself.
Infant Food Packages There are three food package options: Exclusively breastfed No food package is needed for the infant until he/she is 6 months old. The mother should receive either a model or tailored food package appropriate for an exclusively breastfeeding woman. Partially Breasfeeding Infant If the mother reports that she is breastfeeding and offering or requesting formula, first ask open- ended questions to determine why formula is being used or requested and find out what the mother’s breastfeeding plan or goal is. Affirm the mother for breastfeeding. Depending on the situation, counseling may be done by the educator or can be passed on to a High Risk Counselor, WLS, or DBE. Discuss with the mother the alternatives to formula, such as breast milk collected by hand or breast pump. If, after counseling and education, the mother requests formula, verify that the infant’s breastfeeding description is “part BF” and provide only the minimum amount of formula needed to meet, but not exceed the nutritional needs of the infant. Reinforce the importance and benefits of any amount of breastfeeding. Remember that mothers have greater breastfeeding success when they continue to breastfeed and/or express breast milk regularly. The amount of formula the infant receives determines the mother’s food package. Explain that food packages with smaller amounts of formula may enable her to receive more food for herself. Fully Formula Fed A fully formula-fed infant receives a formula food package and the mother receives a food package for postpartum/non breastfeeding women until her infant is 6 months old. After her fully formula- fed infant reaches 6 months or age, the mother is no longer WIC-eligible.
Age of breastfed infant at first day of the month BF Within Range (standard formulas) BF Out of Range (standard formulas) 0 – 3 months 1 to 4 cans 5 to 9 cans 4 – 5 months 1 to 5 cans 6 to 10 cans 6 – 12 months 1 to 4 cans 5 to 7 cans
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Infants 11 month of age until their first birthday Issue an infant food package to all infants, including those between 11 and 12 months of age. If the recertification occurs during the month the child turns one year of age, recertify using the Infant Nutrition Interview, assign infant nutrition risk factors, and issue an infant food package for the full month. Issue a child (toddler) food package at the beginning of the month when the child has already turned one year of age.
Medical Indication for Formula Certain medical indications may pose a temporary or long term problem for breastfeeding and require supplementation of formula or banked human milk (although banked human milk is not a WIC-eligible food, as defined by 7 CFR 246.10). Staff must work with mothers to determine the amount of formula that the food package shall contain and the length of time the doctor recommended the supplement, particularly if the need is for a standard formula and there is no prescription. If the mother does not know, staff will recommend she contact her infant’s health care provider. Maternal medical indications: Breast anatomical challenges (e.g., tubular breasts or marked breast asymmetry, inverted nipples for which shields and pumping alone will not suffice). Breast surgery (e.g., reduction, augmentation, abscesses, cancer). Endocrine abnormality (e.g., diabetes, pituitary insufficiency – noted as a lack of noticeable breast changes during pregnancy, failure of lactogenesis stage 2 – milk did not noticeably come in) . Polycystic ovary syndrome (PCOS). Mothers with PCOS are at greater risk for insufficient milk supply, however many mothers with PCOS do not experience breastfeeding challenges and produce ample milk. Perinatal complications (e.g., hypertension, hemorrhage, retained placental fragments). Contraindicated medication. Infant medical indications: Premature (<37 weeks/0 days gestation) or very low birth weight. Excessive weight loss (not regained birth weight by 14 days of age or loss of more than 10% of birth weight). Acute dehydration not responsive to routine breastfeeding. Breastfeeding jaundice. Hypoglycemia. Inborn errors of metabolism (e.g., PKU). Special formula needed. Not feeding well at discharge and sent home pumping with a formula supplement (should be followed by a physician within 24-72 hours after discharge).
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No Medical Indication for Formula If there is no medical indication, promote any amount of breastfeeding, ask open-ended questions to understand the reason for the formula request, affirm the parent’s breastfeeding success so far (promote any amount of breastfeeding), and provide information and troubleshoot with the mother. Infant formula should only be provided to infants after evaluation and counseling by the High Risk Counselor, WLS, or DBE.
If, after counseling and education, the mother chooses to receive formula, tailor the food package to best meet, but not exceed, the nutritional needs of the infant. First, determine if the infant is already receiving formula, then change the infant’s breastfeeding description to “part BF” and provide only the minimum amount of formula needed.
Work with the mother to create food packages that best support her breastfeeding plan, explaining that smaller formula packages may enable her to receive more food for herself with a food package for partially breastfeeding women.
Infant Formulas Categories Infant formulas are classified into three categories:
1. Primary Contract Brand Infant Formula: Any (standard) infant formula manufactured by the company with whom Colorado WIC has a formula rebate contract. (See MPSF: WC-00-25-P). A prescription is not required for WIC to issue primary contract brand infant formula. a. All infants enrolled on the Colorado WIC Program receiving a standard infant formula should receive one of five primary contract brand infant formulas: Enfamil Infant, Enfamil ProSobee, Enfamil Gentlease, Enfamil Reguline or Enfamil AR. Mead Johnson Nutritionals contracts with Colorado WIC to provide rebate dollars for each container of Enfamil Infant, Enfamil ProSobee, Enfamil Gentlease, Enfamil Reguline or Enfamil AR issued to WIC participants. Rebate money is used to support additional caseload.
Contract for Infant Formula Rebate: Federal regulations require that state WIC Programs contract with a single infant formula manufacturer. Additionally, federal regulations require the use of Primary Contract Brand Infant Formulas, except when contraindicated by a specific medical condition. The Colorado WIC Program contracts with Mead Johnson Nutritionals to be the provider of standard milk and soy-based formulas. These formulas contain at least 10 mg iron per liter and 20 kilocalories per fluid ounce. Rebates for the contract formulas, which are used to enroll more children and women in WIC, support a significant percentage of the Colorado WIC caseload. There are no exceptions for the provision of standard formulas made by other manufacturers.
Colorado WIC receives rebate for the following formulas: Enfamil Infant - A milk-based formula. Enfamil ProSobee – A soy-based formula. Enfamil Gentlease - A reduced-lactose milk-based formula that has partially hydrolyzed protein. Enfamil Reguline – A milk-based formula with added prebiotics. Enfamil AR – A milk-based formula with added rice starch.
2. Non-Contract Brand Infant Formula: Any infant formula or exempt infant formula that is not a contract formula. (See MPSF:WC-00-25-P)
3. Exempt Infant Formula. Any infant formula designed for infants with special medical conditions who require a modified infant formula. (See FDC Act 21 U.S.C. 350a). Exempt infant formulas are those that are represented and labeled for use by an infant who has an inborn error of metabolism, a low birth weight or who otherwise has an unusual medical or dietary problem. They are often used with infants who have medical problems that affect their nutritional needs and/or their ability to digest regular infant formulas. It is very important that a physician regularly reevaluate the need and acceptance by an infant receiving an exempt infant formula.
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Issuance of an exempt infant formula is only permitted with a properly completed Colorado WIC Program’s Physician Authorization Form or a physician’s prescription and High Risk Counselor approval of prescription prior to issuance. It is important that a physician regularly reevaluates the appropriateness of the type and amount of the formula or nutritional prescribed. For more information, see Prescription Required Formulas and Nutritionals policy in Section 2, Nutrition Services.
Formulas to Accommodate Religious Beliefs: In the event that one of Colorado WIC’s contract formulas does not meet a participant’s religious requirements, such as need for a kosher formula, a non-contract formula can be issued without a physician’s authorization. Documentation of the issuance of a non-contract formula to accommodate religious eating patterns must be included in the participant’s record.
Issuance of Ready-To-Feed Federal and State regulations require that infant formulas be issued in concentrated liquid or powder physical forms. Ready-to-feed (RTF) WIC formulas may be authorized when the CWA determines and documents that: The family’s water supply is contaminated and / or is unsafe for consumption. The caregiver has difficulty correctly diluting concentrate or powder formula. For a medically fragile infant (i.e. premature). The formula only comes in ready-to-feed form.
Banked Human Milk Banked human milk is not a WIC-eligible supplemental food and WIC federal funds cannot be used for the purposes of collecting, storing, purchasing, or disseminating banked human milk.
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Infant Food Package
Age Exclusively Breastfeeding (breastfed- no WIC formula) Partially Breastfeeding – in range (breastfed and receiving WIC formula) Partially Breastfeeding – out of range (an infant who is breastfed and receiving WIC formula) Fully Formula-Fed (infant who receives WIC formula and is not breastfed) Birth through 3 mo.a None 435 oz powder or 364 oz concentrate c or 384 oz RTF 436 - 870 oz powder or 365 - 806 oz concentrate c or 385 – 832 oz RTF 870 oz powder or 806 oz concentrate c or 832 oz RTF 4 mo. through 5 mo.a None 522 oz powder or 442 oz concentrate c or 474 oz RTF 523 - 960 oz - powder Or 443 - 884 oz concentrate c or 475- 913 oz RTF 960 oz - powder or 884 oz concentrate c or 913 oz RTF 6 mo. through 11 mo.a,b
(16) 2.5-oz jars baby food meat (2) 8-oz boxes baby cereal
32) 4-oz jars baby food F/V Or (16) 4 oz jars baby food F/V + $11 CVB Or (0)4 oz jars baby food F/V +$22 CVB 384 oz powder or 312 oz concentrate c or 338 oz RTF
(1) 8-oz boxes baby cereal (32) 4-oz jars baby food F/V Or (16) 4 oz jars baby food F/V + $11 CVB Or (0)4 oz jars baby food F/V +$22 CVB 385 - 696 oz powder or 313 - 624 oz concentrate c or 339 - 643 oz RTF
(1) 8-oz boxes baby cereal
(32) 4-oz jars baby food F/V Or (16) 4 oz jars baby food F/V + $11 CVB Or (0)4 oz jars baby food F/V +$22 CVB 696 oz powder or 624 oz concentrate c or 643 oz RTF
(1) 8-oz boxes baby cereal
(32) 4-oz jars baby food F/V Or (16) 4 oz jars baby food F/V + $11 CVB Or (0) 4 oz jars baby food F/V +$22 CVB
a All formula amounts are considered “up to” amounts. b When individually tailoring infant food packages to provide the CVB substitution, nutrition assessment and appropriate nutrition education must be provided addressing developmental readiness, safe food preparation, storage techniques, and feeding practices to make certain participants are meeting their nutritional needs in a safe and effective manner. c Colorado WIC uses the Full Nutrition Benefit (FNB) for concentrate formulas, and the Maximum Monthly Allowances (MMA) for powder and RTF formulas.
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Guidelines for Providing Supplemental Formula To Non-Exclusively Breastfed Infants: Staff carefully determine with mothers the amount of formula the food package shall contain for the non-exclusively breastfed infant. When possible staff should provide the minimum amount of formula needed and issue powder (not concentrate) formula.
Number of cans powdered formula
Breastfed Infant's Average Daily Formula Intake Enfamil EnfaCare Nutramigen with Enflora LGG Similac Alimentum Similac NeoSure EleCare Infant Enfamil Infant Gentlease Infant Prosobee Enfamil AR Enfamil Reguline EleCare Infant Neocate Infant PurAmino Similac PM 60/40 Pregestimil Comforts Hypoallergenic Parent’s Choice Hypoallergenic Alfamino Infant Gerber Extensive HA Neocate Syneo Infant 1-3 ounces 1 1 1 1 2 1 1 4 ounces 2 2 2 1 2 2 2 5-6 ounces 2 2 2 2 3 2 2 7 ounces 3 2 2 2 3 3 3 8 ounces 3 3 3 2 3 3 3 9 ounces 3 3 3 3 * # 4 3 3 10 ounces 4 # 3 3 3 4 * # 4 4 11-12 ounces 4 4 * # 4 * # 3 5 4 * # 4 * # 13 ounces 5 * 4 4 4 + 5 5 5 14-15 ounces 5 5 + 5 + 4 6 + 5 + 5 + 16-17 ounces 6 + 5 5 5 6 6 6 18-19 ounces 6 6 6 5 7 6 6 20 ounces 7 6 6 6 7 7 7 21 ounces 7 7 6 6 8 7 7 22 ounces 8 7 7 6 8 8 7 23 ounces 8 8 7 7 8 8 8 24 ounces 9 8 7 7 9 8 8 25-26 ounces 9 9 8 7 9 9 9 27 ounces 10 9 8 8 9 9 9 28 ounces + 11 10 9 8 9 9 9 * Maximum “in range” formula for 0-3 month olds + Maximum “in range” formula for 4-5 month olds # Maximum “in range” formula for 6-11 month olds
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Issuing eWIC Cards
Policy: Local agency staff must issue an eWIC card to WIC families at the same time as notification of certification. Foster children must be issued their own eWIC cards.
Regulation: 7 CFR 246.7, 7 CFR 246.12
Procedure/Additional Guidance: eWIC Card Issuance At the WIC staff person: Chooses the participant’s individual food package from the Compass model food package drop down list in the Food Package panel. (Alternatively, staff may tailor a food package, or create a new package “from scratch.”) Verify the correct food package(s) are assigned to each participant in the economic unit. Assigns one eWIC card to each economic unit. Each foster child receives their own eWIC card. Accesses the Card Operations panel, selects the “Initial Setup” button. The PAN pop-up appears. Swipes the eWIC card in the magnetic card reader (or manually enters the 16-digit PAN). Compass performs a search to: o Verify the PAN is associated with numbers received by that clinic; and o Is not assigned to another economic unit. If the PAN is not assigned and is in the clinic card inventory, the pop-up closes and the active PAN displays at the top of the Card Operations panel. Accesses the Food Benefits panel. Verifies the appropriate issuance (1-3 months) and clicks the “Issue Benefits” button to issue food benefits to the family’s PAN. Obtains the endorser or proxy’s electronic signature or verbal acknowledgement in Compass to acknowledge receipt of food benefits and record their proof of identification. Completes back of eWIC card: When appropriate, writes the foster child’s name on the back of the eWIC card. Local Agency option: writes the FID on the back of the eWIC card. Instructs the endorser how to: o Either initial or additional endorser signs the “Authorized signature” line on back of the eWIC card. Set a Personal Identification Number (PIN); Use and protect the eWIC card; Change their PIN; Report lost/stolen/damaged cards. Reviews/Explains: The Family Food Benefits printout and provides a printed copy (can be mailed or emailed) to the endorser/proxy. For subsequent food benefit issuance after the certification visit, staff must offer a printed copy of the Family Food Benefits but are not required to provide it if the participant/endorser declines a copy. The Family Food Benefits can be viewed from the WICShopper app, EBTEdge website, or obtained from the customer service line (844-234-4950). To the endorser/proxy that they can only purchase their WIC foods at Colorado WIC-authorized stores. To the endorser/proxy that they can only purchase the items listed on the current month’s Family Food Benefits printout. The Colorado WIC Food List & Shopping Guide shows the specific brands, amounts and sizes of WIC foods that can be purchased at the store. How to select WIC foods at the store and use the eWIC card at checkout. Ways to obtain the remaining WIC food balance. Authorized stores are required to follow certain rules and provide only the approved items. Otherwise, they risk not getting paid or being disqualified as a CO WIC-approved retailer. Potential misuse violations and consequences (as stated on the Participant Rights and Responsibilities) At subsequent WIC visits, the eWIC card serves as a proof of identification for all participants and endorsers of that household.
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PIN Unlock If an endorser or WIC shopper incorrectly enters their PIN 4 times in a row, their account will be locked until midnight. WIC staff may unlock a participant’s PIN prior to the re-set at midnight, however WIC staff must first verify the endorser’s (or proxy’s) identity. This may be done over the phone by asking the participant/endorser the PAN on the card, participant’s DOB and address. When in person, staff recognition, or any other acceptable proof of ID may also be used. For security reasons the signed eWIC card may not be used as proof of identity in this particular situation.
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Ordering Instructions for Products Not on Retail Shelves
Policy: Local agency WIC staff may special order infant formulas and WIC-eligible nutritionals when a formula is not locally available within the needed time frame, in the quantities needed, or is excessively priced. Orders must be submitted on a monthly basis; no more than one month’s issuance of formula may be ordered at a time. All special order formula requests must be sent to the state office. Ward Road Pharmacy and Sentido Healthcare are the Colorado WIC Program’s authorized retailers for formulas not available at local retailers.
Regulations: Colorado WIC Policy
Procedure/Additional Guidance: Perform the following steps to special order formula:
1. Ensure that the correct formula is assigned to the client’s food package for that month and will be picked up by the endorser/client during the valid benefit period.
2. Issue benefits to the family’s PAN.
3. Complete the Special Formula Order Form for each formula requested.
a. Enter the clients’s first name only. If a household has two or more clients needing the same formula, please submit separate orders for each client. b. Enter the benefit start date (always the first day of the benefit month) and the appointment date. The appointment date is the date the formula is needed and must be within the monthly benefit date range. c. Enter the PAN (eWIC card number) in this format: first 6 digits, hyphen, last 10 digits. d. Choose the formula type: standard, specialty, or metabolic. e. From the drop down list of formulas, select the specific formula, ensuring the correct form (powder, concentrate, RTF), size, and flavor (if available). Verify that the formula being ordered matches the formula that is issued to the client and is included in their benefits. If a requested formula or flavor doesn’t display*, enter it in the other comments field. *Note: If a desired formula or flavor does not display, it may be because it is not available through the specialty ordering process. f. Indicate the order amount and the unit (can, case, or 6-pack). The unit type must match what is issued on the eWIC card in Compass. g. Indicate the amount already in the clinic (if any). h. Select the WIC clinic name from the drop down list. If the clinic name doesn’t display, enter it in the other comments field. i. Enter any additional information in the other comments field, such as clinic closure dates. If the formula is being delivered to the client’s home, include the endorser’s full name and the delivery address in the comments field.
4. If printing the Family Food Benefits list, draw a line through the formula name and note “ordered from Ward Road Pharmacy/Sentido Health.” Instruct the family not to purchase the formula at a retail store; they will pick it up at the clinic or, in rare situations, it will be delivered to their home. If picking up at the clinic, schedule a time within the valid food benefit date for them to return to the clinic to pick up the formula.
5. Submit subsequent month’s orders by the 15th of the current month (when possible).
Confirmation of Orders Local staff ordering the formula will receive three emails: 1) automated confirmation of submitted order; 2) copied on email from state office to our pharmacy vendors. This email includes an authorization code and serves as confirmation that the order has been fully processed 3) email from one of the pharmacy vendors with the date the
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formula should arrive at the clinic. Email cdphe.wicformula@state.co.us if any of those confirmation emails are not received.
Order Changes Email cdphe.wicformula@state.co.us to cancel an order or change quantities of a formula that has already been ordered prior to making any changes to the family’s eWIC card in Compass. Wait for directions from State Office before making Compass changes.
Formula Pick-up Confirmation When the formula is picked up at the clinic, obtain the endorser’s signature on the packing slip (from the pharmacy shipment box), record the date and save the form in a specialty formula order file. Signed packing slips may be destroyed 3 ½ years from the end of the applicable fiscal year.
When endorser/client does not pick up the special formula Make every effort to contact the endorser/client to learn whether the formula will be picked up. If formula will not be picked up, learn why and document details in the client’s care plan.
1. If formula that has never left the clinic is not provided to the client for whom it was originally intended, the formula may be issued to another WIC client, donated to a local hospital, or destroyed. If reissue is preferred and a recipient is not identified within the local agency, Email the state office at cdphe.wicformula@state.co.us. 2. If a new recipient is identified for the unclaimed formula, follow the instructions below. The original clinic: a. When a new client is identified within the same agency: Emails the state office at cdphe.wicformula@state.co.us with the name, FID and, clinic/agency of the new recipient. Make no changes in Compass until state office staff have reviewed the situation to ensure payment for the formula has been processed.
OR
b. When the new client identified is served at a different agency: Works directly with the other clinic/agency RD to arrange transfer of the formula, which may be in person, by courier, or by mail. Include the Ward Road Pharmacy/Sentido Health packing slip in the shipment. a. The receiving clinic: i. Provides the formula to the new recipient within the client’s valid benefit period. ii. Obtains the endorser’s signature and date on the packing slip and keeps the packing slip in the Ward Road file. iii. Notifies the state office Formula Inbox (cdphe.wicformula@state.co.us ) to remove the formula benefits from the new client’s account for that month.
3. If the formula is donated or disposed of and not issued to a client, staff must document the disposition on the packing slip, sign, date, and retain in the Ward Road order file.
Home Delivery In rare situations and with state office approval, special formulas can be delivered to client homes. For home deliveries, WIC staff must notify clients in advance of the delivery date and confirm that clients still need the next month’s formula order, including verifying that the formula name and quantity have not changed. Confirmation of successful home delivery is maintained in a central file at the state office and includes tracking information provided by Ward Road Pharmacy and Sentido Health.
All Other Questions/Issues Related to Specialty Formula Orders Local agency staff should email cdphe.wicformula@state.co.us for guidance on all specialty formula order situations not specifically addressed.
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Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 03/01/2026
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Food Packages - Prescription-Required Formula and Nutritionals Policy: Local agency WIC staff may issue approved medical formulas and nutritionals to infants, children and women based upon qualifying medical conditions and receipt of medical documentation from a healthcare provider licensed to write prescriptions in Colorado (MD, PA, DO, NP). The WIC High Risk Counselor must approve prescriptions for prescription-required formulas prior to issuance. Supplemental foods may also be issued as an accompaniment to the WIC formula.
Regulation: 7 CFR 246.10 Procedure/Additional Guidance: In order to receive a food package with a prescription required formula or nutritional, participants must have one or more qualifying conditions that impair ingestion, digestion, absorption or the utilization of nutrients that could adversely affect the participant’s nutritional status, and the use of conventional foods is precluded, restricted, or inadequate to meet their special nutritional needs as determined by a health care professional licensed under State law to write medical prescriptions.
The qualifying conditions include but are not limited to: • premature birth • low birth weight • failure to thrive • inborn errors of metabolism and metabolic disorders immune system disorders • malabsorption syndromes gastrointestinal disorders • severe food allergies that require an elemental formula • life threatening disorders, diseases and medical conditions that impair ingestion, digestion, absorption or the utilization of nutrients that could adversely affect the • participant’s nutritional status
Prescription-Required Formula Package is required in order to issue either of the following:
1. Exempt Infant Formula: Exempt infant formula means an infant formula that meets the requirements for an exempt infant formula under section 412(h) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 350a(h)) and the regulations at 21 CFR parts 106 and 107. Exempt infant formulas are those that are represented and labeled for use by an infant who has an inborn error of metabolism, a low birth weight or who otherwise has an unusual medical or dietary problem. They are often used with infants who have medical problems that affect their nutritional needs and/or their ability to digest regular infant formulas. It is very important that a physician regularly reevaluate the need and acceptance by an infant receiving an exempt infant formula. 2. WIC Eligible Nutritionals: Certain enteral products that are specifically formulated and commercially manufactured (as opposed to a naturally occurring foodstuff used in its natural state) to provide nutritional support for individuals with a qualifying condition, when the use of conventional foods is precluded, restricted, or inadequate. Such WIC-eligible nutritionals must serve the purpose of a food, meal, or diet (may be nutritionally complete or incomplete) and provide a source of calories and one or more nutrients; be designed for enteral digestion via an oral or tube feeding; and may not be a conventional food, drug, flavoring, or enzyme. WIC-eligible nutritionals include many, but not all, products that meet the definition of medical food in section 5(b)(3) of the Orphan Drug Act (21 U.S.C. 360ee(b)(3)). WIC eligible nutritionals may not be a conventional food, drug, flavoring, or enzyme. Blenderized foods (i.e., conventional foods liquified in a blender) do not meet WIC-eligible nutritionals requirements.
Prescription-Required Formula Package is Not Authorized For: ● Infants whose only condition is: ✔ A diagnosed formula intolerance or food allergy to lactose, sucrose, milk protein or soy protein that does not require the use of an exempt infant formula; or ✔ A non-specific formula or food intolerance. ● Women and children who have an intolerance to lactose or milk protein that can be successfully managed with the use of another WIC food packages; or
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● Any participant solely for the purpose of enhancing nutrient intake or managing body weight without an underlying qualifying condition. For example, PediaSure should not be issued for a healthy child for the purpose to enhance the child’s nutritional intake. Issuance of PediaSure is allowed when the child’s health provider specifies its use as part of an overall nutritional plan for a child diagnosed as failure to thrive.
Medical Documentation Acceptable medical documentation from a health care provider must be provided and approved by the WIC High Risk Counselor prior to issuance of exempt infant formulas, WIC eligible nutritionals, and/or supplemental foods. Medical documentation can be written on the Physician’s Authorization Form or a health care provider’s prescription pad and scanned to the participant’s record. When absolutely necessary, all of the required medical documentation information may be obtained by telephone, provided written medical documentation is received within a reasonable amount of time (i.e., one to two weeks’ time). Telephoned requests from a physician must be documented in the participant’s record. All medical documentation must be kept on file (scanned to the participant’s record) at the local clinic.
Medical documentation must include the following: ✔ The name of the authorized WIC formula prescribed, including amount needed per day; ✔ Length of time the prescribed WIC formula is required by the participant; ✔ The qualifying condition(s) (medical reason / diagnosis) for issuance of the authorized WIC formula and ✔ Signature, date and contact information.
Medical Supervision Requirements Due to the nature of the health conditions of participants who are issued WIC formulas that require medical documentation, close medical supervision is essential for each participant’s dietary management. The responsibility remains with the participant’s health care provider for this medical oversight and instruction. It is the responsibility of the WIC High Risk Counselor to ensure that the appropriate type and amounts of supplemental foods prescribed by the participant’s health care provider or authorized by the WIC High Risk Counselor are issued in the participant’s food package. Prescriptions for Out-of-State Transfers A participant presenting as an out-of-state transfer may need an exempt infant formula, WIC eligible nutritional and /or supplemental foods but may not have the required medical documentation. The medical documentation requirement can be satisfied by using one of the following approaches: ● Colorado local agency WIC staff calls the originating WIC clinic and verifies that proper and timely medical documentation was presented there. ● The out-of-state VOC satisfies the medical documentation requirements when the VOC specifies recent issuance of an exempt infant formula, WIC eligible nutritional and /or supplemental foods. In either instance, a description of the approach must be documented in the participant’s Compass record with the plan to secure proper written medical documentation from a medical provider in Colorado. Staff may issue a maximum of one-month formula/food benefits prior to receiving written medical documentation.
Obtaining Formula That Is Unavailable from Local Retailers Refer to the Ordering Instructions for Products Not on Retail Shelves policy in Section 2: Nutrition Services for instructions on obtaining special formula products that are not available from local retailers. Formula Issuance During a Disaster/Emergency For information about providing formula during a natural disaster or emergency, please refer to the policy called Access to WIC Services During Natural Disasters/Emergencies.
Approval Procedures for Prescription Required Formulas The WIC High Risk Counselor must: ● Review and approve or deny the formula request. ● Document appropriate supplemental foods on the approved Physician Authorization Form. Changes to the approved foods may be documented in the participant’s care plan. ● Complete the “WIC USE ONLY” field with his/her signature, date, and the date the prescription expires. ● Ensure completion of the Medical Documentation screen in Compass with the following:
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● Rx Expiration Date (expiration date of prescription) ● Medical Diagnosis (choose from drop down list) ● Medical condition o Prematurity o Vegan o Additional nutrients needed for growth/weight gain o Intolerance o Concern of overweight/obesity o Other (if selected, the reason must be entered in the Additional Details field. ● Approved by (name of WIC High Risk Counselor) ● Authority (name of medical provider) ● Doc ID (as labeled by staff) ● Scan the signed prescription into the family’s record in Compass. If the WIC High Risk Counselor is not available to complete the Medical Documentation field, the Educator may first obtain verbal approval from the WIC High Risk Counselor and then complete the screen.
If the WIC High Risk Counselor is unavailable, the WIC Educator can call a State WIC Nutrition Consultant for issuance approval. In those situations, the WIC Educator must document issuance authorization details in the participant's record and communicate with the WIC High Risk Counselor to review as soon as possible.
Roles and Responsibilities of the Health Care Provider, WIC High Risk Counselor & WIC Educator Health Care Provider’s Role: ● Selects the formula/product and (unless defers to WIC High Risk Counselor) appropriate supplemental foods from a list of allowable WIC products, educates the participant/family on its use, and monitors tolerance, growth, hemoglobin, improvement of symptoms, etc., and continued need. Provides the endorser/participant Medical Documentation in the form of a prescription or the Colorado WIC Program’s Physician Authorization Form. Complete Medical Documentation includes the following required information: ✔ Name of the authorized WIC formula prescribed, including amount needed per day; ✔ Length of time the prescribed WIC formula is required by the participant; ✔ Medical reason/diagnosis for issuance of the authorized WIC formula; ✔ Authorized supplemental foods (unless deferred to WIC High Risk Counselor); and ✔ Signature, date and contact information. ● Provides the participant with a starter supply of the formula/product when it is needed immediately, to allow the WIC clinic to schedule an appointment for the participant and to arrange stocking with the retailer. ● In addition to a physician (MD), medical documentation can be completed and signed by a physician assistant (PA), a doctor of osteopathy (DO), a nurse practitioner (NP), or a health care professional licensed to write medical prescriptions in Colorado. The WIC High Risk Counselor’s Role: The following responsibilities of the WIC High Risk Counselor may never be delegated to paraprofessional staff: ● Works in partnership with the physician to provide the formula/product that best meets the participant's needs. Contacts the physician when more information is needed and helps differentiate among the available products to assist the physician in prescribing. ● Reviews the Medical Documentation for completeness and appropriateness for the participant's needs.Maintains all medical documentation in the participant's record. ● Reviews participant record to determine the participant's age, growth, development, symptoms, and diagnosis. ● Reviews history of WIC food package issuance to determine what previous formulas and/or nutritionals and supplemental foods the participant has been issued. How long has the participant used these formulas and what were the symptoms? ● Reviews product list to determine the recommended use, nutritional information, and any cautions mentioned for the prescribed product. ● Determines the appropriate supplemental foods, prescribed amounts, and length of time required. ● Contacts the physician, as needed, to discuss concerns about the prescribed formula and/or supplemental foods.
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● Discusses the following as needed
✔ Participant's weight history, previous formulas, and reported symptoms. ✔ Other formulas and nutrition products that are WIC approved. ✔ The prescription form and the maximum time prescription are valid. ✔ Instructions for dilution and amount of formula needed. ✔ Amount of formula that WIC can issue and how participant can purchase or obtain additional formula. ✔ Using a less expensive product or changing to a WIC-approved formula to help the participant as much as possible. ● The plan to assess the use of the product (examples: use 1 month and see physician) ● Determines the length of time the product and/or supplemental foods can be issued without a new prescription. The time limit should not exceed the maximum time that the prescription is valid. ● Signs and dates the Physician Authorization Form in the “WIC Use Only” area and scans to the participant’s record. Notes when a new prescription is needed (try to combine with a scheduled WIC mid-certification or recertification appointment to avoid having the participant return for extra appointments). ● Reinforces the physician's recommendations for use of the formula, dilution instructions and any additional supplemental foods. ● Contacts a State WIC nutrition consultant to discuss an order for a formula/product not WIC approved or for consultation regarding a formula/product or medical diagnosis. ● Documents in the WIC participant’s care plan to ensure continuity of care: appropriate follow up, education, future directions. Documentation includes formula preparation and dilution instructions provided and any issues encountered with the pharmacy and ordering the special product. ● Makes appropriate referrals to ensure follow up and evaluation (physician, public health nurse, home health care, Department of Social Services, EFNEP, etc.). Is prepared to discuss the following: ✔ Will safety and tolerance be concerns if the product is issued? ✔ Is there adequate measuring equipment available for the participant to use? ✔ Does the participant need help to provide the correct dilution and amount of formula? ✔ Is there a plan for a health care provider to see the participant and evaluate tolerance and continued use of the product? These issues are often a concern with formula exceeding 24 kcal/oz and if the formula requires the addition of other ingredients (carbohydrates, MCT oil, vitamin supplements, etc.). ● Follows the high risk protocol regarding seeing participants and providing necessary documentation when exempt infant formulas and WIC eligible nutritionals are issued to WIC participants. ● Ensures availability of the formula/product by placing an order with a WIC-approved vendor. If the formula/product is not available locally, submits an order to the State Office following the procedure: eWIC Ordering Instructions for Products Not on Retail Shelves for Local Agencies.
The WIC Educator's Role: ● Refers to the Medical Documentation to see the WIC High Risk Counselor’s notations regarding the length of time the product will be issued. ● Reviews the care plan that has been completed by the WIC High Risk Counselor. Follows any instructions that are given such as food package to provide, number of month’s benefits to issue, what retailer to contact, what education to review with the participant or education materials to provide, and when the participant needs to return to the WIC clinic. ● Explains to the participant when the next prescription or authorization is needed and provides the participant with a Physician Authorization Form to bring to the next WIC appointment ● Contacts the WIC retailer as needed to arrange for the product to be stocked, gives timelines for expected use and determines when it will be available. ● Follows the high risk protocol and schedules the participant to see the WIC High Risk Counselor as needed.
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Formula and Supplemental Food Amounts for Infants, Children, and Women: Monthly Maximum Amounts Infant 0-3 mo Infant 4-5 mo Infant 6-11 mo Child 1-4 years Women Formulaa (reconstitute d ounces) (Exempt Infant Formulaa or WIC eligible nutritionals only) 870 oz powder -or- 806 oz concentrate -or- 832 oz RTF 960 oz powder -or- 884 oz concentrate -or- 913 oz RTF 696 oz powder -or- 624 oz concentrate -or- 643 oz RTF Formulaa (Infant formula, Exempt infant formula or WIC eligible nutritionals) 910 ounces reconstituted formula (powdered, concentrate or ready-to feed) 910 ounces reconstitute d formula (powder, concentrate or ready-to feed) Supplemental foods None None *Age appropriate supplemental infant foods may be approved for issuance by WIC High Risk Counselor **Age appropriate supplemental child foods may be approved for issuance by WIC High Risk Counselor **Category appropriate supplemental foods may be approved for issuance by WIC High Risk Counselor
NOTE: Issuance of Special and Metabolic food packages always requires a written order from an authorized health care provider for the formula. * With medical documentation, infants 6-11 months of age with a medical condition that precludes food may receive the same amount of contract formula, exempt infant formula or WIC eligible nutritionals as 4-5 month old infants in lieu of infant foods (infant cereal, bananas, baby fruits and vegetables).
** With medical documentation, children and women whose special dietary needs require the use of pureed foods (in addition to requiring the use of a special formula) may receive jarred infant food fruits and vegetables in lieu of the cash value benefit.
Colorado WIC Program: Authorized Formulas and Nutritionals Please review the maximum allowable amount of formulas authorized by Colorado WIC tables for current approved formulas and nutritionals, as well as more detailed information on these options. a Colorado WIC uses the Full Nutrition Benefit (FNB) for concentrate formulas and the Maximum Monthly Allowance (MMA) for powder and RTF formulas.
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Replacement of eWIC Card
Policy: The local agency must respond to any report of a lost, stolen, or damaged card within one business day of the date of report, and replace the EBT card and benefits within seven (7) business days of notice from the participant, endorser, or proxy.
Regulation: 7 CRF 246.12
Procedure/Additional Guidance: When an eWIC card is reported as damaged, lost or stolen, the local agency WIC staff person deactivates the card in Compass. When staff reissue a new, active, replacement eWIC card, the benefits are automatically transferred to the new eWIC card and available for purchase. The replacement eWIC card may be picked up in person by the endorser/participant, or it may be mailed. Proof of ID must be verified before the card can be replaced. When the replacement card is picked up in person, staff recognition or any other acceptable proof of ID may be used. When the replacement card is mailed, proof of ID may be verified over the phone by asking the participant’s and endorser’s date of birth, phone number and address. Note, if the stated phone number or address doesn't match what is in Compass due to a recent move or change in telephone number, ask additional questions to verify identity, such as FID, name of clinic, next or last appointment date, name of WIC staff person seen at last appointment, etc. When an eWIC card is returned that is damaged or returned by a participant, staff must complete the following: Deactivate the card in Compass. Cut damaged card in half and destroy, or place in an appropriate document shredder.
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Food Packages: Women (Pregnant, Breastfeeding and Postpartum)
Policy: WIC staff select food packages for pregnant women according to the woman’s nutritional needs. Food packages for breastfeeding and postpartum women are determined by her infant’s age, the amount of formula (if any) issued to her infant(s), and the mother’s nutritional needs.
Regulation: 7 CFR 246.10
Procedure/Additional Guidance: Food Package Types/Categories for Women ● Pregnant: For women with singleton pregnancies.
● Partially Breastfeeding: For women whose breastfed infant receives infant formula in amounts “in range,” and women pregnant with multiples (Compass lists women pregnant with multiples as a separate food package, but they receive the same foods in the same amounts as a partially breastfeeding woman).
● Postpartum Woman (not breastfeeding) / Novel Breastfeeding: For women who are within 6 months postpartum and not breastfeeding, and women who are within 6 months postpartum and breastfeeding an infant who receives infant formula in amounts “out of range” for partially breastfeeding. ✔ When a woman reports that she is partially breastfeeding a > 6-month old infant who receives “out of range” infant formula, the WIC user: 1) issues a final minimum of 15 days food benefits and; 2) chooses “No Food Benefits” in FB Issuance, either on family panel or food package panel. Although she no longer receives a food package, she continues to be counted as an active WIC participant with the category of “breastfeeding” and continues to receive breastfeeding support, nutrition education, and referrals.
● Exclusively Breastfeeding: For breastfeeding women up to 1 year postpartum whose infants do not receive infant formula from WIC (these breastfeeding women are assumed to be exclusively breastfeeding their infants). This food package is also designed for issuance to women participants partially breastfeeding multiple infants from the same pregnancy “in range”, and pregnant women who are also partially (mostly) breastfeeding an infant “in range.”
● Exclusively Breastfeeding Multiples: For women who are exclusively breastfeeding multiple infants who receive no formula from WIC. The monthly maximum for these women is 1.5 times the maximum quantity of the Exclusively Breastfeeding Women food package above. In order to provide maximum amounts allowed, foods are divided into “even and odd month” food packages which are issued over a two-month period of time. This food package is also for pregnant women also partially (in range) or fully breastfeeding multiple infants.
● Women receiving WIC eligible nutritionals are also eligible to receive a food package that can include up to the maximum allowable amount of juice, milk (or milk alternatives), breakfast cereal, cheese, eggs, fruits and vegetables, whole grains, legumes, canned fish, and peanut butter. (The WIC High Risk Counselor can determine appropriate supplemental foods.) When substantiated with proper and complete medical documentation/PAF and approval from the WIC High Risk Counselor, women can receive WIC eligible nutritionals.
● The WIC High Risk Counselor may also approve issuance of whole or 2% milk for women receiving WIC eligible nutritionals.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 03/01/2026 Page 2 of 3 Summary of Women Food Packages Food Pregnant Partially BFing Postpartum/Novel BFing Exclusive BFing Exclusive BFing Multiples Milk (gallons) 3.25 3.25 3.25 3.25 5.25 Cheese (pounds) a 1 1 1 1 1 Eggs (dozen) 1 1 1 2 3 Juice (ounces) 64 64 64 64 96 Cereal (ounces) 36 36 36 36 54 Whole grains (lbs) 3 3 3 3 4.5 Dry Beans and/or Peanut Butter 1 pound and 18 oz 1 pound and 18 oz. 1 pound or 18 oz 1 pound and 18 oz 1 lb., 8 oz and 27 oz Canned fish (ounces) 10 15 10 20 30 oz CVB $47 $52 $47 $52 $78
a Staff must ensure clients are aware they may opt for either a cheese model food package OR a standard milk model food package including three additional quarts of milk. The model food package including cheese can only be assigned after nutrition assessment is completed and the client has expressly chosen a cheese model food package.
Food Package Allowances/Substitutions WIC staff may prescribe allowable alternatives and tailor the package according to additional participant needs and preferences. All substitutions are considered for client preference unless stated otherwise. If the reason for substitution was not simply client preference, the reason why a substitution was issued must be expressly documented. WIC staff may determine the issuance of the following foods: ● Plant-based milk alternative or tofu as a substitution for milk. ✔ Following a nutrition assessment, plant-based milk alternatives (1 quart per 1 quart) or tofu (1 lb per 1 quart) may be substituted for milk in situations that include, but are not limited to milk allergy, lactose intolerance, vegan diet, religious preference (i.e. kosher), or participant preference. ● Beans/Peanut butter as a substitution for eggs. ✔ Per participant preference, staff may substitute dry legumes (1 pound), canned legumes (64 ounces), and/or peanut butter (18 ounces) for each 1 dozen eggs when individually tailoring food packages. ● $3 CVB substitution for juice. ✔ Per participant preference, staff may substitute a $3CVB can be provided in place of 64 oz. of juice when individually tailoring food packages. ● Alternative nut/seed butters. ✔ Following a nutrition assessment, staff may substitute alternative nut/seed butters for peanut butter at a rate of 1:1 in situations that include, but are not limited to, allergy, religious or cultural reasons, or participant preference. Alternative nut/seed butters may also be issued in place of peanut butter when peanut butter is issued as a substitute for eggs. ● When substantiated with proper and complete medical documentation and approval from the WIC High Risk Counselor, the following can be issued to women. ✔ WIC-eligible nutritional. ✔ Infant cereals as a substitute for breakfast cereal. ✔ Infant fruits and vegetables as a substitute for the CVB.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 03/01/2026 Page 3 of 3 The WIC High Risk Counselor may approve the issuance of the following foods: ● Supplemental foods for women receiving nutritionals. ● Whole or 2% milk for women receiving nutritionals.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services
Revised: 04/01/2026
Page 1 of 3 High and Low Risk Protocols
Policy: WIC staff must follow the Colorado WIC protocols in the identification and follow-up of high and low risk participants. Participants classified as high risk must be scheduled for a high risk nutrition education visit with the High Risk Counselor within the required time frames. All participants must receive nutrition education counseling at their initial visit and at all recertification, mid-certification and follow-up visits.
Regulation: USDA WIC Nutrition Risk Criteria, Colorado WIC Policy
Procedure/Additional Guidance Assigned nutrition risk factors (NRFs) determine whether a participant is classified as high or low risk.
For participants classified as high risk, schedule a high risk appointment within the required timeframe. At least one HR appointment with the High Risk Counselor is required per certification period, and this appointment must be documented in the participant’s WIC record. If the participant misses their high risk appointment, staff may offer to reschedule. However, scheduling another high risk appointment is not required. A chart review does not meet the requirement for addressing a high risk NRF.
If another (different) high risk NRF is identified after the initial high risk counseling visit, another High Risk Appointment is required to address the new high risk NRF. The High Risk Counselor will determine whether subsequent visits will be with the High Risk Counselor or the Educator. Participants must not be denied supplemental foods for failure to attend an educational activity or for lack of willingness, readiness, or ability to participate in the activity. For additional guidance, refer to Section 2: Nutrition Education Policy. . High Risk Counseling Timeframe Requirements ● Within 30 Days: In most cases, the High Risk Counselor must counsel the high risk participant within 30 days from the date the high risk factor was identified.
● Exceptions to the 30-day rule are: o Within 24 Hours of NRF Assignment: For the nutrition risk factors listed below, the High Risk Counselor must counsel the high risk participant within 24 hours from the time of the high risk NRF assignment. When a contact between the endorser/participant and the High Risk Counselor is not possible within 24 hours, the Educator may issue 1 month of food benefits. The High Risk Counselor must contact the participant by telephone/video call within 7 days, document the high risk contact, and determine if a clinic visit is needed before the next date of food benefit issuance. For example, a participant is consuming alcohol while pregnant, and the High Risk Counselor is not available but calls the participant 1 day later by phone. After talking with the participant, she decides to stop drinking. Using professional judgment, the High Risk Counselor decides to schedule a return clinic visit in 3 months.
✔ NRF 201b Severely Low Hemoglobin/Hematocrit (Child, pregnant woman, breastfeeding woman and non-breastfeeding woman): When a participant’s blood value falls within a range specified in the Standards for Severely Low Hemoglobin-NRF201b-High Risk Condition table and permission: ⮚ Has been granted for WIC to contact the health care provider: Print two Abnormal Blood Work Notices. Give one copy of the Notice to the endorser/participant. On the second Notice, write in the High Risk Counselor's name and contact information and fax or email that Notice to the health care provider within 24 hours. Schedule an appointment with the High Risk Counselor within the next 30 days. ⮚ Has not been granted for WIC to contact the health care provider: Print one Abnormal Blood Work Notice. Give the Notice to the endorser/participant and urge that it be shared with the participant's health care provider. Also, WIC staff must notify the High Risk Counselor of this abnormal blood value within 24 hours.
✔ NRF 135 - Slowed/Faltering Growth Pattern
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services
Revised: 04/01/2026
Page 2 of 3 Infant birth up to 2 weeks of age: Current weight – Excessive weight loss after birth, defined as ≤7% birth weight.
✔ NRF 372A – Alcohol Use Pregnant: Any current alcohol use.
Breastfeeding: ⮚ High Risk Drinking: Routine consumption of ≥8 drinks per week or ≥4 drinks on any day. ⮚ Binge Drinking: Routine consumption of ≥4 drinks within 2 hours.
Note: For non-breastfeeding women, 372A is a low risk NRF.
✔ NRF 372B – Substance Use Pregnant & Breastfeeding: ⮚ Any illegal substance use and/or abuse of prescription medications. ⮚ Any marijuana use in any form.
Non-Breastfeeding Postpartum: ⮚ Any illegal substance use and/or abuse of prescription medications.
Note: 372B is not assignable to non-breastfeeding women who use marijuana.
✔ NRF 602 – Breastfeeding Complications or Potential Complications Breastfeeding woman with any of the following: ⮚ Severe breast engorgement ⮚ Recurrent plugged ducts ⮚ Mastitis ⮚ Flat or inverted nipples ⮚ Cracked, bleeding or severely sore nipples ⮚ Failure of milk to come in by 4 days postpartum ⮚ Tandem nursing ⮚ Age 40 years or older*
*The 24-hour high risk counseling rule applies to all complications or potential complications that comprise NRF 602 except for “age 40 years and older.” This is low risk and does not require a referral to the High Risk Counselor.
✔ NRF 603 – Breastfeeding Complication or Potential Complications: Breastfed infant with any of the following: ⮚ Jaundice ⮚ Weak or ineffective suck ⮚ Difficulty latching onto mother’s breast ⮚ Inadequate stooling (for age, as determined by a physician or other health care professional) or less than 6 wet diapers per day.
Initial (24-hour high risk) counseling for NRFs 602 and 603 can be conducted via phone or in-person, as determined by the clinical judgment of the High Risk Counselor, Designated Breastfeeding Expert (DBE), Educator Advanced Lactation Credentials (CLC, CLE, or IBCLE), or Educator WIC Lactation Specialist (WLS).
If initial (24-hour high risk) counseling is provided by:
High Risk Counselor, DBE, or Educator Advanced Lactation Credentials: ⮚ Document ‘High Risk Follow-up Appointment’ on the Nutrition Education panel and complete the participant’s care plan. ⮚ Provide a phone follow up within two weeks (as best practice). ⮚ Refer a participant to a health care provider when warranted.
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Revised: 04/01/2026
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Educator WLS: ⮚ Document as individual counseling in the participant’s care plan. ⮚ Schedule a high risk follow-up appointment with High Risk Counselor, DBE, or Educator Advanced Lactation Credentials within two weeks of risk assignment. Can be conducted via phone or in- person, as determined by the clinical judgment of the High Risk Counselor, DBE, or Educator Advanced Lactation Credentials. ⮚ Refer participant to a health care provider when warranted.
● Within 90 Days from date of NRF assignment o NRF 113 – Obese Child 2-5 years of age
High Risk Resolved Clicking the High Risk Resolved check box on the Risk panel changes the participant’s risk status from high to low risk. The High Risk Resolved check box may only be selected when a user incorrectly assigns a high risk nutrition risk factor (NRF) to a participant who, in actuality, is low risk. If two or more high risk NRFs have been assigned and one high risk NRF is assigned in error, do not select this check box as the participant’s risk status must remain as high. Only the High Risk Counselor has the authority to check the High Risk Resolved check box.
Colorado WIC Program Policies and Procedures Section 4: Organization and Management Revised: 03/01/2026
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Homeless and Domestic Violence Shelters: Approval and Closure Process
Policy: The State or local agency shall attempt to establish to the extent practicable, that the homeless facility meets the following conditions with respect to resident WIC participants: ● The homeless facility does not accrue financial or in-kind benefit from a person's participation in the Program, e.g., by reducing its expenditures for food service because its residents are receiving WIC foods; ● Foods provided by the WIC Program are not included into a communal food service, but are available exclusively to the WIC participant for whom they were issued; ● The homeless facility places no constraints on the ability of the participant to partake of the supplemental foods, nutrition education and breastfeeding support available under the Program.
The local agency staff shall: ● Contact the homeless facility periodically to ensure continued compliance with these conditions; and ● Request the homeless facility to notify the State or local agency if it ceases to meet any of these conditions.
Regulation: 7 CFR 246.4, 7 CRF 246.7
Procedure/Additional Guidance: Homeless Facility: Any of the following facilities which provide meal service: a publicly supervised or privately operated shelter, including a welfare hotel or congregate shelter, designed to provide temporary living accommodations; a facility that provides a temporary residence for individuals intended to be institutionalized; and a public or private place not designed for, or ordinarily used as, a regular sleeping accommodation for human beings.
Homeless Individuals: A woman, 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) designated to provide temporary living accommodation; 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 for human beings.
Steps for Approving A Shelter The steps for approving a shelter are as follows: 1. Local agency forwards name and address of facility wishing to become a WIC-eligible homeless shelter to the State WIC Office. 2. State Office sends information and an Application for Approval of a Homeless Shelter (WIC #90) to the shelter. 3. Shelter returns the completed form to the State Office. 4. State Office reviews the form for ability and willingness to comply with required eligibility conditions. If the shelter meets criteria, they become provisionally authorized. 5. State Office sends Letter of Agreement signed by State staff with provisional authorization to the shelter. A copy is sent to the local WIC agency to inform staff of the need to visit the shelter. 6. A representative of the local WIC Program visits the shelter within 60 days to conduct an initial orientation visit. This visit will serve as an opportunity for the local WIC Program to become more familiar with the facility, review compliance with the Letter of Agreement, and provide information regarding WIC to the shelter. WIC outreach pamphlets and posters should be distributed and displayed in the shelter. The representative completes the Initial Evaluation of a WIC-Eligible Homeless Facility form (WIC #91). 7. After the orientation visit, the local WIC Program representative returns the completed Initial Evaluation of a WIC Eligible Facility form to the State Office. If the shelter is found to be able to comply, a letter will be sent from the Colorado Department of Public Health & Environment/WIC Program to the shelter and local agency, stating that the shelter is a fully-authorized WIC shelter. 8. A biennial (one time every two years) evaluation by a local WIC representative is required to ensure continued compliance with the Letter of Agreement and to allow an opportunity for further community outreach with the shelter. Shelters may receive an on-site visit or telephone contact at the discretion of the local agency. The
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Biennial Evaluation of WIC-Eligible Homeless Facility form (WIC #94) is to be completed every two years and a copy should be sent to the State Office within thirty (30) days of the evaluation.
Steps for Closing A Shelter The steps for closing a shelter are as follows: 1. Closure: Local agency forwards name and closure information for the facility to the State WIC Office for a facility that has notified them they are closed or plan on closing. 2. Termination: If the local agency has determined the facility is out of compliance based on a biennial evaluation or otherwise, the local agency will notify their assigned Nutrition Consultant. The State WIC Office will then work with the Local agency to make the final determination. 3. A Closure Letter will be sent from the Colorado Department of Public Health & Environment/WIC Program to the shelter and local agency, stating that the shelter is closed or terminated and shall refer all participants using such accommodation to any other accommodations in the area which meet these conditions.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 10/01/2018
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Homeless Applicants
Policy: WIC staff must make every effort to reduce barriers that could prevent homeless people from receiving WIC Program benefits.
Regulations: CFR 246.7 (e)(2)(iv), 7 CFR 246.7 (n)
Procedure/Additional Guideance: Definitions of a homeless family and homeless individual are as follows: Family: A group of related or nonrelated individuals who are living together as one economic unit. Residents of a homeless facility or an institution shall not all be considered members of a single family.
Homeless Individual: A women, infant, or child who lacks a fixed and regular night time residence, or whose primary nighttime residence night is: a supervised publicly or privately operated shelter (including a welfare hotel, a congregate shelter, or a shelter for victims of domestic violence) designated to provide temporary living accommodation; an institution that provides a temporary residence for individuals intended to be institutionalized; a temporary accommodations 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 place for human beings.
Questions must be asked to gain insight as to whether a participant can be defined as homeless when living with another. The following two examples describe different situations:
If the mother and baby have been staying with her sister for 10 months but are sleeping on the living room floor and the brother-in-law is losing patience and demanding that she find a job but she can’t because no one else can watch her baby—she’s probably homeless. If a mother and baby are staying with her sister, have their own room, bring in income from a part-time job, split grocery costs and share child care with the sister—they probably aren’t homeless, no matter how long they’ve been there. It sounds like a fairly fixed arrangement.
Providing WIC Program Services to the Homeless Staff must implement the following procedures to reduce barriers that could prevent homeless persons from receiving WIC Program benefits.
Financial Eligibility o A homeless person may not be excluded from receiving WIC benefits due to an inability to provide proof of financial eligibility. o If the person is living in a shelter or institution, the "family unit" does not include other residents of the shelter. Only the participant or group of related persons shall be counted. o A homeless person who reports zero income or is unable to provide documentation of income may sign a statement of self-declaration of income or a statement of zero income. o A person living in a temporary situation in a shelter or in a friend's home can be considered an economic unit of one; a pregnant woman with her 2-year old child would be an economic unit of three. If after 365 days the participant continues to live in the same home, then the entire household is considered an economic unit and the total household income should be used for WIC eligibility screening.
Residence Eligibility o A homeless person may not be excluded from receiving WIC benefits due to an inability to provide proof of residence. o A homeless person who is unable to provide documentation of residence may sign a statement of self- declaration of their residence.
Certification o Enter a participant's homeless status in the Contact/Address panel in Compass. o Conduct normal screening procedures for certification and assign all applicable nutrition risk factors. At a minimum consider these applicants at nutritional risk solely because of their homeless status.
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o If during certification it becomes known that the individual resides in a shelter, staff must determine if it is a WIC-eligible shelter. o Persons staying at a homeless facility should be enrolled for one full certification period even if the shelter is not a WIC-eligible shelter prior to the date of certification. The agency should determine if the shelter is willing and able to be a WIC-eligible shelter prior to the participant's recertification date. The participant should be advised that he/she would not be able to receive WIC food benefits at the next certification period if the shelter is not willing to be a WIC-eligible shelter.
o Participants who continue to live in a shelter which will not comply with the WIC eligibility conditions can be recertified, but will not be able to receive food benefits with the exception of infant formula. The participant can still receive nutrition education and referral services. The participant should then be given the name of a WIC-eligible shelter in the area so he/she can relocate if they so choose.
Verification of Certification (VOC) o Staff should provide a Verification of Certification (VOC) form at the first participant visit in order to facilitate a homeless individual staying on the WIC Program when he/she moves. o Staff must explain the purpose of the VOC form and request the participant to bring the VOC form to each visit. o The date of food benefits issuance must be noted on the VOC form each time food benefits are given.
Food Benefit Issuance o Information regarding storage, transportation, ability to access the grocery store, and use of specific food items should be asked to help staff determine, in partnership with the participant, what food package would best meet their needs. Provide the maximum food package that will be safe and sanitary. o If the person is living in a shelter, the WIC foods must be kept separate from the facility’s general food supply and be used by the participant only. o Information regarding storage, transportation, ability to access the grocery store, and use of specific food items should be asked when certifying the participant.
Food Package o Colorado WIC regulations allow local agency staff to tailor the WIC food package to accommodate the unique individual needs, circumstances and living situations of homeless participants. o No exemptions or exceptions are allowed from the requirement for medical documentation to support the issuance of exempt infant formulas and WIC-eligible medical foods. o Participants can purchase as many or as few items as desired per shopping trip and have the option to purchase canned or powdered milk instead of fresh milk and canned beans or peanut butter instead of dry beans. o Participants who do not have access to a safe water supply, no refrigeration, or limited storage should be offered options such as juice in individual serving containers and shelf stable (UHT) milk. o If proper refrigeration is not available, eggs and fluid milk, including evaporated, should not be issued to the participant. o Federal regulations allow extra peanut butter or beans to be issued to homeless individuals in lieu of eggs (at the substitution rate of 18 oz peanut butter or 1 pound beans for 1 dozen eggs). o Breastfeeding should be encouraged as the easiest and safest way to feed the infant. Formula-fed infants should be offered powdered formula, mixed one bottle at a time. Ready-to-feed formula may be issued according to Colorado WIC Food Package Tailoring Guidelines.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 10/01/2018
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HOMELESS FOOD PACKAGE GUIDELINES WIC Food Refrigeration, dry storage, and cooking NO refrigeration and NO cooking facilities with dry storage Milk Same as regular food package whereby participant may choose to purchase fluid milk in quarts, half-gallons or gallons, -or- powdered, or evaporated milk Powder or UHT Cheese Substitute for milk - same as regular food package Substitute for milk-same as regular food package Eggs Same as regular food package Substitute peanut butter Juice Same as regular package -or- issue single serving juice Single serving Breakfast cereal and infant cereal Same as regular package Same as regular package Whole grains Same as regular package Same as regular package Peanut butter and beans Same as regular package whereby participant has a choice of peanut butter, dry or canned beans Encourage purchase of peanut butter or canned beans Canned fish Same as regular package Encourage purchase of single serving size cans Fruit & Vegetable voucher Same as regular package Encourage purchase of items that do not require cooking or refrigeration such as apples, oranges, carrots, etc. Formula Powder or liquid conc. or ready-to-feed Powder
Nutrition Education o Nutrition education should focus on the participant's specific needs. o Providing effective and appropriate nutrition education to homeless persons requires that staff have an understanding of the participant's transient lifestyle. o Because a participant may only be enrolled for a short period of time, ongoing, long-term education goals may not be appropriate. o Priority topics for discussion include: How to use the eWIC card. List of WIC-allowable foods. Referral to other services. Use of WIC food with an emphasis on food safety, sanitation, and storage. Fast and easy nutritious snacks. Preparation of foods that require little or no cooking.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 10/01/2018
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o Other information that should be covered with participants who live in a homeless shelter includes the following: WIC benefits are for the participant only. WIC foods cannot be used in community meals. WIC approved facilities cannot prevent WIC participants from receiving WIC foods and nutrition education.
Outreach o Local agencies should include in their outreach plans a procedure for identifying and contacting organizations in their community who work with homeless persons. These organizations should be made aware of the WIC Program.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2025 Page 1 of 2
Households Size
Policy: Local agency WIC staff must assess and document household size for all applicants and participants.
Regulation: 7 CFR 26.7 (d)(2)
Procedures/Additional Guidance Family/Household definition: A family/household is defined as a group of related or non-related individuals who usually (although not necessarily) live together and share economic resources and consumption of goods and/or services. Residents of a homeless facility or an institution are not considered members of a single family. Military personnel living overseas or assigned to a military base, even though they are not living with the family, should be considered members of the economic unit when they are sharing financial resources with the household.
Foster Child, Adopted Child, and Kinship Placement As it relates to WIC eligibility, “foster” children are defined based on who has legal responsibility of the child. o Foster Child: A foster child living with a family but remains the legal responsibility of a welfare or another agency is considered a family of one. The foster child’s income is the amount paid to the foster parent for the child's care. o Adopted Child / Guardianship: When a family adopts a child or accepts legal responsibility for a child, the child is counted as a member of the family. The family's size and total income are used to determine the child's income eligibility for WIC. o Kinship Placement: When a child is placed in kinship care, the legal responsibility of the child can vary: County Legal Responsibility: If the county department retains legal responsibility for the child, the child is considered a foster child and counted as a family of one. Caregiver Legal Responsibility: If the kinship caregiver has legal responsibility for the child, the child is counted as a member of the family. If the child is an infant, their Medicaid can be used to income qualify the household under adjunctive eligibility since the kinship caregiver is responsible for applying for Medicaid. o Documentation Requirements: For foster, kinship, and adoption/guardianship situations, request foster papers or guardianship documentation. Scan and attach these documents to the Compass record. Pregnant woman: An income assessment should be conducted counting a pregnant woman as a household size of one first. If she is over income, then the agency can increase the household size by the number of fetuses in utero with the mother’s permission. Joint custody: A child that lives in more than one home as a result of a joint custody situation shall be considered as part of the household of the parent/guardian who is applying for WIC on behalf of the child. A child may only receive benefits as part of one household or family. Child support: If a family pays child support for a child that does not live with them, the child may NOT be considered as part of the household (unless the child lives in an institution or school). The family also may not deduct the cost of the child support when reporting their gross income to WIC. Child in school/institution: A child who lives in a school or institution, and the child’s support is being paid for by the parent or guardian, the child may be counted in the family size of that parent/guardian. Minor: The final decision of whether a minor is emancipated and thus a separate economic unit for WIC Program purposes is whether or not the minor is living as a separate household without any economic support from any other persons in the household. If the minor receives any support for which she does not pay, such as shelter or meals, she should not be considered a separate household. For example, if the minor has a separate apartment with a kitchen in the family’s home and the minor pays all expenses for her own support; it is possible that the minor may then be considered a separate household. More than one family in a house: When two separate families live under the same roof determining household number is important to determine the economic independence of the family applying for WIC. he
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2025 Page 2 of 2
income they report must be sufficient to cover their living expenses (i.e., food, clothing, and daycare). Financial resources and support must be retained separately. (See related policy in Special Populations section, WIC Program Services to the Homeless.) Temporary living situation: If an individual who meets the definition of homeless is living temporarily in a shelter or friend’s home, he/she can be considered a separate economic unit. If after 365 days the participant continues to live in the same place, then the entire household is considered an economic unit and the total household income should be used for WIC screening. Deployed military service member: Military personnel living overseas or assigned to a military base, even though they are not living with the family, should be considered members of the economic unit when they are sharing financial resources with the household. When a military individual is counted as a member of the economic unit, their income must also be included in the economic unit. Children in Temporary Care of Friends or Relatives: When financial information is known for the child (e.g. child in military family unit) then this information can be used. The child would be considered a part of the original family unit. When the family unit’s financial information is not available and the parent/s send adequate money to the family caring for the child, then the child can be considered a household of one. If there is no financial information available from the parent/s of the child’s previous economic unit and the new family receives little to no financial support to provide care for the child, then the child is considered part of the economic unit where the child now lives.
Examples: A pregnant woman and her one child live with the woman’s boyfriend and his two children. They share food, utility, and rental expenses. The woman has a job and receives child support for her child. The boyfriend has a job. In this case, the economic unit is 5.Income for both adults plus the child support must be included in the income determination. If the family is over income, then the agency can increase the household size by the number of fetuses in utero with the mother’s permission. A woman who is not categorically eligible for WIC lives in a house with her two children (one applying for WIC), and the grandmother. The woman is employed and the grandmother receives social security. They share food and other expenses. The economic unit is 4. The woman’s income plus the grandmother’s social security need to be included in the income determination. A pregnant woman lives with her parents and her younger sister. The pregnant woman is unemployed. Both parents are employed as is the younger sister. The parents provide for all expenses except that the younger sister contributes money for groceries. The economic unit is 4. The income of both parents and the sister need to be included in the income determination. If the family is over income, then the agency can increase the household size by the number of fetuses in utero with the mother’s permission. A pregnant woman and her daughter live in the woman’s parent’s house. The pregnant woman is employed and provides the food, clothing, and other living expenses for herself and her daughter. The parents do not provide any money, and do not share income or food with their daughter or her child. The economic unit is 2 (pregnant woman counts as 2). Only the pregnant woman’s income needs to be considered in the income determination. Even though the parents provide “housing” this is not considered income, but is considered an “in-kind” benefit. If the family is over income, then the agency can increase the household size by the number of fetuses in utero with the mother’s permission.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 7/01/2026 Page 1 of 1
Income Guidelines
Policy: In order to financially qualify for the WIC Program, a participant’s combined household gross income cannot exceed the WIC Income Eligibility Guidelines (IEG). The WIC IEGs are 185% of the Federal Poverty Guidelines published in the Federal Register.
WIC INCOME ELIGIBILITY GUIDELINES Effective July 1, 2026 – June 30, 2027
NOTE: An income assessment should be conducted counting a pregnant woman as a household size of one first. If she is over income, then the agency can increase the household size by the number of fetuses in utero.
Regulation: 7 CFR 246.7 (d)(1)
Procedure/Additional Guidance: Use the following steps to calculate gross income. Compass calculations follow these same steps. 1. If a household has only one income source or if all income sources have the same frequency, compare the income, or the sum of the separate incomes, to the published IEGs for the appropriate frequency and household size. 2. A pay stub for each income source is needed. If pay is consistent, only one pay stub per income source for the past 30 days is required. 3. If a household reports income sources at more than one frequency, perform the following calculations: ● Annualize all income by multiplying weekly income by 52, income received every two weeks by 26, income received twice a month by 24, and income received monthly by 12. ● Do not round the values resulting from each conversion. ● Add together all the unrounded, converted values. ● Compare the total to the annual income for the appropriate household size to determine income eligibility.
HOUSEHOLD SIZE* GROSS INCOME YEARLY MONTHLY TWICE- MONTHLY BI-WEEKLY WEEKLY 1 $29,526 $2,461 $1,231 $1,136 $568 2 $40,034 $3,337 $1,669 $1,540 $770 3 $50,542 $4,212 $2,106 $1,944 $972 4 $61,050 $5,088 $2,544 $2,349 $1,175 5 $71,558 $5,964 $2,982 $2,753 $1,377 6 $82,066 $6,839 $3,420 $3,157 $1,579 7 $92,574 $7,715 $3,858 $3,561 $1,781 8 $103,082 $8,591 $4,296 $3,965 $1,983 For each additional family member, add: +$10,508 +$876 +$438 +$405 +$203
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026 Page 1 of 3
Ineligible Applicants and Participant Terminations
Policy: When applicants applying for the program are found ineligible for WIC they must receive the Notice of Ineligibility printout from Compass unless the screening is done over the phone.
When a participant is determined not to be eligible for WIC during their certification period, they must receive 15 days of food benefits and the Notice of Termination printout from Compass regardless if eligibility determination was done in person or over the phone. If benefits expire less than 15 days in the future, staff must issue the next month of benefits to ensure a 15-day notification period. If the benefits expire in more than 15 days in the future (redeemed or not), food benefits for the current month should be issued. 1) The following are exceptions to giving 15 day’s worth of benefits: ● When 90 days (three months) or less remains in the certification period, the remainder of the food benefits may be issued through the current certification period. ● If the participant is terminated for one of the reasons below, the participant receives no additional food benefits. ▪ No recent food benefit pick up (not available for staff selection). ▪ Deceased. ▪ Dual Participation with WIC. ▪ Program Misuse for reason of intentionally misrepresenting circumstances to obtain benefits, and not eligible for the program. ▪ No longer in family. ▪ No BF 6 months postpartum.
Regulation: 7 CFR 246.7(h), 7 CFR 246.7(i)
Procedure/Additional Guidance: WIC Applicants ● Over the Phone: If an applicant is screened over the phone for WIC eligibility and they are determined not to be eligible, explain eligibility to the applicant however a Notice of Ineligibility is not required. ● Certification: If an applicant is determined income ineligible on the Income Determination panel during the Certification visit, staff must check the Action box to move the applicant from a Pending status to an Ineligible status. An applicant found over income at the certification visit may not receive WIC benefits. o Print the Notice of Ineligibility and give it to the applicant (in-person or by mail).
WIC Participant Termination Reasons Participants may be terminated during their certification for the following staff assigned termination reasons: ● Terminate Postpartum/BF - Recert as Pregnant. ● Terminate Postpartum/BF – Recert as Postpartum/BF. ● Terminate Postpartum/non-BF – Recert as BF. ● Terminate Pregnant – Recert as non-BF/BF. ● Terminate Pregnant – Recert as Pregnant. ● Recertify Active VOC. ● Not BF 6 months postpartum. ● Program misuse. ● Remove from waiting list. ● Not serving priority. ● Voluntary Withdraw. ● Autoterm. ● Moved Out of State. ● No Longer in Family. ● Over Income.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026 Page 2 of 3
WIC Participant Terminations and the Notice of Termination When a participant is found over income at: ● Recertification: A participant found over income at a recertification visit may receive benefits through the previous certification period. ● Mid-Certification: A participant found over income at a mid-certification visit should be provided with enough food benefits to ensure the participant receives the 15-day notice of ineligibility, unless there are 90 days (3 months) or less until the end of the certification period, then the remainder of food benefits can be issued. o If an Active participant is determined income ineligible on the Income Determination panel, staff must issue any required food benefits (depending on where they are in the certification period) first, then return to the Income panel and click the “Check Income Eligibility” button. Then, staff must check the Action box. Note: If one member of a family or economic unit is found to be income ineligible for WIC during a certification/recertification then the entire family is income ineligible.
A Notice of Termination form can be found under Printouts menu in Compass and must be given to the participant (either in person or mailed). Client Voluntary Withdrawal Due to Reported Ineligibility In some cases, participants may notify WIC that they believe they are no longer income-eligible or adjunctively eligible. Staff should use the following guidance: ● Inform the participant in writing 15 days before being suspended or disqualified and provide them WIC income guidelines and advise them to submit proof of income for re-determination if they wish to continue participation.Such notification shall include the reasons for this action, and the participants right to a fair hearing. ● It is the participant’s responsibility to provide proofs if they are interested in remaining on the program. ● If no proofs are submitted, staff must terminate the participant under the reason “Voluntary Withdrawal.” Per policy, staff must issue any required benefits and provide the Notice of Termination. ● If the participant later submits proof of income showing eligibility, staff may reinstate the participant as long as it is still within their certification period.
A Notice of Program Termination form does not need to be issued for: ● Participants who have reached their Certification End Date (as this is noted on the Family Food Benefits List) ● Participants who are being recertified as a different category. ● Participants automatically terminated by Compass. These reasons include: o Failure to Provide Proof. o No Recent Food Benefit Pick-up (occurs when participant has not picked up > 1 month worth of benefits). o Failure to Reapply (after certification has expired). o BF 1 Year Postpartum. o Child’s 5th Birthday. o No BF 6 months postpartum. ● Deceased individuals. ● Individuals who are no longer part of a family and are not transferring to another WIC family. ● Participants moving out of state.
Reinstatement A participant who has been terminated by Compass (for example, No food benefit pickup) may be reinstated if they have not reached their Certification End Date. However, when their Certification End Date has passed, the participant must be recertified in order to receive benefits.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026 Page 3 of 3
Once the participant reaches their Certification End Date, Compass sets their WIC status to Terminated. To recertify, access the Application panel and create a new application. WIC status changes to Pending and staff may proceed with the recertification.
Categorical Ineligibility And Food Benefits Applicants/Participants who do not meet the definition of pregnant, postpartum, or breastfeeding women, infants and children are categorically ineligible for the Program. ● A child receives WIC Program benefits through the last day of the month of their fifth birthday. ● A breastfeeding woman receives WIC Program benefits until: o The last day of the month her breastfed infant turns one year old. o 0-6 months postpartum: She stops breastfeeding and is within 6 months after delivery shall be reclassified as a postpartum woman and receive postpartum food benefits from that date until the end of her certification period (not to exceed 6 months postpartum). o 6-12 months postpartum: A woman who stops breastfeeding more than 6 months after delivery is eligible to receive 15 days of food benefits starting the day she reports she is no longer breastfeeding. ● A non-breastfeeding postpartum woman receives WIC Program benefits for 6 months postpartum (after delivery).
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2022
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Intrastate Dual Participation
Policy: All clinics must run the intrastate dual participation monthly and resolve those listed on the record as possible dual participants.
Regulations: 7 CFR 246.7 (l)
Procedure/Additional Guidance: Intrastate dual participation is assessed using the Intrastate Dual Participation function in the Operations functional area of Compass. A clinic supervisor or designated WIC staff member should run this report at the end of each month. WIC staff must verify in Compass whether each possible dual participant in that clinic is actually dual participating. When another WIC clinic is involved, communication between clinics may need to occur in order to resolve the potential dual participation.
Note: When a person is added to Compass, an immediate dual participant search is conducted by the system on the Dual Participation pop-up. If any names show up in the list indicating possible duals, staff are required to determine whether the person is enrolled in another clinic. If the person is enrolled in another clinic, staff must discontinue adding the person by clicking the “Back” button in the Dual Participation pop-up and then the “Delete” button on the Member/Proxy pop-up. Once this is complete, staff must perform a search to find the participant’s record, and then a transfer the participant into the clinic by accessing the Transfer panel.
Using Compass to verify dual participation: Access the Intrastate Dual Participation panel in Operations. Click Unresolved in the View section of the panel. Enter the correct agency and clinic name in the drop down lists. Click Get Data to populate a list of possible intrastate dual participants.
Not the Same Person (No Dual Participation or Duplicate Record) When it is determined that the two records are not the same person, the matching record must be resolved. This is done by marking the “Resolved” checkbox and selecting “No Dual – Different Person” option in the Reason drop down list. Staff may also enter additional clarifying information (i.e., “twins”) in the “comment” field.
True Dual Participation When a participant is truly a dual participant,defined as enrolled in two or more WIC programs and received benefits from both during the same month for the same participant, WIC staff must follow the procedures outlined in the Section 8: Participant Violations policy. Staff must counsel the participant on the illegality of dual participation and apply the required sanctions.
Duplicate records for the same participant In the process of running the Intrastate Dual Participation function, existing duplicate records for the same participant may be discovered. These records can be two or more records within the same clinic or in different agencies. Follow the instructions below to merge duplicate records.
Instructions for Tracking and Merging Duplicate Records Assign one person from each clinic to track all duplicate records.
Download the Dual Participant Record Spreadsheet Enter the following information in the Dual Participant Record Spreadsheet: Clinic Name, Clinic contact, Contact Information, Participant Name, Participant ID (PID) Not to Use, Family ID (FID) Not to Use, Family ID to Keep, Date Resolved. Communicate to all clinic staff which Compass record will be used and which record will not be used. DO NOT edit any participant or family information in Compass. This includes not changing names, adding letters or words before the last name, etc. DO NOT change the status of the participant. Navigate to the Intrastate Dual Participation panel in Compass and mark the “Resolved” checkbox. Select “Dual - No Double Benefits Provided” in the Reason drop down box. Record in the Comments field the Family ID Number (FID) that will not be used.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2022
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Check the “Do not allow food benefits” box in the Participant Violations Panel of the participant whose record will not be used. Remove the check mark after the records have been merged. Send all typed spreadsheets electronically to the Compass Care Team through Elementool. DO NOT send in hand-written spreadsheets. The Compass Care Team will research each duplicate record and make appropriate changes.
Colorado WIC Program Policies and Procedures Section 3: MIS Revison Date: 10/01/2018
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Issue Resolution at the State WIC Help Desk
Policy: Report all suspected Compass application issues and data integrity issues to the State WIC Compass Help Desk.
Regulation: Colorado WIC Policy
Procedure/Additional Guidance: Computer, Network and Internet Issues Compass is a web-based system that relies on local area networks and Internet connectivity that is created and maintained by county IT departments. Therefore, some problems must be resolved by the county or local agency IT staff.
When a local agency WIC user encounters a network, computer equipment malfunction, computer login or Internet problem, please contact the local agency IT unit as the first level of support. The local IT unit should be able to solve most reported problems. If the local agency IT determines that additional state support is required to resolve an issue, have a technical person contact the State WIC Compass help desk for level II support.
Compass Application Issues The WIC Compass Help Desk will investigate the system concern and if they determine that an application error might exist, the Help Desk will create a ticket and the issue will then be reviewed and resolved. The fix will be included in a future release of a new Compass version. If the State WIC Compass Help Desk determines that the application is working correctly, they will provide the local agency or staff person with an explanation and possible written system documentation on the application behavior. As a final step, the State WIC Compass Help Desk may escalate the ticket to the local agency assigned Nutrition Consultant or Compass Training Coordinator if it appears that the problem is a matter of training or policy. The State WIC Help Desk may send it to Level 2 Technical Support if the problem appears to be of a more complex technical nature.
Data Issues The Help Desk will investigate the concern and if they determine that a data integrity issue may exist, they will immediately escalate the issue to the State Database Administrator for further investigation and resolution.
Colorado WIC Program Policies and Procedures Section 11: Civil Rights Revised: 01/01/2020
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Limited English Proficiency
Policy: Local agencies must ensure that interpretative services are available for participants with limited English proficiency.
Regulations: 7 CFR 246.7, FNS Instruction 113-1
Procedure/Additional Guidance: Local agencies must have a plan in place to communicate and provide services in the languages spoken in the service area. This plan should include items such as: Use of bilingual staff. Contracting with interpreting services, including in-person or telephone interpretative services. o Local agencies cannot require applicants or participants to provide their own interpreters. o If a client choose to bring a family member or friend to interpret, this may be allowed as long as it is a responsible individual. o A child should not be used as an interpreter. Translated documents and forms. o All outreach and screening materials and most nutrition education materials generated through the State WIC Office are available in both English and Spanish. The Rights and Responsibilities and Colorado WIC Food List and Shopping Guide are also available in Arabic, Burmese, Nepali and Somali. o For materials and resources needed to serve other non-English speaking populations, contact the agency’s assigned State Office Nutrition Consultant. Use of technology and internet based tools. Training of staff in the use of resources available to serve LEP individuals.
Local agencies must record the client’s preferred spoken language in Compass in the “Family/Intake” screen in the “family” section. All commonly spoken languages in Colorado are listed on the drop down menu. Contact the state office if additional language options are needed. Unless the client is proficient in English, staff should select the native or preferred language of the client to help with statistical reporting of languages spoken in the service area. Indication can also be made on this screen if an interpreter is needed for the appointment by checking the check box. This code helps to alert the appointment scheduler of any special needs that must be considered for this family, which might include an interpreter, whether in person or via telephone. Set the printout language to English or Spanish to ensure the correct language for printed notices and appointment reminder texts.
Colorado WIC Program Policies and Procedures Section 4: Organization and Management
Revised: 01/01/2024
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Local Agency WIC Equipment and Inventory
Policy: Local Agencies shall purchase and maintain appropriate equipment to operate the Compass computer system.
Regulation: Office of Management and Budget Circular A-130, State Agecny and FNS Guidelines and instructions
Procedure/Additional Guidance: Computers Based on a predetermined schedule,the State office will allocate additional funding to elegible local agencies through a comtract amendment process for the purchase of new destop and laptop computers. The notification regarding eleigibility will be sent to the agencies prior ot the actual contract amendment. Local Agencies should work with their local IT department and collaborate on the specific needs required for WIC computers. Some specifics to be sure of before making computer purchases are: Compatibility with Compaass: The new computers should be compatible with Windows 10, as Compass operates using this operating system. Scanning Documents: When purchasing 64-bit computers, scanning documents within Compass requires a work around. Agencies need to scan the documents as black & white TIFF or JPEG files outside of Compass first andthen attach the files to Compass. Anti-virus Software: It is recommended to use either McAfee or Norton for anti-virus software to ensure the security of the sytems. Sufficient USB Ports: The new computers should have an adequate number of USB ports to acocomodate various periperhrals, such as mice, keyboards, signature pads, and magnetic stripe card readers.
The Local Agency WIC Program are instructed to follow their local agency policy when disposing of any computers and/or computer equipment.
All contract funds, including the computer funding, must be expended by the end of the current fiscal year. Unspent funds will not roll to the next fiscal year.
Multi-Function Printers The responsibility for the purchase of a multi-function printers lies with the local agency, if it is needed.
Magnetic stripe card reader The responsibility for the purchase of a strip card reader lies with the local agency, if it is needed.
Compass, the system used for WIC operations, requires the card reader device to present the card data as keyboard input. Therefore, a standard magnetic card reader device, such as one fo the USB-connected Magtek readers, will work seamlessly with Compass.
When considering which magnetic stripe card reader to purchase, the local agency must pay attention to the following critical specifications: 1. Card Format Compatibility: The card reader must be capable of reading ANSI/ISO/AAMVA car formats, ensuring that it can handle the standard formumats used for identification cards. 2. Keyboard Emulation Interface: The reader must provide a keyboard emulation interface, which means that when a card is swiped, the data from the card wil be transmitted to the computer as if it were being typed on a deyboard. Ths allows Compass to receive the card data and process it accordingly.
By selecting a magnetic stripe card reader that meets these specifications, the local agency can ensure seamless integration with Compass and smooth processing of card data for eQIC purposes.
Topaz Signature Pads The responsibility for the purchase of a Topaz Signature Pad lies with the local agency, if it is needed. The specific specifications for the signature pads and pens are as follows:
Colorado WIC Program Policies and Procedures Section 4: Organization and Management
Revised: 01/01/2024
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1. Topaz T-L755 Signature Gem LCD 4x3 pad (#T-LBK755-BHSB-R): This model is the Topaz Signature Gem LCD 4s3 pad. The model number is T-LBK755-BHSB-R 2. Topaz Signature Gem Series Replacement Pen (#P=ET110-HN): This is the replacement pen designed for the Topaz Signature Gem Series. The model number for the pen is P-ET110-HN
When purchasing these signature pads and pens, the local agency should ensure that they match the specified models to ensure compatibility with the system and smotth operation for capturing signatures electronically.
Inventory Local agencies that use WIC funds to purchase computer equipment, computer peripherals, television equipment and television should maintain a written equipment record for their records according to the Local Agency guidance.
Colorado WIC Program Policies and Procedures
Section 10: Monitoring and Audits Revised: 01.01.2023
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Local Agency Monitoring Visits
Policy: The State WIC Office will conduct onsite monitoring reviews of at least 20% of a Local Agency’s clinics every other year to assure program operations are carried out in compliance with federal and state requirements.
Local WIC agencies will establish self-evaluation procedures to review their own operations and those of associated clinics and/or contractors at least every other year by the completion of the Colorado WIC Program Administrative Monitoring Form.
Regulation: 7 CFR 246.19(b)(1-6)
Procedure/Additional Guidance
Monitoring Visits: The process used to evaluate all aspects of the local agency WIC Program including program management, nutrition education, participant services, civil rights compliance, accountability, retailer participation, and food delivery. USDA regulations require the State agency to establish an ongoing management evaluation system which includes monitoring of local agency operations, the review of local agency financial and participation reports, the development of corrective action plans to resolve Program deficiencies, the monitoring of the implementation of corrective action plans, and on-site visits. The State agency may conduct additional on-site reviews as the State agency determines to be necessary.
Site Visits: A site visit is an informal meeting between State and local agency staff at the local agency. State Office budget permitting, each local agency, and representative clinics within that agency, receives a site visit during the year the local agency is not being formally monitored. The purpose of a site visit is to: Review unresolved problems or concerns from previous monitoring. Train local agency staff. Provide appropriate assistance to ensure continued compliance with Federal and State program requirements. Accomplish administration planning. Prepare local staff for future State initiatives. Assist with local agency nutrition education planning. Answer questions from local agency staff.
Local Agency Self-Monitoring: The process by which the local agency examines and evaluates its WIC Program operations prior to the monitoring visit in order to identify strengths and problems. The Colorado WIC Program Administrative Monitoring Form is the basis for local agency self-monitoring as well as use of the other monitoring forms throughout the year.
Monitoring Forms Colorado WIC Program Administrative Monitoring Form (AMF) Colorado WIC Program Clinic Observation form WIC Participant Record Review form Education Contact/Referrals Review form Pump/Signature Capture/PAF Review form Colorado WIC Program Local Agency Monitoring and Site Visit Action Plan Local Agency Breastfeeding Peer Counselor (BF PC) Program Summary Form
Forms are available on the Colorado WIC website.
Monitoring Visit Activities: The entire clinic staff is encouraged to participate in the monitoring experience including the visit itself and the pre- and post-monitoring activities. During the in-depth monitoring, all aspects of program operation are thoroughly reviewed.
Colorado WIC Program Policies and Procedures
Section 10: Monitoring and Audits Revised: 01.01.2023
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For new agencies, in operation six months or less by the end of the current fiscal year, the first in-depth monitoring occurs the following fiscal year. Both agencies are responsible for the following procedures:
Pre-Visit Monitoring Procedures The State Office Nutrition Consultant (NC) notifies the Local Agency WIC Director/Manager (Director/Manager) approximately 30 days in advance to establish the date(s) for monitoring. NC confirms the date(s) in writing and sends/emails it along with the Colorado WIC Program Administrative Monitoring Form (AMF) to the Director/Manager. Director/Manager completes the AMF. Once completed, the Director/Manager retains a copy of the AMF and emails a copy to NC who reviews the AMF prior to the monitoring visit. NC will review and evaluate participant records at the State Office prior to the on-site visit. The number reviewed is based on participant caseload. Potential categories for review include: o An infant. o A child. o A pregnant woman. o A breastfeeding woman. o A non-breastfeeding, postpartum woman. o A participant who has terminated from the Program. o A participant identified as high risk. o An infant or child receiving a special formula.
On-site Monitoring Procedures On the day(s) of monitoring, the appropriate local agency WIC staff members and Director/Manager join NC in an entrance meeting to discuss the process and significance of monitoring. NC observes the clinic in operation, sits with staff during appointments, reviews participant records, administrative files, and other pertinent documentation. At least one local agency staff member should be available to answer questions that arise. NC observes the following types of clinic operations: o Participant certification process o Initial explanation of WIC o Anthropometric and hematologic measurement techniques and equipment o Health and nutrition assessment o Food benefit issuance o Nutrition counseling of low and high-risk participants o Referrals to other health or social service programs o Clinic facilities
Local agency staff and the NC review the following administrative and participant service procedures: o Food delivery and vendor relations. o Documentation of nutrition services. o Staff and participant nutrition education. o Quality and continuity of nutrition services to participants. o Food package issuance and tailoring. o Administrative procedures, including clinic accessibility hours and staffing pattern. o Program outreach and referrals. o Civil Rights complaints. o Breast Pump Loan Program. o Staff training requirements.
Colorado WIC Program Policies and Procedures Section 10: Monitoring and Audits Revised: 1/01/2023
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Appropriate local agency staff, the Director/Manager and the NC participate in a closing meeting where results of the monitoring visit and subsequent recommendations are shared. Agency strengths and problems identified during the monitoring process are discussed and, where appropriate, a plan, including timeframe, is developed for the resolution of problems.
Post-Visit Monitoring Procedures Within 30 days after the monitoring visit, NC sends the final monitoring report to Director/Manager. The report includes the Local Agency Monitoring and Site Visit Action Plan, Monitoring Visit Cover Letter, the final AMF, and the Clinic Observation Forms, Participant Record Review, Education Contact/Referrals Review and Pump/Signature Capture/PAF Review forms completed during the visit. Within 30 days after receiving the final monitoring report, the Director/Manager completes the agency response section of the Local Agency Monitoring and Site Visit Action Plan and emails/faxes it to NC. NC reviews the local agency's response and follows up as appropriate. This either includes a second visit or a follow-up telephone call to the Director/Manager within ninety (90) days to 6 months of monitoring visit.
Colorado WIC Program Policies and Procedures Section 5: NSA Expenditures Revison Date: 10/01/2018 Page 1 of 1
Local Agency Time Study
Policy: All WIC staff at the state agency and local agencies will maintain time logs/studies. Time Study reports are due by the 20th of the month following the period and are dependent on whether the Agency reports 1 week per month or 1 month per quarter.
Regulation: 7 CFR 246.17, USDA Memo 9/30/92—Addendum to WIC Program Annual Closeout Report
Procedure/Additional Guidance: The purpose of the time study is to document, through the use of staff time logs, the expenditure of at least 1/6 of Colorado WIC's administrative budget for nutrition education, the expenditure of allocated funds for breastfeeding promotion, and the amount of time spent providing client services and general administration.
Scope of Study All WIC staff at the state agency and local agencies will maintain time logs.
Duration of Data Collected At local agencies, staff will maintain daily time logs for one full work week (five days) per month or for one full month per quarter. State staff members are required to document daily time and effort. Therefore, costs for State staff will be based on actual time.
Date Collection Instrument and Reporting Time logs will be filled in by the worker after each activity. The activity axis will include listings of nutrition education, breastfeeding promotion, client services, and general administration activities performed by WIC staff. Local agencies will provide a report listing the percentage of time spent in each activity for each WIC staff with the Contract Reimbursement Statement.
Colorado WIC Program Policies and Procedures Section 4: Organization and Management Revised: 03/01/2026
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Local Staffing
Policy: Local WIC programs are required to have specific staff to carry out identified program functions and roles to ensure that local agencies are able to meet all program requirements and functions defined by federal regulations and state policy.
Regulation: CFR 246.11 c (7) (ii), CFR 246.2, CFR 246.6 b (2), USDA FNS WIC Nutrition Services Standards, FNS WIC Breastfeeding Curriculum: Peer Counselor Management
Procedure/Additional Guidance Staffing for the local WIC clinic includes the following positions/roles. Some staff may be in more than one position/role. ● Local Agency WIC Director ● Regional WIC Local Agency Director ● WIC High Risk Counselor (RD/RN) ● WIC Educator ● Local Agency Retail Coordinator ● Local Agency Outreach Coordinator ● Local Agency Breastfeeding Coordinator ● Lactation Management Specialist ● Educator WIC Lactation Specialist/Educator Advanced Lactation Credentials ● High Risk Counselor WIC Lactation Specialist/High Risk Counselor Advanced Lactation ● Designated Breastfeeding Expert ● Designated Breastfeeding Expert IBCLC ● Breastfeeding Peer Counselor Program Coordinator ● Breastfeeding Peer Counselor ● Breastfeeding Peer Counselor Lactation Management Specialist ● Non-WIC Staff with WIC Duties ● Volunteers
Local Agency WIC Director Local Agency (LA) WIC Director performs professional administrative and supervisory work in the planning, development, implementation and evaluation of the WIC Program. Oversees and coordinates the WIC activities of all clinic sites to ensure compliance with federal and state regulations. In large agencies, many of the duties described in this role may be delegated to other staff members. However, the ultimate responsibility for each duty falls on the WIC Director. In small agencies, the WIC Director and the WIC High Risk Counselor may be the same individual. The LA WIC Director works under the supervision of the agency's health officer or a designated high-level administrator. The LA WIC Director has line authority over subordinate professional and paraprofessional staff involved in the WIC Program.
Best practice is a dedicated 0.8 to 1.0 full-time equivalent (FTE) for this role.
Qualifications ● Education and Registration/License: The WIC Director must be a Registered Dietitian (RD) with the Commission on Dietetic Registration, a Registered Nurse (RN with a Bachelor’s Degree) licensed to practice in the State of Colorado, or a Medical Doctor (MD). Because WIC is a nutrition program, the position of WIC Director is ideally held by a Registered Dietitian. Note: In addition to the licensure requirements, a Bachelor’s Degree is the minimum education level required for this position. Preference is given to those who have a Master of Science (MS) or Master of Public Health (MPH) degree. ● Experience: Experience in public health or ambulatory care settings is preferred. A minimum of one-year experience in a public health setting or one year in a hospital setting is acceptable for consideration.
Knowledge, Skills and Abilities
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A fully functioning WIC Director should possess the knowledge, skills, and abilities listed below. In hiring for this position, supervisors should look for persons who possess most of these skills: ● Knowledge of human nutrition in health and nutrition needs for disease and its application to public health practices. Knowledge of nutrition needs for infants, children and women during the prenatal, postpartum, and breastfeeding stages. ● Knowledge of training, supervision, counseling, and educational concepts and methods. ● Ability to communicate effectively orally and in writing. ● Ability to manage Program operations and carry out Program planning functions; ability to formulate plans, policies, and procedures. ● Ability to organize, prepare, and analyze reports. ● Ability to establish and maintain effective working relationships. ● Ability to promote breastfeeding as the optimal infant feeding choice while allowing participant choice. ● Ability to supervise and direct professional and paraprofessional staff. ● Ability to develop forms and educational materials.
Responsibilities/Duties ● Completes the Colorado WIC New Employee Training program within the timelines defined. Manages overall WIC clinic operations: ● Formulates plans (including nutrition education plans), policies, standards, and procedures for the operation of the agency WIC Program within state and federal guidelines. ● Understands state and federal rules and regulations and follows up on agency deficiencies. ● Interprets and makes arrangements for implementation of federal and state regulations and policies. ● Evaluates implementation of new policies. ● Manages caseload and spending levels to meet appropriations by the State Office. ● Develops and makes recommendations for WIC budget proposals. Contacts State WIC fiscal officer and/or nutrition consultant regarding fiscal concerns/issues. ● Oversees, coordinates, and manages prescreening and waiting lists. ● Completes all forms/reports as requested by State WIC staff for monitoring and site visits; attends monitoring and site visit sessions; follows up on all monitoring findings and submits a timely response to the State Office. ● Ensures required retail monitoring and vendor training is done and that retailer monitoring reports are completed; works with retailers to prevent or correct problems. Ensures retailer contacts are documented in retailer files, and retailer misuse is documented in participant electronic charts. Ensures the State Retailer Coordinator is contacted with vendor problems/issues. ● Evaluates services to participants including clinic flow, use of staff time, clinic access, phone coverage, clinic space, and community needs. ● Provides the State Office with immediate feedback on adverse consequences of State policies or if policies are not understood. ● Ensures consistency among clinics in technical procedures and use of forms. Makes regular visits to all decentralized clinics to oversee operations. ● Oversees maintenance of equipment and testing for accuracy at all clinic sites. ● Maintains participant confidentiality and ensures that participants are treated equally and with respect, compassion, and empathy. ● Informs the State Office of major changes (i.e., staff, address, telephone, clinic hours which affect services). ● Participates in continuing education activities; attends meetings, conferences, and workshops; keeps abreast of current nutrition research as it relates to the WIC Program and participants. Registered dietitians must maintain registration with the required 75 credit hours per five-year period. ● Runs appropriate reports to verify food benefit issuance and redemption, processing standards, caseload management, etc. ● Contacts nutrition consultant with questions concerning caseload, management reports, clinic flow, State policies, equipment needs, nutrition education, staffing, and monitoring visits. ● Maintains a basic working knowledge regarding the Compass computer system and how it operates. ● Complies with the state WIC office regarding security, operations and functions of the Compass system. ● Ensures that administration areas of Compass are updated: referrals, pamphlets, Master Schedule, etc. ● Acts as LA Breastfeeding Coordinator (unless other staff is appointed).
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● Completes the WIC Lactation Specialist (WLS) Training to become WLS certified during the next WLS certification window ● Oversees breast pump loan program. ● Oversees Breastfeeding Peer Counseling (BFPC) Program (if applicable). ● Ensures staff is well trained. o Recruits, interviews, and recommends individuals for hire. o Oversees or conducts the orientation, training, and evaluation of newly hired WIC personnel. ✔ Ensures new staff complete Level I, II and III of the Colorado WIC New Employee Training Program as outlined by the state office. ✔ Observes staff interaction during appointments, including performing thorough nutrition assessments and providing nutrition information and counseling participants. o Defines staff roles and responsibilities, evaluates participant/staff ratios and staff needs. o Supervises WIC staff including annual performance evaluations, ongoing coaching and feedback. o Ensures continuing education opportunities for staff, including at least two sessions per year devoted to nutrition education. o Holds regular staff meetings to provide and enhance communication, to provide updates on policy and procedures, and provide staff training. Monthly staff meetings are optimal; however, small agencies may need bi-monthly or quarterly meetings. o Ensures quality nutrition education services to participants. o Develops or adapts and implements protocols of nutrition care. o Ensures staff members are trained in protocols. o Ensures that a WIC High Risk Counselor is available and trained to provide high risk education contacts. o Defines high risk for the agency (ensuring the State defined minimum definitions of high risk are covered); ensures WIC Educators know how to make appropriate referrals of high risk participants to the WIC High Risk Counselor. o Observes counseling skills of all staff members to ensure that accurate and appropriate information is being disseminated and that counseling skills are adequate. Trains staff in areas where improvement is needed. o Ensures that the documentation in participant electronic chart meets the required criteria listed in the WIC Program Manual. o Reviews, selects, or develops nutrition education materials as needed. o Attends and ensures that all staff members attend State sponsored WIC training. Attends and ensures that all staff members attend required State sponsored WIC trainings. o Recommends and registers staff for the WLS training (including suggesting staff take training as a refresher if staff completed the WLS training more than 5 years prior). o Oversees the implementation of Program nutrition objectives, participates in the nutrition education planning process via State Office guidance, and ensures that nutrition education and data collection conforms to standardized and accepted practices. ● Coordinates activities with other community services. o Arranges outreach and publicity for the agency WIC Program. o Develops formal referral relationships with pediatric and obstetric health caregivers. o Acts as a liaison to the community regarding WIC services, policies, and/or nutrition issues (e.g., informing and updating health care providers, social service agencies, assessing community needs). o Coordinates and assists staff to be familiar with community resources and services when referring WIC participants.
Partnership WIC Local Agency Director Partnership WIC Local Agency Director (PWLAD) performs professional administrative and supervisory work in the planning, development, implementation and elevation of the WIC program. Oversees and coordinates the WIC activities of multiple agencies/counties and clinic “satellite” sites to ensure compliance with federal and state regulations. The PWLAD may delegate some of the duties described in this role; however, the ultimate responsibility for each duty and all contract requirements falls on the PWLAD. The PWLAD works under supervision of the agency’s health officer or a designated high-level administrator and has line authority over subordinate professional and paraprofessional staff involved in the WIC program at all sites in the region. Roles related to the human resource management of staff at satellite agencies may remain a responsibility of that agency, depending on the structure and agreement between agencies and approved by the state authority.
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Best practice is a dedicated 0.8 to 1.0 full-time equivalent (FTE) for this role.
Qualifications ● Education and Registration/License: The WIC Director must be a Registered Dietitian (RD) with the Commission on Dietetic Registration, a Registered Nurse (RN with a Bachelor’s Degree) licensed to practice in the State of Colorado, or a Medical Doctor (MD). Because WIC is a nutrition program, the position of WIC Director is ideally held by a Registered Dietitian. Note: In addition to the licensure requirements, a Bachelor’s Degree is the minimum education level required for this position. Preference is given to those who have a Master of Science (MS) or Master of Public Health (MPH) degree. ● Experience: Minimum of five years’ experience in a public health setting is preferred. Minimum of two years’ WIC experience is required.
Knowledge, Skills, Abilities All knowledge, skills, and abilities included in the LA WIC Director description, plus: Ability to manage multi- agency agreements, training, staffing, and resource management.
Responsibilities/Duties All Responsibilities/Duties included in the LA WIC Director description and all agreed upon duties in the MOU between partnership agencies, plus:
WIC High Risk Counselors (RD/RN) The WIC High Risk Counselor performs professional and supervisory public health nutrition activities by delivering direct care participant services as well as participating in program planning and evaluation as assigned. In small agencies, this professional may be the same individual as the WIC Director. The WIC High Risk Counselor works under the supervision of the LA WIC Director and may supervise the WIC Educator and/or other WIC High Risk Counselors as assigned.
Best practice is a ratio of approximately 1 full-time equivalent HRC to 1500-1850 clients for this role, depending on other duties (supervision, clinic oversight, etc.).
Possible Titles: ● Nutritionist ● Registered and/or Licensed Dietitian ● Community High Risk Counselor ● Public Health High Risk Counselor ● Community Nurse ● Public Health Nurse ● WIC High Risk Counselor
Qualifications ● Education and Registration/License: The WIC High Risk Counselor must be a Registered Dietitian (RD) with the Commission on Dietetic Registration, a Registered Nurse (RN with a Bachelor’s Degree) licensed to practice in the State of Colorado, Medical Doctor (MD), or Physician Assistant (PA). Because WIC is a nutrition program, the position of WIC Director is ideally held by a Registered Dietitian. Note: In addition to the licensure requirements, a Bachelor’s Degree is the minimum education level required for this position. Preference is given to those who have a Master of Science (MS) or Master of Public Health (MPH) degree. o RD eligible allowed for a maximum of 6 months post hire date. ● Experience: Experience in ambulatory care, public health, or clinical setting.
Knowledge, Skills and Abilities A fully functioning WIC High Risk Counselor will need the knowledge, skills, and abilities listed below. In hiring for this position, a supervisor should look for persons possessing the majority of these skills:
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● Knowledge of human nutrition in health and disease and its application to public health practices. ● Knowledge of nutrition needs for infants and children and women during the prenatal, postpartum, and breastfeeding stages. ● Knowledge of effective counseling and educational concepts and methods. ● Ability to communicate effectively orally and in writing. ● Ability to establish and maintain effective working relationships. ● Ability to develop and carry out ongoing plans for nutrition education. ● Ability to interpret scientific information for lay audiences. ● Knowledge and understanding of the high risk functions related to the Compass computer system. ● Ability to assess nutritional status, design nutritional care plans, and counsel participants toward improved diets with behavior change. ● Ability to promote breastfeeding as the optimal infant feeding choice while allowing participant choice. ● Ability to be understanding and empathetic when dealing with participants. ● Ability to prepare educational materials and prepare and deliver in service trainings. ● Ability to supervise paraprofessional/professional staff as needed to assist the WIC Director/Coordinator.
Responsibilities/Duties ● Completes the Colorado WIC New Employee Training program within the timelines defined. ● Interviews participants and makes thorough nutrition assessments by interpreting anthropometrics and laboratory data, health histories, medical diagnoses, physician's orders, eating habits and nutrition practices, diet assessments, and other related factors. ● Develops, implements, evaluates, and follows up on participant care plans. Counsels participants and families on nutritional needs with consideration of income, cultural and religious food patterns, home facilities, educational level, and other psychosocial factors. ● Maintains participant confidentiality and ensures that participants are treated equally with respect, compassion, and empathy. ● Consults with health care providers on participants’ nutritional needs, formula requiring prescription, and health concerns; makes appropriate referrals and follow up. ● Provides appropriate documentation in participant electronic charts, including participant concerns, nutrition assessment, and materials provided, nutrition education, referrals, and progress toward attaining new behavior change nutrition goals, and follow up plans. ● Counsels all high risk participants at least once during a certification period and within the required time frame. ● Determines follow up care for as long as the participant is considered high risk. ● Completes the WIC Lactation Specialist (WLS) Training to become WLS certified during the next WLS certification window. ● Provides information on the benefits of breastfeeding, aids in breastfeeding promotion in the clinic, offers praise for breastfeeding, and refers staff to IBCLCs as necessary. ● Assesses need and issues breast pumps, instructs on pump use and milk collection/storage, as needed. ● Assesses and provides counseling on common and complex breastfeeding problems, including WIC breastfeeding risk factors and provides high risk follow up, as necessary. ● Authorizes the use of exempt infant formulas, WIC-eligible medical foods, and individual needs for certain tailoring of WIC food packages. ● Reviews and signs as the authorized certifying professional for WIC Educators who have not completed Level I of the Colorado WIC New Employee Training Program. ● Provides nutrition education through individual and/or group instruction to participants, professionals, and community groups. ● Helps orient, train, supervise, and evaluate WIC paraprofessionals, volunteers, and clerical staff as assigned. ● Conducts and/or assists with in service education for staff and professional groups. ● Reviews, evaluates, and/or develops nutrition education materials. ● Participates in Program planning development and evaluation; works on assigned nutrition projects. ● Acts as a resource person for nutrition information. ● Assists with outreach and public relation activities. ● Participates in monitoring electronic charts, paper files, clinic activities, nutrition education, and counseling.
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● Participates in continuing education activities; attends meetings, conferences, and workshops; keeps abreast of current nutrition research as it relates to the WIC Program and participants. ● Participates in staff conferences, meetings, in service training, and State meetings.
WIC Educator The WIC Educator delivers WIC services to participants by determining and documenting eligibility, issuing food benefits, maintaining participant and Program electronic records and paper files related to participant certification, interviewing, providing nutrition education with behavior change goals, and developing individual care plans based on a sound understanding of nutritional concepts.
The WIC Educator develops proficiency in providing the full range of WIC services to participants. Titles of these individuals might include Lead WIC Educator, Administrative WIC Educator, WIC Receptionist, WIC Technician, WIC Clerk, or WIC Program Assistant. Lead WIC Educators are typically assigned higher-level duties such as training and supervising other staff.
The WIC Educator is expected to work under minimal supervision and to exercise independent judgment and a high degree of initiative within established procedures. The Educator works under the supervision of the WIC Director, WIC High Risk Counselor or designated WIC Supervisor.
Best practice is a ratio of approximately 1 full-time equivalent Educator to 400-500 clients for this role, depending on other duties.
Qualifications ● Because WIC is a nutrition program, the job of WIC Educator is ideally held by a Diet Technician (someone who has a two-year degree in nutrition science). Also highly desirable in this position is a Licensed Practical Nurse (LPN). All persons hired as a WIC Educator must complete the Colorado WIC New Employee Training Program modules within defined timelines. ● Education: Minimum high school diploma or GED. ● Experience: Previous work experience with the public. WIC and/or public health experience and experience with low income participants is preferred. ● Special Qualifications: Bilingual (Spanish) desirable.
Knowledge, Skills and Abilities A fully functioning WIC Educator will need all of the knowledge, skills, and abilities listed here. In hiring for the position, a supervisor should look for the first ten skills. The last six can be learned on the job. ● Knowledge of business English, spelling, and math. ● Knowledge of standard office practices and procedures. ● Knowledge of socio economic conditions of local community and social agencies. ● Ability to operate standard office equipment, including a computer. ● Ability to read and interpret a variety of complex rules, regulations, and other materials. ● Ability to prepare and maintain accurate and neat records. ● Ability to provide participant services to assigned caseload and complete paperwork within time limits. ● Ability to establish and maintain effective working relationships. ● Ability to communicate effectively orally and in writing. ● Ability to work with minimal supervision; ability to work as a team member. ● Ability to pass the Colorado WIC New Employee Training Program with the required passing scores for Level I II and III. ● Ability to work with height/length, weight, and measuring devices. ● Ability to perform finger stick blood tests to determine hematocrit or hemoglobin levels. ● Knowledge of effective interviewing and counseling techniques. ● Knowledge of nutrition and nutritional concepts. ● Ability to promote breastfeeding as the optimal infant feeding choice while allowing participant choice.
Responsibilities/Duties ● Completes the Colorado WIC New Employee Training program within the timelines defined.
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● Explains the Program to prospective participants; takes applications over the phone and in person; maintains waiting lists by priority and prescreening list, when necessary. ● Provides assistance in completing the certification process for people who have difficulty in speaking or writing. ● Schedules appointments with participants and follows up on participants who miss their appointments. ● Takes accurate health assessments at specified intervals involving heights, lengths, weights, and hematocrit or hemoglobin measurements; accurately enters this information into the Compass computer system and/or routes to appropriate person. ● Collects comprehensive diet information with a participant centered positive approach. ● Determines and documents complete Program eligibility; identifies all relevant risk factors; enrolls participants; reevaluates participants for continued Program eligibility. ● Determines and tailors food packages to individual needs; documents tailoring; and issues food benefits. ● Provides full explanation of the Program to participants to prevent and help resolve participant misuse; explains purpose of the WIC food package and the nutrients provided. ● Educates participants on the Colorado WIC Program Food List & Shopping Guide. ● Assesses need for and refers participants to appropriate health care and social service programs; makes individual referrals to health/social professionals and follows up referrals. ● Assists participants with individual nutrition education plans; dialogues with participants to identify appropriate behavior change goals; makes appropriate referrals; follows up and documents progress toward goals; reevaluates and establishes new goals; follows protocols. ● Identifies high risk participants according to the definition and makes appropriate referrals to the WIC High Risk Counselor. ● Provides information on the benefits of breastfeeding, aids in breastfeeding promotion in the clinic, offers praise for breastfeeding, conducts breastfeeding education classes and support groups (as able/necessary) and refers to WIC High Risk Counselor, DBE, Educator Advanced Lactation Credentials, or Educator WIC Lactation Specialist (WLS). ● Maintains confidentiality of participants and ensures that participants are treated equally with respect, compassion, and empathy. ● Understands retailer requirements; documents participant and retailer requests or problems and resolves simple problems; refers more complex or repeated problems for resolution. ● Ensures all equipment is clean and maintained in working order and tested for accuracy at regular intervals. ● Orders and maintains adequate inventory of office supplies, clinical supplies, forms, educational pamphlets, eWIC card stock, and other materials for the clinic site. ● Participates in on-going training on the Compass computer system. ● Highly encouraged to attend the WIC Lactation Specialist Training to become a WLS.
Local Agency Retailer Coordinator (LARC) WIC contact person for the state office and for the WIC vendors regarding food delivery topics. Communicate with local vendors regarding current WIC policy and procedures. Complete retailer monitoring visits and reports. Follow-up with participants and store complaints and concerns. The Local Agency Retailer Coordinator (LARC) works under the supervision of the WIC Director, WIC High Risk Counselor or designated WIC Supervisor.
Best practice staffing is equal to 26 hours per year + (3 hours x # of stores = total hours) = total # of hours needed.
Qualifications ● Education: Minimum high school diploma or GED. ● Experience: Previous work experience with the public. WIC and/or public health experience and experience with low-income participants is preferred. Experience with retail stores and/or cashier experience is helpful.
Knowledge, Skills and Abilities (See the complete listing of skills for the WIC Educator position) ● Ability to read and interpret the WIC retailer rules and regulations. ● Ability to prepare and maintain accurate and neat records. ● Ability to communicate effectively orally and in writing. ● Ability to assist with conflict resolution and confidentiality issues.
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● Knowledge of effective counseling and education concepts and methods. ● Ability to establish and maintain effective working relationships. ● Ability to deliver orientation/training/monitoring sessions to various levels of store staff.
Responsibilities/Duties ● Sets up a process so that any staff member can record comments or problems. Keeping detailed, precise records is the key to effective coordination between the State, Local Agency and stores. ● Conducts pre-authorization visits. ● Collects and maintains vendor reports from State WIC staff detailing WIC food benefit redemption, inventory and/or volume history. Assists with training and problem resolution, as needed, for the store. ● Completes training and orientation visit for all new WIC vendors, including shelf surveys. ● Conducts informal site visits ● Conducts routine retailer monitoring visits using the Retailer Monitoring Report form within the agreed upon monitoring schedule. Submits Retailer Routine Monitoring Reports to State Office within 3 days of visit. Follows-up on findings and violations found during the visit. o Reviews WIC policy and procedures such as redeeming food benefits, the Colorado WIC Food List & Shopping Guide, stocking requirements, with the local agency, stores, and participants as appropriate. o Develops processes for tracking and resolving vendor and participant complaints and/or problems. o Participates in the LARC Quarterly Calls. o Completes LARC 101 Training Module every three years (October-December). o Provides written documentation supporting sanctions/disqualifications of participants and/or vendors if needed, including testifying at Fair Hearing Procedures. o Provide vendor coordination guidance to local agency staff.
Local Agency Outreach Coordinator Publicizes the availability of the WIC Program, builds an outreach network, informs organizations in the outreach network about the WIC Program, and coordinates with other community resources to increase the WIC caseload. Outreach Coordinator works under the supervision of the WIC Director, WIC High Risk Counselor or designated WIC Supervisor.
Qualifications ● Education: (See the education and qualifications listed for all of the WIC positions) ● Experience: Previous work experience with the public. WIC and/or public health experience and experience with low-income participants is preferred. Experience with other community programs and agencies plus work with various media is helpful.
Knowledge, Skills and Abilities (See the complete listing of skills for the WIC Educator, WIC High Risk Counselor.) ● Ability to coordinate and chair a committee. ● Ability to evaluate all possible outreach approaches and possible audiences. ● Ability to work with a variety of media. ● Ability to communicate effectively orally and in writing.
Responsibilities/Duties ● Coordinates outreach planning with the WIC Director, the WIC staff, an outreach committee or task force. ● Publicizes the availability of the WIC Program. ● Establishes an outreach network with community agencies/programs serving similar populations. ● Educates the agencies/organizations about the WIC Program and how possible participants can apply. ● Documents outreach activities, agencies contacted and the date of completion. ● Assists the LA WIC Director with updating the referral list in Compass. ● Under the direction of the LA WIC Director, performs duties associated with the WIC Referral System (WRS).
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Local Agency Breastfeeding Coordinator Every WIC agency in Colorado has a designated LA Breastfeeding Coordinator, although larger agencies may have a designated coordinator at each clinic. The Breastfeeding Coordinator is responsible for coordinating breastfeeding promotion and support activities for the agency or clinic in collaboration with the agency’s WIC Director. The LA Breastfeeding Coordinator works under the supervision of the WIC Director, WIC High Risk Counselor or designated WIC Supervisor.
Best practice is based on the number of staff supported by this role, depending on other duties (0.25 FTE: 1-10 staff; 0.25 - 1.0 FTE: 11-25staff; 1.0+ FTE: >25 staff).
Qualifications ● Education/Training: Minimum high school diploma or GED; a four-year degree from an accredited university/college is preferred, ideally a degree in nutrition science or other health science field. Additionally, has received at least 20 hours of advanced training in breastfeeding promotion and support beyond the Colorado WIC New Employee Training Program (e.g., breastfeeding workshops; WIC breastfeeding training, State WIC Meetings, WLS, CLC, CLE, or IBCLC). ● Experience: Must meet all requirements for a WIC Educator. Previous work experience with the public and/or community programs. Breastfeeding experience is desirable, but not required.
Knowledge, Skills and Abilities (See complete listing of skills for the WIC Educator position.) ● Ability to disseminate and implement appropriate policies and guidelines that support and promote breastfeeding as the preferred method of infant feeding. ● Ability to collaborate with prenatal, well child, and family planning programs, hospitals, and/or other community health care providers to coordinate breastfeeding promotion and support activities. ● Ability to prepare and maintain accurate and neat records, and submit reports to the State Office in a timely manner. ● Ability to communicate effectively orally and in writing.
Responsibilities/Duties ● Completes the WIC Lactation Specialist (WLS) Training to become WLS certified during the next WLS certification window. ● The clinic/agency environment is breastfeeding-friendly by implementing the following requirements: o Portray breastfeeding as the preferred infant-feeding method in a culturally and aesthetically appropriate manner. o Establish a positive attitude toward breastfeeding by clinic and agency staff. o Avoid use of printed and audiovisual materials and office supplies developed by formula manufacturers in any WIC clinic. o Store infant formula in areas not visible to the WIC participant. o Provide a supportive clinic environment in which women feel comfortable breastfeeding their infant. o Incorporate positive peer influence into the prenatal period through use of peer counselors, bulletin boards that display successful breastfeeding mothers and infants, or hosting sessions where pregnant women can talk with breastfeeding women, and/or scheduling pregnant and breastfeeding women at the same time. o Include participants’ family and friends in breastfeeding education sessions. o Issue a formula package consistent with the mother’s breastfeeding goals and the infant’s nutritional needs. ● Systems/programs are in place to provide timely support services to breastfeeding women and infants. Activities may include: o Create procedures to ensure breastfeeding women and infants are certified within 7 to 10 days of delivery. o Coordinate in-services on assessing the breastfeeding dyad. o Collaborate with community programs/organizations to identify or develop systems of support (e.g., La Leche League, local hospital lactation programs, home visitation program, public health nursing). o Coordinate a telephone follow-up program. o Regularly assess agency needs for breast pumps and supplies and, in collaboration with WIC Director, completes breast pump and supply order form.
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o Review policies and procedures for issuing breast pumps and supplies with all staff periodically. o Use breastfeeding reports to identify common reasons women cease breastfeeding and develop strategies to address barriers. o Track breastfeeding rates for the agency/clinic. o Participate in Breastfeeding Coordinator conference calls, meetings, and other activities with the state breastfeeding coordinator. ● Ensures all staff members are competent in providing breastfeeding education and support. Activities may include: o Orient new employees on the agency’s breastfeeding activities and services, WIC policies and procedures, and the Program’s breastfeeding goals. o Assess staff training needs and coordinate training opportunities as appropriate, including referring staff to complete the WLS training program. o Plan and implement breastfeeding continuing education for staff annually. o Review participant breastfeeding education materials and staff training materials annually to ensure they are up-to-date and accessible to staff. o Apprise staff of changes in WIC breastfeeding policies, procedures, or recommendations. Review tailoring of the breastfeeding infant food package with staff on a regular basis. o Work with the LA Director to include questions in the interview process for prospective employee’s ability to provide breastfeeding education as well as in the annual evaluation process of the employee. o Serve as a breastfeeding resource person for staff (e.g., is well versed in Colorado WIC breastfeeding policies and procedures, maintains local agency/clinic breastfeeding library [books and videos], and materials needed to complete the Breastfeeding Module). o Coach staff to build their skills in providing breastfeeding education and support. ● The clinic/agency staff actively promotes and supports breastfeeding to the WIC population and community. Activities may include: o Coordinate activities to celebrate WIC National Breastfeeding Week. o Present to local organizations and health care programs on the services provided by WIC emphasizing breastfeeding education and support services. o Participate in the local breastfeeding task force or possibly initiate the development of a task force if one does not exist. o Submit breastfeeding articles and public service announcements to local media.
Educator WIC Lactation Specialist (Educator WLS)/Educator Advanced Lactation Credentials This is an enhanced role for a WIC Educator who has received higher-level breastfeeding education through the Colorado WIC Lactation Specialist (WLS) training and/or advanced lactation credentials (CLC, CLE or IBCLC) and has developed their expertise. The following roles and responsibilities are within the scope of practice for an Educator WLS and/or Educator Advanced Lactation Credentials:
Qualifications ● Meets qualifications of a WIC Educator. ● Education: o Educator WLS - Minimally, has participated in the Colorado WLS training. o Educator Advanced Lactation Credentials - Minimally, has obtained advanced lactation credential (CLC, CLE, or IBCLC) from an accredited program including completing course work, passing an exam and maintaining the credential as required by the accrediting body (e.g., continuing education credits, fees). ● Experience: Previous work experience with the public and/or community programs.
Knowledge, Skills and Abilities (see WIC Educator role for complete listing) ● Ability to disseminate and implement appropriate policies and guidelines that support and promote breastfeeding as the preferred method of infant feeding. ● Ability to review evidence-based literature and apply to practice. ● Ability to pass the WLS or CLC, CLE, or IBCLC exam at the completion of the training [and pass two required WLS observations (unless already CLC, CLE or IBCLC certified)].
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Responsibilities/Duties ● Assesses and provides counseling on common and complex breastfeeding problems. ● Performs the counseling expectations described in the “Breastfeeding Complications or Potential Complications (602/603)” content in the High and Low Risk Protocol policy. ● Provides prenatal anticipatory guidance [responding to concerns and issues about breastfeeding; such as, reinforcing that it takes about a month to establish milk supply; no formula first month; what to request in the hospital (Baby-Friendly Hospital Initiative’s Ten Steps to Successful Breastfeeding), issues returning to work or school; hand expression; breastfeeding resources in community]. ● Responds to participant breastfeeding questions, providing information on the benefits of breastfeeding, offering praise for breastfeeding, and aids in breastfeeding promotion activities in the clinic. ● Assesses need, coordinates and loans/issues breast pumps and supplies, instructs on pump use and milk collection/storage.
Optional Functions ● Teaching participant breastfeeding classes and/or leading breastfeeding support groups. ● Providing support calls to mothers prenatally or early postpartum to offer encouragement and respond to questions, including after pump issuance. ● Recommending breast shells, breast pads, and other breastfeeding aids.
High Risk Counselor WIC Lactation Specialist (WLS)/High Risk Counselor Advanced Lactation Credentials All High Risk Counselors are required to participate in a training to be able to function as a WIC Lactation Specialist (WLS). High Risk Counselors may also obtain advanced lactation credentials (CLC, CLE, IBCLC) to further their expertise and support for participants. The following roles and responsibilities are within the scope of practice for High Risk Counselor WLS and/or High Risk Counselor Advanced Lactation Credentials.
Qualifications ● Meets qualifications of High Risk Counselor. ● Education: o High Risk Counselor WLS: Minimally, has participated in the Colorado WIC WLS training. o High Risk Counselor Advanced Lactation Credentials - Minimally, has obtained advanced lactation credential from an accredited program (CLC, CLE, IBCLC) including completing course work, passing an exam and maintaining the credential as required by the accrediting body (e.g., continuing education credits, fees). ● Experience: Previous work experience with the public and/or community programs.
Knowledge, Skills and Abilities In addition to the following, see complete listing for High Risk Counselors and Educators in Local Staffing section, respectively. ● Ability to disseminate and implement appropriate policies and guidelines that support and promote breastfeeding as the preferred method of infant feeding. ● Ability to review evidence based literature and apply to practice. ● High Risk Counselor WLS - Ability to pass the WLS exam at the completion of the training course. High Risk Counselor Advanced Lactation Credentials - Ability to pass the CLC, CLE, and/or IBCLC exam at the completion of the training course(s) and any required observations.
Responsibilities/Duties ● Mentors Educator WLS and BFPC WLS. ● Performs the counseling expectations described in the “Breastfeeding Complications or Potential Complications (602/603)” content in the High and Low Risk Protocols policy. ● Provides high risk follow-up to a mother and infant within two weeks of risk assignment of NRF 602/603 if initial 24-hour high risk counseling was provided by an Educator WLS. ● Provides prenatal anticipatory guidance (responding to concerns and issues about breastfeeding; reinforces that it takes about a month to establish milk supply; no formula first month; what to request in the hospital; issues for returning to work or school; hand expression; breastfeeding resources in community).
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● Assesses need, coordinates and loans/issues breast pumps and supplies. Can delegate to Educator WLS or Educator Advanced Lactation Credentials. ● Makes referrals to health care providers, IBCLC or hospital lactation staff. ● Contacts participant’s health care provider to discuss concerns (e.g. medications and breast milk; formula supplementation prescriptions). ● Responds to participant breastfeeding questions. ● Recommends breast shells, breast pads, and other breastfeeding aids. ● Troubleshoots breastfeeding concerns such as inadequate milk supply (perceived or real) and solutions for engorgement.
Optional Functions ● Teaching breastfeeding classes and/or leading support groups. ● Providing support calls to mothers prenatally or early postpartum to offer encouragement and respond to questions.
Designated Breastfeeding Expert The Designated Breastfeeding Expert (DBE) has special training and experience helping mothers with complex breastfeeding problems that are outside the scope of practice of BFPCs and other WIC staff. The DBE operates within the policies and procedures of the WIC program and within the context of WIC’s role for breastfeeding support. Each LA operating a BFPC program is required to have access to a DBE to assist WIC participants with complex breastfeeding challenges in a timely manner. This role is typically fulfilled by the LA BFPC Coordinator.
Qualifications ● Education: Is a Registered Dietitian, Nutritionist or health care provider (Master's or Bachelor’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition or Home Economics with emphasis in Nutrition), IBCLC, Registered Nurse, Physician’s Assistant certified by the National Committee on Certification of Physician’s Assistants or has completed a minimum of 8 college courses from an Accredited Institution in the Health Sciences (suggested coursework includes, but is not limited to the following areas: Human Anatomy, Human Physiology, Biology, Infant Growth and Development, Nutrition, Counseling Skills, Sociology, Introduction to Clinical Research, etc.). ● Training: Successful completion of the FNS competency-based training for WIC Breastfeeding Curriculum (levels 1-4) or completion of a State-approved competency-based breastfeeding training that is consistent with the FNS WIC Breastfeeding Curriculum. ● Experience: o Experience working with low-income breastfeeding mothers and infants who experience complex breastfeeding challenges. o Minimum of one year of experience in counseling breastfeeding mother/infant dyads. o Experience providing breastfeeding training/education.
Knowledge, Skills and Abilities A fully functioning DBE will have the following skills or be able to learn them on the job. ● Knowledge of socio-economic conditions of the local community. ● Critical thinking and problem solving. ● Breastfeeding Assessment and Care Plan Development. ● Ability to clearly communicate complex care plans to the WIC breastfeeding team, as appropriate.
Responsibilities/Duties The WIC DBE duties include, but are not limited to: ● Acts on referrals from BFPCs regarding complex breastfeeding challenges beyond their scope of practice. ● Assesses, contributes towards the development of a care plan and counsels the mother/infant dyad with complex breastfeeding challenges. ● Performing the counseling expectations described in the “Breastfeeding Complications or Potential Complications (602/603)” content in the High and Low Risk Protocols policy. ● Communicates care plan to the rest of the WIC breastfeeding team, as appropriate. ● Refers participants to health care providers for further assessment and medical care when needed.
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● Refers to hospital lactation staff and community breastfeeding support resources, as necessary. ● Assesses need, coordinating and loaning/issuing breast pumps and supplies. Can delegate to Educators or High Risk Counselors who are WLSs or have advanced lactation credentials. ● Recommending breast shells, breast pads, and other breastfeeding aids and administering/overseeing supplemental nursing systems (SNS) as necessary. ● Mentors all other WIC staff, specifically Educator WLS, BFPC WLS and High Risk Counselor WLS. ● Maintains lactation credentials and certifications.
Optional Functions ● Teaching breastfeeding classes and/or leading support groups. ● Providing breastfeeding trainings for WIC staff and serving as a resource and mentor. ● Promoting breastfeeding within the community.
Designated Breastfeeding Expert IBCLC The Designated Breastfeeding Expert IBCLC (WIC DBE-IBCLC) has special training and expertise assisting participants with complex breastfeeding problems. This position requires completion of both DBE requirements and IBCLC credential. This position is optional and can be combined with other WIC staffing roles, or as its own position within the LA.
Qualifications ● Meets qualifications of WIC DBE. ● Education: o Minimally, has obtained and maintained the International Board Certified Lactation Consultant (IBCLC) credential as provided by and verified by the International Board of Lactation Consultant Examiners (IBLCE). o Successful completion of the FNS competency-based training for WIC Breastfeeding Curriculum (levels 1- 4) or completion of a State-approved competency-based breastfeeding training that is consistent with the FNS WIC Breastfeeding Curriculum. o Maintains consistent continuing education credits and stays up to date on best practices related to lactation. ● Experience: o Advanced experience assisting families with complex breastfeeding challenges. o Experience working with low-income breastfeeding mothers and infants who experience complex breastfeeding challenges. o Minimum of one year of experience in counseling breastfeeding mother/infant dyads. o Experience providing breastfeeding training/education to colleagues, health care professionals, and the general public.
Knowledge, Skills and Abilities A fully functioning WIC DBE-IBCLC will have the following skills or be able to learn them on the job. ● Knowledge of socio-economic conditions of the local community. ● Critical thinking and problem solving. ● Breastfeeding Assessment and Care Plan Development. ● Ability to clearly communicate complex care plans to the WIC breastfeeding team, as appropriate.
Responsibilities/Duties The WIC DBE-IBCLC duties include, but are not limited to: ● Acts as the breastfeeding expert for the agency, responding to referrals from WIC staff and BFPCs regarding complex breastfeeding challenges beyond their scope of practice. ● Troubleshoots breastfeeding concerns such as inadequate milk supply (perceived or real) and solutions for engorgement. ● Assesses, contributes towards the development of a care plan and counsels the mother/infant dyad with complex breastfeeding challenges. ● Performs the counseling expectations described in the “Breastfeeding Complications or Potential Complications (602/603)” content in the High and Low Risk Protocols policy. ● Communicates care plan to the rest of the WIC breastfeeding team, as appropriate.
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● Contacts participant’s health care provider to discuss concerns (e.g. medications and breast milk; formula supplementation prescriptions). ● Refers to hospital lactation staff and community breastfeeding support resources, as necessary. ● Provides prenatal support and guidance (responds to advanced concerns and issues about breastfeeding; addresses potential physiological challenges that would inhibit/limit breastfeeding; sets expectations for birth and early postpartum, including support to request at the hospital). ● Assesses need, coordinates and loans/issues breast pumps and supplies. Can delegate to Educator/High Risk Counselor WLS. ● Recommends breast shells, breast pads, and other breastfeeding aids and administers/oversees supplemental nursing systems (SNS) as necessary. ● Mentors all other WIC staff, specifically Educator WLS, BFPC WLS and High Risk Counselor WLS. ● Maintains IBCLC credentials and obtains appropriate continuing education credits through training opportunities annually.
Optional Functions ● Teaching breastfeeding classes and/or leading support groups. ● Providing breastfeeding trainings for WIC staff. ● Promoting breastfeeding within the community, especially outreach with health care providers. ● Providing support calls to mothers prenatally or early postpartum to offer encouragement and respond to questions.
Breastfeeding Peer Counselor Program Coordinator The WIC Breastfeeding Peer Counseling (BFPC) Program Coordinator manages the BFPC Program at the local agency level and works under the direction of the LA WIC Director.
Qualifications ● Education: o Minimum high school diploma or GED and advanced lactation credentials, such as Certified Lactation Counselor (CLC) or Certified Lactation Educator (CLE). IBCLC preferred. ● Experience: o Previous work experience with the public. WIC and/or public health experience and experience with low- income participants is preferred. o Has a minimum of one-year experience counseling breastfeeding women. o Has experience in program management. o Has demonstrated experience in supervision. o Has demonstrated expertise in breastfeeding management and promotion.
Knowledge, Skills and Abilities A fully functioning breastfeeding peer counselor program supervisor/coordinator will have the following skills or be able to learn them on the job. ● Completes the WIC Lactation Specialist (WLS) Training to become WLS certified during the next WLS certification window ● Successful completion of the FNS competency-based training for WIC Breastfeeding Curriculum (levels 1-4) or completion of a State-approved competency-based breastfeeding training that is consistent with the FNS WIC Breastfeeding Curriculum. ● Successful completion of the FNS WIC Breastfeeding Curriculum: Peer Counseling Management training. ● Knowledge of socio-economic conditions of the local community. ● Ability to read and interpret a variety of materials. ● Ability to prepare and maintain accurate, neat records. ● Abilities to provide services to the assigned caseload and complete paperwork within time limits. ● Ability to establish and maintain effective working relationships. ● Ability to communicate effectively orally and in brief writing. ● Ability to work as a team member. ● Ability to complete WIC and breastfeeding information modules.
Responsibilities/Duties
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The LA BFPC Coordinator duties include, but are not limited to: ● Assists in establishing program goals and objectives. ● Assists in establishing BFPC program protocols and policies. ● Assures that the BFPC program follows the FNS WIC Breastfeeding Model Components for Peer Counseling. ● Determines BFPC program staffing needs. ● Recruits and interviews potential BFPCs in alignment with program policies and standards. ● Arranges training of BFPCs. ● Mentor new BFPCs during the first three months and provide ongoing supervision ● Holds monthly meetings with BFPCs. ● Reviews documentation records and data as appropriate. ● Monitors the program, including conducting spot checks. ● Routinely reports on the program to supervisor and State BFPC Program Coordinator. ● Works with other BFPC supervisors (if available) to assess for ongoing improvements to the program that may be needed. ● Arranges for availability of WIC Designated Breastfeeding Expert (DBE) for managing complex breastfeeding problems beyond the scope of the peer counselor. (Note: May also serve as the LA’s DBE.)
Breastfeeding Peer Counselor The WIC Breastfeeding Peer Counselor (BFPC) is a paraprofessional support person who provides basic breastfeeding information and encouragement to pregnant and breastfeeding WIC participants who are pregnant or breastfeeding. The BFPC is required to document contacts and make referrals to lactation experts when concerns are beyond their scope of practice.
Note: New hires should not have professional training in health, nutrition, or the clinical management of breastfeeding (e.g. CLC, CLE or IBCLC).
Supervision WIC BFPCs work under the supervision of the LA BFPC Program Coordinator or WIC Director.
Qualifications To ensure that the BFPC relates with a WIC mother, the position qualifications are: ● Has breastfed at least one child (does not have to be currently breastfeeding). Ideally, candidates should have breastfed for 6 months or more, but candidates with less than 6 months of experience who can demonstrate a strong understanding of breastfeeding practices and challenges may also be considered. ● Is enthusiastic about breastfeeding, and wants to help other mothers enjoy a positive experience. ● Bilingual (Spanish/English) preferred but not required. ● Can work a set number of hours a week (as established by the local agency) and is available to WIC participants outside usual clinic hours. ● Completes the FNS WIC Breastfeeding Curriculum training for BFPCs and all required orientation activities.
Knowledge, Skill and Abilities A fully functioning BFPC already has the following skills and/or learns them on the job. ● Knowledge of socio-economic conditions of the local community. ● Ability to read and interpret a variety of materials. ● Ability to prepare and maintain accurate, neat records. ● Abilities to provide services to the assigned caseload and complete paperwork within time limits. ● Ability to establish and maintain effective working relationships. ● Ability to communicate effectively orally and in writing. ● Ability to work as a team member. ● Ability to complete WIC and breastfeeding information modules.
Responsibilities/Duties ● Counsels pregnant and breastfeeding WIC participants through phone calls, text messaging, clinic visits, home visits, and/or hospital visits at scheduled intervals determined by the LA. ● Receives a caseload of pregnant and breastfeeding WIC participants and makes routine periodic contacts.
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● Provides basic breastfeeding information and support to new mothers, including telling them about the benefits of breastfeeding, overcoming common barriers, and getting a good start with breastfeeding. Helps mothers prevent and handle common breastfeeding concerns. ● May be available outside usual 8 to 5 working hours to new mothers who are having breastfeeding problems. ● Maintains confidentiality. ● Keeps accurate records of all contacts made with WIC participants. ● Refers mothers, according to clinic-established protocols, to appropriate resources: o WIC BFPC Coordinator, DBE, High Risk Counselor, Educator Advanced Lactation Credentials, or Educator WLS. o Lactation consultant. o Health care providers. o Public health programs in the community. o Social service agencies. ● Attends and assists with prenatal classes and breastfeeding support groups. ● Attends monthly staff meetings and breastfeeding conferences/workshops as appropriate. ● Reads assigned books and materials on breastfeeding that are provided by the supervisor. ● May assist WIC staff in promoting the BFPC program through special projects and duties as assigned.
Breastfeeding Peer Counselor WIC Lactation Specialist (BFPC WLS) This is an enhanced role for Breastfeeding Peer Counselors (BFPCs) who have expertise in breastfeeding counseling and management through previous experience as a BFPC and additional lactation training (e.g. Colorado WLS training) and who can maintain their role as a peer connecting with a peer. This enhanced role is not necessarily available to any peer who has attended the WLS training. Supervisors must consider each BFPC individually (knowledge, skill, desire, etc.) to assess if they fit the criteria and can continue to be a BFPC while having this additional knowledge.
Note: ● BFPCs must have at least 12 months of work experience in the role in order to attend the WLS training. This requirement can be flexed per the discretion of the LA BFPC Coordinator. ● BFPCs should not be in the role of educator or teacher. BFPCs should be considered part of the team for the care of the mother/baby and should know when to yield to the WIC BFPC Coordinator, DBE, High Risk Counselor, Educator Advanced Lactation Credentials, or Educator WLS.
Qualifications ● Meets qualifications of a WIC BFPC. ● Has completed the WIC Lactation Specialist (WLS) Training to become WLS certified.
Knowledge, Skills and Abilities In addition to the following, see complete listing for BFPC. ● Ability to pass the WLS exam at the completion of the training and pass two required WLS observations.
Responsibilities/Duties ● Provides prenatal anticipatory guidance [responding to concerns and issues about breastfeeding; such as, reinforcing that it takes about a month to establish milk supply; no formula first month; what to request in the hospital (Baby-Friendly Hospital Initiative’s Ten Steps to Successful Breastfeeding), issues returning to work or school; hand expression; breastfeeding resources in community]. ● Provides support calls to mothers prenatally or early postpartum to offer encouragement and respond to questions. ● Responds to participant breastfeeding questions. ● Troubleshoots breastfeeding concerns such as inadequate milk supply (perceived or real) and solutions for engorgement.
Optional Functions ● Assessing need, coordinating and loaning/issuing breast pumps and supplies, instructing on pump use and milk collection/storage for BFPC participants.
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● Perform required follow-up 24-72 hours after a breast pump has been issued to a BFPC client. Follow-up must be documented in the clients’ Participant Care Plan. ● Leading breastfeeding support groups and classes. (Note: BFPC funds are to support programs beyond current operations and breastfeeding classes are considered current operations. If a BFPC WLS leads a breastfeeding class, the funds should come from the WIC budget rather than the BFPC budget. As support groups are not considered current operations, BFPC funds can be used to pay for the BFPC’s time to lead these groups.) ● Depending on level of skill and knowledge of supervision, could serve as the LA BFPC Coordinator.
NOTE: Out of Scope for all Colorado WIC Program Staff ● Recommending use of a galactagogue – should refer to the mother's health care provider, hospital lactation or IBCLC in the community. ● Recommending treatment for or diagnosing breast yeast or bacterial infection or breastfeeding or breast milk jaundice – should refer to a health care provider. ● Fitting and placement of nipple shields – should refer to hospital lactation or IBCLC in the community. ● Diagnosing based on infant test weights done in the WIC clinic. ● Recommending a specialized infant formula when supplementation is medically warranted. Staff should refer the mother back to the health care provider.
Non-WIC Staff with WIC Program Duties LA WIC Directors may assign WIC duties to agency staff not considered WIC employees. For example, a non-WIC staff may be assigned to obtain heights, weights, and hemoglobin/hematocrit measurements. Most often, these staff persons have limited access to Compass. To ensure these individuals are adequately trained, the WIC Director develops a training plan to provide the individual with the skills and knowledge needed to perform her/his work. Civil Rights Training is required for all regardless of job duties.State Office Nutrition Consultants are available to assist with help in developing a training plan.
The supervisor is required to document the training that was provided for the individual including the topics, method of training, test scores, and dates of completion. This information must be kept in the employee’s file and electronically entered into Compass, Staff Competencies. Should the non-WIC staff not have Compass access, maintain documentation of provided training in a separate file.
Standards for Use of Volunteers in WIC Clinics WIC clinics are continually challenged with the problem of how to improve quality services with limited financial resources. One of the creative solutions to this problem has been the use of volunteers in the clinic. One concern when using volunteers is to see that they receive quality training and appropriate supervision. This is necessary to ensure participants receive a high level of care and WIC protocols and procedures are maintained.
LAs may have a volunteer coordinator and established policies for using volunteers. It is recommended that LAs coordinate WIC volunteer services within the agency policies. The following standards must be followed when beginning a volunteer program for WIC:
● LAs will discuss the plan for use of volunteers with the State Office assigned nutrition consultant. ● Program administrators will check LA policies regarding insurance, legal liability, and confidentiality concerning the use of volunteers in the agency setting. ● All volunteers will receive an orientation to the overall WIC Program and to the specific LA. Which might be hard to do since interns may rotate with ● All volunteers will receive direct supervision from a WIC administrative professional and/or WIC Supervisor. Supervision must include ongoing coaching and feedback and a yearly performance evaluation. Observation of volunteers may be included in state site visits and monitoring visits. ● Volunteers are used in different capacities based on their interests and skills and the agency’s needs. Some of the activities that volunteers have been used for include intake eligibility work (e.g., helps participants with completion of forms); clerical work (e.g., filing, typing, answering the phone, folding pamphlets, organizing pamphlets); and height and weight screening (e.g., takes heights and weights). ● Volunteers must not determine nutrition risk, nutrition eligibility, or issue, WIC food benefits.
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An appropriate training plan must be developed based on assigned duties. The training plan should be developed based on the tasks the individual is responsible for in the WIC clinic. The supervisor is required to document the training that was provided for the individual including the topics, method of training, test scores, and dates of completion. This information should be kept in the volunteer’s file and electronically entered into the Compass computer system, if appropriate.
Colorado WIC Program Policies and Procedures Section 4: Organization and Management Revised: 5/1/2022 Local WIC Agency Application Process Policy: The State Agency evaluates and selects Local Agencies based on the selection criteria outlined in the application, available budget, and cost effectiveness of proposed local agency operations. New Local Agencies must complete the application and be approved before contracting or receiving funding from the State Agency program. Local Agencies enter into agreements with the State Agency annually. Regulation: CFR 246.4(a)(5)(i) and (7) and 246.5 Procedure/Guidance: After the receipt of a complete application, the State agency shall notify the applicant agency in writing of the approval or disapproval of its application. When an application is disapproved, the State agency shall advise the applicant agency of the reasons for disapproval and of the right to appeal as set forth in § 246.18. When an agency submits an application and there are no funds to serve the area, the applicant agency shall be notified that there are currently no funds available for Program initiation or expansion. The State agency may fund more than one local agency to serve the same area or special population as long as more than one local agency is necessary to serve the full extent of need in that area or special population. The State Agency must, when seeking new local agencies, publish a notice in the local media (unless it has received an application from a local public or nonprofit private health agency that can provide adequate services). The notice will include a brief explanation of the Program, a description of the local agency priority system, and a request that potential local agencies notify the State agency of their interest. In addition, the State agency will contact all potential local agencies to make sure they are aware of the opportunity to apply. If an application is not submitted within 30 days, the State agency may then select a local agency in another area. If sufficient funds are available, a State agency will give notice and consider applications outside the local area at the same time. The State Agency may conduct periodic reviews of the qualifications of authorized local agencies under its jurisdiction. Based upon the results of such reviews the State Agency may make appropriate adjustments among the participating local agencies, including the disqualification of a local agency when the State agency determines that another local agency can operate the Program more effectively and efficiently. In conducting such reviews, the State Agency shall consider the factors listed in regulation in addition to whatever criteria it may develop. The State Agency may require reapplication by Local Agencies at any time as necessary due to operational, budgetary, or policy requirements.
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Mandatory Reporting
Policy: All local agency WIC staff are mandatory reporters of child abuse or neglect. Local WIC programs should follow their own local agency’s established guidelines and procedures for reporting these situations.
Regulation: Colorado Revised Statute (CRS 19-3-304)
Procedure/Additional Guidance: It is recommended that local agencies develop written internal reporting procedures and resources (for staff and participants) with input from legal counsel, local law enforcement and child protective services. Written procedures should detail how staff members will respond to any reportable or potentially reportable situation, who is required to report, and to whom the report is made (child protective services or law enforcement agency). It is also recommended that local agencies provide mandatory reporting training and resources for staff members. The Colorado Department of Human Services (CDHS) provides the Child Welfare On-line Training System at https://coloradocwts.com/wbt/mandatory_reporter_guest/index.html. This valuable resource introduces staff members to mandatory reporting requirements.
Colorado’s definition of child abuse or neglect Child abuse is an act or omission that threatens the health or welfare of a child and includes signs of physical abuse or physical injury that is not justifiably explained, malnutrition, child is subjected to unlawful sexual behavior, child’s parent or legal guardian or custodian does not provide adequate food, clothing, shelter, medical care, or supervision, emotional abuse, a controlled substance is manufactured or attempted to be manufactured either in the child’s presence or on the premises where the child resides or is found, a child tests positive at birth for either a schedule I controlled substance or a schedule II controlled substance unless the positive test was for a prescribed medication that the mother was taking. (CRS 19-1-103, 19-3-201, 16-22-102, 18-3-401-405.4, 411, 502).
Types of Child Abuse: Physical Abuse Sexual Abuse Emotional Abuse Human Trafficking Institutional Abuse
There are five types of neglect: Physical Neglect Medical Neglect Educational Neglect Emotional Neglect Lack of Supervision
How is a report made? Reporting procedures are detailed in CRS 19-3-307, 25-1-122 (4) (d) and 25-4-1404 (1) (d). Depending upon the local agency’s reporting guidelines, a report is made immediately by calling the county’s child protective service, local law enforcement agency, or Colorado’s Child Abuse and Neglect Hotline: 1-844- CO-4-KIDS (or 1-844-264-5437); followed by a written report prepared by the mandatory reporter.
Child protective services (CPS) personnel are required to assess reports of child abuse and/or neglect. CPS works with community professionals, who are mandated reporters, to prevent, identify, and respond to child abuse and/or neglect.
The Participant Care Plan should be used to document WIC-related observations, verbal or written reports. All documentation must be done in a professional manner as any WIC record can be used for legal purposes.
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To whom should a report be made? Generally, interfamilial abuse (includes abuse that occurs within a family context by a child’s parent, stepparent, guardian, legal custodian, relative, spousal equivalent or any other person who resides in the child’s home) is reported to the child protective services in the county where the victim lives.
Third party abuse (includes abuse by any person who is not a parent, stepparent, guardian, legal custodian, spousal equivalent) is reported to law enforcement where the crime occurred. Local child protective services can provide guidance regarding to whom a report should be made. (Definitions from CRS 19-1-103)
Does a report need to be made? Issues to consider: 1. Is there evidence or suspicion of physical, sexual or emotional abuse? 2. Are there signs of neglect (physical, medical, educational, emotional &/or lack of supervision)? 3. Is the parent/caregiver abusing substances in view of the child/ren? a. How is this impacting the safety/well-being of the child/ren? b. Are substances easily accessible to the child/ren, thereby increasing the risk of accidental ingestion? c. Is there a sober caregiver at home? Is the parent/caregiver driving under the influence with child/ren in the vehicle?
Assistance for mandatory reporters: Staff should follow the reporting policies established by their local agency. A suspicion of abuse or neglect is adequate for reporting to child protective services. Staff should not attempt to further investigate or probe suspected child abuse or neglect. Staff making a report may find speaking with a fellow staff member or supervisor helpful but the mandatory reporter is ultimately responsible for complying with reporting laws.
If staff is unsure about whether a report should be made, they should contact their local child protective services for guidance.
What happens when a report is made? When a report of suspected child abuse and/or neglect is made, child protective services collects relevant information from the reporting party and screens the call to determine if a report will be accepted for assessment. Child protective services will prioritize accepted reports and assign them for assessment or for referral to other agencies, community services or another jurisdiction.
After a report is made, the county is required to notify the person who made the report within 30 days regarding whether or not the referral was assigned for assessment. A call may also be made to the county to follow-up to see if the report was assigned. If the referral was assigned, the person making the report may be contacted for additional information.
Note: References are made to various Colorado statutes in the information. Staff should consult the Colorado Revised Statutes for the most current and complete wording of the child abuse and neglect reporting law. http://www.lexisnexis.com/hottopics/colorado/
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Measuring Equipment Maintenance and Calibration
Policy: Local agencies are responsible for equipment maintenance and calibration and are required to maintain equipment maintenance and calibration logs in a central file.
Regulation: USDA Nutrition Services Standard 2A6
Procedure/Additional Guidance: Scales and Measuring Boards Perform daily maintenance of scales as follows: ● Place scales on a hard, non-carpet surface. If the area is carpeted, place the scale on a piece of plywood or a standing base. ● Before weighing every participant, check that the scale balance is at zero, by moving the ounce and pound weights to zero until the arm rests in the center. Check digital scales to ensure zero reading. If scales do not balance at zero, notify supervisor for scale to be serviced. ● Clean scales with disinfectant as needed. Check for wear and broken or faulty parts. Avoid using the scales until repairs have been completed. ● Clean scales with disinfectant as needed. Check for wear and broken or faulty parts. Avoid using the scales until repairs have been completed.
Perform yearly maintenance of scales as follows: ● Inspection: Scales must be inspected yearly. The scales may be inspected by properly trained staff who are following manufactures instructions, the scales may be inspected by the Colorado Department of Agriculture (CDA) or a private company. o CDA inspection fees are dependent on the type of scale tested and can be $35, $50, or $65 per scale. To locate an inspector in your area, contact the Measurement Standards Office 303-869-9101. ▪ If scales pass inspection by CDA, an approval sticker will be dated and placed directly on your scale. ▪ If scales do not pass inspection by CDA, a blue Work Order sticker will be placed on your scale. Avoid using the scales until repairs have been completed.
● Calibration: If based on the inspection, the scale needs calibration, local agencies may calibrate scales per manufacturer instructions. Staff doing calibration must be properly trained and follow the manufacturer’s instructions. If the CDA determines calibration is needed, a list of companies that can calibrate the scale will be given to the local agency. The CDA does not calibrate scales. ● Record repairs, replacements, and yearly inspections on the maintenance log for each scale.
Perform daily maintenance of measuring boards as follows: ● Clean measuring boards with disinfectant as needed. ● Check for wear and broken or faulty parts. Avoid using measuring board until repairs have been completed.
Perform yearly maintenance of measuring boards to check all boards for accuracy as follows: ● Use a metal measuring tape to check for slippage on wall mounted boards; and ● Check the right angle on head and foot boards. ● Record repairs, replacements, and yearly inspections on the maintenance log for each measuring board.
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Hemoglobin/Blood Screening Equipment The Hemocue Product Order Form can be found on the COWIC website. The State Office handles all supply items listed on this form. This form must be sent to the State Office.
Perform maintenance of hemoglobin analyzers as follows: ● Clean hemoglobin analyzers, per the manufacturer’s directions detailed in the user’s guide. Local agencies may determine the frequency of cleaning based on the volume of tests performed. Examples: clean analyzer monthly if < 20 tests per month; clean weekly if > 150 tests per monthly, etc. ● Record all repairs or replacements on the maintenance log for each hemoglobin analyzer.
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Migrant Applicants
Policy:WIC staff must make every effort to reduce barriers that could prevent migrant individuals from receiving WIC Program benefits.
Regulations: CFR 246.2, CFR 246.7(c) & (d)(2)(ix)
Procedure/Additional Guidance: Definition of Migrant Farm Worker An 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." "Principal employment" means over 50 percent of the migrant farm workers job is in agriculture. "Agriculture" means farming in all its branches and includes: o Cultivation and tillage of the soil. o The production, cultivation, growing, and harvesting of any commodity grown in or on the land, or as an adjunct to or part of a commodity grown in or on the land. o Any practice (including preparation and processing for market and delivery to storage or to market or to carriers for transportation to market) performed by a farmer, on a farm, or in conjunction with an activity described in “Agriculture” (above). A worker establishes a "temporary abode" when the worker's job location requires him to leave his place of regular residence periodically, not permanently, for one or more 24 hour periods. An automobile, van, or camper may be considered a “temporary abode" when used for temporary residence. The decision to include work as a migrant farm worker in the last 24 months was made because barriers to participation in local health services, including WIC, may not immediately be overcome when a participant no longer works as a migrant farm worker.
Migrant farmworkers and their families are at risk of poor nutrition due to low or seasonal income, isolation from dangerous working conditions, exposure to environmental hazards, inadequate housing and often lack of formal education and the English language. For these reasons, migrant farmworker families are a priority for WIC and may need referrals to health providers and local resources.
In order to identify a migrant farmworker or a member of a migrant farmworker family the following questions should be asked to screen for migrant status.
In the past two years: Do you, or does someone in your family, work in agriculture – the farm fields, nursery, tree farm? Is that work a major source of your family's income? Have you, or has someone in your family, moved away from your regular home to do this kind of work?
If client answers “yes” to all questions, they must be considered a migrant farm worker according to the Colorado WIC Program.
Providing WIC Program Services to Migrant Farm Workers In order to overcome the barriers to migrant farm worker participation and provide quality services, the State and local agencies must do the following.
Provide a Verification of Certification (VOC) Staff should provide a Verification of Certification (VOC) form at the first participant visit so that if the participant moves, he/she does not need to certified in each area to which they travel. The agency must provide program benefits until the certification period written on the VOC expires.
Complete Income Determination The income of a migrant farm worker family must be determined at least once a year. Any determination that a migrant farm worker has met the income guidelines, either in the migrant farm worker’s regular home location
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before beginning farm work for a particular agricultural season or in another area during the agricultural season, shall satisfy the income criteria for the migrant farm worker participant in any state for any subsequent certification during that agricultural season. (This procedure applies only to migrant farm workers.) If there is no indication on the VOC form that this was completed, the local agency must determine financial eligibility at the next certification. Lack of documentation for income should not be a barrier for migrant farm worker families to receive WIC benefits. Farm workers who are unable to provide documentation of income may self- declare their income by signing an affidavit.
Ensure no Double Food Issuance It is likely that individuals will receive and redeem food benefits in one state just prior to departing to another state. When they present their VOC cards in the second state, they may still be within the 30-day period of the previous food issuance. Staff must ensure that the participant does not receive double benefits. If benefits have been redeemed for the current month, staff may not provide benefits until the next month. Staff must collect and destroy unused benefits. If benefit information is unavailable, staff should call the previous clinic to verify if the participant has redeemed the benefits.
Tailor Food Packages Staff may tailor food packages to meet the participants’ individualized needs. With eWIC, participants can purchase as many or as few items as desired per shopping trip and have the option to purchase canned or powdered milk in lieu of fresh milk and canned beans or peanut butter in lieu of dry beans. Participants with a poor water supply, no refrigeration, or limited storage may prefer to have food packages with options such as ready-to-feed formula, juice in individual serving containers, shelf stable (UHT) milk, extra peanut butter or beans instead of eggs (at the substitution rate of 18 oz peanut butter or 1 pound beans for 1 dozen eggs).
Follow Processing Standards for Certification and Priority Determinations The local agency must notify the migrant farm worker applicant of his/her eligibility within 10 calendar days of the first request for program benefits. Normal screening procedures will be used and all applicable nutrition risk factors assigned. At a minimum, these applicants must be considered at nutritional risk solely because of their migrant farm worker status. The applicant will be given a priority rating (1-6) using the same criteria as for all WIC participants.
In cases where a local agency is at the maximum participation level and the state has no additional funds to provide to the agency, a person with a valid VOC must be placed ahead of all other persons on a waiting list. This is because any participant with the current certification is entitled to continue receiving program benefits before a person who is not yet participating in the program. If a migrant farm worker with a current VOC arrives, he/she should be placed first on the list. However, if a migrant farm worker participant arrives with an expired VOC at an agency at maximum participation, he/she should be placed on the waiting list according to the priority rating, as any other potential participant.
Provide Nutrition Education Providing comprehensive nutrition education to migrant farm worker participants can be challenging due to the participant's transient lifestyle. Because a participant may only be enrolled for a short period of time, ongoing, long-term education goals may not be appropriate. Although they may have access to nutrition education, often they are not in an area long enough to benefit continuously from any comprehensive nutrition education program designed by a state or local agency. In some instances, language barriers exist which also add to the difficulty of supplying appropriate nutrition education to migrant farm worker families.
Many migrant farm workers have participated in WIC Programs in other states where food delivery, allowable foods, and the method of payment (i.e. eWIC card) are very different. Therefore, priority topics for education should include: How to use WIC food benefits. A description of WIC allowable foods in Colorado. How to use the WIC foods with limited storage and cooking equipment.
Nutrition education concerning food preparation should be suited to the participant's situation. For instance, many migrant farm worker parents work in the fields for long hours and do not have time to prepare complicated meals. Tips on food preparation in nutrition education sessions should take this into consideration.
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Printed Spanish nutrition education materials are available from the State WIC Office and online versions are available on the USDA WIC Works Resource System. Refer to the CO WIC Program Materials Order Form posted on the Colorado WIC Program web site for the complete listing.
Migrant farm workers in Colorado are from various ethnic groups. It is important that those providing nutrition education understand the ethnic dietary practices of these groups. One of the most important factors in teaching nutrition to various cultural groups is to point out the positive aspects of the diet and suggest only those changes that will fit into the lifestyle of the family.
Conduct Outreach Outreach to migrant farm worker participants is needed more than outreach to the general WIC population because their newness to the area often means they do not know where to obtain WIC services. Outreach is also necessary to overcome the isolation from the main population, which is inherent to the migrant farm workers’ lifestyle.
Contact Farm Worker Groups Local farm worker organizations are another important community resource for assistance in reaching migrant farm worker participants. Migrant farm workers usually know these organizations and the organizations are very familiar with the situations of migrant farm workers in their area. Some farm worker organizations may be willing to assist the local agency in conducting outreach, or the local agency may wish to contract with the organization for outreach services. At a minimum, these groups can provide information on when to expect migrant farm workers to arrive, how many usually come, how long they will stay and where they are likely to live.
Offer Flexibility of Services Another very important factor in serving migrant farm workers is flexibility of service hours. Since farm work is so unpredictable, migrant farm workers must work when employment is available. If the mother or other adult responsible for WIC appointments is working in the fields, she or he may be unable to make appointments during daytime clinic hours. One solution to this problem is for the WIC staff to schedule after-hour clinics for certification appointments and then offer alternate nutrition education methods for follow up visits, such as wichealth.org or a telephone or interactive video call while still providing an effective second nutrition education contact. If the participant chooses an alternate nutrition education method for the follow up visit, food benefits can be issued remotely.
Holding a WIC clinic at the migrant farm worker camp is an effective way to reach the participants. Such an approach would remove transportation problems of those who have no way to reach WIC clinics.
Additional Resources for Migrant Farm Workers
Health service locations can be accessed through the Bureau of Primary Health Care, a division of the U.S. Department of Health and Human Services at http://www.bphc.hrsa.gov/.
Information on legal services can be accessed through Colorado Legal Services, Inc., Farm Worker Division, (303) 866-9366 or 1-800-864-4330.
Other information for or about migrant farm workers is available through the National Center for Farmworker Health, Inc., 1-800-531-5120, http://www.ncfh.org/.
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Missed Appointments
Policy: Local agencies shall attempt to contact each pregnant woman who misses her first WIC appointment to reschedule the appointment. If the pregnant woman is enrolled in the WIC Text/Voicemail Messaging Program, a missed appointment text will be sent automatically. Staff do not need to make an additional contact. However, staff are required to contact pregnant woman who opt out of the WIC Texting Program and miss their first WIC appointment.
Local agencies may choose to enforce a Missed Appointment Policy. Once developed, the local agency must apply their missed appointment policy equally to all participants. This includes informing all participants of their missed appointment policy at Certification during the Initial Explanation of WIC.
Although local agencies are required to make reasonable efforts to provide nutrition education to each participant, individuals cannot be denied supplemental foods for failure to attend an educational activity or for lack of willingness, readiness, or ability to participate in the activity.
Regulations: 7 CFR 246.7
Procedures/Additional Guidance: Colorado WIC uses an automated messaging system to send appointment reminder text messages or phone calls, and to notify all applicants and participants of missed appointments. If the participant/applicant agrees to receive phone calls or text messages, staff must check the “Allow Calls” and “Allow Texts” boxes in the Contact/Address panel.
Agencies may also elect to notify participants when an appointment is missed by printing and mailing the Notice of Missed Appointment, accessed from the Scheduler screen by right-clicking a WIC appointment that was in the past and then selecting Notice of Missed Appointment.
Documenting missed appointments When a participant misses a scheduled appointment, staff must manually mark the appointment as “No Show” in Compass.
Contacting Participants Who Miss Appointments Contacting the participant to learn why appointments are missed can help identify and reduce barriers to keeping appointments. Options to reduce barriers include: a. Determine if the participant is eligible for an exemption from physical presence requirement due to a disability, medical condition, or an infant or child with working caregivers whose working status presents a barrier to bringing the child to the clinic. Refer to Physical Presence Requirement policy for additional information. b. Offer nutrition education at a follow-up appointment via wichealth.org, telephone or video call (if eligible). Upon completion of the nutrition education, issue food benefits remotely.
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Non-Discrimination Statement
Policy: The following non-discrimination statement must be used in full on all materials and sources (such as websites) used to inform the public about or describe the WIC Program (such as outreach and referral materials), denial and termination letters, missed appointment policies, reminder materials, eligibility standards, and program applications. Internal and interdepartmental newsletters, as well as those meant for participants and/or other outside agencies, that are used to convey WIC benefits and participation requirements, should also include the non-discrimination statement. If the material is too small to permit the full statement to be included, the material will at a minimum include the statement, in print size no smaller than the text, that “This institution is an equal opportunity provider.”
The non-discrimination statement is not required to be imprinted on items such as cups, buttons, magnets, and pens that identify the WIC Program, when size or configuration make it impractical or on nutrition education and breastfeeding promotion and support materials that strictly provide a nutrition message with no mention of the program.
In addition, recognizing that Internet, radio and television public service announcements are generally short in duration, the nondiscrimination statement does not have to be read in its entirety. Rather, a statement such as "This institution is an equal opportunity provider” is sufficient to meet the nondiscrimination requirement.
English nondiscrimination statement – long form: In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex, disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA.
Persons with disabilities who require alternative means of communication for program information (e.g. Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English.
To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD- 3027) found online at: https://www.usda.gov/oascr/how-to-file-a-program-discrimination-complaint, and at any USDA office, or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by:
(1) mail: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-9410; (2) fax: (202) 690-7442; or (3) email: program.intake@usda.gov.
This institution is an equal opportunity provider.
English nondiscrimination statement —short form This institution is an equal opportunity provider
Spanish Non-Discrimination Statement - long form: De conformidad con la Ley Federal de Derechos Civiles y los reglamentos y políticas de derechos civiles del Departamento de Agricultura de los EE. UU. (USDA, por sus siglas en inglés), se prohíbe que el USDA, sus agencias, oficinas, empleados e instituciones que participan o administran programas del USDA discriminen sobre la base de raza, color, nacionalidad, sexo, discapacidad, edad, o en represalia o venganza por actividades previas de derechos civiles en algún programa o actividad realizados o financiados por el USDA.
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Las personas con discapacidades que necesiten medios alternativos para la comunicación de la información del programa (por ejemplo, sistema Braille, letras grandes, cintas de audio, lenguaje de señas americano, etc.), deben ponerse en contacto con la agencia (estatal o local) en la que solicitaron los beneficios. Las personas sordas, con dificultades de audición o discapacidades del habla pueden comunicarse con el USDA por medio del Federal Relay Service [Servicio Federal de Retransmisión] al (800) 877-8339. Además, la información del programa se puede proporcionar en otros idiomas.
Para presentar una denuncia de discriminación, complete el Formulario de Denuncia de Discriminación del Programa del USDA, (AD-3027) que está disponible en línea en: https://www.usda.gov/oascr/how-to-file-a-program-discrimination- complaint y en cualquier oficina del USDA, o bien escriba una carta dirigida al USDA e incluya en la carta toda la información solicitada en el formulario. Para solicitar una copia del formulario de denuncia, llame al (866) 632-9992. Haga llegar su formulario lleno o carta al USDA por:
(1) Correo postal: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-9410; (2) Fax: (202) 690-7442; o (3) Correo electrónico: program.intake@usda.gov.
Esta institución es un proveedor que ofrece igualdad de oportunidades.
Spanish nondiscrimination statement—short form Esta institución es un proveedor que ofrece igualdad de oportunidades.
Regulations: FNS Instructions 113-1
Procedure/Additional Guidance: Include the nondiscrimination statement on all materials and information sources as required by policy.
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Nutrition Assessment
Policy: Staff must conduct a thorough nutritional assessment, which includes completing a Nutrition Interview. A nutrition interview must be completed at certification, recertification and mid-certification appointments. All questions within the Nutrition Interview must be asked and documented. The exceptions to this include: • The anthropometrics fields for the the biological mother and father. • Local agencies that need to suspend referrals to the Breastfeeding Peer Counseling (BFPC) program for caseload management purposes may skip the BFPC support question.
Many questions lead to assignment of risk factors. Breastfeeding information within the interview may be updated as needed at follow-up appointments.
Note: Some questions in the Nutrition Interview are in bold font, this indicates questions used for data surveillance.
Regulation: CRF 246.4(a)(19)
Procedure/Additional Guidance: A thorough WIC nutrition assessment evaluates the following areas: Growth Iron/Lead Screening Health/Medical Nutrition Practices Lifestyle Personal Factors
Growth: Growth is assessed by taking anthropometric measures on a regular basis and tracking growth patterns. Measures used to assess growth include: stature/weight, BMI, and prenatal weight gain. Growth is an important indicator of nutritional status. For example, poor growth may reflect inadequate nutritional intake or signal an underlying medical problem. Overweight can be associated with current or future health problems in both children and adults. Deviations from normal growth should be referred for follow up since early identification and intervention can prevent more serious health outcomes.
Iron/Lead Screening: Iron levels are measured regularly by performing either a hemoglobin or hematocrit test. The purpose of iron screening is to identify and prevent anemia (low iron in the blood). Lead levels for children are recorded from screenings done outside of WIC. Elevated blood lead levels can adversely affect behavior, development, and IQ. If a child has not had a lead testing, they must be referred to programs where they can obtain such a test.
Health/Medical: Health and Medical history and current conditions are assessed using the Nutrition Interview. Examples of medical conditions that have nutrition implications are: diseases (such as PKU, diabetes, high blood pressure), food allergies, and physical and mental disabilities. Additionally, medications can affect appetite. High-risk medical conditions require a follow up appointment with the high risk counselor at each certification period within 30 days of high risk identification.
Nutrition Practices: The WIC nutrition practices assessment is conducted through dialogue with the client about breastfeeding, if applicable, the foods they usually eat and their regular eating patterns. Using a discussion format, the WIC educator begins the interview with open-ended question asking the client to describe their typical eating and drinking habits. The educator evaluates the client’s response against professionally recognized guidelines (e.g. Dietary Guidelines for Americans, My Plate Food Guide, and American Academy of Pediatrics) and the following criteria that are associated with a healthy diet: A variety of foods derived from different food groups Few processed foods in the diet Majority of foods consumed are nutrient dense (they contain a lot of vitamins and minerals) The amount of food eaten is appropriate
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 01/01/2025 Page 2 of 2 Good eating habits (this includes having family meals, eating at set times rather than grazing, children not drinking from the bottle, etc.)
Then, based on the client’s responses, the WIC staff person asks further questions to obtain additional information and/or clarify what has been said.
Breastfeeding complications and the breastfeeding description are included on the Infant Nutrition Interview under Nutrition Practices. The following table identifies an infant or child’s breastfeeding status:
Description Definition Exclusively Breastfeeding Has been fed only human milk, vitamins, minerals, and/or medications. (This is equivalent to the CDC definition of exclusive) Primarily Exclusive/ No Formula Package
Has been fed something other than human milk, vitamins, minerals and/or medications on rare occasion or one time feeding of infant formula, human milk fortifier, cow’s milk, juice, sugar water, rehydration solution, water, baby food, or anything else. This identifies an infant whose exclusive breastfeeding is interrupted because of special circumstances (e.g., acute illness, hospitalization, caregiver misinformation) is fed. Primarily Exclusive/ Complementary Foods
Has been fed any complementary foods (e.g. cereal, baby food, table foods) in addition to only being fed human milk, vitamins, minerals and/or medications. These foods are provided on a routine or ongoing basis regardless of the amount. Partially Breastfeeding Breastfeeding and receiving formula (WIC or non WIC supplied formula). May also be fed complementary foods. Breastfeeding Child Greater than or equal to 12 months and continuing breastfeeding. No Longer Breastfeeding Was breastfeeding at some point in time but has now discontinued. Never Breastfed Was never breastfed.
Lifestyle: Assessment of lifestyle involves finding out about physical activity (including the types and amounts of physical activity they get) and substance use (such as abuse or exposure to alcohol, drugs, cigarettes or second hand smoke).
Immunizations: Immunization information is captured during the infant and child interview for DTaP shot records only.
Oral Health: Oral health information is captured during the infant and child interview to obtain information regarding dental and other oral health concerns.
Breastfeeding Support: For all breastfeeding women, breastfeeding support is included as part of the assessment during the nutrition interview. Breastfeeding complications and assignment of the BFPC are captured on this panel.
Social Environment: Social Environment includes: culture, family structure, education, living and work situations, abuse/neglect, family planning and primary caregiver with limited ability to make appropriate feeding decisions. Understanding social environment enables WIC staff to provide client centered care and individualized referrals and counseling.
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Nutrition Education
Policy: Local agencies shall offer nutrition education at no cost to all WIC participants, parents, or caregivers according to federal regulations and state guidelines Agencies have the option to enter into an agreement with another agency to offer participant nutrition education.
Nutrition education may be provided through individual or group sessions. During each six-month certification period, at least two nutrition education contacts must be made available. When participants are certified for longer than six months, nutrition contacts shall be made available at a quarterly rate.
Nutrition education shall be participant-centered and include behavior change counseling. Goals must be set and followed-up on at subsequent appointments.
Note: A chart review does not count as a nutrition education contact for low or high risk participants.
Regulation: [246.11(b)]: 246.11(d)
Procedure/Additional Guidance: WIC provides nutrition education along with supplemental foods to guide participants toward a healthier lifestyle and to help them make changes to improve their dietary intake. Using a participant-centered approach helps to enhance the effectiveness of these activities.
Type of Nutrition Education Contacts In-Person Education: An in-person visit with the participant is provided either individually or in a group, and includes participant-centered nutrition education. A participant-centered nutrition education approach should address participant needs (NRFs), participant concerns, and/or relevant anticipatory guidance topics. Ideally, only 1-2 topics are addressed during a single visit. Topics not discussed during the appointment can be entered into the participant’s Plan to be addressed at a future visit.
Remote Education: Remote nutrition education options include: Phone: As with in person education, provide participant-centered education. All required components of a WIC visit must be performed per policy, including nutrition education, goal setting, and documentation. During the end of the phone contact, food benefits will be issued remotely, and a subsequent visit scheduled. Wichealth.org: An internet-based, online nutrition education website available in English and Spanish. Verification that the endorser completed a wichealth.org nutrition education lesson automatically uploads into the household’s Nutrition Education panel in Compass. Completion of a corresponding Care Plan is not required. The goal set at the prior in-person or phone appointment may be followed-up on at the nutrition education contact. Upon completion of an online lesson and during the month the participant’s food benefits expire; staff will verify the lesson completion, contact the participant, and issue food benefits remotely. Program and nutrition-related assistance and follow up must be available to address questions and to provide feedback to endorsers. Note: This education contact option is only for low-risk participants. Interactive Video Call: Technology that allows video conference calls. As with in person education, provide participant-centered education. All required components of a WIC visit must be performed per policy, including nutrition education, goal setting, and documentation. During the end of the video call contact, food benefits will be issued remotely, and a subsequent visit scheduled. The local agency will provide for installation and maintenance of the equipment necessary for the video call contact. Interactive video calls should occur in an environment that promotes effective communication between the WIC staff and the participant and ensures that both are actively involved in the interaction. The confidentiality of participant information must be protected.
Providing Participant-Centered/Behavior Change Counseling
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The education part of the visit should flow naturally from the assessment because it ties in with the participant‘s questions and concerns. However, sometimes no clear direction emerges and in this case, the WIC staff person works with the participant to develop an agenda for topics to discuss. Ways to do this are: Ask the participant about any nutrition questions or concerns they would like to discuss. Nutrition information provided during the visit should match the participant’s needs and interests. Suggest topics based on information gathered during the assessment. Suggest topics that provide anticipatory guidance.
Tips for discussing nutrition information with participants: Use a conversational format. Find out what the participant already knows about a topic and fill in the gaps. Affirm the things that are going well. Be non-judgmental. Personalize education so the participant understands how making changes can improve their health and well- being.
Readiness to Change Counseling While sharing nutrition information, WIC staff should assess the participant’s interest in applying the information to their life by making behavior changes. Sometimes participants are ready to change. Sometimes they are not. Or they might be anywhere between. It is important to get a sense for how ready to change a participant is in order to tailor counseling to meet them where they are. Applying readiness to change counseling is useful for providing ideas for ways to approach participants who are in different stages of readiness to change. The chart below describes readiness to change and the recommended counseling strategy associated with it. Readiness to Change Counseling
Level of Readiness to Change Counseling Strategy
Not Ready or thinking about changing Raise awareness. Be prepared not to push for change. This is likely to cause more resistance.
Uncertain about making a change Explore pros/cons of change, concerns/fears
Ready to change Have the participant talk about the reasons for, importance of, or their plans for change.
Goal Setting Goal setting is an important component of behavior change counseling because it encourages the participant to put into action something discussed during the appointment. The goals set with participants will differ depending on their readiness to change. For participants not ready to change, appropriate goals are ones that help to raise awareness or encourage the participant to think through the pros and cons of change. Examples of goals that are appropriate for no or low readiness to change are to simply read over educational material, to talk to a partner, or to think about what it would look like to make a specific change. These goals may not seem very ambitious; however, they are realistic and consistent with the participant’s motivation and readiness to change. As the participant becomes more committed to making a change, appropriate goals will be ones that are more action oriented. For example, the goal may be to have the participant take small steps toward making the behavior change.
When setting goals with participants it is important to remember these principles: Goal setting should be done interactively with the participant. WIC staff’s role is to suggest ideas for goals that might be appropriate for the participant’s readiness to change. It is the participant’s role to make the decision about what they are able and willing to do. Goals should be specific. A clearly stated goal is easier to follow. Write down the goal (perhaps on a handout) as a reminder after they leave the appointment.
Documentation - Document the goal in the Participant Care Plan. The goal should be described clearly, so that WIC staff can easily follow up on the goal with the participant at the next appointment.
Follow up - Since behavior change is a process, it is important to follow up at the next visit by asking the participant about their progress in achieving their goal. Offer praise for any efforts they have made and provide support as appropriate. It may be necessary to adjust the goal to make it more doable.
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Following up on goals helps to increase the participant’s accountability, provides opportunities for support and problem solving, and demonstrates to the participant that WIC cares about helping them make changes. Document follow up discussion(s) about goals in either the Subjective or Assessment section of the Participant Care Plan.
Nutrition Educational Materials: WIC’s nutrition educational materials help reinforce educational messages. Certain materials are available to order in print and all materials are available electronically to share via email or text.
Missed Nutrition Education Appointments and Non-Denial of WIC Benefits Although local agencies are required to make reasonable efforts to provide nutrition education to each participant, individuals cannot be denied supplemental foods for failure to attend an educational activity or for lack of willingness, readiness, or ability to participate in the activity.
When a participant does not attend or participate in a scheduled nutrition education contact, document why this occurred in the Participant Care Plan.
When a participant misses a scheduled appointment, offer the nutrition education contact the next time you make contact with the participant.
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Nutrition Education Plan
Policy: Each Local WIC Agency must develop an annual Nutrition Education Plan (NEP) that is consistent with the nutrition education component of the State WIC Agency’s Nutrition Education Annual Plan.
Regulation: 7 CFR 246.11 (d) (2)
Procedure/Additional Guidance: The Colorado WIC Local Agency Nutrition Education Plan Workbook provides an overview and general planning guidance. The Workbook serves as an additional resource for LA WIC Directors and is especially helpful for those new to this annual planning process.
The Nutrition Education Planning process involves: 1. Conducting a needs assessment 2. Identifying goals based on identified needs 3. Developing measurable objectives to meet the goals 4. Developing an intervention plan including Identifying strategies, tasks and timelines 5. Developing an evaluation plan 6. Evaluating the Nutrition Education Plan from the previous year
The State Office will provide sample Nutrition Education Plan templates for each year’s specific focus areas for local agency consideration in development of Nutrition Education Plans. Whether and how they are used is up to the local agency. An agency may insert agency-specific information in a chosen template or can modify the template to accommodate their own plan.
Timelines: - July 1: The state office sends Nutrition Education Plan instructions and specific annual objectives to local agencies - September 1: The local agency submits their agency’s completed Nutrition Education Plan to their Nutrition Consultant - September 1 – 30: The Nutrition Consultant provides feedback on the agency’s Nutrition Education Plan - September 30: The Nutrition Consultant approves the agency’s final Nutrition Education Plan - October 1: The local agency begins implementation of the Nutrition Education Plan - October 31: The local agency submits an evaluation of their previous year’s Nutrition Education Plan to their Nutrition Consultant - November 30: The Nutrition Consultant approves the evaluation of the previous year’s Nutrition Education Plan
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COLORADO WIC PROGRAM
LOCAL AGENCY NUTRITION EDUCATION PLAN
WORKBOOK
Colorado WIC Program Local Agency Nutrition Education Plan Revised: 10/01/2018
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Workbook Table of Contents
Introduction ....................................................................................................... 2
Instructions for Completing Plans & Evaluations ............................................................ 3
Nutrition Education Planning Guidance ....................................................................... 4 Needs Assessment ............................................................................................. 4 Data Sources .................................................................................................... 5 Developing a Nutrition Education Plan ..................................................................... 6
Evaluating Achievement of the Previous Year’s Local Agency Nutrition Education Plan ................ 9
Example: Needs Assessment Worksheet ..................................................................... 10
Example: Strategies & Activities .............................................................................. 11
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1. INTRODUCTION
Federal Regulations: Federal Regulations: CFR 246.11 d Local Agency Responsibilities “(2) Develop an annual local agency nutrition education plan consistent with the State’s nutrition education component of Program operations and in accordance with this part and FNS guidelines. The local agency shall submit its nutrition education plan to the State agency by a date specified by the State agency.”
Colorado WIC Policy: All Colorado local WIC agencies are required to develop their own annual nutrition education plans that are consistent with the nutrition education objectives of the Colorado WIC Program Work Plan annual objectives.
Examples of Colorado WIC Program Strategic Priorities: Increase program participation Improve program quality and integrity Grow the demand for and ease of access to healthy foods Enhance collaboration with organizational stakeholders Promote breastfeeding as the preferred method of infant feeding Increase the initiation, duration and exclusivity prevalence rates of breastfeeding among the WIC population Improve local agency staff competency Focus on Early Childhood Obesity Prevention (ECOP) efforts
The Nutrition Education Planning process involves: 1. Conducting a needs assessment 2. Identifying goals based on identified needs 3. Developing measurable objectives to meet the goals 4. Developing an intervention plan including Identifying strategies, tasks and timelines 5. Developing an evaluation plan 6. Evaluating the Nutrition Education Plan from the previous year
The State Office will provide sample Nutrition Education Plan templates for each year’s specific focus areas for local agency consideration in development of Nutrition Education Plans. Whether and how they are used is up to the local agency. An agency may insert agency-specific information in a chosen template or can modify the template to accommodate their own plan.
Timelines: - July 1: The state office sends Nutrition Education Plan instructions and specific annual objectives to local agencies - September 1: The local agency submits their agency’s completed Nutrition Education Plan to their Nutrition Consultant - September 1 – 30: The Nutrition Consultant provides feedback on the agency’s Nutrition Education Plan - September 30: The Nutrition Consultant approves the agency’s final Nutrition Education Plan - October 1: The local agency begins implementation of the Nutrition Education Plan - October 31: The local agency submits an evaluation of their previous year’s Nutrition Education Plan to their Nutrition Consultant - November 30: The Nutrition Consultant approves the evaluation of the previous year’s Nutrition Education Plan
The Nutrition Education Plan should include Performance Management and Quality Improvement Performance management is routine monitoring of action plans to inform ongoing implementation. Committing to reviewing priority action plans and progress on a weekly or monthly basis will increase focus and increase the likelihood of achieving goals. It will also help staff identify what is getting in the way of achieving goals and if the direction needs to change because the plan isn’t working as originally designed. Performance management helps us keep track of what we are doing.
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Quality improvement (QI) is a set of tools and practices used to overcome those barriers identified when reviewing action plans. QI can help “clear the path” for implementation success. QI can also be used to understand the ingredients for success in order to build on future efforts for greater impact. Quality improvement helps us understand and enhance how or how well we do our work.
2. INSTRUCTIONS FOR COMPLETING THE LOCAL AGENCY NUTRITION EDUCATION PLAN & PREVIOUS YEAR’S EVALUATION
Review Materials Review the materials provided including introduction, instructions, planning guidance, and information sheet and plan templates. Nutrition education plan templates are provided to serve as a tool for agencies to use to develop their annual plan.
Research Local Agency Needs and Obtain Data A needs assessment, although optional, can help identify those areas of highest need to address. You need not submit this to State Office. You may use the needs assessment example worksheet provided in this document or another method. If you use the worksheet provided, note that not all questions are relevant to every program. Disregard questions that do not apply. The questions are not intended to imply expectations rather they are simply things to consider.
Develop a Program Plan Develop a timeline for completing each of the selected focus areas of your plan. The plan involves identifying intervention strategies and linking planned activities to outcomes in the plan. We recommend that you work on developing one focus area at a time. Additionally, consider how to involve your staff in the assessment and planning process. A logic model (described in Section III) is a great way to begin the program planning by capturing your program’s overall vision and making sure your strategies are clearly linked to your short, mid, and long-term intended outcomes.
Complete the required Local Agency Nutrition Education Plan templates Determine the number of Nutrition Education Plans that are feasible to achieve based on staffing and resources available. Larger agencies may find it feasible to complete more than one Plan. There is no limit to the number of Plans an agency may implement.
Agencies are encouraged to: Use the sample nutrition education plan templates provided by the State Office and insert agency-specific information in a chosen template, or Modify the template to accommodate your own plan, or Use a blank template to develop your own plan that involves one of the focus areas.
If choosing to develop your own plan, steps for completing the plan are outlined in Section 3. After completing the needs assessment, obtaining data and developing a plan, choose one of the provided goals for the focus areas your agency has selected. For each goal identify the following:
1-2 SMART objectives to focus the specific aims of your agency in contributing to achievement of this goal Lead staff for each objective Target population Criteria for success and measurement tool(s) Specific strategies Key activities necessary to complete the action steps Target completion date, person or group responsible and plan for monitoring progress towards that key activities:
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Please note: If your program is currently implementing an activity that falls under any of the focus areas, you may use this continuing activity for your plan. Each local agency is unique in terms of population served, staffing and resources. Thus, the scope of the activities planned by each agency will differ. Local agencies should submit plans that are realistic for them to accomplish even if the scale of the activities seems small.
Submit your Local Agency Nutrition Education Plan Submit your Local Agency WIC Nutrition Education Plan electronically to your nutrition consultant by September 1. You will receive State Office feedback on the plan no later than September 30. Plan implementation period is October 1 through September 30. Should September 1 be unrealistic for you, determine a mutually agreeable timeline with your Nutrition Consultant.
Submit the Local Agency Nutrition Education Plan Evaluation of the previous year’s Nutrition Education Plan Complete the evaluation sections on your previous year’s Local Agency Nutrition Education Plan and Evaluation template. Submit the evaluation to your nutrition consultant by October 31. Should October 31 be unrealistic for you, determine a mutually agreeable timeline with your Nutrition Consultant.
3. NUTRITION EDUCATION PLANNING GUIDANCE
If the thought of doing a nutrition education plan intimidates you, you aren’t alone. Fortunately, as a dietitian, nurse or other health professional, you already know the value of planning. A well thought-out plan identifies realistic goals and the steps most likely to lead to successful achievement. This plan can guide decisions about what to do next and the creation of monthly and/or weekly “to do lists.” It helps keep team members clear and accountable for key activities or milestones.
In addition to providing a road map to reach specific goals, good planning provides other benefits, such as: Increasing the potential to improve staff morale and support for program initiatives when staff members are included in the planning process. Providing the ability to both recognize and measure successes in program outcomes. Prioritizing resources to ensure they are used effectively and efficiently. Providing a concrete tool with goals, objective, strategies and key activities that help guide your program.
NEEDS ASSESSMENT The needs assessment portion of your program planning is optional and an actual needs assessment worksheet does not need to be turned in to the State Office. The purpose of the assessment is to provide a broad understanding of needs, contributing factors and resources for change - in the same way that a patient assessment integrates different types of information (e.g., biochemical, anthropometric, social, cultural, educational, etc.), a program assessment includes a broad range of information. In both cases, the value of the assessment cannot be overestimated as it supplies information that is essential for planning.
In program planning, the assessment identifies the strengths and weaknesses of a program as well as the barriers and resources for making changes. A thorough assessment generally consists of both objective (hard facts, numerical data) and subjective (based on personal opinion) information. Examples of objective information include breastfeeding rates, the number of participants served and participant survey results. Subjective data
A good plan is like a road map: it shows the final destination and usually the best way to get there. --H. Stanley Judd
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sources include information gathered from focus groups, local agency surveys, and feedback collected from staff during clinic meetings. A template example for completing the needs assessment is located in Section IV. The needs assessment process should focus on the nutrition education focus areas of the Local Agency Nutrition Education Plan. You may find that you want to continue working on goals and objectives from the previous year’s plan which is perfectly acceptable.
DATA SOURCES Data are crucial to program planning. It informs both the needs assessment and evaluation. Data from local sources is called program level data. This data is collected by the local entity for its own purposes, typically through Compass Reports, surveys, interviews, chart reviews, meeting minutes, employee or clinic records, etc. It may also include data from WIC Data Central. The advantages of program-level data are that they speak to your clinic’s or your community’s particular activities and performance. This is the data that should be used to measure the criteria for success activities; listed in the as measured by section of your plan. For specific Compass data requests related to your Nutrition Education Plan, please contact your Nutrition Consultant.
Program Level Data Sources State Run WIC Reports: The Compass computer system has several helpful reports available to local agency staff members to utilize for data collection. Several reports are included here but there are others that may be helpful. Breastfeeding Reports: Breastfeeding Equipment Issued: shows of breastfeeding equipment (serialized and non-serialized) by type that has been issued during the time period. Breastfeeding Prevalence; this report is used to evaluate exclusive breastfeeding at birth, three months, and six months of age and to evaluate the age to which breastfeeding continued during infancy and childhood. Exclusively Breastfeeding and Formula Issuance Report; shows trends for exclusively, primarily exclusive/no formula package and primarily exclusive/Complementary Food for breastfeeding infants through their first birthday. First Formula Introduced Report; shows which month formula was first introduced Reason Ceased Breastfeeding Report; shows the number of breastfed infants and children and the reasons why breastfeeding ceased. Colorado WIC Exclusive Breastfeeding and Formula Issuance report (available at www.breastfeedcolorado.com).
Program Participation Reports: Appointment Summary Report; shows the number of appointments kept, missed due to no show, cancelled, rescheduled and mass rescheduled. Participation with Benefits Report; shows the participation for the specified month and is broken down by participant category. This can be used for caseload management purposes. Termination by System Report; may be used to follow up with those participants that have been terminated due to not pickup up food benefits, failure to provide proofs, etc. Processing Standards Non-Compliance Report; shows the participants that were not scheduled within the required processing standards and the reason this occurred.
Local Data Sources: Data from participant record reviews Data from participant redemptions Data from county run reports Data from WIC Data Central Data from wichealth.org Usage Statistics Questionnaires designed to collect pre/post intervention information Interviews Surveys Focus groups Staff meeting minutes Employee performance plans and supervision records Email record of communications
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DEVELOPING A NUTRITION EDUCATION PLAN Planning is enhanced when it involves a team of individuals. This ensures that a variety of perspectives is considered and increases ownership in the plan.
STEP 1: Choose your Goals and Objectives For the focus areas, the state office has developed templates with overarching goals. Local WIC agencies will complete the template for the required focus areas. Local agencies may develop and submit additional plans if desired.
STEP 2: Use a Logic Model to Plan your Intervention A logic model is an optional step in the planning process but can be a useful tool to plan your intervention. A logic model is a visual representation linking planned activities with their intended outcomes. The purpose of the logic model is not to outline the steps needed to implement the intervention, but rather to show at a high level which interventions are expected to achieve which desired outcomes and in what order. This is illustrated by the example below where the intervention is a class on healthy eating. The diagram shows how the intervention is intended to impact the goal by first achieving intermediate outcomes that lead to the ultimate goal. But your logic model does not show the detailed work that will be involved in creating the intervention – that gets outlined in your NEP (below). Once a logic model is created, it should be discussed with others and modified as needed. The logic model becomes an important tool in developing action steps and monitoring outcomes.
Goal: Colorado WIC families consume healthier foods and beverages Intervention: Have a WIC class for caregivers and children where children learn to make healthy snacks. Target Population: WIC children age 2-5 and their caregivers. Intermediate Outcome: Increase the knowledge of WIC participants regarding healthy snacks for children. Long-Term Outcomes: By getting children involved and teaching them about healthy snacks they will be more likely to ask for healthy snacks.
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STEP 3: Develop SMART Objectives The SMART objectives you create are the anchor of your nutrition education plan and represent the incremental changes your agency needs to achieve in order to accomplish the stated goal (from above). Objectives are specific and measurable steps or outcomes that lead to the goal. In crafting your objectives, translate the intermediate outcomes from your logic model into 1-2 objectives for each focus area of the plan. Remember that objectives are achievements, not strategies, activities or tasks. They are the “what” not the “how”. They define the change you want to see from your work, in clear and specific terms. A lead staff must be assigned to oversee the work on each objective.
You can have process or outcome objectives. PROCESS Objectives are about a change in how you conduct your program and accomplish your strategies. Example: Increase attendance at breastfeeding classes by 20% from January 2019 to September 2019. OUTCOME Objectives are about changing a specific outcome (knowledge learned, behaviors modified, conditions improved). Example: At least 80% of new moms score at least 8 out of 10 on Breastfeeding True/False Checklist.
SMART Objectives are the “big steps” a program will take to attain its goal. They should be: Specific (who, what, and where –describe!), if change is desired, include both the current “level” and desired “level”
from XY Increase exclusive breastfeeding rate from 30 days to 45 days Measurable (how many, how much, to what quality standard), This is the EVALUATION part Identify a system of method of tracking Existing data collection method or develop one Example: Run the Exclusively Breastfeeding and Formula Issuance Report monthly Achievable (attainable with resources available), Consider resources and potential obstacles Set yourself up for success Relevant (achieving this adds value & progress toward goal), Important to your organization Time-bound (by when), Clearly state the target date
SMART Objective Example: By September 30, 2019 Faraway WIC will have increased the exclusive breastfeeding rate of breastfeeding from 30 days to 45 days for at least 80% of WIC participants.
Caregivers Learn how to make healthy snacks Purchase appropriate snack foods and beverages Define a healthy snack Kids ask for new snacks Easier for caregivers to give healthy snacks if kids request them Colorado WIC families consume healthier foods Class on Healthy Snacks Kids
Acceptance of new foods Diagram 1: Logic Model for WIC Agency Intervention Intermediate outcomes Target Population Long-term outcomes Goal
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STEP 4: Complete the Nutrition Education Plan Template Once you have chosen your goals and developed 1-2 Smart objectives for each goal, you are ready to complete your Nutrition Education Plan. The remainder of the plan requires you to define a target population, criteria for success, data source, strategies and key activities.
If using the plan template provided by the State Office the remainder of the plan requires you to insert and/or modify agency-specific information, indicate who will be the lead for each objective, and the anticipated date of completion for each key activity and who will be responsible.
Target Population The target population is the group or groups your plan directly impacts through the defined objective. This can be all WIC participants or a select category that you identify.
Criteria for Success and Measurement The criteria for success and measurement are the evaluation components of the plan. They bring the spotlight on the “S” and “M” part of your smart objective. They should always be stated as specifically as possible.
Definitions: Criteria for Success: Briefly describe what will be observed if the objective is met successfully As Measured By: Briefly describe how the criteria will be measured
Example: Criteria for Success Collected data shows that 100% of appointments meet processing standards As Measured by (Data Source) Compass Processing Standards Non-Compliance Report
Strategy Enter the strategy developed from your planning and/or logic model that addresses the stated objective. A strategy that includes an overall approach or type of effort to achieve one’s objective. It should state the program’s method or intervention that will achieve this increased awareness. Each strategy will include more than one key activities or steps to complete the strategy.
Example of Strategy to increase breastfeeding rates: Educate and build awareness among WIC participants about the benefits of breastfeeding.
Key Activities After the intervention strategy is identified, the key activities to implement the intervention are outlined. Key activities outline the specific activities that must be accomplished to achieve each strategy.
Examples of Key Activities for developing a class on health eating: Get input from caregivers regarding interest in a class, best times, ideas for content/design, etc. Develop a curriculum for the class Purchase (or get donations of) food and other supplies for the class
Note: Additional examples of strategies and key activities can be found at the end of this document
Monitoring Plan The monitoring portion of the implementation plan includes the start and end date, the responsible person or groups and the tracking method. Start and End Date Choose a reasonable completion date for each key activity. Some dates may be dependent upon earlier dates. It is best to list the earlier steps first in the plan. You should consider if there are any external factors that may affect the target completion date. Responsible Persons/Group Key activities are best completed with a clear indication of who is responsible for the activity.
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Tracking Method Briefly describe how you will monitor progress on this activity. Examples include tracking forms, report out at staff meetings, surveys and spreadsheets.
4. EVALUATING ACHIEVEMENT OF THE PREVIOUS YEAR’S LOCAL AGENCY NUTRITION EDUCATION PLAN
Submit the Nutrition Education and Evaluation template with completed evaluation sections for the past year’s plan by October 31. Evaluation involves the systematic assessment of objectives and key activities. The evaluation is an extension of a few key areas of your NEP: the criteria for success, the as measured by, and the monitoring plan. A good evaluation addresses two important questions: 1) Were you able to accomplish your objectives and 2) What barriers were encountered and what were the resulting changes that were made as a result. Two common categories of outcomes in public health are learning and behavior change outcomes.
1. Evaluating Learning Outcomes The purpose of evaluating is to identify whether or not the key activities were implemented as planned and whether the objective was accomplished. Evaluating the accomplishment of objectives can be a rich source for learning since unmet objectives indicate the presence of unforeseen barriers that may require modification of methods.
Evaluating Learning Outcomes
Learning Outcome Objective Categories Underlying questions addressed by the evaluation Possible Methods for Evaluation Increase awareness Do people know more about the issue as a result of the intervention? Surveys (pre/post) can compare two different groups; ask people if they think their awareness has changed. Change attitude Did people’s attitudes change? How much did they change? Survey pre/post (Comparing pre and post requires a valid instrument), can compare two different groups, ask people if they think their attitude is different, retrospective self-report Increase knowledge Do people know what they need to know? Did the intervention increase knowledge? Test of knowledge (pre/post), or just post if you are only interested in knowing if people meet a particular standard Teach a skill Can the person perform the task? Observation, peer-to peer observation, self- evaluation check list
2. Evaluating Behavior Change Behavior change outcomes differ from learning outcomes because they focus on behaviors that are exhibited. Examples of behavior change outcomes are: stopping smoking, eating more fruits and vegetables, exercising, etc. Behavior change outcomes can be evaluated in a variety of different ways. The list below contains a few different examples of the underlying questions that could be used in an evaluation. There are two things to notice about this list, first each question requires a different data source and collection strategy and second, the underlying question needs to carefully define what is being measured. The actual evaluation methods chosen for a project will be influenced by both validity issues as well as availably of data. What percentage of people exposed to the program (or who completed the program) met their behavior change goal(s)? What was the average amount of change people made (e.g., eating 1 more fruit/day, walking 10 minutes a day, etc.).
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Example: Evaluating behavior change objectives in WIC County. The primary outcome of the healthy snack classes is that children will eat healthier snacks. This outcome can be evaluated using the same questionnaire mentioned above. In addition to asking questions to assess the participant’s awareness of healthy snack options, participants could also be asked to list the snacks that were eaten during the last 3 days. Again, comparing answers given before and after the class would show if there were any changes in behavior as a result of the class.
3. Evaluating Changes in Health Changes in health are both the most significant and most elusive evaluation measures. They are significant because interventions are typically designed to improve health. But they are elusive because health outcomes are often difficult to evaluate because they can be affected by many different factors, so it can be very difficult to know if a change in health happened purely due to the intervention, or some combination of other reasons.
Example: Evaluating health outcome data in Faraway WIC County. The health outcome purpose of the healthy snack classes in Faraway WIC County was to reduce the percentage of overweight children aged 2-5. Clinic level data showing the percentage of overweight children would be available, however, it is unlikely to be sensitive to the changes that resulted from the class since only a small number of participants attended the class. Furthermore, there is likely to be a gap between the time the classes occurred and when weight would be affected. A more sensitive way to measure the impact of the classes on children’s weight would be to track the weights of the cohort of children who attended the classes. This would take more time, but would yield potentially better results. Although clinic level data may not be the best way to evaluate the impact of this particular intervention, this data would be useful to track overtime, particularly if the clinic continues to make efforts to prevent overweight and obesity.
4. EXAMPLE: NEEDS ASSESSMENT WORKSHEET
Breastfeeding Promotion and Support GOAL: Increase Colorado breastfeeding rates and duration by providing technical assistance and coaching to improve breastfeeding promotion and support to families in early care and education as well as workplace settings.
Data review: What are your local agency’s breastfeeding prevalence rates? Breastfeeding Prevalence; this report is used to evaluate exclusive breastfeeding at birth, three months, and six months of age and to evaluate the age to which breastfeeding continued during infancy and childhood. Review the lists below. Indicate with a checkmark the items that your clinic is already implementing.
Section A. Colorado WIC Breastfeeding Standards (Reference Nutrition Services – Breastfeeding section in Program Manual) Ensure that clinic area is free from all formula company materials, trademark images, office supplies (pens, water bottles, cups, etc.), formula samples, and other formula incentives. Inform pregnant women about the benefits and management of breastfeeding at initial certification and subsequent visits. Provide formula for breastfeeding infants only when requested by the mother and only after thorough counseling to ensure mother is making an informed decision. Designate a staff person as Breastfeeding Coordinator. Ensure that all High Risk Counselors are lactation management specialists able to respond to breastfeeding high risk factors. Prepare mother to communicate effectively with hospital staff about her breastfeeding decision. Ensure that breastfeeding mothers receive information about the potential impact of formula supplementation on lactation before any formula is given. Provide breastfeeding women with a list of local breastfeeding support resources (La Leche League, support groups, breastfeeding classes, etc.).
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Have an established system of referral resources for breastfeeding women who may need more specialized support or management (IBCLC, breastfeeding clinic or others).
Section B. Best Practices for Breastfeeding Promotion and Support Display breastfeeding promotion material and posters in waiting rooms and clinic areas. Have one or more staff trained as lactation management specialists. Implement a peer counselor program. Loan electric breast pumps to participants. Provide manual breast pumps to participants, as appropriate. Discourage the early use of bottles, pacifiers and artificial nipples with infants who breastfeed. Teach new mothers to recognize and respond to their infant’s hunger and satiety cues. Provide mothers with information on maintaining breastfeeding while separated from their infant. Provide a dedicated lactation room for breastfeeding moms (both participants and staff). Participate in World WIC Breastfeeding Week with special activities to promote breastfeeding. Actively participate in or initiate a community breastfeeding coalition. Write breastfeeding support policies and routinely communicate them to all staff and volunteers. Provide orientation to all new employees regarding breastfeeding support policies. Provide regular classes on breastfeeding management and support for clients. Inform pregnant women of the risks and costs associated with formula feeding.
Staff Input: Discuss with staff the barriers to breastfeeding initiation and continuation in the populations you serve. Describe any breastfeeding promotion activities that you would like to work on over the coming year.
5. EXAMPLE: STRATEGIES AND ACTIVITIES
This section includes suggestions of possible strategies and key activities to give local agencies ideas on how a plan should be completed. You may develop your plan from these suggestions or you may already have ideas.
Possible strategies and activities for each topic area include:
Breastfeeding: Leverage the strengths and assets of partners to design programs that improve breastfeeding rates. Identify a core group of individuals selecting people concerned with breastfeeding to begin the process of reach out to the community. Select diverse perspectives for your community coalition (health care professionals, lactation experts, hospital staff, employers, charity organizations, food banks, child care providers, faith communities, fathers, mothers, grandparents, policy makers, tribal councils, cultural-interest groups, organizations with similar health missions, youth). Define your community (it needn’t be just one county, consider joining with other county/ies) Investigate and evaluate sources of breastfeeding data collected by local organizations Work with Nurse Family Partnership to promote breastfeeding among teen moms Educate and build awareness of how to encourage Breastfeeding Supportive Workplaces Create awareness and provide guidance to employers for how to accommodate breastfeeding employees. Provide sample employer policies and programs. Establish a lactation policy and place within your organization Inform employers about state and federal legislation, through hosting a training through the chamber of commerce or individually Educate on the benefits to employers and employees using the US Department of Health and Human Services Business Case for Breastfeeding. Provide links to resources Publicly recognize employers who follow the laws and support breastfeeding employees. Strengthen health care professional skills and knowledge Share the link to CDC’s health care provider action guides with health care providers. http://www.cdc.gov/breastfeeding/promotion/healthcare.htm
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Encourage local hospitals, birth centers, health departments, and group practice clinicians to provide lactation training for all local health care providers (physicians, nurses and other health care professionals). Consider cosponsoring training. Assess types of training required focusing on provider needs (e.g., level of promotion and intervention, and maternal population served- prenatal, early postpartum, late postpartum, infant) Research provider preferred training methods (face to face, on-line, self paced, seminar, etc) Offer and/or recommend lactation training and breastfeeding curricula available Ensure there are International Board certified Lactation Consultants (IBCLC)in the community practicing within the local public health agency, the hospital, in a clinic, or privately Offer Academy of Breastfeeding Medicine (ABM) clinical protocols to providers Educate and build breastfeeding support in the community to meet the needs of all mothers Organize a mom to mom peer breastfeeding support group through a church, a hospital, a clinic, the local public health agency, the library, Educate parents using the Joint Commission’s Speak Up materials: https://www.jointcommission.org/speakup.aspx Develop and distribute a community breastfeeding resource lists to include where to get help with breastfeeding, where to purchase breastfeeding supplies, breastfeeding friendly employers, child care providers, etc. Investigate ways to provide breastfeeding supportive services (e.g., electric breast pump rentals through unique settings (e.g., pediatricians or other health care providers) and develop community wide referral systems Partner with hospitals to include breastfeeding promotion and education as a part of hospital birthing classes, distribute the Colorado Can Do 5! crib cards Partner with hospitals to set up a WIC electric breast pump loan program Work as a community to ban the provision of formula samples by health care providers Provide training to child care providers on infant feeding and how to be a breastfeeding friendly child care Establish a local public health agency specific lactation policy
Early Childhood Obesity Prevention: The following healthy weight promotion ideas vary greatly in target, intent, complexity and timeline. Some may be complete in one year, while others may be nutrition education plan activities for multiple years.
Educate and build awareness of the importance of interconception care Incorporate special care activities for mothers (and fathers too if appropriate) after the birth of a child. Promote reproductive life planning (planned pregnancies and child spacing). The following topics can become part of this special care just for mom: - Healthy Relationships - Future Dreams and Goals - Financial Security - Emotional Health - Family Planning - Pregnancy Prevention - Health goals for the coming years, if a child is planned in the future or not (well woman exams, healthy eating, active living, taking vitamins, oral health, family health risks) Educate and build awareness of low cost physical activity programs for WIC participants in the community and assess community barriers to healthy eating and active living Increasing access to healthy foods or opportunities for community physical activity. Connect WIC participants to the community opportunities through marketing and/or incentives. Conduct survey to determine what barriers exist with physical activity Conduct interview with participants about what they are purchasing with fruit and vegetable vouchers Identify community or regional initiatives intended to increase community opportunities for physical activity Attend community meeting to learn about proposed projects for parks, open space and activities for children Learn about what local public school program are implementing regarding health eating and physical activity Participate in local obesity prevention coalitions Provide effective and consistent messaging during WIC appointments Utilize 9 Ways to Grow Healthy Colorado Kids messages to promote in WIC, and in collaboration with at least one community partner. Include a new message at each staff meeting for staff to learn
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Provide one page handouts messages at WIC appointments Conduct chart reviews to see if new message are consistently being provided Encourage Wellness Coordinator to provide information on new messages Encourage and support staff training in early childhood obesity prevention: Provide staff training to improve knowledge of the most recent evidence and recommendations related to healthy weight in early childhood. Participant in the Wellness Coordinator System, a strategy to bring state and local WIC agencies together in addressing early childhood obesity through WIC services in Colorado. The Early Childhood Obesity Prevention webpage, provides a summary of additional resources and recommendations https://www.colorado.gov/cdphe/ecop-additional-resources Include a training on Motivational Interviewing training for staff Provide a training on 5-2-1-0 concepts Incorporate cooking, shopping and nutrition education resources into WIC appointments Conduct a grocery tour and promote healthy foods and beverages Provide information on My Plate and 5210 educational resources Conduct a cooking demonstration one day per week at the WIC Clinic Provide Cooking Matters, Shopping Matters, Snap-Ed, or Expanded Food and Nutrition Education Program (EFNEP), or other nutrition-related courses for families https://cookingmatters.org/ http://www.fns.usda.gov/snap/snap-ed http://www.ext.colostate.edu/efnep/ Educate and build awareness of the importance of collaboration with Farm to Family and community garden programs Bring WIC and local farmers together for better health http://www.coprevent.org/search?q=wic+farm+to+family#!/2012/10/wic-farm-to-family-pilot-offers- healthy.html Link WIC participants to community gardens and take a tour
Increase Program Participation: Conduct classes to decrease appointment wait time see a larger number of participants. Certification prenatal classes Follow-Up appointments for children Breastfeeding classes Infant feeding classes Healthy Weight Classes Topic-specific classes such as “Sugar-Sweetened Beverages” Educate and build awareness of strategies for reminding participants of their appointments Participate in the state-wide texting program Develop a system to conduct reminder telephone calls Develop a system to send reminder email messages Print Appointment Reminder and give to participant for next visit Send Appointment Reminder printouts in the mail Encourage participants to call the clinic if they misplaced their materials and/or forget their next appointment Obtain updated contact information at each appointment: recertification, follow up, mid-certification Obtain two sources of telephone contact information for each endorser Conduct a survey to see how participants wish to receive appointment reminders Run Appointment Summary Report to determine missed appointments due to no show Improve outgoing telephone messages at clinics Build awareness of ways to set up the clinic schedule to make appointment as efficient and flexible as possible Identify alternative methods for nutrition education based on participant preference (video chat, phone, wichealth.org) Minimize the length of appointment visits as much as is feasible Provide flexible times when clients can be seen Set aside appointment slots for new prenatal appointments Open the clinic one Saturday a month and rotate staff coverage
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“Lean” your work environment and clinic processes to assist with improvement in time management and to limit distractions Set up an afternoon for follow up missed appointments only Run monthly Processing Standards Non-Compliance report to check on Processing Standards Provide staff training on use of current software technology to increase computer skills and efficiency Educate and build awareness of strategies to maintain or increase caseload Conduct an assessment of staff to client caseload ratios to increase productivity Consider assigning caseload to each WIC staff to determine productivity Run monthly Termination by System Report to follow up with those participants that have been terminated due to not picking up benefits Develop outreach strategies for internal referrals within the local agency programs Advertise the WIC Program in the local newspaper Advertise the WIC Program with the local radio station Attend health fairs and other community events to promote the WIC Program Provide training to local agency partners included on the Rights and Responsibilities form on how to refer to the WIC Program
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Nutrition Education Plan
Policy: COWIC will create a unified Nutrition Education Plan (NEP) that is consistent with the Colorado WIC (COWIC) Vision, Mission, and COWIC State Goals & Strategies.
Regulation: 7 CFR 246.11 (d) (2)
Procedure/Additional Guidance:
COWIC Mission & Vision Mission: To deliver core WIC services through a “four legs of a stool” model that supports mothers, infants, children, and families who are at nutritional risk by providing: Nutrition education based on USDA best practices and guidance. ● Support for mothers to breastfeed for as long as they choose. ● A wide variety of healthy, appealing, culturally-appropriate, and readily available food for all developmental stages and nutritional needs. ● Personalized connections to other helpful community resources to support families. Vision: Strong state and local agencies serving Colorado families with excellent systems, integrity, innovation, and impact to produce healthy outcomes.
The Nutrition Education Plan The unified (NEP) aligns our collective work with the broader COWIC State Goals and Strategies, ensuring every local action contributes to the shared statewide vision. The Colorado WIC Local Agency Nutrition Education Plan will be created based on the COWIC State Plan Goals and Strategies. By using data-informed decision-making, we will identify focus areas within the required USDA components of Breastfeeding and Nutrition/Program Operations that address the most pressing needs of the COWIC Program.
Planning Timeline
Month Phase Action March - April Review State Office evaluates current COWIC State Goals and Strategies. May - June Determine Plan and determine the unified focus for the upcoming year. July Release State Office provides agencies with the final NEP instructions, objectives, and data sources. July - Sept Plan LA works with staff to create implementation plans. October Implement Local Agencies begin implementing the new Nutrition Education Plan. Ongoing Assess State and Local partners review data to evaluate the impact of the previous year’s plan. State office staff will monitor data monthly and/or quarterly. State office staff will provide LAs with evaluation updates no less than one time per year.
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Nutrition Risk Factors & Priority System Policy: Local WIC agencies must apply the Colorado WIC Program nutritional risk factor definitions when risking an applicant/participant for the program. Nutritional/medical risk(s) are identified at certification and recertification.
If at a mid-certification visit staff identify a nutritional risk factor (NRF) that was not entered during the certification/recertification visit, that NRF should be added to the participant record. If any information is added to the Nutrition Interview, Anthropoemtric panel (height/length, weight) or Blood panel, a risk assessment through the “Determine Risk” button should be completed on the Risk panel to determine if a potential system assigned risk is applicable.
Regulation: CFR 246.7(e), USDA WIC Nutrition Risk Criteria, Colorado WIC Policy
Procedure/Additional Guidance: Assignment of nutritional/medical risk(s) at the certification/recertification visit determines whether the participant is at low or high nutritional risk. Low or high-risk classification determines the scope of counseling services the participant receives from WIC. Nutritional risk assignment also determines the participant's priority (1-6, 1 being the highest priority). The priority system is used when a local agency has reached its maximum participation level and ensures that participants with the highest nutritional risk receive benefits.
Priority 1: Pregnant women, breastfeeding women, and infants demonstrating nutritional risk by hematological or anthropometric measures or other documented medical conditions. When determining priority, both members of the breastfeeding pair (mother and infant) must be placed in the highest priority level for which either is eligible. This policy applies even if both members of the pair have independent NRFs. For example, a breastfeeding woman is risked for “Failure to Meet Dietary Guidelines” which makes her a priority 4. However, her infant measures underweight which qualifies the infant as a priority 1. Because of this, both the breastfeeding woman and her infant would be certified as priority 1 participants. Priority levels are reevaluated at each recertification. Priority 2: Except for those infants who qualify for Priority 1, infants (up to 6 months of age) born to a WIC participant or to a mother who was in medical/nutritional risk during pregnancy. Priority 3: Children demonstrating nutritional risk by hematological or anthropometric measurements or other documented medical conditions. Priority 4: Pregnant women, breastfeeding women, and infants demonstrating nutritional risk and additional risk factors as allowed by Federal regulations; and postpartum teens.
Priority 5: Children demonstrating nutritional risk.
Priority 6: Postpartum women at nutritional risk.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
PREGNANT WOMAN System Assigned (S): Compass assigns based on anthropometric, blood values, and/or dates entered in system. User Assigned (U): User assigns by checking a box or radio button, or by assigning on the Risk panel.
Compass Code Name/Definition Priority Risk User or System Assigned 101 Underweight – Prepregnancy Body Mass Index (BMI) <18.5 1 L S 111 Overweight – Prepregnancy Body Mass Index (BMI) >25.0 1 L S 131 Low Maternal Weight Gain - (singleton pregnancies only) Assign when weight plots, at any point, beneath the bottom line of the appropriate weight gain range for her respective prepregnancy weight category. 1 H U 133 High Maternal Weight Gain - (Singleton pregnancy only) At any point in a singleton pregnancy, weight plots at any point above the top line of the appropriate weight gain range for her respective prepregnancy weight category. 1 H U 201 Low Hematocrit/Low Hemoglobin – Low Hemoglobin (Hb) or hematocrit (Hct) is less than the 5th percentile of the distribution of Hb concentration or Hct in a healthy reference population based on age, sex, and state of pregnancy. Cut-off values are provided within the NRF pages. These values are based on the levels established by the Centers for Disease Control and Prevention (CDC). 1 L S 201B Severely Low Hematocrit/Hemoglobin – Hemoglobin value low enough to necessitate a medical referral as listed in the Standards for Severely Low Hemoglobin-NRF201b-High Risk Condition table in the Mini Manual. 1 H U 211 Elevated Blood Lead Levels – Elevated blood lead level (BLL) is the amount of lead in the blood, measured in micrograms of lead per deciliter of blood ( µg/dl), Follow-up action should be taken for a pregnant woman when BLL ≥ 5 µg/dl. 1 H S 300 Series Medical Conditions *See Clinical/Health/Medical Conditions List for definitions, codes, and risk level (high or low). 1 L/H U
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
401 Failure to Meet Dietary Guidelines for Americans Pregnant woman who meets the income, categorical, and residency eligibility requirements may be presumed to be at nutritional risk based on failure to meet Dietary Guidelines for Americans. Based on an individual’s estimated energy needs, this risk criterion is defined as consuming fewer than the recommended number of servings from one or more of the basic food groups (grains, fruits, vegetables, milk products, and meat or beans). Note: Assign 401 to a pregnant woman when a complete nutrition assessment (to include NRF 427) has been performed and for whom no other risk(s) are identified. 4 L U 427 INAPPROPRIATE NUTRITION PRACTICES FOR WOMEN: Routine nutrition practices that may result in impaired nutrient status, disease, or health problems. These practices, with examples, are outlined below: 4 L U 427A Consuming dietary supplements with potentially harmful consequences – Examples of dietary supplements which when ingested in excess of recommended dosages, may be toxic or have harmful consequences: ►Single or multiple vitamins; ►Mineral supplements; and ►Herbal or botanical supplements/remedies/teas. ►Cannabidiol (CBD), for Pregnant and Breastfeeding women only (Products labeled, as CBD with any form of THC should be risked with 372). 4 L U 427B Consuming a diet very low in calories and/or essential nutrients; or impaired caloric intake or absorption of essential nutrients following bariatric surgery – Examples are: ► Low-calorie diet; ► Strict vegan diet; ► Any other diet restricting calories and/or essential nutrients. 4 L U
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
427C Compulsively ingesting non-food items (pica) – Examples of non-food items are: ► 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 4 L U 427D Inadequate vitamin/mineral supplementation recognized as essential by national public health policy - Examples are: ► Consumption of <27 mg of iron as a supplement daily. ► Consumption <150 µg of supplemental iodine per day. ► Consumption of < 400-800 mcg of folic acid from supplements daily. 4 L U
427E Pregnant woman ingesting foods that could be contaminated with pathogenic microorganisms - Examples of potentially harmful foods are: ►Seafood: Any 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, queso fresco; ►Eggs: Raw or undercooked eggs or foods containing raw or lightly cooked eggs including certain salad dressings (Caesar), cookie and cake batters, sauces, and beverages such as unpasteurized eggnog; ►Raw sprouts (alfalfa, bean, clover, radish, microgreens); ►Unpasteurized fruit or vegetable juices; or ►Unwashed fruits or vegetables. 4 L U
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
501 Possibility of Regression in Nutritional Status - A participant who has previously been certified eligible for the Program may be considered to be at nutritional risk in the next certification period if the Competent WIC Authority (CWA) determines there is a possibility of regression in nutritional status without the benefits that the WIC Program provides. Note: Regression cannot be assigned to a participant two certification periods in a row and may only be used once after the initial certification. 4 L U 502 Transfer of Certification – Person with current valid Verification of Certification (VOC) document from another State or local agency. The VOC is valid until the certification period expires and shall be accepted as proof of eligibility for program benefits. N/A L S 601 601A 601B 601D Breastfeeding Mother of Infant at Nutritional Risk – A breastfeeding woman whose breastfed infant has been determined to be at nutritional risk. Priority 1 mother Priority 2 mother Priority 4 mother Note: Mother must be the same priority as at-risk infant
1 2 4
L L L
U U U 602
602A 602B 602C
602D 602E 602F 602G
602H Breastfeeding Complications or Potential Complications- A breastfeeding woman with any of the following complications or potential complications for breastfeeding: ► 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 or older* ► failure of milk to come in by 4 days postpartum ► tandem nursing (breastfeeding two siblings who are not twins). Note: High Risk must be seen by a Lactation Management Specialist (LMS/CLC/IBCLC) or WIC High Risk Counselor within 24 hours. 1 1 1 1 1 1 1 1 H H H H H L* H H U U U U U U U U
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026 801 Homelessness – Woman who lacks a fixed and regular night time residence; or whose primary night time 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 in the residence of another individual not exceeding 365 days; or ► A public or private place not designed or ordinarily used as a regular sleeping accommodation for human beings. 4 L U 802 Migrancy – Categorically eligible woman who is a member of a family that contains at least one individual: ► Whose principal employment is in agriculture on on a seasonal basis and; ► Has been so employed within the last 24 months and; ► Who establishes, for the purposes of such employment, a temporary abode. 4 L U 901 Recipient of Abuse – Individual who has experienced physical, sexual, emotional, economic, or psychological maltreatement that may frighten, intimidate, terrozie, 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, a social worker, health care provider, or other appropriate personnel. 4 L U 902 Woman or Primary Caregiver with Limited Ability to Make Feeding Decisions and/or Prepare Food - Pregnant woman assessed to have a limited ability to make appropriate feeding decisions and/or prepare food. Examples include, but are not limited to: ► Documented or self-reported misuse of alcohol, use of illegal substances, use of marijuana, or misuse of prescription medications. ► Mental illness, including clinical depression.* ► Intellectual disability.* ► Physically disabled to a degree which restricts or limits food preparation abilities. ► < 17 years of age. * Presence of the condition diagnosed, documented, or reported by a physician or psychologist or someone working under a physician’s orders, or as self-reported by applicant/participant/caregiver. 4 L U
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026 903 Foster Care – Entering the foster care system during the previous 6 months or moving from one foster care home to another foster care home during the previous 6 months. 4 L S 904 Environmental Tobacco Smoke Exposure (ETS) – ETS exposure is defined as exposure to smoke from tobacco products inside enclosed areas, like the home, place of child care, etc. ETS is also known as secondhand, passive, or involuntary smoke. The ETS definition also includes the exposure to the aerosol from electronic nicotine delivery systems. 1 L U
BREASTFEEDING WOMAN System Assigned (S): Compass assigns based on anthropometric, blood values, and/or dates entered in system. User Assigned (U): User assigns by checking a box or radio button, or by assigning on the Risk panel. Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
Compass Code Name/Definition Priority Risk User or System Assigned 101 Underweight - Current Body Mass Index (BMI) <18.5 1 L S 111 Overweight - ► Woman <6 months postpartum: Prepregnancy Body Mass Index (BMI) > 25.0 ►Woman > 6 months postpartum: Current Body Mass Index (BMI) > 25.0 1 L S 133 High Maternal Weight Gain – For most recent pregnancy, total gestational weight gain exceeded the upper limit of the IOM’s recommended range based on Body Mass Index (BMI). Note: Singleton pregnancy only 1 L S 201 Low Hematocrit/Low Hemoglobin – Low Hemoglobin (Hb or Hematocrit (HCT) is than the 5th percentile of the distribution of Hb concentration or HCt in a healthy reference population based on age, sex, and state of pregnancy. Cut-off values are provided within the NRF pages. These values are based on the levels established by the Centers for Disease Control and Prevention (CDC). 1 L S 201B Severely Low Hematocrit/Hemoglobin – Hemoglobin value low enough to necessitate a medical referral as listed in the Standards for Severely Low Hemoglobin- NRF201b-High Risk Condition table in the Mini Manual. 1 H U 211 Elevated Blood Lead Levels – Elevated blood lead level (BLL) is the amount of lead in the blood, measured in micrograms of lead per deciliter of blood ( µg/dl), Follow-up action should be taken for a Breastfeeding woman when BLL ≥ 5 µg/dl. 1 H S 300 Series Medical Conditions - *See Clinical/Health/Medical Conditions List for definitions, codes, and risk level (high or low). 1 L/H U 401 Failure to Meet Dietary Guidelines for Americans - Breastfeeding woman who meets the eligibility requirements of income, categorical, and residency eligibility requirements may be presumed to be at nutritional risk based on failure to meet Dietary Guidelines for Americans. Based on an individual’s estimated energy needs, this risk criterion is defined as consuming fewer than the recommended number of servings from one or more of the basic food groups (grains, fruits, vegetables, milk products, and meat or beans). Note: Assign 401 to breastfeeding women when a complete nutrition assessment has been performed and no other nutrition risk(s) are identified. 4 L U 427 INAPPROPRIATE NUTRITION PRACTICES For WOMEN Routine nutrition practices that may result in impaired nutrient status, disease, or health problems. These practices, with examples, are outlined below: 4 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
427A Consuming dietary supplements with potentially harmful consequences – Examples of dietary supplements which when ingested in excess of recommended dosages, may be toxic or have harmful consequences: ► Single or multiple vitamins; ► Mineral supplements; ► Herbal or botanical supplements/remedies/teas. ► Cannabidiol (CBD) for Pregnant and Breastfeeding women only (products labeled as CBD with any form of THC should be a risk with 372) 4 L U 427B Consuming a diet very low in calories and/or essential nutrients; or impaired caloric intake or absorption of essential nutrients following bariatric surgery - Examples are: ► Low-calorie diet; ► Strict vegan diet; ► Any other diet restricting calories and/or essential nutrients. 4 L U 427C Compulsively ingesting non-food items (pica) – Examples of non-food items are: ► 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 4 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
427D Inadequate vitamin/mineral supplementation recognized as essential by national public health policy – Examples are: ► Consumption of < 150 mcg of supplemental iodine per day ► Consumption of < 400 - 800 mcg of folic acid from supplements daily. 4 L U 501 Possibility of Regression in Nutritional Status - A participant who has previously been certified eligible for the Program may be considered to be at nutritional risk in the next certification period if the Competent WIC Authority (CWA) determines there is a possibility of regression in nutritional status without the benefits that the WIC Program provides. Note: Regression cannot be assigned to a participant two certification periods in a row and may only be used once after the initial certification. 4 L U 502 Transfer of Certification – Person with current valid Verification of Certification (VOC) document from another State or local agency. The VOC is valid until the certification period expires and shall be accepted as proof of eligibility for program benefits. N/A L S 601 601A 601B 601D Breastfeeding Mother of Infant at Nutritional Risk – A breastfeeding woman whose breastfed infant has been determined to be at nutritional risk. Priority 1 mother Priority 2 mother Priority 4 mother Note: Mother must be the same priority as at-risk infant 1 2 4 L L L S S S Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
602 602A 602B 602C 602D 602E 602F 602G 602H Breastfeeding Complications or Potential Complications- A breastfeeding woman with any of the following complications or potential complications for breastfeeding: ► 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 or older ► failure of milk to come in by 4 days postpartum ► tandem nursing (breastfeeding two siblings who are not twins). Note: High Risk must be seen by a Lactation Management Specialist (LMS/CLC/IBCLC) or WIC High Risk Counselor within 24 hours. 1 1 1 1 1 1 1 1 H H H H H L H H U U U U U S U U 801 Homelessness – Woman who lacks a fixed and regular night time residence; or whose primary night time 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 or; ► An institution that provides a temporary residence for individuals intended to be institutionalized or; ► A temporary accommodation in the residence of another individual not exceeding 365 days or; ► A public or private place not designed or ordinarily used as a regular sleeping accommodation for human beings. 4 L U 802 Migrancy – Categorically eligible woman who is a member of a family that contains at least one individual: ► Whose principal employment is in agriculture on on a seasonal basis and; ►Has been so employed within the last 24 months and; ►Who establishes, for the purposes of such employment, a temporary abode. 4 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
901 Recipient of Abuse – Individual who has experienced physical, sexual, emotional, economic, or psychological maltreatement that may frighten, intimidate, terrozie, 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, a social worker, health care provider, or other appropriate personnel. 4 L U 902 Woman or Primary Caregiver with Limited Ability to Make Feeding Decisions and/or Prepare Food - Breastfeeding woman assessed to have a limited ability to make appropriate feeding decisions and/or prepare food. Examples include, but are not limited to: ► Documented or self-reported misuse of alcohol, use of illegal substances, use of marijuana, or misuse of prescription medications. ►Mental illness, including clinical depression.* ►Intellectual disability.* ►Physically disabled to a degree which restricts or limits food preparation abilities. ►< 17 years of age. * Presence of the condition diagnosed, documented, or reported by a physician or psychologist or someone working under a physician’s orders, or as self-reported by applicant/participant/caregiver. 4 L U 903 Foster Care – Entered the foster care system during the previous 6 months or moved from one foster care home to another foster care home during the previous 6 months. 4 L S 904 Environmental Tobacco Smoke Exposure (ETS) – ETS exposure is defined as exposure to smoke from tobacco products inside enclosed areas, like the home, place of child care, etc. ETS is also known as secondhand, passive, or involuntary smoke. The ETS definition also includes the exposure to the aerosol from electronic nicotine delivery systems. 1 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
NON-BREASTFEEDING WOMAN System Assigned (S): Compass assigns based on anthropometric, blood values, and/or dates entered in system. User Assigned (U): User assigns by checking a box or radio button, or by assigning on the Risk panel. Compass Codes Name/Definition Priority Risk User or System Assigned 101 Underweight – Current Body Mass Index (BMI) <18.5 6 L S 111 Overweight - Prepregnancy Body Mass Index (BMI) > 25.0 6 L S 133 High Maternal Weight Gain – For most recent pregnancy, total gestational weight gain exceeded the upper limit of the IOM’s recommended range based on Body Mass Index (BMI). Note: Singleton pregnancy only 6 L S 201 Low Hematocrit/Low Hemoglobin – Low Hemoglobin (Hb) or hematocrit (Hct) is less than the 5th percentile of the distribution of Hb concentration or Hct in a healthy reference population based on age, sex, and state of pregnancy. Cut-off values are provided within the NRF pages. These values are based on the levels established by the Centers for Disease Control and Prevention (CDC). 6 L S 201B Severely Low Hematocrit/Low Hemoglobin – Hemoglobin value low enough to necessitate a medical referral as listed in the Standards for Severely Low Hemoglobin-NRF201b-High Risk Condition table in the Mini Manual. 6 H U 211 Elevated Blood Lead Levels – Elevated blood lead level (BLL) is the amount of lead in the blood, measured in micrograms of lead per deciliter of blood ( µg/dl), Follow-up action should be taken for a non- Breastfeeding woman when BLL ≥ 5 µg/dl. 6 H S 300 Series Medical Conditions – *See Clinical/Health/Medical Conditions List for definitions, codes, and risk level (high or low). 6 L/H U 401 Failure to Meet Dietary Guidelines for Americans - Non-breastfeeding woman who meets the income, categorical, and residency eligibility requirements may be presumed to be at nutritional risk based on failure to meet Dietary Guidelines for Americans. Based on an individual’s estimated energy needs, this risk criterion is defined as consuming fewer than the recommended number of servings from one or more of the basic food groups (grains, fruits, vegetables, milk products, and meat or beans). Note: Assign 401 to a non-breastfeeding woman when a complete nutrition assessment (to include NRF 427) has been performed and for whom no other risk(s) are identified. 6 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
427 INAPPROPRIATE NUTRITION PRACTICES For WOMEN Routine nutrition practices that may result in impaired nutrient status, disease, or health problems. These practices, with examples, are outlined below: 6 L U 427A Consuming dietary supplements with potentially harmful consequences – Examples of dietary supplements which when ingested in excess of recommended dosages, may be toxic or have harmful consequences are: ► Single or multiple vitamins; ► Mineral supplements; and ► Herbal or botanical supplements/remedies/teas. 6 L U 427B Consuming a diet very low in calories and/or essential nutrients; or impaired caloric intake or absorption of essential nutrients following bariatric surgery - Examples are: ► Low-calorie diet; ► Strict vegan diet; ► Any other diet restricting calories and/or essential nutrients. 6 L U 427C Compulsively ingesting non-food items (pica) – Examples of non-food items are: ► Dirt; ► Starch (laundry and cornstarch); ► Large quantities of ice and/or freezer frost; ► Cigarette ashes; ► Baking soda; ► Burnt matches; ► Coffee grounds; Dust; ► Chalk; ► Uncooked rice; ► Clay; ► Paper 6 L U 427D Inadequate vitamin/mineral supplementation recognized as essential by national public health policy For example: ► Consumption of < 400-800 mcg of folic acid from supplements daily. 6 L U 501 Possibility of Regression - A participant who has previously been certified eligible for the Program may be considered to be at nutritional risk in the next certification period if the Competent WIC Authority (CWA) determines there is a possibility of regression in nutritional status without the benefits that the WIC Program provides. Note: Regression cannot be assigned to a participant two certification periods in a row and may only be used once after the initial certification. 6 L U 502 Transfer of Certification – Person with current valid Verification of Certification (VOC) document from another State or local agency. The VOC is valid until the certification period expires and shall be accepted as proof of eligibility for program benefits. N/A L S Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
801 Homelessness – Woman who lacks a fixed and regular night time residence; or whose primary night time 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 or; ► An institution that provides a temporary residence for individuals intended to be institutionalized or; ► A temporary accommodation in the residence of another individual not exceeding 365 days or; ► A public or private place not designed or ordinarily used as a regular sleeping accommodation for human beings. 6 L U 802 Migrancy – Categorically eligible woman who is a member of a family that contains at least one individual: ► Whose principal employment is in agriculture on on a seasonal basis and; ►Has been so employed within the last 24 months and; ►Who establishes, for the purposes of such employment, a temporary abode. 6 L U 901 Recipient of Abuse – 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, a social worker, health care provider, or other appropriate personnel. 6 L U 902 Woman or Primary Caregiver with Limited Ability to Make Feeding Decisions and/or Prepare Food – Non-breastfeeding woman assessed to have a limited ability to make appropriate feeding decisions and/or prepare food. Examples include, but are not limited to: Documented or self-reported misuse of alcohol, use of illegal substances, use of marijuana, or misuse of prescription medications. ►Mental illness, including clinical depression.* ►Intellectual disability.* ►Physically disabled to a degree which restricts or limits food preparation abilities. ►< 17 years of age. ► * Presence of the condition diagnosed, documented, or reported by a physician or psychologist or someone working under a physician’s orders, or as self-reported by applicant/participant/caregiver 6 L U 903 Foster Care - Entered the foster care system during the previous 6 months or moved from one foster care home to another foster care home during the previous 6 months. 6 L S Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
904 Environmental Tobacco Smoke Exposure (ETS) – ETS exposure is defined as exposure to smoke from tobacco products inside enclosed areas, like the home, place of child care, etc. ETS is also known as secondhand, passive, or involuntary smoke. The ETS definition also includes the exposure to the aerosol from electronic nicotine delivery systems. 6 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
INFANT System Assigned (S): Assigned by Compass based on anthropometric, blood values, and/or dates entered system. User Assigned (U): Assigned by the user by checking a box or radio button, or by assigning on the Risk panel. Compass Code Name/Definition Priority Risk User or System Assigne d 103A At Risk of Underweight - > 2nd percentile and < 5th percentile weight-for-length 1 L S 103B Underweight- < 2nd percentile weight-for-length Note: CDC labels the 2.3rd percentile as the 2nd percentile on the Birth to 24 months gender specific growth charts. 1 H S 114 At Risk of Overweight- ►Biological mother with a BMI > 30 at the time of conception or at any point in the first trimester of pregnancy. (Compass assigns using biological mother’s most recent pregnancy record.) ►Biological father with a BMI > 30 at the time of certification. BMI must be based on self-reported weight and height by the father in attendance (i.e., one parent may not “self-report” for the other parent) or weight and height measurements taken by staff at the time of certification. 1 L S U 115 High Weight-for-Length – ≥ 98th percentile weight-for-length Note: CDC labels the 97.7th percentile as the 98th percentile on the Birth to 24 months gender specific growth charts. 1 L S 121A At Risk for Short Stature – > 2nd percentile and ≤ 5th percentile length-for-age as plotted on the CDC Birth to 24 months gender specific growth charts. Note: ● CDC labels the 2.3rd percentile as the 2nd percentile on the birth to 24 months gender- specific growth charts. ● Assignment for premature infant is based on adjusted gestational age. 1 L S 121B Short Stature – ≤ 2nd percentile length-for-age as plotted on the CDC Birth to 24 months gender specific growth charts. Note: ● CDC labels the 2.3rd percentile as the 2nd percentile on the birth to 24 months gender- specific growth charts. ● Assignment for premature infant is based on adjusted gestational age. 1 L S Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
134 Failure to Thrive – Presence of failure to thrive (FTT) diagnosed, documented, or reported by a physician or someone working under a physician’s orders, or as self-reported by endorser/caregiver. 1 H U 135 Slowed/Faltering Growth Pattern – Infant Birth to 2 weeks ● Excessive weight loss after birth, defined as ≥ 7% birth weight. Note: Requires further assessment and counseling by the WIC High Risk Counselor within 24 hours of risk identification. Infants 2 weeks to 6 months of age ● Any weight loss. Use two separate weight measurements taken at least 8 weeks apart. Note: WIC High Risk Counselor visit is required within 30 days of risk identification. 1 1 H H S S 141A Low Birth Weight - Birth weight defined as ≤ 2500 grams (≤ 5 pounds 8 ounces) 1 H S 141B Very Low Birth Weight - Birth weight defined as ≤ 1500 grams (≤ 3 pounds 5 ounces) 1 H S 142A Preterm Delivery - Delivery of an infant born ≤36 6/7 week gestation. 1 H S 142B Early Term Delivery – Delivery of an infant born ≥ 37 0/7 and ≤38 6/7 weeks gestation. 1 L S 151 Small for Gestational Age (SGA) - Diagnosed as small for gestational age. 1 H U 152 Low Head Circumference – Infants birth to 24 months ≤2.3rd percentile head circumference-for-age as plotted on the Centers for Disease Control and Prevention (CDC) Birth to 24 months gender specific growth charts. Assignment for premature infant is based on adjusted gestational age. Note: Low Head Circumference is not a measurement WIC Staff take but instead is risked when a medical care provider has diagnosed the infant or child with the condition. 1 H S Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
153 Large for Gestational Age (LGA) - Birth weight of > 9 pounds (≥ 4000 g) or presence of LGA as diagnosed by a physician or someone working under a physician’s orders, or as self- reported by endorser/caregiver. 1 L S 201 Low Hematocrit/Low Hemoglobin – Low Hemoglobin (Hb) or hematocrit (Hct) is less than the 5th percentile of the distribution of Hb concentration or Hct in a healthy reference population based on age, sex, and state of pregnancy. Cut-off values are provided within the NRF pages. These values are based on the levels established by the Centers for Disease Control and Prevention (CDC). 1 L S 201B Severely Low Hematocrit/Hemoglobin – Hemoglobin value low enough to necessitate a medical referral as listed in the Standards for Severely Low Hemoglobin- NRF201b-High Risk Condition table in the Mini Manual. 1 H U 211 Elevated Blood Lead Levels – Elevated blood lead level (BLL) is the amount of lead in the blood, measured in micrograms of lead per deciliter of blood ( µg/dl), Follow-up action should be taken for an infant when BLL ≥ 5 µg/dl. 1 H S 300 Series Medical Conditions – *See Clinical/Health/Medical Conditions List for definitions, codes, and risk level (High or Low). 1 L/H U 411 INAPPROPRIATE NUTRITION PRACTICES FOR INFANTS: Routine use of feeding practices that may result in impaired nutrient status, disease, or health problems. These practices, with examples, are outlined below: 4 L U 411A 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. 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; and ► Imitation or substitute milks (such as rice- or soy- based beverages, non-dairy creamer), or “other homemade concoctions.” 4 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
411B Routinely using nursing bottles or cups improperly. ► 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. 4 L U 411C Routinely offering complementary foods* or other substances that are inappropriate in type or timing. Examples of inappropriate complementary foods: ► 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 other than human milk or iron-fortified infant formula before 6 months of age. * Complementary foods are any foods or beverages other than human milk or infant formula. 4 L U 411D Routinely using feeding practices that disregard the developmental needs or stage of the infant. ► Inability to recognize, insensitivity to, or disregarding the infant’s cues for hunger and satiety (e.g., forcing an infant to eat a certain type and/or amount of food or beverage or ignoring an infant’s hunger cues). ► Feeding foods of inappropriate consistency, size, or shape that put infants at risk of choking. ► Not supporting an infant’s need for 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 textures 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). 4 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
411E Feeding foods to an infant that could be contaminated with harmful microorganisms or toxins. Examples of 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. 4 L U 411F Routinely feeding inappropriately diluted formula. ► Failure to follow manufacturer’s mixing instructions (to include stretching formula for household economic reasons). ► Failure to follow specific instructions accompanying a prescription. 4 L U 411G Routinely limiting the frequency of nursing of the exclusively breastfed infant when human milk is the sole source of nutrients. Examples of inappropriate frequency of nursing: ► Scheduled feedings instead of demand feedings; and ► Less than 8 feedings in 24 hours if less than 2 months of age. 4 L U 411H Routinely feeding a diet very low in calories and/or essential nutrients. Examples: ► Vegan diet ► Macrobiotic diet ► Other diets very low in calories and/or essential nutrients 4 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
411I Routinely using inappropriate sanitation in the feeding, preparation, handling, and storage of expressed human milk or formula. ► Limited or no access to a: ● Safe water supply (documented by appropriate authorities); ● Heat source for sterilization; and/or ● Refrigerator or freezer for storage. ► Failure to prepare, handle, and store bottles, storage containers or breast pumps properly; 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 instruction ● Feeding donor human milk acquired directly from individuals or the Internet. Formula ● Failure to prepare and/or store formula formula per manufacturer’s or physicians 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 4 L U 411J Feeding dietary supplements with potentially harmful consequences. Examples of dietary supplements which, when fed in excess of recommended dosage, may be toxic or have harmful consequences: ► Single or multi-vitamins; ► Mineral supplements; and ► Herbal or botanical supplements/remedies/teas. 4 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
411K Routinely not providing dietary supplements recognized as essential by national public health policy when an infant’s diet alone cannot meet nutrient requirements. ► 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 one liter (or 1 quart) per day of vitamin D-fortified formula and are not taking a supplement of 400 IU of vitamin D. 4 L U 428 Dietary Risk Associated with Complementary Feeding Practices – Infant 4-12 months of age 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. Note: A complete nutrition assessment, including for risk #411, Inappropriate Nutrition Practices for Infants, must be performed prior to assigning this risk. 4 L U 501 Possibility of Regression – A participant who has previously been certified eligible for the Program may be considered to be at nutritional risk in the next certification period if the Competent WIC Authority (CWA) determines there is a possibility of regression in nutritional status without the benefits that the WIC Program provides. Note: Regression cannot be assigned to a participant two certification periods in a row and may only be used once after the initial certification. 4 L U 502 Transfer of Certification – Person with current valid Verification of Certification (VOC) documents from another State or local agency. The VOC is valid until the certification period expires and shall be accepted as proof of eligibility for program benefits. N/A L S Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
603 603A 603B 603C 603D Breastfeeding Complications or Potential Complications – Breastfed infant with any of the following complications or potential complications for breastfeeding: ► jaundice ► weak or ineffective suck ► difficulty latching onto mother’s breast ► inadequate stooling (for age, as determined by a physician or other health care professional), and/or less than 6 wet diapers per day. Note: High Risk must be seen by a Lactation Management Specialist (LMS/CLC/IBCLC) or WIC High Risk Counselor within 24 hours. 1 H U 701 Infant Up to 6 Months Old of WIC Mother or of a Woman Who Would Have Been Eligible During Pregnancy – Infant < 6 months of age whose mother was a WIC Program participant during pregnancy or whose mother’s medical records document that the woman was at nutritional risk during pregnancy because of detrimental or abnormal nutritional conditions detectable by biochemical or anthropometric measurements or other documented nutritionally related conditions. 2 L S 702A 702B 702D Breastfeeding Infant of Woman at Nutritional Risk - Priority 1 infant Priority 2 infant Priority 4 infant Note:Infant must be the same priority as at-risk mother 1 2 4 L L L S S S 801 Homelessness – Infant 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 for human beings. 4 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
802 Migrancy – Infant who is a member of a family that contains 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. 4 L U 901 Recipient of Abuse – An infant who has experienced physical, sexual, emotional, economic, neglect or psychological maltreatement that may frighten, intimidate, terrozie, 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, a social worker, health care provider, or other appropriate personnel. 4 L U 902 Infant of Primary Caregiver with Limited Ability to Make Feeding Decisions and/or Prepare Food – Infant whose primary caregiver is assessed to have a limited ability to make appropriate feeding decisions and/or prepare food. Examples include, but are not limited to: ►Documented or self-reported misuse of alcohol, use of illegal substances, use of marijuana, or misuse of prescription medications. ►Mental illness, including clinical depression.* ►Intellectual disability.* ►Physically disabled to a degree which restricts or limits food preparation abilities. ► < 17 years of age. * Presence of the condition diagnosed, documented, or reported by a physician or psychologist or someone working under a physician’s orders, or as self-reported by applicant/participant/caregiver. 4 L U 903 Foster Care - Entering the foster care system during the previous 6 months or moving from one foster care home to another foster care home during the previous 6 months. 4 L S 904 Environmental Tobacco Smoke Exposure (ETS) – ETS exposure is defined as exposure to smoke from tobacco products inside enclosed areas, like the home, place of child care, etc. ETS is also known as secondhand, passive, or involuntary smoke. The ETS definition also includes the exposure to the aerosol from electronic nicotine delivery systems. 1 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
CHILD System Assigned (S): Compass assigns based on anthropometric, blood values, and/or dates entered in system. User Assigned (U): User assigns by checking a box or radio button, or by assigning on the Risk panel. Compass Code Name/Definition Priority Risk User or System Assigned 103A At Risk of Underweight – Child > 12 months to <24 months: > 2nd percentile and < 5th percentile weight-for-length Child 2-5 years of age: > 5th percentile and ≤10th percentile Body Mass Index (BMI)-for-age 3 L S 103B Underweight – Child > 12 months to <24 months: < 2nd percentile weight-for-length Note: CDC labels the 2.3rd percentile as the 2nd percentile on the Birth to 24 months gender specific growth charts. Child 2-5 years of age: < 5th percentile Body Mass Index (BMI)-for-age 3 H S 113 Obese – Child 2-5 years of age: > 95th percentile Body Mass Index (BMI)-for-age Note: standing height only 3 H S 114 Overweight - Child 2-5 years of age: > 85th and < 95th percentile Body Mass Index (BMI)-for- age At Risk of Overweight - Child > 12 months to 5 years of age: Biological mother** and/or biological father with a BMI > 30 at the time of certification.* *BMI must be based on self-reported weight and height by the parent in attendance (i.e., one parent may not “self-report” for the other parent) or weight and height measurements taken by staff at the time of certification. **If the mother is pregnant or has had a baby within the past 6 months but was not on WIC during that pregnancy, use her preconceptual weight to assess for obesity since her current weight will be influenced by pregnancy-related weight gain. For children <24 months of age whose biological mother was on WIC during the most recent pregnancy, Compass assigns using the biological mother’s most recent pregnancy record. 3 3 L L S S/U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
115 High Weight-for-Length - Child > 12 months to < 24 months of age: > 98th percentile weight-for-length as plotted on the CDC Birth to 24 months gender specific growth charts. Note: CDC labels the 97.7th percentile as the 98th percentile on the Birth to 24 months gender specific growth charts. 3 L S 121A At Risk for Short Stature – Child > 12 months to < 24 months of age: >2nd percentile and ≤5th percentile length-for-age as plotted on the CDC Birth to 24 months gender specific growth charts. Note: CDC labels the 2.3rd percentile as the 2nd percentile on the Birth to 24 months gender specific growth charts. Note: Assignment for a child with a history of prematurity is based on adjusted gestational age. Child 2-5 years of age: > 5th percentile and ≤10th percentile height-for-age. 3 L S 121B Short Stature – Child > 12 months to < 24 months of age: < 2nd percentile length-for-age as plotted on the CDC Birth to 24 months gender specific growth charts. Note: CDC labels the 2.3rd percentile as the 2nd percentile on the birth to 24 months gender-specific growth charts. Note: Assignment for a child with a history of prematurity is based on adjusted gestational age. Child 2-5 years of age: < 5th percentile height-for-age 3 L S 134 Failure to Thrive – Presence of failure to thrive (FTT) diagnosed, documented, or reported by a physician or someone working under a physician’s orders, or as self-reported by endorser/caregiver. 3 H U 141A Low Birth Weight – (Child < 24 months of age): Birth weight defined as ≤ 2500 grams (≤ 5 pounds 8 ounces) 3 L S 141B Very Low Birth Weight – (Child < 24 months of age): Birth weight defined as ≤ 1500 grams (≤ 3 pounds 5 ounces) 3 L S 142A Preterm Delivery (Child < 24 months of age) - Delivery of an infant born ≤ 36 6/7 week gestation. 3 L S 142B Early Term Delivery (Child < 24 months of age) – Delivery of an infant born ≥ 37 0/7 and ≤ 38 6/7 weeks gestation. 3 L S Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
151 Small for Gestational Age (SGA) – (Child < 24 months of age): Diagnosed as small for gestational age. 3 L U 152 Low Head Circumference – Infants birth to 24 months ≤2.3rd percentile head circumference-for-age as plotted on the Centers for Disease Control and Prevention (CDC) Birth to 24 months gender specific growth charts. Assignment for premature infant is based on adjusted gestational age. Note: Low Head Circumference is not a measurement WIC Staff take but instead is risked when a medical care provider has diagnosed the infant or child with the condition. 3 L U 201 Low Hematocrit/Low Hemoglobin – Low Hemoglobin (Hb) or hematocrit (Hct) is less than the 5th percentile of the distribution of Hb concentration or Hct in a healthy reference population based on age, sex, and state of pregnancy. Cut-off values are provided within the NRF pages. These values are based on the levels established by the Centers for Disease Control and Prevention (CDC). 3 L S 201B Severely Low Hematocrit/Hemoglobin – Hemoglobin value low enough to necessitate a medical referral as listed in the Standards for Severely Low Hemoglobin-NRF201b-High Risk Condition table in the Mini Manual. 3 H U 211 Elevated Blood Lead Levels – Elevated blood lead level (BLL) is the amount of lead in the blood, measured in micrograms of lead per deciliter of blood ( µg/dl), Follow-up action should be taken for an child when BLL ≥ 3.5 µg/dl. 3 H S 300 Series Medical Conditions – *See Clinical/Health/Medical Conditions List for definitions, codes, and risk level (high or low). 3 L/H U 401 Failure to Meet Dietary Guidelines for Americans - Child ≥ 24 months of age who meets the income, categorical, and residency eligibility requirements may be presumed to be at nutritional risk based on failure to meet Dietary Guidelines for Americans. Based on a child’s estimated energy needs, this risk criterion is defined as consuming fewer than the recommended number of servings from one or more of the basic food groups (grains, fruits, vegetables, milk products, and meat or beans). Note: Assign 401 to child 2-5 years of age when a complete nutrition assessment has been performed and no other nutrition risks are identified. 5 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
425 INAPPROPRIATE NUTRITION PRACTICES FOR CHILDREN - Routine use of feeding practices that may result in impaired nutrient status, disease, or health problems. 5 L U 425A Routinely feeding inappropriate beverages as the primary milk source – Examples of inappropriate beverages as primary milk source: ► Non-fat or reduced-fat milks between 12 and 24 months of age only (unless overweight or obesity is a concern) or sweetened condensed milk; and ► Goat’s milk, sheep’s milk, imitation or substitute milks (that are unfortified or inadequately fortified),or other “homemade concoctions.” 5 L U 425B Routinely feeding a child any sugar-containing fluids Examples of sugar-containing fluids: ► Soda/soft drinks ► Gelatin water ► Corn syrup solutions; and ► Sweetened tea 5 L U 425C Routinely using nursing bottles, cups, or pacifiers inappropriately - ►Using a bottle to feed: ● Fruit juice, or ● 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 beyond 14 months of age. ►Using a pacifier dipped in sweet agents such as sugar, honey, or syrups. ►Allowing a child to carry around and drink throughout the day from a covered or training cup. 5 L U 425D Routinely using feeding practices that disregard the developmental needs or stages of the child - ► 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 request for appropriate foods). ► Feeding foods of inappropriate consistency, size, or shape that puts child 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 foods when the child is ready and capable of eating mashed, chopped or appropriate finger foods). 5 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
425E Feeding foods to a child that could be contaminated with harmful microorganisms or toxins– 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); and ►Deli meat, hot dogs, and processed meats (avoid unless heated until steaming hot). 5 L U 425F Routinely feeding a diet very low in calories and/or essential nutrients - Examples: ►Vegan diet; ►Macrobiotic diet; and ►Other diets very low in calories and/or essential nutrients. 5 L U 425G Feeding dietary supplements with potentially harmful consequences - Examples of dietary supplements which when fed in excess of recommended dosage may be toxic or have harmful consequences: ►Single or multi-vitamins; ►Mineral supplements; and ►Herbal or botanical supplements/remedies/teas. 5 L U 425H Routinely not providing dietary supplements recognized as essential by national public health policy when a child’s diet alone cannot meet nutrient requirements - ►Providing child < 36 months of age less than 0.25 mg of fluoride daily when the water supply contains less than 0.3 ppm fluoride. ►Providing child 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 per day if a child consumes less than 1 liter (or 1 quart) of vitamin D fortified milk or formula. ► 5 L U 425I Routine ingestion of nonfood items (pica) Examples of inappropriate nonfood items: ►Ashes; ►Carpet fibers; ►Cigarettes or cigarette butts; ►Clay; ►Dust; ►Foam rubber; ►Paint chips; ►Soil; and ►Starch (laundry or cornstarch). 5 L U Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026 428 Dietary Risk Associated with Complementary Feeding Practices - Child > 12 to < 24 months of age 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. Transistion from a diet based on infnant/toddler foods to one based on the Dietary Guidelines for Americans, and is at risk of inappropriate complementary feeding. Note: A complete nutrition assessment, including #425 - inappropriate Nutrition Practices for Children, must be completed prior to assigning this risk. 5 L U 501 Possibility of Regression - A participant who has previously been certified eligible for the Program may be considered to be at nutritional risk in the next certification period if the Competent WIC Authority (CWA) determines there is a possibility of regression in nutritional status without the benefits that the WIC Program provides. Note: Regression cannot be assigned to a participant two certification periods in a row and may only be used once after the initial certification. 5 L U 502 Transfer of Certification – Person with current valid Verification of Certification (VOC) documents from another State or local agency. The VOC is valid until the certification period expires and shall be accepted as proof of eligibility for program benefits. N/A L U 801 Homelessness – Child who lacks a fixed and regular night time residence; or whose primary night time 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 for human beings. 5 L U
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026 802 Migrancy – Child who is a member of a family that contains at least one individual: ►Whose principal employment is in agriculture on on a seasonal basis and; ►Has been so employed within the last 24 months and; ►Who establishes, for the purposes of such employment, a temporary abode. 5 L U 901 Recipient of Abuse – A child subjected to abuse, encompassing physical, sexual, emotional, neglect, or psychological maltreatment. The experience of abuse may be self- reported by the individual, an individual’s family member,a social worker, health care provider, or other appropriate personnel. Child abuse and/or neglect is any act or failure to act that results in harm to an infant or child or puts an infant or child at risk of harm. 5 L U 902 Child of Primary Caregiver with Limited Ability to Make Feeding Decisions and/or Prepare Food - A child whose primary caregiver is assessed to have a limited ability to make appropriate feeding decisions and/or prepare food. Examples include, but are not limited to: ►Documented or self-reported misuse of alcohol, use of illegal substances, use of marijuana, or misuse of prescription medications. ►Mental illness, including clinical depression.* ►Intellectual disability.* ►Physically disabled to a degree which restricts or limits food preparation abilities. ►< 17 years of age. * Presence of the condition diagnosed, documented, or reported by a physician or psychologist or someone working under a physician’s orders, or as self-reported by applicant/participant/caregiver. 5 L U 903 Foster Care – Entered the foster care system during the previous 6 months or moved from one foster care home to another foster care home during the previous 6 months. 5 L U 904 Environmental Tobacco Smoke Exposure (ETS) – ETS exposure is defined as exposure to smoke from tobacco products inside enclosed areas, like the home, place of child care, etc. ETS is also known as secondhand, passive, or involuntary smoke. The ETS definition also includes the exposure to the aerosol from electronic nicotine delivery systems. 3 L U
Clinical/Health/Medical Conditions All Conditions are User-assigned, unless specifically noted. Risk level assigned (High or Low Risk) noted in the Definition section. NRF Code Compass Description Definition Categories P B N I C 301 Hyperemesis Gravidarum* Severe nausea and vomiting to the extent that the pregnant woman becomes dehydrated and acidotic. (High Risk) X 302 Gestational Diabetes* Any degree of glucose/carbohydrate intolerance with onset or first recognition during pregnancy. (High Risk) X 303 History of Gestational Diabetes* History of diagnosed gestational diabetes mellitus (GDM). (Low Risk) X X X 304 History of Preeclampsia* History of diagnosed preeclampsia. (Low Risk) X X X 311A History of Preterm Delivery Delivery of an infant born ≤ 36 6/7 weeks gestation: (Low Risk) Pregnant: Any history of preterm delivery. Breastfeeding/Non-Breastfeeding: Most recent pregnancy. X X X 311B History of Early Term Delivery Delivery of an infant born ≥ 37 0/7 and ≤ 38 6/7 weeks: (Low Risk) Pregnant: Any history of early term delivery Breastfeeding/Non-Breastfeeding: Most recent pregnancy X X X 321 History of Spontaneous Abortion, Fetal or Neonatal Loss Any history of spontaneous abortion, fetal or neonatal loss. (Low Risk) ● 321A Pregnant: Any history of fetal or neonatal death or 2 or more spontaneous abortions. ● 321B Breastfeeding: Most recent pregnancy in which there was a multifetal gestation with one or more fetal or neonatal deaths but with one or more infants still living. ● 321C Non-Breastfeeding: Spontaneous abortion, fetal or neonatal loss in most recent pregnancy. Note: Spontaneous abortion occurs before 20 weeks; fetal death occurs at or after 20 weeks gestation; neonatal death is within 0-28 days of life. X X X 331 Pregnancy at Young Age** **System assigned 331A: < 16 years (High Risk) 331B: 16 to ≤ 20 years (Low Risk) Pregnant: Current pregnancy Breastfeeding/Non-Breastfeeding: Most recent pregnancy X X X 201 Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
NRF Code Compass Description Definition Categories P B N I C 332 Short Interpregnancy Interval** Interpregnancy interval of less than 18 months from the date of a live birth to the conception of the subsequent pregnancy for the following: (Low Risk) Pregnant: Current pregnancy Breastfeeding/Non-Breastfeeding: Most recent pregnancy X X X **System assigned 334 Lack of or Inadequate Prenatal Care Prenatal care beginning after the 1st trimester (after 13th week). (Low Risk) X 335 Multi-fetal Gestation More than one fetus in: Pregnant: the current pregnancy (High Risk) Breastfeeding: the most recent pregnancy (High Risk) Non-Breastfeeding: the most recent pregnancy (Low Risk) X X X 336 Fetal Growth Restriction (FGR)* Fetal weight <10th percentile for gestational age. (High Risk) Note: Fetal Growth Restriction (FGR) may be diagnosed by a physician with serial measurements of fundal height, abdominal girth and can be confirmed with ultrasonography. FGR replaces the term Intrauterine Growth Retardation (IUGR) X 337 History of Birth of a Large for Gestational Age Infant* Pregnant: Any history of giving birth to an infant weighing ≥ 9 pounds (4000 grams). (Low Risk) Breastfeeding/Non-Breastfeeding: Most recent pregnancy, or history of giving birth to an infant weighing ≥ 9 pounds (4000 grams). (Low Risk) X X X 338 Pregnant Woman Currently Breastfeeding Pregnant woman who is currently breastfeeding. (Low Risk) X 339 History of Birth with a Nutrition A woman 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. (Low Risk) Pregnant: Any history of birth with nutrition-related congenital or birth defect. Breastfeeding/Non-Breastfeeding: Most recent pregnancy Related Congenital or X Birth Defect* X X Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
NRF Code Compass Description Definition Categories P B N I C 341 Nutrient Deficiency or Disease* Nutritional deficiency or disease caused by insufficient dietary intake of macro and micronutrients. Diseases include, but are not limited to: (High Risk) X X X X X ● Protein energy malnutrition ● Scurvy ● Rickets ● Vitamin K deficiency ● Pellagra ● Cheilosis ● Beriberi ● Hypocalcemia ● Osteomalacia ● Menkes disease ● Xerophthalmia 342 Gastro- intestinal Disorders* Disease(s) and/or conditions(s) that interfere with the intake or absorption of nutrients. The diseases and/or conditions include, but are not limited to: (High Risk) ● 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 X X X X X 343 Diabetes Mellitus* Consists of a group of metabolic diseases characterized by inappropriate hyperglycemia resulting from defects in insulin secretion, insulin action or both. (High Risk) X X X X X 344 Thyroid Disorders* Thyroid dysfunctions that occur in pregnant and postpartum women, during fetal development, and in childhood are caused by the abnormal secretion of thyroid hormones. The medical conditions include, but are not limited to: (High Risk) ● Hyperthyroidism ● Hypothyroidism ● Congenital Hyperthyroidism ● Congenital Hypothyroidism ● Postpartum Thyroiditis X X X X X Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
NRF Code Compass Description Definition Categories P B N I C 345 Hypertension and Prehypertension* Presence of Hypertension or Prehypertension, including preeclampsia. (High Risk) X X X X X 346 Renal Disease* Any renal disease including pyelonephritis and persistent proteinuria, but excluding urinary tract infections (UTI) involving the bladder. (High Risk) X X X X X 347 Cancer * A chronic disease whereby populations of cells have acquired the ability to multiply and spread without the usual biologic restraints. The current condition, or treatment of the condition, must be severe enough to affect nutritional status. (High Risk) X X X X X 348 Central Nervous System Disorders* Conditions which affect energy requirements, ability to feed self, or alter nutritional status metabolically, mechanically, or both. These include but are not limited to: (High Risk) ● Epilepsy ● Cerebral palsy (CP) ● Neural tube defects (NTD), such as spina bifida ● Parkinson’s disease ● Multiple sclerosis (MS) X X X X X 349 Genetic and Congenital Disorders* A hereditary or congenital condition at birth that causes physical or metabolic abnormality. The current condition must alter nutrition status metabolically, mechanically, or both. May include but is not limited to: (High Risk) X X X X X ● Cleft lip or palate ● Down’s syndrome ● Muscular dystrophy ● Thalassemia major ● Sickle cell anemia (not sickle cell trait) 351 Inborn Errors of Metabolism* Inherited metabolic disorders caused by a defect in the enzymes or their co- factors that metabolize protein, carbohydrate, or fat. Inborn errors of metabolism (IEM) generally refer to gene mutations or gene deletions that alter metabolism in the body, including but not limited to: (High Risk) X X X X X ● Amino acid disorders ● Organic acid metabolism disorders ● Fatty acid oxidation disorders ● Lysosomal storage diseases ● Urea cycle disorders ● Carbohydrate disorders ● Peroxisomal disorders ● Mitochondrial disorders Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
NRF Code Compass Description Definition Categories P B N I C 352A Infectious Diseases Acute* A disease which is characterized by a single or repeated episode of relatively rapid onset and short duration. The infectious disease must be present within the past 6 months. Includes, but not limited to: (High Risk) ● Hepatitis A ● Hepatitis E ● Listeriosis ● Pneumonia ● Meningitis (Bacterial/Viral) ● Bronchitis (3 episodes in last 6 months) ● Parasitic Infections X X X X X 352B Infectious Diseases Chronic* Conditions likely lasting a lifetime and require long-term management of symptoms. Includes, but not limited to: (High Risk) ● HIV (Human Immunodeficiency Virus) ● AIDS (Acquired Immunodeficiency Syndrome) ● Hepatitis B ● Hepatitis C ● Hepatitis D X X X X X 353 Food Allergies* Food Allergies are adverse health effects arising from a specific immune response that occurs reproducibly on exposure to a given food. Risk NRF 353 when a food allergy is diagnosed, documented, or reported by a physician or a medical professional working under a physician’s orders. It may also be assigned when self-reported by the applicant/participant/caregiver, provided there is a prior physician diagnosis. Although reactions can occur from the ingestion of any food, a small number of foods are responsible for most food-induced allergic reactions. The foods that most often cause allergic reactions are listed below (High Risk): ● Peanuts ● Cow’s milk ● Shellfish ● Tree nuts ● Eggs ● Fish ● Wheat ● Soy ● Sesame Clarification: NRF353 applies only to food allergies. It should not be used for X X X X X Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
non-immunologic adverse reactions to food. Examples of such non-allergic food reactions include wheat sensitivity, lactose intolerance, histamine fish poisoning, and caffeine toxicity. 354 Celiac Disease* An autoimmune disease precipitated by the ingestion of gluten (a protein in wheat, rye, and barley) that result in damage to the small intestine and malabsorption of the nutrients from food. Also known as Celiac Sprue, Gluten- sensitive Enteropathy, and Non-tropical Sprue. (High Risk) X X X X X Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
NRF Code Compass Description Definition Categories P B N I C 355 Lactose Intolerance* The syndrome of one or more of the following: diarrhea, abdominal pain, flatulence, and/or bloating, that occurs after lactose ingestion. (Low Risk) Note: Evidence of the condition may be documented by the WIC staff X X X X X 356 Hypoglycemia* Presence of hypoglycemia. (High Risk) Note: 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. Symptomatic hypoglycemia is a risk observed in a substantial proportion of newborns who are small for gestational age. It is uncommon and of shorter duration in newborns who are of the appropriate size for gestational age. X X X X X 357 Drug Nutrient Interactions 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. Medication purpose can be an indicator of potential drug nutrient interactions. Includes but not limted to: (High Risk) ● Diuretic (Midamor, Hygroton, Lasix) ● Antacid (Tums) ● Antibiotic (Ciprofloxacin) ● Proton pump inhibitors (Prevacid, Prilosec) ● Thyroid hormone (Synthroid, Levothroid) ● Antihyperglycemic (Metformin) ● Analgesic (Methadone) ● Antiemetic, Antinauseant (Zofran) ● Antiepileptic (Phenobarbital) ● Corticosteroid (Predninsone) ● Antiulcer, AntiGERD, Antisecretory (Zantac) ● Antidepressant (Zoloft) ● Ulcerative Colitis Treatment (Sulfasalazine) X X X X X 358 Eating Disorders* Eating disorders are characterized by severe disturbances in a person’s eating behaviors and related thoughts and emotions. Eating disorders can include, but are not limited to: anorexia nervosa (AN), Bulimia Nervosa (BN), and Binge-Eating Disorder (BED). The presence of an eating disorder diagnosis can be documented or reported by a healthcare provider or someone working under a physician’s orders, or as self-reported by the applicant/participant/caregiver. X X X Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
Note: Evidence of the condition may be documented by the WIC High Risk Counselor 359 Recent Major Surgery, Trauma, Burns Major surgery (including C-sections), trauma or burns severe enough to compromise nutritional status. Any occurrence: (High Risk) ● Within the past two months may be self-reported. ● More than two months previous must have the continued need for nutritional support diagnosed by a physician or a health care provider working under the orders of a physician. X X X X X Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
NRF Code Compass Description Definition Categories P B N I C 360 Other Medical Conditions * Diseases or conditions with nutritional implications that are not included in any of the other medical conditions. The current condition, or treatment for the condition, must be severe enough to affect nutritional status. This includes, but is not limited to: (High Risk) ● Juvenile Idiopathic Arthritis (JIA) ● Systemic Lupus Erythematosus ● Polycystic Ovary Syndrome (PCOS) ● Cardiovascular Disease ● Persistent Asthma (moderate or severe) requiring daily medication ● Cardiovascular Disease ● Cystic Fibrosis The presence of medical condition(s) diagnosed, documented, or reported by a healthcare provider or someone working under a physician’s orders, or as self- reported by applicant/participant/caregiver. X X X X X 361 Mental Illness* A syndrome characterized by clinically significant disturbance in an individual’s cognition, emotion regulation, or behavior that reflects a dysfunction in the psychological, biological, or developmental processes underlying mental functioning. Associated with significant distress or disability in social occupations, or other important activities. Mental illnesses where the condition, or treatment for the condition may affect nutrition status include, but are not limited to: ● Depression ● Post-Traumatic Stress Disorder (PTSD) ● Personality Disorders ● Schizophrenia ● Anxiety Disorders ● Obsessive-Compulsive Disorder (OCD) ● Bipolar Disorders ● Attention-Deficit/Hyperactivity Disorder (ADHD)(High Risk) The presence of a mental illness is diagnosed, documented, or reported by a healthcare provider or someone working under a physician’s orders, mental health provider or as self-reported by an applicant, participant, or caregiver. X X X 362 Developmental, Sensory or Motor Disabilities Interfering with the Ability to Eat Developmental, sensory, or motor disabilities that restrict the ability to chew or swallow food or require tube feeding to meet nutritional needs. Disabilities include but are not limited to: (High Risk) ● Minimal brain function ● Feeding problems due to a developmental disability such as pervasive development disorder (PDD) which includes autism X X X X X Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
● Birth injury ● Head trauma ● Brain damage ● Other disabilities 363 Pre-Diabetes* Impaired fasting glucose (IFG) and/or impaired glucose tolerance (IGT) are X X referred to as pre-diabetes. These conditions are characterized by hyperglycemia that does not meet the diagnostic criteria for diabetes mellitus. (High Risk) 371 Nicotine and Tobacco Use Use of any product that contains nicotine and/or tobacco to include but not limited to cigarettes, pipes, cigars, electronic nicotine delivery systems (e- X X X cigarettes, vaping devices), hookahs, smokeless tobacco (chewing tobacco, snuff, dissolvable), or nicotine replacement therapies (gums, patches). Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
NRF Code Compass Description Definition Categories P B N I C 372 Alcohol and Substance Use 372A Alcohol Use Pregnant: ▪ Any current alcohol use** (High Risk) Breastfeeding (High Risk) & Non-Breastfeeding Postpartum (Low Risk): ▪ High Risk Drinking: Routine consumption of ≥8 drinks per week or ≥4 drinks on any day. ▪ Binge Drinking: Routine consumption of ≥4 drinks within 2 hours. Note: One drink is 1 can (12 oz) of beer; 5 oz wine; 1 ½ fluid oz liquor. X X X X X X 372B Substance Use Pregnant & Breastfeeding: (High Risk) ▪ Any illegal substance use and/or abuse of prescription medications. ▪ Any marijuana use in any form. Non-Breastfeeding Postpartum: (High Risk) ▪ Any illegal substance use and/or abuse of prescription medications. Note: 372B is not assignable to non-breastfeeding women who use marijuana. 381 Oral Health Conditions* Oral health conditions include, but are not limited to: (Low Risk) ● Dental caries, often referred to as “cavities” or “tooth decay” ● Periodontal diseases (stages include gingivitis and periodontitis) ● Tooth loss, ineffectively replaced teeth or oral infections which impair the ability to ingest food in adequate quantity or quality Note: Evidence of the condition may be documented by the WIC staff X X X X X 382 Fetal Alcohol Spectrum Disorders* Fetal Alcohol Spectrum Disorders (FASDs) are a group of conditions that can occur in a person whose mother consumed alcohol during pregnancy. Effects can include physical, mental, behavioral, and/or learning disabilities with lifelong implications. Infants & Children (High Risk) Pregnant, Breastfeeding & Non-Breastfeeding (Low Risk) X X X X X 383 Neonatal Abstinence Syndrome* Neonatal abstinence syndrome (NAS) is a drug withdrawal syndrome that occurs among drug-exposed (primarily opioid-exposed) infants as a result of the mother’s use of drugs during pregnancy. NAS is a combination of physiologic and neurologic X Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
symptoms that can be identified immediately after birth and can last up to 6 months after birth. (High Risk) * Presence of the condition diagnosed, documented, or reported by a physician or someone working under a physician’s orders, or as self-reported by applicant/participant/caregiver. A self-reported diagnosis (My doctor says that I have/my son or daughter has…”) should prompt the CWA to validate the presence of the condition by asking more pointed questions related to that diagnosis. Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
Colorado WIC Program Policies and Procedures Section 4: Organization and Management Revised:01.01.2021
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Ordering and Securing eWIC Cards
Policy: Local agencies are responsible for tracking current eWIC card inventory, ordering and maintaining security of the eWIC cards received for their agency.
Regulation: Colorado WIC Policy
Procedure/Additional Guidance: Managing eWIC cards The state office has designated a Replenishment Threshold for each clinic. Local staff must contact State office if the threshold level needs to be reset. When the Current Inventory is below the Replenishment Threshold a warning message will appear that EBT cards are in need of replenishment immediately. The message will appear on the local clinic’s LA/Clinic EBT Card Inventory Summary page.
Ordering eWIC cards In Compass, go to the LA/Clinic EBT Card Inventory in Operations. Go to the Summary page. Click “edit.” Enter the number of cards requested in the “Currently on Order” field. Note there are 250 cards per box, so orders must be placed in increments of 250. Enter the current date in the “Current Order Date” field. Save. The order will automatically be sent to the State WIC office. Allow at least two weeks for delivery to your clinic or agency.
In emergency situations only, eWIC cards may be ordered by calling the State WIC Office (303-692-2400).
To Receive and Verify eWIC cards The clinic must receive and verify the shipment before any eWIC cards can be issued to participants. Each shipment of eWIC cards contains a packing list noting the range of cards and the number of boxes sent. Two staff members are required to complete the process of receiving and verifying the order. Steps for receiving and verifying eWIC cards are listed below.
Receiving (First Person) 1. When the shipment of eWIC cards arrives at the WIC clinic, check for damage to the shipment boxes and that all boxes are received. Match the range of PANs listed on the boxes with the range recorded on the packing slip. 2. In eWIC Compass, expand the LA/Clinic EBT Card Inventory branch in the Operations panel and click “Shipment Receiving.” 3. On the Shipment Receiving panel, ensure that “Shipped not Received” is selected to display your clinic’s card order information 4. Check that the PANs received match the numbers of those displayed in eWIC Compass. 5. Click “Edit.” The “Received Date” will automatically populate with today’s date. Click the “Add Row” button (next to the Receiving Details table grid) and enter the Begin PAN and Quantity of the shipment (which is also listed above the Receiving Details grid). Tab over to the “Received” column, select the box and Save. 6. Your name will appear next to the “Updated By”: field.
Verifying (Second Person) 1. In eWIC Compass, expand the LA/Clinic EBT Card Inventory branch in the Operations panel and click “Shipment Receiving.” 2. On the Shipment Receiving panel click “Received not Verified.” 3. Click the “Verify” button and Save. 4. Your name will appear next to the Verified By: field.
Colorado WIC Program Policies and Procedures Section 4: Organization and Management Revised:01.01.2021
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Security of eWIC Cards Clinic staff members are responsible for the security of eWIC cards. The state office recommends that eWIC cards are maintained within the clinic in the original box and that cards are removed only as needed. All eWIC cards must be kept in a locked area when the clinic is closed.
Physical Inventory The WIC Director or a designee must perform a physical inventory of all eWIC cards at each location site on a quarterly basis to ensure that all cards are accounted for and correctly assigned to each clinic. Contact the State Office Help Desk if any adjustments need to be made.
Lost and Damaged Cards Damaged or unusable cards must be destroyed by cutting or shedding before disposing. Lost and damaged cards must be accounted for in the clinic inventory. Contact the State Office Help Desk if any adjustments need to be made.
Colorado WIC Program Policies and Procedures Section 7: Caseload Management Revised: 10/01/2018
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Outreach
Policy: The WIC Program must publicize the availability of the Program at least once per year using outreach techniques believed to be the most effective. Additionally, the State WIC Office must release an annual statewide general press release.
Regulation: CFR 246.4(a)(7), 246.7(a)(9)
Procedure/Additional Guidance The United States Department of Agriculture (USDA) specifies that WIC Programs perform the four following principle activities to assure effective outreach (each discussed in detail below): Publicize the availability of the WIC Program Build an outreach network Inform organizations in the outreach network about the WIC Program Coordinate with other community resources
Outreach consists of the techniques used to promote and advertise the WIC Program to inform applicants, participants, and potentially-eligible persons of the Program availability, Program participants’ rights and responsibilities, the nondiscrimination policy and the procedure to file a complaint. Should the Colorado WIC Program’s financial resources become limited, participants at the highest nutritional risk must be served. Therefore, an effective outreach program targets those with the highest nutritional risk.
Principle Activities for Effective Outreach Publicizing the Availability of the WIC Program: Several techniques can be used to publicize the availability of a local WIC Program. Media related activities include news releases, newspaper feature stories, and public service announcements. Other activities include distribution of flyers, pamphlets, and posters.
Public Service Announcements must include the following elements: o Program Availability Hours of operation Location of clinics o Complaint Information How to file a complaint The WIC Nondiscrimination Statement
Building an Outreach Network : An effective outreach program includes an established network of community agencies, organizations, and employers who serve the same population. The purpose of this network is to ensure that potentially-eligible clients are referred to the WIC Program. Include community agencies and organizations serving low income pregnant, breastfeeding and postpartum women, infants, and children in the outreach network. Since many working families qualify for the WIC Program, include employers of potentially-eligible clients in the outreach network. Provide to these organizations written materials that describe WIC and how to apply
Informing Organization in the Outreach Network about the WIC Program o Once the outreach network is established, provide continual updates regarding the WIC Program to the agencies/organizations. This can be accomplished by routinely visiting the agency, through telephone contacts, and/or sending personal update letters or arranging to provide short presentations on the WIC Program at a staff meeting could also be a valuable outreach technique. Minimally, each agency/organization should be contacted at least once a year, and more often if a major change in the Program occurs (i.e., caseload increase or decrease). o Community agencies should maintain a stock of pamphlets describing the WIC Program with the address and telephone number of the nearest WIC office, so they can be distributed to potentially- eligible clients. Also, if the agency permits, a WIC poster should be displayed.
Colorado WIC Program Policies and Procedures Section 7: Caseload Management Revised: 10/01/2018
Page 2 of 6 Coordinate with Community Resources: The local WIC Program’s outreach activities should be coordinated with other community programs.
Targeting Outreach Efforts to Special Populations and High Risk Groups
Migrant Farm Workers: The migrant population needs outreach even more than the general population because their newness to the area often means they do not know where to obtain WIC services. Outreach is also necessary to overcome their isolation from the general population. Outreach techniques used for migrants may include: o Outreach in migrant camps by bilingual staff members or volunteers. o Special WIC clinics held in the migrant camps. o Inclusion of migrant farm worker organizations in the outreach network.
Refugee Population: The refugee population also needs outreach more than the general population because of their newness to the area. Outreach techniques that may be useful for the refugee population include: o Notifying agencies that sponsor refugees about the WIC Program. o Making WIC outreach pamphlets available in the appropriate language(s). o Including community organizations that service refugees in the outreach network.
Infants and Children under the Care of Foster Parents, Protective Services, or Child Welfare Services Infants and children in protective services, placed in a foster home, or under the care of child welfare are considered to be families of one and are, therefore, eligible to participate in WIC when caseload slots are available. Outreach is necessary to let the caregivers of this population know about Program services. This population may be reached by: o Notifying agencies/organizations that work with infants and children placed in protective care or foster homes: Medicaid Office Mental Health TANF Office Foster Parent Support Groups
Protective Services Office
o Use public service announcements (PSAs) targeted specifically toward caregivers of these infants and children. Encourage clients to do outreach. Support groups for foster parents and other caregivers may exist in some communities. These groups could provide a number of referrals and word of mouth is often the most effective means of getting the word out.
Targeting High Priorities Target services to the highest WIC priorities, especially when WIC agencies are at caseload. Targeting WIC services to those who would benefit most from the Program includes priorities 1 and 2 or pregnant/ breastfeeding women and infants, migrants, and homeless individuals. Infants and children under the care of foster parents, protective services, or child welfare authorities, including infants exposed to drugs prenatally should be targeted. Suggested activities for targeting infants and pregnant/breastfeeding women include:
Enlist the help of people in the community who are well known and respected by the people you are targeting or who care about the people you are targeting. These key people might be popular radio announcers, grocers, doctors, teachers, nurses, 4-H leaders, athletes, and pharmacists. They may be willing to do spot radio announcements or newspaper interviews on nutrition, discuss WIC with people they work with, or be advocates for WIC in other ways. Contact employers in your community to see if they are willing to display outreach posters or brochures or let you speak at a staff meeting can be very effective at reaching working people who are not using WIC services.
Form a local task force and work with groups to put together a strategy for publicizing WIC to high priorities within the community. o Other programs within your health department or nursing service. o Church groups. o Boards of Education.
Colorado WIC Program Policies and Procedures Section 7: Caseload Management Revised: 10/01/2018
Page 3 of 6 o Local chapters of the nursing/physician/dietetic organizations. o Mayor or County Commissioners. o Local representatives of elected officials. o School nurses and wellness teams. o Local chapter of March of Dimes. o Medicaid offices. o Temporary Assistance to Needy Families (TANF) offices. o Supplemental Nutrition Assistance Program (SNAP) offices. o Hunger Free Colorado. o La Leche League or local breastfeeding task forces. o Hospitals. o Agriculture extension offices. o Day care facilities. o Provide WIC information (posters, pamphlets, presentations etc.) to all the places in your community that specifically attract infants and pregnant and breastfeeding women (versus attracting children or families in general). Medicaid offices. o Child birth classes. o Summer feeding programs. o La Leche League meetings. o Obstetricians' and pediatricians' offices. o Stores/thrift shops that sell maternity or infant clothes. o Obstetrics wards in hospitals. o Teen mothers' classes or groups. o New parents' classes at the YMCA/YWCA or Red Cross. o Day care centers that serve infants. o Babysitting co-ops. o Diaper services. o Supermarkets – at customer service or next to the baby food, diapers, or formula. o Exercise programs geared for pregnant women. o Infant swim classes. o Birthing clinics. o Offices serving other nutrition assistance programs, e.g., Supplemental Nutrition Assistance Program (SNAP), CSU Extension.
Encourage clients to help with outreach. Make a poster directed at clients telling clients (especially pregnant and breastfeeding women or infants) about WIC. Or, give incentive prizes to participants for referring applicants. Extra "points" can be given for referring pregnant and breastfeeding women and infants. Try to get a merchant to donate incentive prizes (such as a half price restaurant meal, a movie pass, or a discount haircut). Participant surveys show that word of mouth referrals are by far the most effective outreach mechanism. Write a newspaper article about good nutrition for pregnancy, breastfeeding, and/or infancy. Use a catchy title that will attract the reader's attention. At the end of the article, describe the WIC Program, and include your local address and phone. Include a "human interest" photo that will attract the readers' attention, (e.g., a pregnant woman being weighed, a mother holding her newborn). Use public service announcements (PSAs) designed specifically to attract pregnant and breastfeeding women and infants. Consider whether your PSAs need to be done in a second language too, such as Spanish. Target radio and television stations with programming oriented to high-priority populations that may be interested in WIC. Outreach in small towns throughout the county. These towns may offer a new pool of high priority clients. Advertise and offer free height and weight screenings for infants. At the screening, let families know about the WIC Program. Include information about WIC on the county or local health department’s webpage. Add a link from the county webpage to the Colorado WIC Facebook page. (www.Facebook.com/CDPHE.WIC). Share posts to the Colorado state WIC Facebook page. This helps cross promote both organizations. Let participants know about the Colorado WIC Facebook page.
Considerations When Doing Outreach Avoid jargon in your outreach materials. For example, people may not understand the meaning of a "food package" or "nutrition risk criteria." Outreach not only to target populations but also to those people who care for them such as grandparents in a local senior citizen group. Be sensitive to the community's values. For example, do not stress that WIC is a USDA program in a county where USDA may be associated with farm foreclosures.
Colorado WIC Program Policies and Procedures Section 7: Caseload Management Revised: 10/01/2018
Page 4 of 6 Develop an “additional resources” sheet for people who apply for WIC as a result of outreach efforts but do not qualify or are put on a waiting list.
Documenting and Reviewing Effectiveness of Outreach Activities Local agencies are encouraged to develop a documentation mechanism that suits their needs. The State agency reviews outreach efforts during monitoring visits through review of the documentation maintained by the agency.
Local agencies may want to determine if their outreach network is functioning effectively. By reviewing the Referral Summary report, the agency can see who is making referrals to your clinic and those programs where outreach efforts can be enhanced.
Outreach Resources The State Office has outreach pamphlets and posters available in English and Spanish. Agencies can adapt these for local use by including the address and telephone number of the nearest WIC office.
Colorado WIC Program Policies and Procedures Section 7: Caseload Management Revised: 10/01/2018
Page 5 of 6 WIC Outreach Network
Farm Worker Organizations
Education Institutes
Agencies
Child Care Serving
Program Homeless Individuals
Health and Medical Organizations
Community Organizations Serving High-Priority Populations
Local WIC Program
Hospitals, Clinics,
Physicians
Faith-Based Organizations
Employers of Potentially- Eligible Clients
Social Service Agencies
Community Assistance
and Unemployment
Agencies Colorado PEAK
Page 6 of 6 General Agencies or Organizations in the WIC Outreach Network
Specific Examples Employers of Potentially-Eligible Clients Major employers in the community
Factories/warehouses
Fast food restaurants/restaurants
Grocery stores
Retail stores
Health and Medical Organizations Local childbirth associations
Local medical associations
La Leche League
Local dietetic and nursing associations
Hospitals, Clinics and Physicians Local physicians (obstetricians, pediatricians, etc.)
Local hospitals (include Social Service and dietary departments, maternity and pediatric units)
Local health department or nursing services (EPSDT) Health Care Program for Children with Special Needs (HCP) Nurse Family Partnership,
Health maintenance organizations
Family Planning
Community Assistance & Unemployment Agencies Salvation Army
Goodwill
Local Job Training Partnership Act (JTPA)
Local WIN (Work Incentive) Programs
Social Service Agencies Medicaid
Supplemental Nutrition Assistance Program
Temporary Assistance to Needy Families
Foster Care Program Colorado PEAK
Religious Organizations/Advocacy Groups Churches/Synagogues
Colorado Advocates Against Hunger
Bread-For-The-World
Emergency food banks
Housing Authority
Crisis Center
Battered Women Center
Community Action Program
Educational Institutes Adult education programs
High school Teen Parents’ Program
Local colleges and universities
CSU-Extension service SNAP-Ed
Extended Food and Nutrition Education Program (EFNEP)
Agencies Serving Homeless Individuals Homeless Shelters
Food Kitchens
Unemployment Offices
YMCA, YWCA
Colorado WIC Program Policies and Procedures
Section 8: Certification, Eligibility and Coordination Revised:03/01/2026
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Participant Notification: Initial Explanation of WIC, Rights & Responsibilities
Policy: During initial certification and subsequent recertification visits, WIC endorsers and participants receive an explanation to the WIC Program, including their rights and responsibilities.
Regulation: CFR 246.7 (i)(10), CFR 246.7 (j)(1)-(9), CFR246.7 (j)(4)
Procedure/Additional Guidance: Initial Explanation of the WIC Program ● Explain the reason the participant is being enrolled on the program by stating a connection between their eligibility and the desired health outcome. This does not mean every risk must be reviewed, but rather is intended to summarize the reasons the participant is being enrolled. Example: “Your child is being enrolled in WIC to help him have good nutrition and to watch his growth over the next year.” ● Food provided by the WIC program is supplemental; it is not intended to provide all of the participant’s daily food needs. ● A thorough nutrition assessment is the basis for individualized care. Example: “The goal of the WIC program is to improve the health and nutrition of families. Today we are going to talk about your health and diet, which will help me tailor foods to meet your needs, and I’ll share information on organizations that may be helpful.” ● Length of certification. Inform each participant of the length of their certification, when their last food benefits will be issued, and that they will need to be recertified at the end of their certification period to determine if WIC benefits may continue past that period. ● Local rules and policies. Explain local WIC program rules or policies, including policies regarding late or missed appointments. ● Transfer policy. Explain the transfer policy and use of the VOC card. ● Participant's right to a fair hearing if they disagree with any decision made regarding their participation in the WIC Program. ● Referrals and importance of health care. Provide information on how to access and use local health and nutrition services, including: the types of health services available, where they are located, how they may be obtained, and why they may be useful. ● Correct use of the eWIC card. See section below. ● Shopping for their WIC food benefits using the Colorado WIC Food List & Shopping Guide. ● Instruct participants on the process for receiving additional food benefits at future appointments. ● eWIC card misuse: Explain that giving away, selling or attempting to sell WIC foods, formula, or eWIC card online or by any other means will be considered a participant violation. Misuse of the eWIC card may result in participants being dropped or suspended from the WIC Program. ● Substance Use and Abuse: Provide education on the harmful effects of drug, alcohol, tobacco, and certain over-the-counter medications on fetal growth and development. For participants who admit use of these substances, discuss the fact that there are no safe levels of exposure and that quitting is recommended. ● HIV status: Advise all pregnant, postpartum, and breastfeeding women to know their HIV status. Provide information regarding the risks of transmitting HIV from mother to baby during pregnancy and delivery and the importance of getting early medical treatment to reduce the risk to their baby. Inform all women that HIV- positive mothers should not breastfeed. ● If the local agency is not serving all priorities, explain the nature of the WIC priority system and the participant’s priority designation.
WIC Participant Rights and Responsibilities The Participant Rights and Responsibilities (R&R) document explains the basic rights of WIC participants and describes the responsibilities WIC participants must follow to continue to receive program benefits.
● Clients enrolled in the COWIC Texting Program will receive an appointment reminder text that includes a link to a video (R&R video) explaining their participant rights and responsibilities, as an alternative to reading a written copy. Clients may still request a written copy of the Rights and Responsibilities if preferred.
Colorado WIC Program Policies and Procedures
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● At every certification and recertification appointment, staff may ask the client if they have questions about the R&R video and provide a copy (electronic or hard copy) of the R&R if requested by the client. ● If a client has not viewed the R&R video before their appointment, staff must offer the client the option to view the video at that time or provide a copy (electronic or hard copy) of the R&R for the client to read or for staff to read to the client. This document must be provided in a language the client understands. Written versions of the R&R are available in multiple languages on the COWIC website. ● At the time of certification/recertification, obtain either the endorser’s signature or verbal acknowledgment to indicate they have read or viewed the R&R, understand and agree to it, and are aware of the certification end date. The signature or acknowledgement is then recorded in the client’s Compass record.
In state transfer: When an active participant transfers to a different agency or clinic in Colorado, it is not necessary for the agency or clinic to have the endorser review the R&R. The signature captured from the current certification period transfers with the participant’s Compass record. Out of state transfer: Out of state transfers must read the R&R and staff must capture the endorser’s signature.
Program explanation during subsequent recertifications
● Restate the purpose of the current visit. ● Restate the reasons for eligibility, including the connection to the desired health outcome. ● Ask if the participant has any questions or concerns about WIC services, WIC foods or the use of the eWIC food benefits card. ● Offer the participant the Food Benefits List and a current Colorado WIC Food List & Shopping Guide. ● Request the endorser read/review the R&R in a language the individual understands. ● Capture the endorser’s electronic signature at the time of recertification for each participant to indicate they have read, understand and agree with the R&R and understand when the certification ends. Compass attaches the captured signature to the participant’s record.
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Page 1 of 1 Participant Satisfaction Survey
Policy: The state office and local WIC agencies collaborate to conduct periodic participant satisfaction survey.
Regulation: WIC Nutrition Services Standards
Procedure/Additional Guidance The purpose of the survey is to assess customer service, effectiveness of nutrition and breastfeeding promotion and support, and to collect information about participant needs and interests. Participant Satisfaction Survey results help both state and local agencies plan services for the future years.
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Participant Violations
Policy: The local agency must disqualify, or take other actions in response to participant violations. Note: When a participant is disqualified, they must reapply for the program. They may not have benefits suspended temporarily and be reinstated to the program if it is within the same certification period. They must reapply.
Regulations: 7 CFR 246.2, 7 CFR 246.7 (j), 7 CFR 246.7 (l), 7 CFR 246.10 (b) (2) (ii) (D), 7 CFR 246.12 (u) (1), 7 CFR 246.12 (u) (5), 7 CFR 246.23 (c)(1)
Procedures/Additional Guidance Participant violation means any deliberate action of a participant, parent, or caretaker of an infant or child participant, or proxy that violates Federal or State statutes, regulations, policies, or procedures governing the Program. Participant violations include, but are not limited to, deliberately making false or misleading statements or deliberately misrepresenting, concealing, or withholding facts, to obtain benefits; selling or offering to sell WIC benefits, including cash-value vouchers, food instruments, EBT cards, breast pumps, or supplemental foods in person, in print, or online; exchanging or attempting to exchange WIC benefits, including cash-value vouchers, food instruments, EBT cards, breast pumps, or supplemental foods for cash, credit, services, non-food items, or unauthorized food items, including supplemental foods in excess of those listed on the participant's food instrument; threatening to harm or physically harming clinic, farmer, or vendor staff; and dual participation.
Prevention ● Explanation of WIC: Throughout the certification visit, educate the endorser as to how the Program benefits the health and nutrition of WIC participants and explain how tri-monthly benefit issuance procedures work. In an effort to prevent misunderstanding, ask if the endorser has any questions regarding the type of supplemental foods provided or the procedure to be followed when purchasing foods. ● Explanation of Misuse: During the certification visit, WIC staff should carefully explain what constitutes misuse of the WIC Program and the consequences. ● Dual Participation (participating in two WIC Programs simultaneously): Each new enrollee needs to thoroughly understand the illegality of participating in two WIC Programs. At the initial visit clients should be told that they can lose benefits for this action and may be required to pay back the value of benefits obtained while participating in two programs simultaneously. ● Participant Rights and Responsibilities: All endorsers must read (or be read) the Colorado WIC Program Rights and Responsibilities at each certification and recertification visit. At every certification visit, the endorser/participant must sign electronically acknowledging their understanding of the WIC Rights and Responsibilities.
Identifying and Managing Endorser/Participant Misuse When there is a report of misuse of the Program: ● Investigate the report. ● Determine if a violation occurred. ● If no violation is found, no action should be taken. ● If a violation is identified, document the violation in Compass (see Documenting a Participant Violation or Sanction section in this policy) and counsel the WIC participants on the appropriate use of their WIC benefits. ● Contact the state office for any clarification.
First-Time Suspected Misuse A first time occurrence is defined as one event or multiple events until the person has been counseled on the specific misuse. Since there are many cases of suspected misuse that cannot be technically proven, counseling should be less accusatory and more informational in nature. Refer to the Summary of Endorser/Participant Misuses and Consequences by Category table below.
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To start the session, simply state what was found: i.e., "This Craigslist posting is for the same formula that was issued to you" not "You are selling WIC formula on Craigslist." When possible, state the problem in terms of the issue—not in terms of the endorser.
Next, remind the endorser that this act constitutes misuse. Counsel to reeducate on the misuse, and on all other misuses within the same category of violations/misuses. Warn of the consequences of a second misuse. Show him/her the previously signed Rights and Responsibilities form.
If the participant/endorser has deliberately misrepresented information to be eligible for WIC Program benefits and is subsequently found ineligible, the State Office must issue a claim for the WIC benefits received. Clinic staff must contact the State WIC Office immediately
Subsequent Occurrences of Endorser/Participant Misuse A subsequent occurrence of misuse by one individual constitutes a serious situation. A second or third occurrence is defined as one event or multiple events from the time a person was last counseled until the person is subsequently counseled again. While the endorser may still deny the act, the circumstances of the same thing happening twice are too suspicious not to warrant some action. Before enforcing consequences for a second or third occurrence, however, clinic staff members need to have sufficient documentation that a misuse occurred and be certain that the misuse was intentional.
When a second or third occurrence is identified, the local agency must proceed with corrective action as outlined in the "Summary of Endorser/Participant Misuses and Consequences by Category" listing in this section.
If insufficient evidence is available to assign consequences for a second or third misuse, at a minimum another violation should be entered on the Participant Violations panel and counted as another warning. The participant should again be educated and warned of possible consequences of a repeat misuse.
Management of Multiple Misuses in Different Categories Occasionally a WIC participant may have multiple violations in different misuse categories (e.g., trying to return foods for store credit and verbal abuse). In such a case, document each violation on the Participant Violations panel. The infractions may occur at the same time or at different times. In order to apply the second occurrence consequences, the participant must have two misuse actions in the same category. In other words, if a participant had a misuse in Category I and a misuse in Category III, the participant should be warned, but not disqualified. However, if the consequence for a first occurrence is a mandatory sanction , the appropriate sanction must be applied.
Disqualification from the WIC Program Disqualification is the withholding of Program benefits for a defined period of time. A participant's disqualification period starts the day after the benefits’ Last Date to Use that allow for the 15-day notice period.
All participants (except as noted below) who are being disqualified and terminated from the Program must be told of their termination 15 days prior to the end of their benefits. At the time the participant/endorser is notified of termination, clinic staff must ensure the participant’s last set of benefits have an expiration date of 15 days into the future. If benefits expire in less than 15 days staff must issue the next month of benefits to ensure a 15-day notification period. If the benefits expire in more than 15 days (redeemed or not), no additional benefits should be issued. If the participant has two or three months of benefits, they should be allowed to keep only the benefits with dates for the 15-day notice period. All other future benefits must be removed. Loaned breast pumps must be returned within 15 days after termination.
Claims & State Office Responsibilities With certain types of participant violations the State WIC Office is required to file a financial claim against participants when there is substantiated proof the participant or endorser has improperly received or disposed of benefits (see “Summary of Endorser/Participant Misuses and Consequences by Category” listing in this section).
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When one of these violations has occurred the local WIC agency must contact the State WIC Office who will then determine the value of improperly obtained benefits and issue a claim letter to the participant.
When notified by the local agency, the State Office will: ● Investigate the situation to determine if a claim letter should be sent. ● Collect and maintain copies of documentation from the participant’s file pertaining to the violation in question. ● Determine the value of the benefits in question. ● Determine if the case should be referred to legal authorities for criminal action. ● Notify the local clinic of a participant’s status. In some cases, a participant may be terminated from the Program because of the value of the claim or because the claim is a second claim issued against the participant. ● Send a claim letter to the participant including: o Reason for the claim letter. o Value of benefits to be repaid. o Method of repayment. o Contact to discuss repayment. o Consequences of non-payment. o Participant’s rights for a fair hearing and method for obtaining a fair hearing.
Mandatory Disqualification: Whenever the State Office assesses a claim of $1000 or more, assesses a claim for dual participation, or assesses a second or subsequent claim of any amount, the participant will be disqualified from the Program for one year. The State Office may decide not to impose the one-year disqualification if full restitution of the claim letter is made.
Exceptions for Disqualification: The State Office may permit a participant to remain on the Program or to reapply for benefits if full payment is made, if a repayment schedule is agreed upon within 30 days of receipt of a claim letter, or, in the case of a participant who is an infant, child, or under age 18 and not the endorser, the State or local agency may approve the designation of a proxy who can assure that no further violations will occur and that benefits will be used properly.
Procedures for Fair Hearing: At the time of disqualification or when a claim letter is sent, the participant must be advised of the procedures to follow to obtain a fair hearing. A client may request a fair hearing up to 60 days from the date the agency mails or gives the applicant or participant the notice of adverse action.However, in order to continue to receive benefits while waiting for the outcome of a fair hearing, an appeal must be filed within 15 days of notice of disqualification or receipt of a claim letter. Any time a Fair Hearing is requested, either verbally or in writing, local staff should call the State Office immediately and follow the Fair Hearing procedures as described in the Program Manual, section 11, Civil Rights, Fair Hearing Policy and Procedures for Applicant/Participant Appeals.
Reinstatement of Program Benefits after Disqualification Period Once the disqualification period has ended, the local agency's responsibilities are: ● If the endorser returns: ✔ Reinstate the participant if he/she contacts the agency no later than fifteen (15) days after the end of the disqualification period and he/she is within his/her original certification period. ✔ If the certification period has expired, treat the participant as you would any past participant applying to the Program.
● If the endorser does not return: ✔ Keep the participant in terminated status if the endorser does not contact the agency within the fifteen (15) day period to resume benefits. ✔ If the endorser contacts the clinic after fifteen days, the participant will have to reapply for WIC services as a new applicant.
Documenting a Participant Violation or Sanction 1. Enter the violation and alert in Compass:
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● Go to Participant Violations Panel: ✔ Check the Do not allow food benefits check box so that WIC staff are required to counsel the participant before the issuance of future benefits. When checked, no new food benefits can be provided for this participant. A family alert message is set indicating that an action is required on the violations panel before food benefits can be issued. ✔ Add a violation row: ✔ Violation Date- Date the violation occurred. ✔ Violation Type- Enter the type of misuse. ✔ Details- Include any known details and whether it is a 1st or 2nd occurrence. Put more details in the comments area if more room is needed. ● Go to the Comments/ Alerts Panel: ✔ Create a new record on the Comment/Alert panel describing the situation. Enter an expiration date of 1 year in the future. For example: “Please counsel on not attempting to sell benefits. See participant violations panel before issuing more benefits.” This alert will post on the family alert tab. Check the “Display As Alert” check box. 2. Counsel the Participant. 3. Document the Violation and Sanction. ● Go to Participant Violations Panel. ✔ Record any comments from the participant in the “Comments” section. ✔ If a sanction is appropriate, add a row for a sanction. ✔ Start Date- Date the participant was counseled. ✔ End Date- One year after the counseling (If disqualifying the participant, the end date should be the date the sanction will be completed and the disqualification is over). ✔ Sanction Type- Enter the sanction type as either: “Warning/Education” or “Disqualify”. 4. If payment is due from the participant, check the Claim Req checkbox. Additional supporting detail can be recorded in the comments box, or a document can be scanned into the system. 5. Obtain the participant/endorser’s electronic signature after the counseling session. If an electronic signature is not available due to equipment malfunction, staff must print a copy of the notice, obtain the endorser’s signature, and scan the form into the participant’s Compass file. 6. Print out the Notice of Program Violation (or Disqualification if appropriate) using today’s date as the start and end date. Capturing the participants' and WIC staff signatures on the Notice is optional. 7. Uncheck the “Do Not Allow Food Benefits” if food benefits are to be issued. 8. Go to the Comments/ Alerts Panel. Remove the alerts by removing the check mark in the “Display As Alert” check box.
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Summary of Endorser/Participant Misuses and Consequences by Category MISUSE – CATEGORY I CONSEQUENCES A. Selling or trying to sell WIC benefits (including breast pumps), WIC foods, or eWIC cards to, or exchange with, other individuals or entities. This includes: ● Trying to return food for cash refunds or store credit. ● Selling or trying to sell verbally, in print, or online through websites such as craigslist, Facebook, Twitter, eBay, etc.
B. Obtaining or attempting to obtain cash or
credit in lieu of or in addition to authorized
foods.
FIRST OCCURRENCE: Unsubstantiated claim: Counsel to warn, reeducate, and document in the Participant Violations panel. Obtain the endorser’s electronic signature and provide the endorser with a printed copy of the form. Counsel and reeducate on the misuse, and on all other misuses within the same category of violations/misuses. Warn of the consequences of a second misuse. Show him/her the previously signed Rights and Responsibilities form.
SUBSTANTIATED FIRST OCCURRENCE OR SECOND OR SUBSEQUENT OCCURRENCE WITHIN 2 YEARS FROM DATE OF FIRST WARNING: Counsel, reeducate, and document the second occurrence (or substantiated first occurrence) in the Participant Violations panel.
Contact the State Office to issue a claim letter for the value of any misused benefits. Send copies of all documentation to the State WIC Office.
Disqualify the participant/endorser from the WIC Program for three months if the claim is under $1000 and is a substantiated first occurrence. Disqualify the participant/endorser for one year (Mandatory Disqualification#) if the claim is for $1000 or more, or if it is a second or subsequent claim for any amount. Give 15 days of benefits* and terminate the participant/endorser with a reason of “program abuse.” Document actions on the Participant Violations and Certification panels. Obtain the endorser’s electronic signature and provide the endorser with a printed copy of the form.
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MISUSE – CATEGORY II CONSEQUENCES C. Attempting to redeem WIC benefits at a
retailer not authorized by Colorado WIC.
D. Obtaining or attempting to obtain unauthorized or excess foods in lieu of authorized foods within the family food benefits. FIRST OCCURRENCE: Counsel to warn, reeducate, and document discussion in the Participant Violations panel. Obtain the endorser’s electronic signature and provide the endorser with a printed copy of the form. Review benefit-cashing procedures with client/endorser.
SECOND OCCURRENCE WITHIN 12 MONTHS OF FIRST WARNING: Counsel, reeducate, and document second occurrence in the Participant Violations panel. Disqualify the participant/endorser from the WIC Program for one month. Give 15 days of benefits* and terminate the participant/endorser with a reason of “program abuse.” Document actions on the Participant Violations and Certification panels. Obtain the endorser’s electronic signature and provide the endorser with a printed copy of the form.
NOTE: After the disqualification period, at clinic’s discretion, participant/endorser may be required to return to clinic monthly to receive benefits.
THIRD OCCURRENCE WITHIN 12 MONTHS OF FIRST WRITTEN WARNING: Counsel, reeducate, and document third occurrence using the Participant Violations panel. Disqualify the participant/endorser from the WIC Program for three months. Give 15 days of benefits* and terminate the participant/endorser with a reason of “program abuse.” Document actions on the Participant Violations and Certification panels. Obtain the endorser’s electronic signature and provide the endorser with a printed copy of the form.
NOTE: After the disqualification period, at clinic’s discretion, participant/endorser may be required to return to clinic monthly to receive benefits.
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MISUSE – CATEGORY III CONSEQUENCES E. Intentionally misrepresenting circumstances (e.g., financial status, residency) to obtain benefits. FIRST OCCURRENCE: If the endorser/participant is eligible, counsel and document in the Participant Violations panel. Obtain the endorser’s electronic signature and provide the endorser with a printed copy of the form. If the endorser/participant is ineligible, give 15 days of benefits and terminate with a reason of “program abuse.” Document actions on the Participant Violations and Certification panels. Obtain the endorser’s electronic signature and provide a printed copy of the form. Contact the State Office to issue a claim letter for the value of the misused benefits. Send copies of the documentation to the State Office.
SECOND OCCURRENCE: If the endorser/ participant is eligible, counsel and document on the Participant Violations panel. Obtain the endorser’s electronic signature and provide the endorser with a printed copy of the form. The participant may continue to receive WIC benefits. If the endorser/ participant is ineligible, give 15 days of benefits and terminate with a reason of “program abuse.” Document actions on the Participant Violations and Certification panels. Obtain the endorser’s electronic signature and provide the endorser with a printed copy of the form.
Contact the State Office to issue a claim letter for the value of the misused benefits. Send copies of the documentation to the State Office.
In the event the participant becomes eligible during the disqualification period, they may not re-apply for WIC Program benefits for one year from the date of their disqualification notice unless full restitution is made or a payment schedule is agreed upon within 30 days of receipt of a claim letter.
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MISUSE – CATEGORY IV CONSEQUENCES F. Dual participation — Enrolled in two or more WIC programs and received benefits from both during the same month for the same participant. FIRST OCCURRENCE: IF UNINTENTIONAL: Counsel to warn, educate, and document discussion in the Participant Violations panel. Obtain the endorser’s electronic signature and provide endorser with a printed copy of the form. Remove any benefits the participant still has for the program from which they are being terminated.
INTENTIONAL FIRST OCCURRENCE OR SECOND OCCURRENCE: Counsel, reeducate and document second occurrence in the Participant Violations panel. Obtain the endorser’s electronic signature and provide endorser with a printed copy of the form.
Contact the State Office to issue a claim letter for the value of the misused benefits. Send copies of all documentation to the State WIC Office.
Issue 15 days of benefits* and disqualify the participant/endorser from both local agency programs for one year (Mandatory Disqualification#) with a reason of “dual participation.” Document actions in the Participant Violations and Certification panels. Obtain the endorser’s electronic signature and provide endorser with a printed copy of the form.
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MISUSE – Category V CONSEQUENCES G. Verbal abuse – Using abusive language, making threats, false accusations, unrealistic demands, etc., to store, clinic staff, or other participants. FIRST OCCURRENCE: Ask the endorser to leave the clinic or store and return when calm or when a new appointment can be made. Call police if threat of violence. Issue benefits. Counsel to warn, reeducate, and document in the Participant Violations panel. Obtain the endorser’s electronic signature and provide endorser with a printed copy of the form.
SECOND OCCURRENCE WITHIN 12 MONTHS OF WRITTEN WARNING: Counsel, reeducate and document the second occurrence on the Participant Violations panel. Disqualify endorser/participant from the Program for two months. Obtain the endorser’s electronic signature and provide endorser with a printed copy of the form. Give 15 days of benefits* and terminate the participant/endorser with reason of “program abuse.” Document actions on the Participant Violations and Certification panel. Obtain the endorser’s electronic signature and provide endorser with a printed copy of the form.
The WIC director must assess the situation and decide if the conduct of the clinic or vendor staff may have provoked the incident. The endorser has the right to complain about improper or discourteous treatment and should not be penalized for making a legitimate complaint; however, this does not relieve the participant from treating clinic and retail staff with respect. If the violation is the result of incidents occurring at the store, the WIC director must ascertain that sufficient documentation of misuse has been provided before imposing sanctions.
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MISUSE – Category VI CONSEQUENCES H. Physical abuse – Physically harm, or attempt to physically harm, store, clinic personnel, or other participants. Theft and/or purposeful destruction of agency or personal property by an adult (does not include theft or not returning a loaned electric breast pump**). FIRST OCCURRENCE: Report incidents of physical abuse, theft, and destruction of property (agency or personal) to the police. If the person causing the abuse or destruction is the participant or endorser, the participant is disqualified from the Program for one year. Give 15 days of benefits* and terminate with a reason of “program abuse.” Document in the Participant Violations and Certification panels. Obtain the endorser’s electronic signature and provide endorser with a printed copy of the forms.
If the person causing the abuse or destruction is not the participant or endorser, the individual is reported to the police and asked to not return to the clinic.
SECOND OCCURRENCE: The incident is reported to the police. WIC staff complete the Participant Violations panel documenting the second occurrence. Give 15 days of benefits* and disqualify the endorser for one year. Obtain the endorser’s electronic signature and provide endorser with a printed copy of the disqualification form. Terminate the participant with reason of “program abuse.” Document actions in the Certification panel. Obtain the endorser’s electronic signature and provide endorser with a printed copy of the form.
* NOTE: In these situations, WIC is required to provide 15 days of benefits before terminating a participant. If the participant already has benefits for 15 days beyond the date of notification, no additional benefits should be issued. If more than 15 days of benefits have already been issued to the participant, remove them from the participant’s eWIC account. The disqualification or termination period starts when the participant’s 15-day notice benefits have expired.
**Procedures for recovering a lost/stolen WIC-owned electric breast pumps are described in Section 2. Nutrition Services, under Breast Pump Ordering and Maintenance.
# Mandatory Disqualification: Whenever the State Office assesses a claim of $1000 or more, assesses a claim for dual participation, or assesses a second or subsequent claim of any amount, the participant will be disqualified from the Program for one year. The State Office may decide not to impose the one-year disqualification if full restitution of the claim letter is made.
# Exceptions for mandatory one-year disqualification: The State Office may permit a participant to remain on the Program or to reapply for benefits if full payment is made, if a repayment schedule is agreed upon within 30 days of receipt of a claim letter, or, in the case of a participant who is an infant, child, or under age 18 and not the endorser, the State or local agency may approve the designation of a proxy who can assure that no further violations will occur and that benefits will be used properly. This exemption only applies to the mandatory one-year disqualifications.
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Prevention and Management of WIC Program Abuse at the Local Level
Policy: Local agency policies and procedures must be in place to prevent conflicts of interest in a reasonable manner. At a minimum policies and procedures must prohibit the following WIC certification practices or provide effective alternative policies and procedures when such prohibition is not possible: Certifying oneself; Certifying relatives or close friends; or One employee determining eligibility for all certification criteria and issuing food benefits for the same participant.
Regulation: CFR 246.4(a)(25), CRF 246.4(a) (26), WIC Policy Memorandum #2016-5
Procedures/Additional Guidance The CO WIC Program Fiscal Manager is responsible for maintaining a file of all staff fraud and/or abuse that includes the nature of the fraud and any associated dollar losses. Local Agencies shall report any occurrence of such violations to the State Office immediately upon detection.
Additionally, the WIC Compass Help Desk will forward all Secure Compass User ID Forms to the CO WIC Program Fiscal Manager that specifies WIC employee separation due to fraud and abuse.
Providing WIC Services to WIC Staff and their Family Members When local WIC staff and/or members of their family are eligible for the WIC Program, they may not handle the certification or food benefit issuance process for themselves or their family. "Family" includes spouses, children, brothers, sisters, nieces, nephews, or grandchildren. Another WIC staff member must handle the certification and ongoing food benefit issuance for WIC staff that are WIC clients or for family members of WIC staff. WIC staff may never certify or issue ongoing benefits to themselves or their own family members.
Separation of Duties At a minimum, the staff person who determines income eligibility and the staff person who determines medical or nutritional risk cannot be the same person. Either person may issue food benefits. Further, having one staff member check identification or residency and another staff person conduct the remainder of the certification does not meet the regulatory intent of separation of duties.
If a clinic is unable to achieve acceptable separation of duties, an individual other than the certifier (e.g. the WIC Director) must conduct a record review of all non-breastfeeding infant certification record and at least 20 percent of a random sample of the remaining certification records within two (2) weeks of the certification, and conduct an additional record review of 10 percent of each clinic’s certification files every six months. Documentation of both reviews must be maintained on file at the local agency for review during monitoring visits.
If a WIC clinic is unable to achieve acceptable separation of duties and conducting record reviews constitutes a hardship, the local agency director may submit a request to the state office to conduct the record reviews. For those agencies the state office will conduct a record review of all certification and recertification visits. Records meeting the state office’s risk criteria will be flagged and reported to the local agency WIC Director for further review.
The local agency WIC Director or designee must conduct a thorough investigation within one week of notification. Documentation of the local agency investigation and response must be maintained on file at the local agency for review during monitoring visits.
A WIC Local Agency Separation of Duties Plan must be submitted to the state office for approval. A copy of the state-approved plan is maintained at the State office for each local WIC clinic.
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Verification of compliance with this policy is a component of the local agency monitoring visit conducted every other year by State staff. Evaluators observe clinic operations to ensure that the agency’s approved Separation of Duties Plan is followed as stated. In those clinics using the local agency record review approach, their Separation of Duties Exception Record Review Logs will be reviewed.
WIC Local Agency Separation of Duties Plan
Local Agency: ____________________________ Clinic: ______________________
Submitted by: ____________________________ Title: ______________________
Printed Name
_________________________________ Date: __________________________
Signature
Following is how the potential for conflict of interest will be reduced and separation of duties accomplished at this clinic:
For all certifications and recertifications, one WIC employee will determine income eligibility and a different WIC employee will determine medical or nutritional risk eligibility.
The WIC Director or designee will conduct a record review of all non-breastfeeding infant certification record and at least 20 percent of a random sample of the remaining certification records within two (2) weeks of the certification, and conduct an additional record review of 10 percent of each clinic’s certification files every six months. Documentation of both reviews will be maintained on file at the local agency.
The record review will be conducted by the state office and the WIC Director will conduct a thorough investigation of any records sent from state office that are flagged for potential fraud. The above clinic is unable to achieve acceptable separation of duties and conducting record reviews at the local agency is a hardship due to the following reason(s) : _____________________________________________________________________________________________ _____________________________________________________________________________________________ _____________________________________________________________________________________________ _____________________________________________________________________________________________ (The hardship reason must be documented by the local agency and approved by the state office.) Approved by: _________________________________________________
State agency staff person name and title
_____________________________________ __________________
Signature
Date
Colorado WIC Program Manual Section 4: Organization & Management Revised: 10/01/2018
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Separation of Duties Exception Record Review Log
Clinics who have chosen to implement separation of duties by use of the local agency record review must review all non-breastfeeding infant certification records and at least 20 percent of a random sample of the remaining certification records within two (2) weeks of the certification. Local agencies must also conduct an additional record review of 10 percent of each clinic’s certification files every six months. This review must be conducted by someone other than the Educator(s), preferably the local agency WIC Director or Clinic Manager. The participant names and Compass participant ID are recorded below. The log must then be signed by the reviewer and stored in a central location accessible during local agency WIC monitoring.
Local WIC Agency: ____________________________
Clinic: _______________________________________ Date of Record Review: _______________
Participant Records Reviewed: Participant Name Compass Participant ID #
I have reviewed the Compass participant records listed above and certify that (check one): I have not detected any indication of fraud or abuse. I have detected fraud and/or abuse. For all detected incidences, I have initiated an investigation and have submitted a written summary of findings and actions taken to the State WIC office.
________________________________________ ___________________________________
Signature
Printed Name ________________________________________
Date
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2024
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Processing Standards
Policy: Local agencies will process all applications for Program benefits made either by phone, in writing, or in person within 10 or 20 days of contacting the local agency, depending on applicant category. All applicants found eligible must be given food benefits on the same day they are told they are eligible. Applicants include all persons who have never received WIC services, and any WIC participants whose certification period has ended.
• The following applicants must be screened and notified of program eligibility/ineligibility within 10 calendar days of the date of their first request for an appointment to receive program benefits: o Pregnant women. o Members of migrant populations. o Homeless individuals.
The State Office may provide an extension of the 10 day notification period to 15 days for local agencies that make a written request which includes a justification of the need for an extension and when the local agency expects to be back within processing standards. This extension allowance is only allowed for up to 90 days.
All other likely to be served applicants must be screened and notified of their eligibility/ineligibility within 20 calendar days of the date of their first request for an appointment to receive program benefits. Likely to be served applicants include all priority and age groups the agency is currently serving.
Exception: If the agency is at maximum caseload and funds are insufficient to support Colorado WIC Program’s active enrollment and the agency has approval from the State Office, these standards do not apply. See the Waiting List policy in the Caseload Management section for additional details.
Each local agency must routinely schedule appointments for applicants/participants who are employed or who live in rural areas by addressing their special needs through the adoption of procedures and practices to minimize the time participants and applicants must spend away from work and the distances applicants and participants must travel. This shall include at least one of the following procedures: appointment scheduling, adjustment of clinic hours and/or location, or remote benefit issuance.
Regulation: 7 CFR 246.7(f)
Procedure/Additional Guidance: The processing time frame begins with the applicant’s first visit, phone call or written request to the WIC clinic to request WIC Services and applies to all applicants regardless of whether or not they have been certified in the past.
When applicants contact the WIC clinic to request program benefits, follow these steps: 1. Determine if applicant may meet eligibility criteria. 2. Complete the New Member/Proxy pop-up window in Compass and enter the appropriate data including the applicant’s name, sex, date of birth, expected date of birth (for age 2 and under), race and ethnicity and category if the family member is not already in the Compass system. 3. Obtain the applicant’s address and phone number and enter into the Contact/Address fields within the Family/Intake panel in Compass. 4. Offer an appointment within the required timeframe and enter the appointment date, time and type in Compass Scheduler. Local agencies who do not use the Compass Scheduler must maintain an appointment log documenting the date of the first offered appointment. Clinics that are open only one or two days per month, offer an appointment within 10/20 days at another clinic.
5. If no appointments are available or if the applicant chooses to wait longer than the standard 10 or 20 days, a check mark will appear in the “Processing Standards Exceeded” box. Staff must select the applicable reason from the drop down list before the appointment can be saved. Available reasons are:
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2024
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a. Declined appointment offered – to be used when the client chooses not to accept an appointment offered by clinic staff that is within the processing standards timeframes and requests a later appointment on a more convenient day or time. b. No available appointments – to be used when the clinic does not have any appointments that can be offered to the client within the processing standard timeframes. c. Participant Rescheduled – to be used when the reason for exceeding the processing standards timeframe is because the client missed an earlier appointment or requested an appointment to be rescheduled for a later date. d. Staff Rescheduled – to be used when the reason for exceeding the processing standards timeframe is because staff need to reschedule an appointment for a later date. 6. Attempt to contact pregnant women who miss their first WIC appointment, to reschedule the appointment. 7. If an applicant or WIC participant does not keep their appointment the processing timeframe begins again when the applicant reapplies.
Colorado WIC Program Policies and Procedures Section 4: Organization and Management Revised: 10/01/2018
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Product Distribution in WIC & Research Requests
Policy: Distribution of products given to WIC clinics or referrals must not take away or replace WIC service. Requested research efforts involving the Colorado WIC Program by both profit and non-profit groups must seek the approval of the Colorado WIC Director.
Regulation: Colorado WIC Policy
Procedure/Additional Guidance: The State Office allows local WIC agencies to partner with profit and non-profits groups in the distribution of their products following these requirements: The distribution or referral must not replace or take away from WIC services. Products distributed must be in the best interest of WIC participants. Products may not undermine breastfeeding efforts (consider WHO Code compliance). Local agencies must notify their State Nutrition Consultant before distributing a product. Data should not be exchanged for products. Colorado WIC can provide summaries of data at the group level. WIC data is public and available on the Colorado WIC webpage. For more specific information on data sharing, see the Section 4, Data Sharing For Participant and Applicants Data policy.
Research Inquiries Research requests must be approved by the Colorado WIC Director. Research is defined as any request for individual-level data, even if the data does not identify WIC participants, in exchange for distribution of products or any time when WIC participants have additional data collected about them that is not normally collected at the WIC appointment. Common research requests may include but are not limited to asking which participants received the product, the participants’ use of the distributed products and/or the impact of the product on WIC participants. Research requests will be judged by the possible benefit of WIC participants, the appropriateness of methods, and the reasonableness of the time required to complete the research.
Colorado WIC Program Policies and Procedures Section 11: Civil Rights Revised: 10/01/2018
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Program Accessibility for Applicants and Participants with Disabilities
Policy: Reasonable accommodations must be provided to persons with physical and/or mental disabilities.
Regulations: 7 CRF 246.7, FNS Instruction 113-1
Procedure/Additional Guidance: Local agencies make reasonable accommodations for the known physical or mental limitations of an otherwise qualified applicant or participant with a disability. When structural changes are not viable, local agencies may achieve program accessibility through other methods. These methods include: Referring participants to an alternate site that is accessible and within reasonable traveling distance if a particular clinic site may not be readily accessible for disabled individuals. Obtaining medical data (height, weight, and hemoglobin/hematocrit) from other sources, such as a private physician, and using it as eligibility criteria (see Certification, Eligibility and Coordination, Section 8 of the Program Manual, Physical Presence at Certification and Recertification Visits and Certification Procedures Required Medical/Nutritional Data). Providing home visits by WIC staff or coordinating services with a public health nurse who can make a home visit. Allowing a proxy designated by the participant to pick up food benefits at the clinic site per policy. Offering benefits remotely to a participant per policy.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026 Page 1 of 2 Proof of Identity Policy: WIC participants, initial endorsers and additional endorsers must present an acceptable proof of identity (ID) at certification, recertification and transfer appointments. Documentation of identity for WIC participants is recorded on the Identity panel of the Compass system. Regulation: 7 CFR 246.7 (c)(2)(i) Procedure/Additional Guidance: WIC Staff must view and document in Compass one of the following acceptable proofs of identity below. Note: It is acceptable for clients to submit proof of ID electronically prior to the certification, recertification and transfer appointments. Acceptable Proof of ID Documentation Includes: ● Driver’s license - must be issued by a state, be current, and include a picture (this may include viewing the card or the card via Colorado Digital ID). ● Health First Colorado (Colorado’s Medicaid Program) card or portal. ● CHP+ card. ● Work/School ID. ● Passport/U.S. Government ID - must be issued by a state or national government, be current, and include a picture (includes I-94 noting SQ/SI parole). ● U.S. Passport Card. ● Alien Registration Receipt Card/Permanent Resident Card. ● Temporary Resident Card. ● Employment Authorization Card. ● Tribal Identification Card. ● U.S. Certificate of Naturalization. ● Certificate of U.S. Citizenship. ● U.S. Citizenship Identification Card. ● Department of Corrections ID. ● Green Card. ● Colorado Identification Card (this may include viewing the card or the card via Colorado Digital ID). ● Military Identification Card. ● Original or certified copy of birth certificate from any state or country, including temporary birth certificates. ● U.S. Immunization Record (infant or child only). May be viewed in Colorado Immunization Information System (CIIS). CIIS may only be used as proof of ID if immunization records are present in the record. U.S. Hospital Documentation (infant only). ● Colorado eWIC card/Colorado eWIC card number (not to be used for certifications). ● Staff recognition (for in-person appointments only. Not to be used for certifications). Staff recognition is for visual recognition of the participant and does not suffice as proof of ID for remote appointments. ● Matricula/Consular card. ● Non-US or International Driver’s License or Photo ID Card – Issued by a foreign government. Must contain a photograph and be valid per the expiration date. If ID is non-expiring, it must have been issued within 5 years of the issue date. ● Original Social Security card. ● Foster Child Papers (issued by State or Local Human Services). ● The following documents are acceptable when they include at least two of the following: infant date of birth, mother’s name or infant’s last name, or hospital identifier. ✔ Infant wristband. ✔ Hospital discharge papers. ✔ Footprint card. ✔ Application for birth certificate. ✔ Documentation of birth from a Certified Nurse Midwife/Registered Midwife. ● Other. When “Other” is chosen as the proof of ID, a description of the “Other” documentation must be entered in the Comments/Alerts panel.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026
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● Affidavit. If an individual lacks acceptable proof of identity documentation, they may verbally declare (affidavit) their identity. o In the Proof of Identity panel, select “Affidavit” from the Proof of Identity dropdown. From the Affidavit Reason drop down, select the appropriate reason for why the client cannot provide a proof of identity. You will be prompted for a client signature.
Forgotten Proof of ID at Certification/Recertification/Add Baby Appointments If the applicant has proof of identity, but forgot to bring it to the WIC appointment and provided proof of residence and income, complete a Provisional Certification. Issue one month of food benefits. Schedule a return visit or inform the participant to submit the missing proof of identity electronically within 30 days. Once the ID is provided, certify for the normal timeframe and issue remaining food benefits. If the missing proof of ID is not provided within the 30-day period, applicants are no longer presumed eligible and cannot receive WIC Benefits. The applicant will have to enroll again.
Note: During in-person benefits issuance for appointments that do not require a proof of ID, choose “No Proof of ID Required” from the Proof of ID drop down in the Signature Capture pop up.
Change of Name Documentation is required when a participant reports a name change (marriage, divorce, or other legal name change) before changes can be made to the participant record. The proof can be any of the listed acceptable forms for proof of identification, as well as other forms of proof, such as an announcement in a newspaper or a court document.
Obtaining a Colorado ID For those clients that are having difficulty obtaining ID, please refer to: https://coloradoidproject.wordpress.com/getting-id/which provides instructions as well as options to assist with payment for IDs.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2025
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Proof of Income
Policy: Endorsers/Participants must provide proof of income information during the certification and recertification visits. Staff must document the Endorser/Participant’s proof of income in Compass. Electronic or paper versions of proof of income are acceptable.
Regulation: 7 CFR 246.7(d)(2)(v)
Procedures/Additional Guidance Income is defined as the total gross income of all household members. Gross income is all income before deductions are made for income taxes, employee social security taxes, insurance premiums, bonds, etc. It also includes any money received or withdrawn from any source, including savings.
Acceptable Types of Income Documentation Include: Verification of participation or eligibility notice for TANF (Temporary Assistance for Needy Families/Colorado Works), Health First Colorado (Medicaid), or SNAP (Supplemental Nutrition Assistance Program or “food stamps”)/ Food Distribution Program on Indian Reservations (FDPIR) is acceptable documentation for adjunctive eligibility.See Adjunctive Eligilibity policy. Active participation in Colorado Works/TANF may be verified via official award letters, the Colorado PEAK system, and the Colorado Benefit Management System (CBMS). Active Health First Colorado participation may also be verified through the Health First Colorado Voice Response System and the Health First Colorado Portal. Verification of eligibility may also be verified by a caseworker with client’s approval. This approval must be documented in Compass. Disability Assistance (SSI): Letter or check stubs. Military Leave and Earnings Statement (LES). Check stubs from employment. Federal or State W-2 forms or income tax forms. When using the W-2 or income tax forms, staff must ensure that assessment of the annual income is appropriate. Unemployment Letter/Notice. Written Statement from employer or other person. Savings, checking, or CD account statements (when check stubs or tax documents are not available). Self-employment documentation/financial records. Child support/alimony document. Student Award Letter. Foster Placement/Award Letter. Verification of Certification (VOC). Affidavit. In the event an applicant lacks documentation of income, select “Affidavit”, to attest to their income. When an applicant truly lacks documentation of income they may self-declare their gross income. Enter the declared income on the Income panel under “Amount” field, document source as “Verbal Report” and list “Affidavit” as proof of income. Once the Income Determination Table is complete, collect the applicant/endorser’s signature. Other. If an applicant provides documentation that clearly establishes household income but the form of documentation presented is not listed in Compass, enter “Other” in Compass along with a description of the documentation in the Notes column.
Note: If a person has documentation of income but has not brought it to the WIC appointment and provided proof of ID and residence leave the Income Determination Table in the Income panel blank. Provisionally certify the participant and issue one month of food benefits. Schedule a return visit or inform the participant to submit
Colorado WIC Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 10/01/2023 Page 1 of 3
Proof of Residence
Policy: Endorsers/Participants must provide documentation of physical Colorado residence (address) at all certification, recertification, and all in-state (Colorado local agency to local agency) and out-of-state transfer visits. Electronic or paper versions of proof of residence are acceptable. A PO Box is not an acceptable proof of residence.
Regulation: 7 CFR 246.7 (c)(2)(i)
Procedure/Additional Guidance: WIC Staff must view and document in Compass one of the following acceptable proofs of residency:
Acceptable Proof of Documentation of Residence Includes: Driver’s license. Rent or mortgage receipts. Government ID/Document (including Colorado Identification Card and Colorado Address Confidentiality Program authorization card). Rental agreement. Government mail (including eligibility notices from Medicaid/SNAP/TANF -postmarked envelope or card showing current address). Bank or credit card statement/personal check or pay stub with printed address. Utility or other bill (including electric, gas, phone, cable, water). Written statement from landlord including the parent’s, endorser’s, or participant’s name. In the event that the parent, participant, or endorser’s name is not stated on any of the above types (for example, a pregnant woman may live with a friend and all utility and rent bills may be in the friend’s name), the applicant may present a letter from the person with whom they live. Written statements from landlords must include name of the parent, endorser or participant, address of the residence, landlord’s or primary renter’s name, signature, and date. The letter may be from the actual landlord or from the primary renter of the residence. Car Registration/Title/Insurance. Pay stub/W2 form. Matricula/Consular Card Medicaid Portal CIIS (Colorado Immunization Information System) Hospital/Medical Facility documentation Affidavit. In the event a person lacks documentation of residence, an affidavit may be used attesting to the place of their current residence. Note: If a participant has documentation of residence but has not brought it to the WIC appointment and provided proof of ID and income, , complete a Provisional Certification, issue one month of food benefits, and schedule a return visit or inform to participant submit their proof of residence electronically within 30 days . Other. When “Other” is selected, WIC staff must include a description of that proof in the Comments/Alerts panel for that visit day. “Display as Alert” and “Expiration Date” should not be completed. Prior approval from State Office is not required to use “Other” for proof of residence.
Note: Rental agreements, rent or mortgage receipts, SNAP Eligibility Letters and landlord letters must indicate a time frame that includes the WIC certification or recertification date. Utility bills, bank statements and WIC/Public Assistance letters should be for a period within 30 days or be postmarked within 30 days of the WIC certification/recertification date. Length of residency cannot be a prerequisite to receiving WIC benefits. Documentation of residence establishes where a person currently lives. It does not necessarily represent legal residence or legal residency status. While participants must live in Colorado, they do not need to be legal residents or citizens of Colorado or the United States.
Colorado WIC Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 10/01/2023 Page 2 of 3
Residence Eligibility Complaints Any time a Local WIC program receives a complaint against a participant about questionable residence eligibility, either verbally or in writing, local staff shall determine if any further investigation or action is needed to address the reported complaint.
Change of Address When active participants notify WIC of a change of address, enter their new address into the Contact/Address panel to ensure they continue to receive notices mailed from WIC. When a participant moves and prefers to receive WIC from the same local agency, proof of the new residence is not required until the next certification visit.
When a Client Does Not Have An Address (e.g. Homeless Applicant) When a participant/applicant does not have an address (e.g. homeless applicant) and does not want to use a friend or family member’s address, document “No Address” as the physical address. Since the zip code is a required field, enter the zip code of choice (likely the clinic).
Documentation of Confidential Addresses If a participant is in the Colorado Address Confidentiality Program (ACP), the ACP mailing address should be entered in Compass as the participant’s mailing address. For participants who need their physical address protected and have a mailing address (PO Box number), but are not enrolled in the ACP, document in the physical address “client address is protected. PO Box only.” Document any additional information in the participant’s Care Plan.
(See examples with screenshots on the next page)
Colorado WIC Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 10/01/2023 Page 3 of 3
Example #1: Client does not participate in ACP.
Example #2: Client participates in ACP.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01/01/2025 Page 1 of 1
Provisional Certification Requirements
Policy: In order to qualify for a Provisional Certification, the applicant must bring in two out of the three proofs. For example, if an applicant brings proof of identity but is missing acceptable documentation for both income and residency, food benefits may not be issued at this visit. Instead, schedule a return visit or inform the participant to submit their proof of income or residency electronically.
Regulation: 7 CFR 246.7(2)
Procedures/Additional Guidance There are two situations when an applicant may not have documentation for identity, residence or income, and the Local Agency staff must follow these procedures.
Situation #1: Applicant brings proof of identity and one of the two additional proofs required (i.e.: brought proof of residence but not proof of income) to the certification/recertification visit. The applicant has two of the three required proofs: o Provisionally certify the applicant for 30 days and provide one month of food benefits. Schedule a return visit or inform the participant to submit the missing proof electronically within the next 30 days to complete the certification. o If the missing proof is provided within the 30 day period, record the documentation provided on the Income and/or Contact/Address panel., fulfill the provisional certification, and provide food benefits. o If the missing proof is not provided within the 30 day period, the participant cannot receive additional food benefits and a second grace period may not be granted.
Situation #2: Proof of Identity, Income and/or Residency does not exist. Documentation: In rare situations, an applicant may not have eligibility documentation (e.g employer refuses to provide income documentation, homeless person, documentation does not exist due to fire, theft, disaster, etc.). o WIC staff should work with applicants to identify possible forms of documentation. When an applicant does not have documentation, an Affidavit may be used whereby they may verbally declare their residence, income or identity. o The participant is certified for the normal time.
By signing the Rights and Responsibilities, the endorser/participant gives WIC permission to verify information presented for certification on the WIC Program.
*Note: WIC staff can issue a manual/hand pump to clients provisionally certified, however single-user electric and multi-user loaned breast pumps and related pump aids/supplies cannot be issued until the client is fully certified.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 10/01/2018
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Proxies
Policy: WIC endorsers may allow another individual to attend a WIC appointment as their proxy.
Regulation: 7 CFR 246.2
Procedure/Addional Guidance: Proxy means any person designated by a woman participant, or by a parent or caretaker of an infant or child participant, to obtain food benefits on behalf of a participant. Parents or caretakers applying on behalf of child and infant participants are not proxies.
The Role of the Proxy: The endorser/participant can choose a proxy to attend the WIC appointment and receive the household’s food benefits on their behalf. A proxy can only pick-up benefits and receive nutrition education; they are not allowed to certify or recertify participants. Participant auto termed during a certification period may be reinstated with a Proxy. Use of a proxy is limited to twice in a six-month period. Professional discretion may be used to allow a proxy to attend more than twice in a six-month period or to receive more than one month’s food benefits. If a proxy is needed more than two times in a six-month certification, it is an indication for staff to problem solve with the endorser and determine if the endorser needs to be changed and/or determine if the participant is eligible for an Education Choice option for follow up visits.
Procedure: When a proxy is used, issue one month’s food benefits (loaded to the household account). o Compass allows up to 3 proxies to be listed on the Family panel. If additional proxy names are needed, previously listed proxy names should be changed to “inactive.” Staff must verify endorser authorization by either a signed note, an email from the endorser’s email address on file, or a verbal approval. The Proxy attending the WIC appointment shows proof of identification. WIC staff enters the proxy’s name in the proxy field on the Family panel. WIC staff issues benefits. Proxy signs electronically to indicate that he/she acknowledges that the WIC benefits have been issued to the WIC participant’s household account. WIC staff record the proxy’s proof of identification in the food benefit screen in Compass.
Colorado WIC Program Policies and Procedures Section 11: Civil Rights Revised: 10/01/2018 Page 1 of 1
Public Notification
Policy: Each local agency must implement a public notification system to inform applicants, participants, and potentially eligible persons of the program availability, program rights and responsibilities, the policy of nondiscrimination, and the procedure for filing a complaint.
Regulations: 7 CFR 246.4(a)(7), FNS Instruction 113-1
Procedures/Additional Guidance:
Basic Elements of Public Notification At least annually, state and local agencies must publish information about the WIC Program. Public service announcements must include the following elements: Program availability including hours of operation and location of clinics. Information on how to file a complaint. The WIC nondiscrimination statement.
Methods of Public Notification State and local agencies must take the actions below to inform the general public, potentially eligible populations, community leaders, grassroots organizations, and referrals sources about the WIC Program. Prominently display the nondiscrimination poster, And Justice for All, or an FNS WIC-approved substitute, and ensure that Spanish translations are posted in clinics where applicable. Inform potentially eligible persons, applicants, participants, and grassroots organizations (particularly those in underserved populations), of programs or changes in programs. This includes information pertaining to eligibility, benefits, and services, the location of local facilities or service delivery points, and hours of service. This information can be communicated by methods such as, but not limited to, Internet, newspaper articles, radio and television announcements, letters, leaflets, brochures, computer-based applications, and bulletins. Provide appropriate information, including Web-based information, in alternative formats for persons with disabilities. Include the required nondiscrimination statement on all appropriate FNS and agency publications, Web sites, posters, and informational materials provided to the public. Convey the message of equal opportunity in all photographic and other graphics that are used to provide program or program-related information.
Colorado WIC Program Policies and Procedures Section 1: Vendor and Farmer Management Revised: 10/01/2025
Retailer Routine Monitoring
Policy: ● Each vendor will receive an in-person monitoring visit that includes a contemporaneous opportunity for questions and answers at least once during their three-year agreement period. ● Annually, at least 5% of WIC-authorized Colorado WIC vendors will receive a monitoring visit.
Regulation: 7 CFR 246.12
Procedure/Additional Guidance: Retailer Routine Monitoring is delegated to the Local WIC Agencies, specifically the Local Agency Retailer Coordinator (LARC) role/position. At a minimum, WIC-approved stores will be monitored once during their three-year agreement period. Monitoring visits will include both training components and problem identification activities.
Military commissaries are exempt from formal monitoring visits. Specifically, unless invited, WIC staff members are not required to monitor military commissaries. If problems occur at a commissary, staff can request a monitoring visit, however, the commissary has the right to refuse. Farmers will be monitored for compliance with federal regulations.
The State WIC Benefit Delivery Unit (BDU) will provide supervision and instruction to ensure the uniformity and quality of vendor monitoring. This is achieved through the required LARC 101 Training as well as quality assurance activities conducted by the WIC Vendor Specialist. The WIC Vendor Specialist position reviews each and every Retailer Routine Monitoring Report submitted by the LARC and enters the visits and results into our MIS. The BDU will monitor the types and levels of non-compliance among authorized vendors and take corrective actions, as appropriate.
The BDU is available to work with LARC to determine which stores will be visited. Each store must receive at least one monitoring visit from the LARC within the course of each three-year contract period, with no more than three years between the store’s last WIC monitoring visit. The State Agency requires that local agencies monitor all stores in their service area during the 3-year contract period. At the start of every new 3-year contract period, the State Office will provide the spreadsheet to help local agencies determine their monitoring schedule plan.
Scheduling and Conducting a Retail Monitoring Visit For details, please review the Retailer Routine Monitoring Procedures and Report. This report provides the content and steps of the monitoring visit. The LARC will coordinate a time and date for a Retailer Routine Monitoring visit with a store manager. This ensures they are aware of the upcoming visit. The manager can either attend or identify someone else to attend as the store representative. This representative is responsible for ensuring that all personnel involved with WIC transactions are trained.
The LARC will inform the store representative that the following items will be reviewed during the visit: stocking of WIC items, prices on shelves for WIC items, the level of training and preparation provided to cashiers, gathering their input, and gathering feedback for WIC.
Determining Compliance The store is to be found in compliance if no violations are found. The store is to be found out of compliance if one or more violations (as detailed in the Retailer Routine Monitoring Report) are found. Examples of violations are: WIC cashier training is not available/not documented/not conducted, stocking infant formula past the “use by” date, minimum stock levels not met, etc., as detailed in the Vendor Handbook.
Documenting and Communicating Compliance Vendors Found In-Compliance: If the store is found to be in compliance, the LARC will conduct each of the following three actions: Page 1 of 2
1. Make and provide a copy of the monitoring report for the store during the visit. (The LARC may also send a copy of the report to the store within 14 days of the visit). 2. Send a completed copy of both the Monitoring Report and the Shelf Survey to the State WIC Program within three business days of the visit. 3. Keep a copy of the Monitoring Report in the clinic vendor file for at least six (6) years.
Vendors Found Out of Compliance: Sanctions and/or violation points will be issued for non-compliance as outlined in Program Violations, in the Vendor Handbook and documented in the monitoring report. If the store is found to be out of compliance, the LARC will conduct each of the following actions: 1. Obtain a Corrective Action Plan (CAP) (if required): Ask the store contact/manager to design and write out a corrective action plan on the monitoring report at the conclusion of the monitoring visit. The store must submit evidence that they have enacted the CAP within two weeks of the monitoring visit. 2. Copy to the Store – Provide a copy of the report for the store to keep in their WIC Manual. 3. Copy to the State – Send a copy of the Monitoring Report and the shelf survey to the State WIC Office. Scan and email the materials if possible. 4. Keep a copy of the Monitoring Report in the clinic vendor file for at least six (6) years. 5. As appropriate, follow up with the store to ensure corrective action.
The BDU will work with LARC in communication with the vendor regarding serious Program violations. This may include phone consultation from the State WIC Office, sending the Vendor Handbook or other training materials, making additional visits to the store, and/or conducting compliance activities.
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Colorado WIC Program Policies and Procedures Section 4: Organization and Management Revised: 01/01/2024
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Retention of WIC Records and Reports
Policy: Local WIC programs shall retain WIC records for the time period indicated.
Regulation: 7 CFR 246.25 (a)
Procedure/Additional Guidance: The following list summarizes WIC's policies on retention of records and reports. Local health agencies may have local policies that require a longer retention period.
REPORT/RECORD KEEP FOR Agency Budget 6 years Agency Contract 6 years Caseload Management Work Sheets At agency discretion Compass User Access Verification Reports 3 ½ years* Grocer complaint forms 3 ½ years* Mandatory reports 5 years (or longer based on agency requirements) Nutrition Education Plan 2 years* Receipts 6 years Retailer Orientation Reports 3 ½ years Retailer Monitoring Reports 6 years Secure Compass User ID Forms/Compass Access Request Form 3 ½ years* Staff meeting minutes At agency discretion Time Certification 6 years Ward Road Pharmacy/Sentido Health special formula signed invoices 3 ½ years* WIC client records 5 years (per Compass parameter) For any records not specifically called out in the table above, record retention is 3 ½ years.
*Years should be counted from the end of the applicable fiscal year. Example: Secure Compass User ID forms w-ith any date between October 2018 and September 2019 (FY 2019) should be kept at least through March 2023.
Alteration of WIC Records Do not alter WIC records. Correct paper records by crossing out the errors and initialing them. Never use correction fluid (white- out). This policy protects WIC staff should participant records be subpoenaed in legal actions or in audits.
Colorado WIC Program Policies and Procedures Section 11: Civil Rights Revised:10/01/2018
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Review of Procedures to Protect Against Disability and Sex Discrimination
Policy:Local agency contracts with the CDPHE WIC Program require compliance with the Americans with Disabilities Act (ADA), Public Acts 42USC 6101 et seq, 42USC 2000 d, and 29 USC 794, and the Colorado Antidiscrimination Act. This ensures that no contracted local agency can discriminate on the basis of disability, and program services must be available and accessible for individuals with disabilities. In addition, the CDPHE Equal Employment Opportunity/ Affirmative Action officer requires that every county health department and nursing service has a designated ADA Coordinator to oversee the fulfillment of these acts and to see that any grievances filed are handled properly.
Regulations: Americans with Disabilities Act, Public Acts 42USC 6101 et seq, 42USC 2000 d, and 29 USC 794 Colorado Antidiscrimination Act
Procedure/Additional Guidance: Local agencies will comply with the policy requirements to protect against disability and sex discrimination.
Colorado WIC Program Policies and Procedures Section 4: Organization and Management
Revised: 03/01/2026
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Scanned Documents and Obtaining Signatures/Verbal Acknowledgements
Policy: Scanning Documents – Certain documents must be scanned in to Compass for later reference. When scanning to Compass is not possible or the document is too large to scan, scan it and maintain an electronic copy or paper copy in a central file. Staff must note in the participant’s care plan that the document is in a central file.
Participant Signatures/Verbal Acknowledgements – Participant signatures/verbal acknowledgements are required within the Compass system. If a participant is in-person for their WIC appointment, and a signature is required, capture their signature on the signature pad. When providing remote services to a participant (e.g. remote recertification) and a physical signature is not possible, clinic staff may get a verbal acknowledgement from the participant and mark “Remote Appt - Verbal Acknowledgement” in the appropriate dropdown field of Compass.
Regulation: CO WIC State Policy
Procedure/Additional Guidance Scanned Documents The following documents must be scanned and attached to the family Compass record. ● Physician Authorization Form (completed by physician, approved and signed by WIC High Risk Counselor). ● Proxy self-statement. ● Endorser’s self-statements. ● Interim Endorser’s self-statements. ● Foster papers or guardianship documentation. ● Endorser relinquishment/change of endorser.
No Signature Available If a signature is not available, staff must check the No Signature Available checkbox and select one of the following reasons: ● Remote Appt – Verbal Acknowledgement ● Equipment malfunction ● Mailed ● Refused ● NE Class
Signatures for Nutrition Education Classes There are two ways to capture an electronic signature from those attending a NE class: ● Signature can be captured at the time benefits are issued. ● If benefits are issued while the participant is in the NE class, staff can capture the participant's signature after the class by accessing the NE Class in Scheduler and clicking on the Signature button.
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 01/01/2025
Page 1 of 5 Screening (Substance Abuse, HIV/AIDs, Lead and Immunizations) and Referrals
Policy: Local WIC Programs should establish referral systems and provide appropriate health and social services referrals to participants.
Local WIC Programs are responsible for contacting referrals received through online referral systems or other methods within 10 days from the date of submission.
Regulation: Colorado WIC Policy, CFR 246.4 (a)(8) and (9) 246.7 (a) and (n), CFR 246.11 (a)(3) and (b)(1), CFR 246.14 (c)(1) and (9), USDA Memo 94-28
Procedures/Additional Guidance:
Referrals to WIC The Colorado PEAK online application allows a person using PEAK to select WIC as a program they wish to be contacted by. The PEAK system creates live reports, by county, of those interested individuals’ contact information. Designated local WIC agency staff manage referrals via a secure database.
The WIC Statewide Referral Form is an electronic form community partners and the public can use to submit requests for WIC to contact potentially-eligible WIC participants. Designated local WIC agency staff manage referrals via a secure database.
Development of Referral Systems The establishment of a local agency referral network consists of two components: identification of community resources and education of WIC staff on community resources. A local referral network includes programs housed within the same agency as the WIC Program (intra- agency), as well as other community organizations (inter agency). The number of community agencies within the WIC Program service area will determine the size of the referral network. To ensure participants are appropriately directed to other community services, it is necessary to inform all WIC staff about the organizations within the referral network. WIC staff should understand the purpose/function and eligibility criteria for each agency/organization in the network. o Several mechanisms could be used to inform the WIC staff members. Agency representatives can be invited to provide a short presentation at WIC staff meetings. Pamphlets from the various community organizations could be made available to the WIC staff. Maintaining a "community resource" notebook with these pamphlets would provide the staff with easy access.
Referrals can be informal (informing the client about the SNAP Program) or formal (sending a standardized referral form). This will depend on the reason for the referral. If the referral includes client information or requires local staff to contact the local program or organization on behalf of the family, the participant or endorser’s signature of consent must be obtained. If the endorser has granted permission to release information to the physician based on their answer provided in the Nutrition Interview, client information may be released to the physician. Referrals may be printed and given to the participant upon request.
Making Referrals Agencies have the option to provide either an informal or formal referral. Methods for each type of referral are described as follows: Informal Referral: A referral can be accomplished simply by providing all adult participants and caretakers of participating infants and children with the list of available resources. Formal Referral: A local agency may opt to develop a more formal referral system wherein a staff member initiates contact with a resource (e.g. substance abuse counseling or treatment agency) on behalf of an interested participant. Please note: Confidentiality rules must be followed.
It is recommended that all clients be directed informally to: • The Supplemental Nutrition Assistance Program (SNAP)
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 01/01/2025
Page 2 of 5 • Medicaid (Health First Colorado) • Child Health Plan Plus (CHP+) • Temporary Assistance to Needy Families (TANF) Programs, • Colorado PEAK at https://coloradopeak.secure.force.com (an on-line service for Coloradans to check for potential food and cash assistance programs, apply for Medicaid and Child Health Plan Plus programs, WIC, SNAP, TANF and Aging and Adult Services Financial programs and manage benefits on-line)
Staff should provide the addresses, web address and/or telephone numbers for these referral resources. The local WIC Program can obtain this information from the Social Services Agency.
Documenting Referrals All referrals by local WIC staff persons must be entered on the Referrals - Participant panel in the Compass system or noted in the participant’s Care Plan. All written information given to participants on assistance programs must be recorded.
Referral Follow-Up To ensure that quality nutritional care is provided to WIC clients, follow up should be provided on all referrals.
Substance Abuse Information and Referral The Colorado WIC Program screens for drug, alcohol, and tobacco use to determine nutrition/medical criterion through the use of questions asked on the Nutrition Interview. WIC staff must provide information on the dangers of drugs and other harmful substances and referrals to pregnant, postpartum, and breastfeeding women and to the parents and caretakers of WIC infants and children. Participants who indicate that they or their child are exposed to secondhand tobacco smoke must also be warned of the dangers to themselves and/or their children. Information must be provided in verbal form. Visuals, written communication and online resources may supplement the information provided verbally. Staff members are not expected to diagnose drug and other substance abuse or to provide in-depth counseling. Rather, they are to provide information on the dangers of substance abuse and secondhand smoke in the course of routine activities.
Federal Drug and Other Harmful Substance Abuse Information and Referral regulations specify the following requirements for all local WIC Programs: Participants with suspected drug or other harmful substance abuse problems must be referred to an appropriate counseling, treatment or education program where services are locally available. Each local agency must maintain and make available for distribution a list of local resources for substance abuse counseling and treatment. o (e.g., Alcoholics Anonymous, Narcotics Anonymous, Cocaine Anonymous, Al-Anon Family Groups, Adult Children of Alcoholics, Women for Sobriety), drug and alcohol treatment programs as well as local smoking cessation programs sponsored by organizations such as the American Lung Association and American Cancer Society. In communities where resources are limited, the public health nurse or the participant's physician should be considered as a possible resource. Local agencies are required to coordinate with local alcohol and drug abuse treatment services.
HIV/AIDS Information and Referral The Colorado WIC Program can play an important role in preventing the transmission of HIV/AIDS in the perinatal population. The following guidelines define the policy for the WIC Program regarding issues related to HIV/AIDS and WIC participants: Encourage comprehensive health care for all WIC participants. Advise all pregnant, postpartum, and breastfeeding women to know their HIV status and receive early diagnosis through routine, voluntary testing, and counseling. Provide appropriate referrals to participants for testing, counseling, and medical treatments as needed. Strongly encourage and support breastfeeding as the healthiest way to feed infants. Inform all participants that HIV-positive mothers should not breastfeed, and that HIV is more easily transmitted through breast milk during the period immediately following the onset of infection.
o The Colorado WIC Program concurs with the Colorado Department of Public Health and Environment and United States Department of Agriculture to support the recommendations of the American
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 01/01/2025
Page 3 of 5 Academy of Pediatrics and the Centers for Disease Control and Prevention that women in the United States should not breastfeed if they are HIV positive or have AIDS.
Blood Lead Screening Information & Referral To implement the provision in Public Law 106-387, included in the WIC Appropriations Act FY2001, local WIC Programs are required to: Ask if the child has had a blood lead screening test starting at 12 months of age. If the child has not had a test, they must be referred (at each certification/midcert/recertification) to programs where they can obtain such a test. Document lead screening referrals in the Nutrition Education Panel by selecting "Referred for Lead Screening" under child standard counseling. Once a lead test has been performed and documented, screening and referral is no longer required.
The blood screen within the Assessment panel is where staff record if a child has received a blood lead screening test. In Colorado, lead testing is covered by Medicaid and the Child Health Plan Plus (CHP+). Additionally, most private insurance providers will cover the cost of the testing when the test is ordered by a physician. Some local health departments may also provide lead testing. Public Law 106-387 does not allow WIC funds to be used to conduct blood lead screening tests. A hematological test for anemia, such as a hemoglobin or hematocrit, is the only laboratory test required to determine a person’s eligibility for WIC. It is therefore, the only cost that may be charged to WIC.
Clinical Laboratory Improvement Amendments (CLIA) Certification Number: Clinical laboratories are registered under the Clinical Laboratory Improvement Amendments (CLIA) federal regulation to ensure quality laboratory testing. All labs that perform testing on human specimens for diagnosis, treatment or health assessment in the United States must hold the appropriate CLIA certificate. The CLIA regulations set standards for personnel, records, quality control and quality assurance. Each WIC local agency must operate under a CLIA Certificate. This CLIA Certificate is typically held by the Health Department, not by the WIC Program. Each WIC clinic needs to be listed on the CLIA Certificate, however if a local agency does not know their CLIA Certificate number (typically starts with “06D”), the WIC director may ask the Public Health director, lab manager or nurse manager in their agency. If an agency is unsure of their CLIA number, contact: Jeff Groff Program Manager EBAT and Laboratory Certification P 303.692.3681 | F 303.344.9965 8100 Lowry Blvd, Denver, CO 80230 jeff.groff@state.co.us
Immunization Screening, Information, and Referral Low-income children are less likely to be immunized than their higher-income counterparts, placing them at high risk for potentially serious diseases, such as diphtheria, pertussis, poliomyelitis, measles, mumps, and rubella. WIC staff members play a significant role in helping to improve the immunization rates for low-income infants and children by assessing immunization records, educating participants on the importance of immunizations and by making referrals as necessary to bring immunizations up-to-date.
Local WIC agencies are required to: Ask caregivers of infants and children under 25 months of age to bring immunization records to all certification/recertification and mid-certification visits. Note: If the record is available in the Colorado Immunization Information System (CIIS), agencies with access to CIIS may access electronic records in lieu of obtaining the immunization information from the caregiver. Assess immunization records for infants and children less than 25 months of age for recommended DTaP shots. 1st DTaP is at 2 months of age 2nd DTaP is at 4 months of age 3rd DTaP is at 6 months of age 4th DTaP is between 15 and 18 months of age
Colorado WIC Program Policies and Procedures Section 2: Nutrition Services Revised: 01/01/2025
Page 4 of 5 Provide information on the immunization schedule and refer caregivers to obtain immunizations if the infant or child’s immunizations are not up-to-date or the immunization record is not available. Once a child has received their 4 DTaP immunizations, staff no longer need to ask about the child's immunization status. Referral Resources
Referral Resource General Purpose/Function
Alcohol & Drug Abuse Prevention counseling and comprehensive treatment for substance abuse
Childbirth Education Associations Prenatal education
Child Health Plan Plus (CHP+) Medical Assistance for low income children who are not eligible for Medicaid
Colorado State University Extension Service Consumer classes, food preparation information, recipes
Early & Periodic Screening, Diagnosis & Treatment (EPSDT) Program Nutrition education
Family Planning/Planned Parenthood Guidance and counseling to provide freedom of choice in the number and spacing of children
Supplemental Nutrition Assistance Program Food assistance for low income
Genetic Counseling/Screening Genetic counseling, diagnosis and education primarily for PKU, hypothyroidism, galactosemia, sickle cell anemia, homocystinuria, maple syrup urine disease
Health Care Program for Children with Special Needs (HCP) Diagnosis and treatment services for special needs children
Head Start Preschool educations for disadvantaged children
Housing Authority Housing information/placement for low income
Immunization Clinics Immunizations
La Leche League Breastfeeding support
Local Physicians, Medical Clinics, Hospitals Medical care
Maternity Services Prenatal, postnatal comprehensive care
Medicaid Medical assistance for low income women and children
Mental Health Services Prevention and crisis intervention counseling
Prenatal Plus Assistance for high-risk women who are on Medicaid
Temporary Assistance to Needy Families Financial assistance for low income children
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Referral Resources based on Condition/Problem
Condition/Problem Referral Source
New Migrant Family Farm Worker Health Services Program
Infant/Child w/Cleft Palate or other Handicapping Conditions Health Care Program for Children with Special Needs (HCP)
Infant/Child w/Failure to Maintain Growth Percentile Public Health Nurse
An individual or family needing food assistance Supplemental Nutrition Assistance Program
Inadequate Food Supply Local Food Banks
Breastfeeding Women La Leche League
Overweight Postpartum Women Weight control classes
Women entering with Short Inter-Conceptual Period of High Parity Family Planning/Planned Parenthood
Pregnant Women for HIV Testing Planned Parenthood, Private Physician, Local Health Department
Pregnant Women who have not received Prenatal Care Local Prenatal Program, local private physician accepting Medicaid
Pregnant Women who Smoke A community smoking cessation program
Colorado Quitline 1.800.QUIT.NOW (1.800.784.8669)
https://www.coquitline.org
A Severely Anemic Participant Public Health Nurse, local physician
Teenage Mother or Teenage Pregnant Women Public Health Nurse, Community prenatal support groups
Colorado WIC Program Policies and Procedures Section 4: Organization and Management Revised: 03/01/2026
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Staff Training
Policy: All local WIC agency employees of the Colorado WIC Program must complete the Colorado WIC Certification Program, which trains staff on WIC policy and procedures relating to eligibility determination, nutrition assessment, screening techniques, food benefit issuance and nutrition education.
All local agency WIC personnel must attend a minimum of two staff training sessions per year of nutrition-related education and training.
Regulation: CFR 246.1 (c)(2), 246.11 c (7)
Procedure/Additional Guidance: Colorado WIC Certification Program The WIC Certification Program is a competency based training program designed for WIC staff. All new staff members are expected to complete the training within the timeframes specified below. The Colorado WIC website (www.coloradowic.com) has a section that posts guidance documents, instructions for accessing the online post-tests and the Orientation Checklists for Level I, II and III.
Objectives: ● To ensure quality service to WIC participants throughout the state. ● To train all staff to properly perform the WIC certification procedure, proper anthropometric and hematologic measurements, nutrition and health assessment, nutrition education, risk identification, and food package selection/issuance. ● To provide all WIC staff with current nutrition information for the WIC population. ● To train using interactive self-directed learning methods.
Assigning A Trainer Local WIC programs are encouraged to identify a trainer for each new employee to oversee the many aspects of new employee training. This trainer: ✔ Ensures new employee completes the required modules, online courses, post-tests, record reviews, observations; ✔ Ensures new employee is scheduled participant visits and has ongoing access to expert support; ✔ Ensures all participant records entered by the new employee are reviewed and signed off by a CWA; ✔ Is available to assist with questions and evaluate progress throughout the training process; ✔ Enters new employee training completion by accessing the Staff Competency panel under Operations in Compass.
Certified WIC Authority (CWA): To become a CWA, the new person must complete all required activities outlined in Level I of the Colorado WIC Certification Program to independently perform CWA-designated duties.
For those staff that are completing Level I and are not yet a CWA, a WIC High Risk Counselor or experienced WIC Educator with CWA qualifications must review any participant information recorded by the new employee. The CWA creates a separate Participant Care Plan that includes a note in the Plan section indicating review of eligibility determination, nutrition assessment and participant care plan notes of the new employee. Because a goal is required for each new care plan, the goal created by the new employee can be copied and pasted into the CWA’s review care plan to ensure it populates into the Family Panel.
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Level I: ● Basic WIC background requirements and procedures to certify and provide benefits to participants. ● Specific training materials: ✔ WIC Orientation Module & Post-Test ✔ Food Package Module & Post-Test ✔ Nutrition Risk Factor Module & Post-Test ✔ Screening Module & Post-Test ✔ Colorado WIC Hemoglobin Testing training video ✔ Welcome to WIC Video ✔ Review of Mini-Manual ✔ Saving the Children: Story of WIC Video Part I & Part II (recommended) ✔ Review of Nutrition Education Counseling Guide ✔ Compass Training Online Course ✔ Level I Participant Record Review ✔ Level I Observation Checklist
All Level I activities must be completed within three months (90 days) of employment. Each new employee must have a local agency trainer/mentor who ensures that all activities on the Level I Orientation Checklist are completed. This designated staff person electronically documents the training activity completion in the Compass system, Staff Competencies.
Online Compass Training course: Online Compass Training consists of 13 self-paced, interactive training modules. The online modules are designed to orient new WIC employees to the Compass computer system. New employees should complete the Level I modules and post-tests prior to beginning the online Compass Training course.
Level II: ● Current nutrition and food safety information for the WIC population including basic nutrition, infant, child, pregnancy, breastfeeding, and postpartum. ● Specific training materials: ✔ Prenatal and Postpartum Module & Post-Test ✔ Breastfeeding Module and Resource Manual & Post-Test ✔ Infant Nutrition Module & Post-Test ✔ Preschool Child Nutrition Module & Post-Test ✔ Basic Nutrition Module & Post-Test ✔ Baby Behavior Online Module & Post-Test ✔ Partnering with WIC for Colorado Kids Video ✔ Closer Look – Allowable Foods Video ✔ WIC Visit Assessment and Counseling Evaluation Tool
All Level II activities must be completed within six months of employment. Each new employee must have a local agency training/mentor who ensures that all activities on the Level II Orientation Checklist have been completed. This designated staff person electronically documents training activity completion in the Compass computer system, Staff Competencies.
Level III: ● Participant- centered care online course. This course offers ten self-paced modules and activities focused on providing Participant-Centered Education (PCE) by incorporating counseling methods i.e. motivational interviewing, rapport building, and active listening. ● Specific training materials: ✔ Introduction: Welcome to WIC PCE ✔ What Motivates People to Change? ✔ The Spirit of PCE ✔ Opening the Conversation ✔ O.A.R.S ✔ Roadblocks to Listening ✔ Moving from Assessment to Counseling ✔ Providing Advice: Offering Nutrition Education ✔ Rolling with Resistance ✔ Next Steps ✔ Level III: PCE Post-Test ✔ PCE handouts and training activities (recommended; not required)
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● All Level III activities must be completed within nine months of employment. Each new employee must have a local agency training/mentor that ensures that all activities on the Level III Orientation Checklist have been completed. This designated staff person electronically documents training activity completion in Compass, Staff Competencies.
Staff Training Required to Provide Alternate Nutrition Education WIC staff members involved in providing alternate nutrition education contacts must receive training on how to fill this role effectively. At a minimum, training is to include the following elements: ● Familiarity with the wichealth.org website, including the format and topic areas, the names of the lessons available, how to access the lessons, and how to access client search to electronically verify lesson completion for WIC participants if needed. ● Completion of the online module, Providing Phone Nutrition Education for Follow Up Visits, required prerequisites for the module, and pass the phone counseling observation.
Ongoing Staff Training All local agency WIC personnel must receive ongoing nutrition-related education and training. It is the local agency’s responsibility to determine the educational needs of each staff person. Training sessions can be provided by the state agency or organized/identified by local agency staff.
Examples of acceptable training programs: ● Nutrition lectures or classes presented by state and/or local staff. Community nutrition resources may be utilized: i.e.; hospital dietitians, extension agents, and/or interns, to assist with planning programs and/or speaking. ● A staff representative may attend a nutrition/training program or conference and present an in-service to the remainder of the staff upon his/her return. ● After reviewing current nutrition letters, journal articles, or audiovisual materials, the local agency staff may discuss the information and the implications. ● A staff person successfully completes a self-learning module. ● State and Regional WIC Meetings ● Other pertinent in-service education programs, i.e., team building, supervision, customer service, counseling, communication, computer skills, diversity training. ● Webinars and other on-line trainings
Evaluation of Counseling Skills Local WIC agencies must comply with their local agency’s personnel rules regarding staff performance evaluations. A key part of this process is to identify areas for growth and to advance counseling skills. Each Local Agency WIC Director is required to ensure appropriate staff training is provided.
A nutrition counseling evaluation tool is posted on the CO WIC web site for local agencies’ use: WIC Visit Assessment & Counseling Evaluation Tool. Local WIC Agencies may also develop and use their own evaluation forms.
Evaluation of WIC Service Delivery Local agency supervisors may use two staff evaluation tools developed by State Office and posted on the Colorado WIC web site: ● WIC Participant Record Review form ● Clinic Observation Form
Documentation of Training Successful completion of training is documented in Compass under Operations/Staff/Staff Training.
Training Requirements for Dietetic Interns All non-employee WIC dietetic interns providing direct participant services, including scheduling, nutrition education, benefit issuance, program eligibility, and nutrition risk determination, must at a minimum complete
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Level I of New Employee Training. Dietetic interns must be supervised by a WIC RD preceptor who will oversee their work.
Dietetic interns whose role is limited to seeing high-risk (HR) clients, completing HR notes, and not performing program certifications (e.g., eligibility determination, risk assignment, benefit issuance, and scheduling) are only required to complete the following Level I modules and post-tests: Orientation, Food Package, Screening, and Nutrition Risk Factors. However, preceptors may require additional COWIC training as needed.
Colorado WIC Program Policies and Procedures Section 1: Vendor and Farmer Management Revised: 10/01/2025
State WIC Responsibilities - Local Agency Communication and Training
Policy: The State WIC Benefit Delivery Unit (BDU) maintains routine communication and training processes for Local Agency Retailer Coordinators (LARC) through various methods.
Regulation: 7 CFR 246.12 (i), 7 CFR 246.4
Procedure/Additional Guidance: Communications and Training methods for Local Agencies include: ● WIC’s WORLD - the annual vendor training newsletter. ● Local Agency Newsletters and Weekly Digest Articles. ● Colorado WIC retailer training video. ● Compass Retailer Reports. ● Train-the-Trainer Sessions at store visits (e.g., monitoring, orientation, and informal). ● Technical Assistance with Vendor Complaints/Problems and Violations. ● Program Manual- Policy and Technical Guidance (e.g., Civil Rights Complaints). ● Vendor Handbook- Policies related to Disqualification/Sanctions. ● Quarterly conference calls with LARC to provide up-to-date information on vendor issues and program updates, and changes. ● Vendor Coordination training in the LA clinics can be provided on request. LARC should work with staff to provide training on retailer issues and procedures. ● Reports and Procedures (e.g., monitoring, orientation, pre-authorization,mandatory training, site visit, shelf surveys, etc.) are available on the ColoradoWIC.com website and upon request. ● LARC 101 Training. ● Food List Training.
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Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination of Services Revised: 03/01/2026 Page 1 of 3 Transfers, VOC and WIC Overseas Program Policy:. Local programs shall follow the correct procedures to ensure WIC participants who transfer into or out of Colorado WIC will receive continuous benefits during their certification period. Regulation: 7 CFR 246.5 (c)(3)(i), 7 CFR 246.7 (k)(1)(3)(4), 7 CFR 246.7(d) (ix), 7 CFR 246.7 (j)(4) Procedure/Additional Guidance: A Verification of Certification (VOC) is a WIC document issued to participants that confirms their current eligibility and is used as proof of income and nutrition risk. The purpose of the VOC is to streamline and simplify the process of a participant being certified in the new state. At certification appointments, WIC staff are required to inform participants about the transfer policy, the purpose of the VOC document, and review this information with endorsers as needed during recertification appointments. VOC Issuance Requirements: A VOC must be given to participants who: ● Report they are moving out of Colorado. ● Are part of a migrant family. ● Are experiencing homelessness. ● Are affiliated with the military and transferring overseas. A VOC must include: ● Participant name, DOB, ID number. ● Certification details (dates, category, priority, income determination date). ● Recent measurements and nutrition risks. ● Food benefit dates. ● Local Agency contact info and signature from local staff. Screening During Intakes ● When scheduling an initial appointment, ask if the applicant or participant has been on WIC before, and if so, where and when. ● If currently on WIC, follow the appropriate transfer guidelines below. Transfer Guidelines Follow appropriate transfer steps depending on whether the person is moving within Colorado or to another state. In-State Transfers (within Colorado) ● Use Compass to locate and transfer the participant. ● Proof of ID and address is required at the new clinic. Acceptable forms of ID are the same as those allowed at initial certification visits. ● If proof of address is not provided at an in-state transfer appointment, issue one month of food benefits and require proof of address at the next visit in one month. Out-of-State Transfers Participant Moves Out of Colorado. ● Print the VOC from the Compass printouts. Staff must print and sign their name and date the VOC. ● Provide a copy of the PAF, if applicable. ● Tell participants to bring their eWIC card, VOC, and proof of ID and address to the clinic in their new state. ● Do not deactivate their eWIC card unless the participant confirms they've moved. ● Once the move out of state is confirmed, terminate in Compass with the reason “Moved Out of State” and deactivate their eWIC.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination of Services Revised: 03/01/2026
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Participant Transfers from Another State to Colorado With a VOC: ● Accept a valid VOC as proof of income and nutrition risk eligibility. ● Enter the details from the VOC into Compass. ○ If the certification expires within 30 days, consider recertifying to avoid requiring the participant to schedule an additional appointment. ● Proof of ID and address is required. Acceptable forms of ID are the same as allowed at initial certification visits. ● Complete the Voter Registration panel. ● Enter anthropometric and hematological data from the VOC into Compass. Do not repeat measurements or complete the nutrition interview. ● Assign the nutrition risk factors (NRFs) listed on the VOC. ○ If none are listed, assign NRF 502-Transfer of Certification on the Risk Panel. ● Review the COWIC Rights and Responsibilities ● Assign the eWIC card and issue food benefits. ● If the participant has an out-of-state WIC EBT card: ○ For rolling month states: Use the month of the first date to use, the end of that month will be the last benefit date in Compass. For example, if the first date to use is August 15, then August 31 will be their last benefit date that is entered into Compass. ○ For calendar-month states: Check if benefits for the current month have already been used before issuing Colorado benefits to avoid dual issuance. Without a VOC: ● Try to contact the participant’s previous state WIC office to obtain a VOC. State WIC contacts are listed here: https://www.fns.usda.gov/fns-contacts?f%5B0%5D=fns_contact_related_programs%3A32 ● If VOC information cannot be obtained or no valid VOC exists, treat the participant as a new certification ● Explain to the participant that an income assessment will be completed. ● Inform the participant that if the income assessment determines they are over income, they will be ineligible for WIC in Colorado.
WIC Overseas Program The WIC Overseas Program is similar to the USDA-funded WIC Program but is funded by the Department of Defense to serve active duty military personnel, other military support staff, and their dependents stationed overseas. While income, category, and nutrition risk criteria are generally the same as the USDA WIC Program, the WIC Overseas Program has specific eligibility restrictions. Participants affiliated with the military must be issued a Verification of Certification (VOC) when transferring overseas from a Colorado WIC clinic during their certification period. Transfers from Colorado to WIC Overseas When a participant is transferring from Colorado to the WIC Overseas Program: ● Issue a VOC. ● Include a copy of the PAF, if applicable. ● Issue food benefits to cover the period until the participant can request a transfer to a new clinic. ● Inform the participant that: ○ Not all overseas military bases have WIC programs. ○ Eligibility rules may differ overseas. ○ Issuance of a VOC doesn’t guarantee eligibility in an overseas program.
Transfers from WIC Overseas to Colorado When a participant transfers from the WIC Overseas Program to Colorado WIC:
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination of Services Revised: 03/01/2026
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● Treat the VOC as an out-of-state transfer. ● If the client is within their certification period, enroll them in Colorado WIC. Note: WIC programs in Hawaii, Alaska, Guam, the US Virgin Islands, and Puerto Rico WIC Programs are USDA-funded and follow normal state transfer procedures.
Colorado WIC Program Policies and Procedures Section 1: Vendor and Farmer Management Revised: 10/01/2025
Vendor Coordination – Confidentiality
Policy: The local agency must use caution to consistently protect applicant, participant and vendor privacy. ● Participant information (name, contact information, status) is not to be provided to vendors. Instead, if an issue is reported, relay that WIC will follow up with anyone determined to be an applicant or participant and apply procedures as appropriate. ● Vendor information other than listed above (e.g., address, WIC authorization status) is confidential and not to be released.
Regulation: 7 CFR 246.26
Procedure/Additional Guidance: Applicant and Participant Confidential Information WIC status is confidential information and not to be released.
Vendor Confidential Information Vendor information is confidential and not to be released, except for WIC authorization status, store name, store address, telephone number, website, e-mail address, and store type/description (e.g., chain, grocery, pharmacy).
Vendor confidential information also includes any food data and redemptions, such as UPC and item descriptions that may identify a store and its sales.
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Colorado WIC Program Policies and Procedures Section 1: Vendor and Farmer Management Revised: 10/01/2025
Issues and Complaints About Vendors
Policy: State and local WIC agencies must document and handle complaints about vendors.
Regulation: 7 CFR 246.9, 7 CFR 246.8, 7 CFR 246.12
Procedure/Additional Guidance:
Complaints From Participants: Educator to LARC Participants should be encouraged to discuss their experiences at the store with their WIC Educator. The educator should assist the participant to determine if the issue can be identified, such as attempting to purchase items with WIC that are not approved and provide additional nutrition education as appropriate. If a store issue or complaint is identified, comments from participants should be relayed to the Local Agency Retailer Coordinator (LARC).
LARC to Store LARC are encouraged to contact a store representative to discuss and resolve problems. The information gathered in discussion with the vendor and the vendor’s proposed resolution to the problems should be documented as appropriate in the Compass Vendor Log. Maintain documentation such as completed reports, receipts, rain checks, etc. A clinic must have complete files if the vendor appeals.
Participant information is confidential. Neither the participant name nor a copy of the report should be provided to the vendor. The State WIC Benefit Delivery Unit (BDU) is available to provide guidance to LARC to resolve problems and discuss complaints.
For any complaint alleging discrimination based on race, color, national origin, sex, age, or disability, procedures are detailed in the Program Manual, Section 11: Civil Rights.
Violations: Ongoing or More Serious Vendor Problems to State WIC Office The BDU will contact vendors regarding general authorization processes such as pricing, renewal and state wide training. The BDU will also be responsible for resolving ongoing problems at a specific vendor. Complaints that are serious or ongoing about a specific vendor should be reported to the BDU for follow-up. The State Office is responsible for sending violation letters to vendors and assigning violation points to vendors. A LARC may send a violation letter to a vendor only after the State WIC Office has received copies of the pertinent documentation and has reviewed and approved violation correspondence. With any correspondence related to the assignment of sanction points, the vendor should be provided with the appeals procedures.
Copies of email and other communications along with any other available documents such as receipts or rain checks, should be maintained in the Local Agency store file and/or kept electronically; copies should be sent (preferably via email) to the BDU. After discussion with the LARC, the BDU will conduct appropriate follow-up. This follow-up may include communication with the store management, compliance activity, contact with the chain headquarters of the store, tracking violation points and activities in Compass and/or a violation letter detailing corrective action.
The State WIC Office will typically forward copies of violation letters to the headquarters office of chain stores. Along with the notification of the violation, the vendor will receive notification of their right to appeal.
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Colorado WIC Program Policies and Procedures Section 1: Vendor and Farmer Management Revised: 10/01/2025
Vendor Coordination - Local Agencies Preparing WIC Families
Policy: Local Agency WIC staff must make WIC participants aware of authorized foods, penalties for improper actions, and the process for communicating store experiences.
Regulation: 7 CFR 246.12
Procedure/Additional Guidance:
● Authorized Foods It is important to prepare WIC families on the WIC foods and how to shop for them to provide the best chance for success. Participants are offered the Food Benefits List and a current Colorado WIC Food List and Shopping Guide. They are educated on the quantities they are authorized to purchase. When appropriate, use samples of the allowable foods to show the participant what to purchase. Participants should also be made aware of the important and valuable mobile application, WICShopper, that is also available to assist WIC families with their WIC shopping.
● Penalties for Improper Behavior Local agency WIC staff should discuss the consequences for participants who redeem benefits incorrectly, return WIC foods for cash, attempt to purchase unauthorized foods, or behave improperly in the store. Document incidences of improper behavior as discussed in Section 8, Certification, Eligibility and Coordination, Prevention and Management of Endorser/Participant Misuse.
● Participant Communications with WIC Staff Encourage WIC participants to relay what happens in stores, especially stores with previous complaints. While not required, participants should be told that WIC might be able to improve store service if we get enough information, such as dates, receipts and cashier names, to act upon.
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Colorado WIC Program Policies and Procedures Section 1: Vendor and Farmer Management Revised: 10/01/2025
Vendor Coordination – State Office and Local Agency Roles/Responsibilities
Policy: The State WIC Office develops policies and procedures to authorize and monitor vendors in a way which ensures Program integrity. The State WIC Office works with Local WIC Agencies to coordinate vendor activities.
Regulation: 7 CFR 246.12
Procedure/Additional Guidance:
The State WIC Benefit Delivery Unit (BDU) is available to work with local agencies (LA) regarding matters that concern vendors. The State WIC fiscal staff and Nutrition Consultants can also assist LA WIC staff with vendor problems and/or questions.
State Office BDU Role and Responsibilities ● Work with vendors and Local Agency Retailer Coordinators (LARC) to foster positive working relationships. ● Develop policies and procedures to ensure consistency and accuracy in all efforts to promote Program integrity. ● Provide vendors and LARC with support and information. This includes providing timely data and training guidance, answering questions about the Colorado WIC Food List & Shopping Guide, etc. ● Provide guidance for LARC on enforcing policies and procedures. ● Authorize and reauthorize vendors to participate in the Program. Coordination of the application review, application processing, and resultant agreement. ● Provide training coordination for LA WIC staff and vendors. ● Work with LARC and vendors to resolve ongoing problems. ● Facilitate communication between State staff and LAs regarding vendor issues. ● Ensure Federal requirements for monitoring and compliance investigations are met. ● Enforce Federal regulations and initiate actions for sanctions against vendors who are in violation of the Program’s policies and procedures. ● Provide general oversight of the vendor component of the Program. ● Participate on both the internal Allowable Foods List Committee and the Colorado WIC Allowable Foods List Advisory Committee to promote inclusive decision-making, understanding, and open, effective communication with external stakeholders. ● Assist vendors in obtaining payments for WIC transactions in conjunction with the Fiscal Unit. ● Maintain Vendor Management data tracking systems. ● Maintain the pricing system in conjunction with WIC Fiscal staff. ● Publish the WIC’s WORLD newsletter. ● Conduct activities with local agencies—such as training sessions, quarterly conference calls, and one-on-one dialogue—to assist in the development of competencies in order to meet and exceed State objectives as outlined in the State Plan. ● Analyze processes to identify areas that can be improved to enhance Program integrity. ● Provide training material and reports to ensure information is useful, accurate, culturally and linguistically appropriate. ● Implement a vendor peer group system (i.e., grouping similar stores together), competitive price criteria, and allowable reimbursement levels to ensure, along with WIC Fiscal Unit, that the WIC Program pays authorized vendors competitive prices.
Local Agency Retailer Coordinator (LARC) Roles and Responsibilities ● Conduct pre-authorization, orientation, formal and informal monitoring visits to ensure compliance with Program policies and procedures. Document results by submitting accurate and completed reports to the BDU. ● Provide training for vendors and new WIC educators. ● Work with store personnel to handle questions about the Colorado WIC Food List & Shopping Guide, obtaining special formulas, ensuring minimum stocking requirements are met, and resolving ongoing vendor issues. Page 1 of 2
● Respond to and work to find resolution to participant/vendor complaints or issues and document complaints in vendor files or the MIS system. ● Report ongoing or serious vendor problems to the BDU for follow-up, including forwarding copies of written complaints to State WIC Benefit Delivery Unit Coordinator. ● Work with the BDU to develop procedures that address vendor problems. ● Enforce Federal regulations and Program policies and procedures that apply to vendors and participants consistently and accurately to ensure Program integrity. ● Communicate policy procedural changes to vendors and to other LA WIC staff. ● Participate in BDU’s quarterly conference calls to facilitate communication between State staff and LAs regarding vendor issues, and program updates and changes. ● Recommend compliance investigations or inventory audits be conducted on vendors who may be (or suspected of being) in violation of the Program. ● Assist with disqualification/sanction implementation including, providing written documentation supporting the case against the vendor, testifying at Fair Hearing Procedures, etc. ● Provide general oversight of and point-of-contact for vendors within the service area. ● Work with the BDU on recommendations for the Colorado WIC Food List & Shopping Guide. ● Maintain a complete file on all vendors within the service area. ● Provide State WIC Program with feedback on participant training material and reports to ensure information is useful, accurate, culturally, and linguistically appropriate. ● Analyze processes to identify areas that can be improved to enhance Program integrity. ● Act as local agency expert in WIC Retailer Coordination, including knowledge of policies and procedures detailed in the WIC Vendor Handbook. ● Work with State WIC and with Local Agency Director/Management in the creation of processes to run and/or receive reports, enter any resulting appropriate violations in the Compass “Participants Violations” panel, alert staff to counsel participants at next appointment, counsel participant, and track notice of sanction.
Forms and reports (listed below) used by LARC to complete the LARC roles and responsibilities are available in the LARC Google Drive, including the following documents.
● Pre-Authorization Procedures Report. ● Retailer Routine Monitoring Procedures and Report. ● Other resources and documents.
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Colorado WIC Program Policies and Procedures Section 1: Vendor and Farmer Management Revised: 10/01/2025
Vendor Coordination - Vendor Files
Policy: State Office The State WIC Benefit Delivery Unit (BDU) will maintain originals or images (e.g., via paper copies and/or tracking databases, and/or electronically) of: ● Vendor Agreements, Applications, details of contacts made with the store, correspondence, Pre-authorization, and Retailer Routine Monitoring Reports, training information, etc. for each Vendor. ● Participant Access determinations.
Local Agency LARC shall set up a process that staff members can record comments related to a vendor and/or relay information to the LARC.
Regulation: 7 CFR 246.12
Procedure/Additional Guidance: ● Any vendor information that individually identifies the vendor, except WIC authorization status, store name, store address, telephone number, website, e-mail address, and store description (e.g., chain, grocery, pharmacy) must be restricted to persons directly connected with the administration or enforcement of the Program to maintain vendor confidentiality. ● When forwarding copies of materials to the BDU, scan documents and send them electronically if possible. o Include the proper contact person for a formula ordering problem, a shopping problem, or other issues. o Keep this information available so that patterns may be easily identified. Set up a system to send the information to a central location and/or LARC. o Encourage participants to relay what happens in stores. Having a detailed account with dates and circumstances all documented in a logical order and presented to store personnel is very effective. (REMEMBER: Do not report the participant name/information to a vendor.) ● Keeping detailed, precise records is a key to effective coordination between the State, Local Agency, and vendor. Enter significant communications and events (e.g., visits, issues, resolution, etc.) into the Compass Vendor Log.
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Colorado WIC Program Policies and Procedures Section 1: Vendor and Farmer Management Revised: 10/01/2025
Vendor Training: Pre-Authorization and Orientation
Policy: The local agency will conduct pre-authorization and initial orientation activities at the vendors in their area as instructed by the State WIC Benefit Delivery Unit (BDU).
Regulation: 7 CFR 246.12
Procedure/Additional Guidance: Pre-authorization site visits are conducted as part of the application process for new vendors seeking WIC authorization. Once COWIC determines a vendor’s application is complete and they are eligible for WIC authorization, a pre-authorization visit to the store is scheduled. This visit consists of verifying that WIC minimum stock requirements are being met, prices are posted, and WIC foods are fresh and within their expiration date. Following a successful inspection, training is provided, and the grocery store or pharmacy will become an authorized WIC vendor.
If minimum stocking requirements are not met, the vendor will have one opportunity to come into compliance with the stocking requirements. The vendor will have 20 days from the date of the pre-authorization visit to correct any findings. If it is determined that the selection criteria have not been met, the application is denied.
The local WIC agency will conduct an orientation session with at least one representative of the store within 45 days after receipt of the application. If the store is applying under a new Agreement, the LARC will complete a pre-authorization visit within 45 days of receipt of the application. However, the Colorado WIC Program may require a pre-authorization visit within 14 days to confirm the vendor’s compliance with the selection criteria.
The purpose of the orientation visit is to: • Provide training to store representative(s) on WIC training topics, including benefits and nutritional goals of COWIC, why specific foods are prescribed, and details of the Food List. • Review WIC transaction procedures. • Discuss Program policies and procedures and the sanctions for noncompliance. • Identify any areas that are out of compliance with Program policies and procedures and set a mutually agreed upon plan and date for correction. • Provide training and support to the store representative(s) through information and tools so that they can successfully conduct cashier initial preparation training on WIC policies and procedures. A physical copy of the WIC Handbook can be requested.
Training and Documentation Store and chain managers are responsible for training cashiers, as well as other staff involved with WIC transactions, on accepting eWIC cards so that they are comfortable and prepared to take eWIC transactions by providing initial cashier training. Section VI details WIC training. Store trainers are welcome and strongly encouraged to be in attendance at the orientation visit that is conducted by WIC staff and to use tools and materials provided by WIC in their cashier training. Internal training processes used to conduct initial cashier training should be submitted to COWIC for approval.
Training must be documented, provided to WIC, and a copy maintained in the WIC manual as required.
The Pre-Authorization Report Form, as well as additional details are available in the Vendor Handbook and through the State Office WIC Project Assistant. Page 1 of 1
Colorado WIC Program Policies and Procedures Section 1: Vendor and Farmer Management Revised: 10/01/2025
Vendor Training: Routine Partnership Connections
Policy: Local Agency Retailer Coordinators (LARC) are the first point of contact for the WIC-authorized stores in their area.
Regulation: Colorado WIC Policy
Procedure/Additional Guidance: LARC are encouraged to develop partnerships with the authorized vendors in their area and have routine contact with the store representatives as appropriate through store visits or phone communications, including the following:
● Contact the store regularly to establish good communication with the store personnel. ● Understand the Program vendor rules. Everyone in WIC who has contact with store personnel should be knowledgeable of vendor procedures. Colorado WIC vendor training materials are valuable sources of information. (See State WIC Roles: Training LARC for training materials and communications.) Familiarize yourself with these materials and the handbook before meeting with store staff. ● Provide the store with direct phone and email contact information for their LARC. This will make it easier for store personnel to call if they are having problems or have questions. ● Find out who to contact at the store. Begin contact with the manager and vary contact with the agreement of the manager, based on the nature of the problem. If someone is responsible for ordering formula, you may find it best to talk with that person directly regarding a formula-stocking problem. ● Consider asking to attend a store’s staff and/or training meeting. Take a few copies of the newsletter, WIC’s WORLD, materials, clarification from local or state meetings or training sessions, and/or other appropriate materials and/or information regarding a specific issue or problem that the store may be having. ● Conduct informal site visits. These visits are a way of contacting the vendor to assess the current situation, to determine if they are having any problems or questions and to assist them. Depending upon the level of training provided to the store, the visit might be counted as a formal interactive training visit in annual reporting to USDA. ● Consider following-up with the store liaison after the store conducts the periodic training required by State WIC to determine how the training progressed and for feedback and input. Relay pertinent information to the Benefit Delivery Unit. ● Track communications with the vendor as appropriate in the Compass Vendor Log screen.
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Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 10/01/2023
Page 1 of 2 Voter Registration
Policy: Local WIC programs must provide potential voters with the opportunity to register to vote, assist those who request help in completing the paper or online form, send completed registration paper forms to local election offices, and document voter registration information in Compass.
Regulation: The National Voter Registration Act (NVRA) of 1993 is a federal civil rights law that requires public assistance agencies including WIC to offer voter registration services to all persons applying for benefits, recertifying or renewing their eligibility, or whenever a client changes an address. The following services are required to be made available to WIC Program applicants who are not already registered to vote: Offer the voter registration application forms. Assis applicants in completing voter registration application forms (unless the applicant refuses such assistance). Accept completed voter registration application forms and send to the appropriate county clerk and recorder within 5 days.
Procedure/Additional Requirements: At every certification, recertification and change of address, WIC staff members are required to ask all endorsers and adult participants, “If you are not already registered to vote where you live now, would you like to apply to register to vote here today?” In Compass, endorsers must sign/verbally acknowledge the Rights and Responsibilities form that includes the statement, “I have been offered the opportunity to apply to register to vote.” Staff must complete the Voter Registration panel in Compass, noting whether or not the endorser or adult participant is registered to vote where they currently live, and if a voter registration form was completed (whether paper or online). If the client wishes to register to vote, staff must provide an Agency-Based Voter Registration Application (NVRA-1) form and instruct applicants to fill out all required information. o Clients may prefer registering to vote online. For those clients, please refer them to the Secretary of State’s website and click ‘Register to Vote’. Agencies are required to offer each applicant with the same degree of assistance in completing the voter registration form unless the applicant refuses such assistance. Assistance includes reviewing voter registration application for completeness, and providing bilingual assistance when necessary. Local agency staff must ensure that the following information is kept confidential: o Information relating to a declination to register to vote. o The identity of the voter registration agency through which any particular voter is registered. In addition, local agency staff must not: o Seek to influence an applicant’s political preference or party registration. o Display any political preference or party allegiance. o Make any statement to an applicant or take any action, the purpose or effect of which is to discourage the applicant from registering to vote. o Make any statement to an applicant or take any action, the purpose or effect of which is to lead the applicant to believe that a decision to register or not to register has any bearing on the availability of services or benefits.
Tracking of Voter Registration Activities Voter registration information tracked in Compass is tallied by the State WIC office and reported to the Secretary of State’s office. No separate reporting by local WIC agencies is required.
Ordering Voter Registration Forms and Posters Voter registration forms can be ordered from: http://www.sos.state.co.us/ccorner/NVRAAgencyOrderForms.do Please direct any questions to the secretary of state’s office at NVRA@coloradosos.gov. Note that with the added statement “I have been offered the opportunity to apply to register to vote” added to the Rights and Responsibilities form.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 10/01/2023
Page 2 of 2 Voter Registration Training The Secretary of State’s office is responsible for training local staff and providing voter registration forms. Questions regarding voter registration should be directed to the Secretary of State’s office at NVRA@coloradosos.gov
An optional on-line training for staff is available from the NVRA agency information web page at: https://www.coloradosos.gov/pubs/elections/NVRA/NVRAHome.html
Colorado WIC Program Policies and Procedures Section 7: Caseload Management Revised:10/01/2018
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Waiting List
Policy: When funds are insufficient to support Colorado WIC Program’s active enrollment, waitlist procedures must be activated. The State agency determines when to activate waiting lists and which participant priorities to place on a waiting list.
Regulation: CFR 246.7 (e)(4), 246.7(f)(1), FNS Instruction 803-6 Rev. 1
Procedure/Additional Guidance: A waiting list is a list of individuals who have expressed interest in receiving WIC benefits and who are likely to be served when caseload slots become available. The waiting list process ensures that WIC services are provided to participants with the highest nutritional risk (lowest priority). The decision regarding which priorities to place on waiting lists is based on available funding and estimates of the cost to provide WIC services to groups of participants of identical priority. The State agency notifies the local WIC agencies in writing of the need for waiting lists, the type of waiting list, which priorities to place on the waiting list, and the implementation date.
Type of Waiting Lists Access to the Clinic Services Administration>Waiting List panel is available to selected State Office staff only. On this panel, the State Office user defines the effective date of the waiting list and the specific participant categories and priorities that will be eligible for the waiting list. There are two types of waiting lists – certified and uncertified. When waiting list status is activated, the State Agency will designate whether to implement one or both types: Uncertified waiting lists include those applicants who expressed interest in applying for the WIC Program but have not been screened. These applicants must be placed on the list based on their highest potential priority (Priority 1 for pregnant and breastfeeding women and infants, Priority 3 for children and Priority 4 for postpartum women). Uncertified waiting lists are manually recorded on a log.
Certified waiting lists include applicants who have been certified eligible through screening, but whose priority is not currently being served. Certified waiting lists will be created by the computer system after the certification information has been entered into the computer. The lists will be grouped by priority.
Documentation Each local agency must keep a waiting list of all individuals who express interest in receiving WIC benefits, either in person or by telephone. Each local agency will maintain the following data elements for each applicant entered in Compass: The applicant’s name Address and/or phone number Applicant status (pregnant, breastfeeding, age of applicant, etc.) The date the applicant was placed on the waiting list.
Notifying Applicants & Participants The local agency WIC user must: Screen every interested applicant for eligibility and priority. Inform applicants regarding the need for a waiting list. Notify applicants of their placement on a waiting list on the day of initial contact. Explain that the local program will serve highest priority applicants first when funding and caseloads are limited and that WIC services will be extended to as many eligible participants as possible. Once an applicant is on the waiting list, encourage them to contact the local program with address changes or new telephone numbers to facilitate future appointment scheduling. Refer all applicants to other health and social service agencies such as food banks, SNAP, etc.
Any individual who specifically requests to be placed on a waiting list in person must be added to the list, regardless of their qualification status.
Colorado WIC Program Policies and Procedures Section 7: Caseload Management Revised:10/01/2018
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Actively enrolled participants who fail to keep their scheduled WIC appointments and then contact the local WIC program requesting to rescheduled appointment when that local program has no appointments available may be placed on the waiting list.
Equal treatment An applicant who has never been on WIC must have the same access to available appointment slots as a participant who is applying for a second or subsequent certification. Civil rights regulations do not allow a request for information on ethnic classification as part of waiting list procedures.
Discontinuing Waiting lists The State WIC Office determines when waiting lists will be discontinued and will provide local WIC agencies written notification and instructions. Generally, local agencies will perform the following: Contact the first person on the list, either by letter or telephone and schedule them for an appointment to determine eligibility. Make it clear that this is only to complete screening and does not mean that they will be automatically certified on the program. Document on the waiting list that notice was given. If the attempt is made to contact an applicant by phone and the individual cannot be reached, a follow up letter must be sent to notify the applicant to complete the screening process. Document that the letter was sent. Continue down the list and contact each person. Applicants who respond to the notification shall complete screening to determine eligibility. Check income if data is older than 30 days. Collect anthropometric and blood work data: o if not taken at time of application, o is >60 days old, or o does not reflect current participant category Drop an applicant from the list when they: o do not respond to notification after 15 days from the date of the letter; o miss their screening appointment; o are no longer categorically eligible (i.e. child turns 5); or o have completed the screening visit and determined to be either eligible or ineligible.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01.01.2023
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WIC Appointment Protocols
Policy: WIC clinics must use the Compass Scheduler to record all client appointments.
Regulation: 7 CRR 246.7
Procedures/Additional Guidance: The Compass Scheduler is used to send appointment reminders and informational text messages to WIC clients. For this reason, it is important that all clinics use the Compass Scheduler to schedule client appointments so that all Colorado WIC clients receive the same level and equal services regardless of where they live in the state or which clinic they attend. In addition, many statewide data reports use the data within the Compass Scheduler; use of the Compass Scheduler is critical for accurate data collection and analysis.
Certification/Recertification Appointment The certification appointment refers to the first appointment a WIC applicant is scheduled to apply for WIC. The recertification appointment is for participant who are or have been on WIC and are reapplying for WIC eligilbity. The following occur during this type of appointment: Eligibility determination. Initial Explaination of WIC (certification appointment or as needed during recertifications). Follow up on previous goals (recertification only). Nutrition Assessment. Nutrition Interview. Anthropometrics (Height/Length, Weight, Hemoglobin (if applicable). Nutrition risk assignment. Nutrition education. Counseling and goal setting. Provide handouts/resources as necessary. Referrals. Certify. Inform participant of their certification end date. Documentation. Eligibility proofs provided. Nutrition Education and goals. Food package assignment. Food benefit issuance.
Mid-Certification Appointment: This appointment type must occur for infants ( 5-7 months of age or 5-7 months after enrollment) and children (5-7 months between certification visits). Follow-up on previous goal. Verify contact information. Nutrition assessment. Nutrition Interview. Anthropometrics (Height/Length, Weight, Hemoglobin (if applicable). Nutrition risk assignment. Nutrition education. Counseling and goal setting. Provide handouts/resources as necessary. Referrals. Documentation. Eligibility proofs provided. Nutrition Education and goals. Food package assignment. Food benefit issuance.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 01.01.2023
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Follow-up Appointment: In-person Visit For low risk participants, generally occurs 3 months after the certification appointment and the midcertification appointment. Women receive follow up appointments quarterly or more often as needed. Anthropometrics. For infants: As a best practice, length and weight should be taken at each follow up visit. For pregnant women: check weight at least once per trimester for all in-person clinic visits. An Education Choice option may be offered one time to low-risk pregnant women after the certification/recertification visit, allowing one measurement to be excused. For all other participants: Height and weight checks should be done if anthropometric and blood risk factors have been assigned and/or there is a concern with weight status or growth. Nutrition education. Counseling and goal setting. Provide handouts/resources as necessary. Referrals. Documentation. Nutrition Education and goals. Food package assignment. Food benefit issuance.
Follow-Up Appointment: Education Choice wichealth.org Endorser/participant completes wichealth lesson any time between the previous appointment and before the next date of food benefit issuance. Verification of lesson completion. Remote Food benefit issuance. Phone/Video contact Follow-up on previous goal. Verify contact information. Nutrition education. o Counseling and goal setting. o Provide handouts/resources as necessary. Referrals. Documentation Nutrition Education and goals. Food package assignment. Remote Food benefit issuance.
When a Client Does Not Attend Their Scheduled Appointment: Mark the client as “No Show” in the Compass schedule. For a phone appointment (low or high risk), staff may want to make an extra attempt to contact the client as some clinic phone numbers show up as “unknown” or as an unrecognized phone number to the client. This extra attempt gives the client another chance to answer the phone.
Colorado WIC Program Policies and Procedures Section 4: Organization and Management Revised: 01/01/2025
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WIC Branding and Communications
Policy: The Colorado WIC Program is a member of the National WIC Association (NWA) and participates in NWA’s Recruitment & Retention (R&R Campaign). To maintain consistency in messaging and professional images for program materials, Colorado WIC adheres to NWA’s national branding guidelines. The Food and Nutrition Service of the USDA (FNS) also provides messaging, graphics, and images for WIC agencies to use.
Local agencies must ensure their materials follow these branding guidelines to maintain consistency for clients across the state. Branding includes the look, feel, design, and messaging, which dictate how an organization presents itself in terms of appearance and content. All messages need to be consistent and conform to those developed under NWA research to maximize impact and alignment with state and national messaging efforts.
Regulation: Colorado WIC Policy, National WIC Association Branding Guidelines
Procedure/Additional Guidance: Branding: A unified brand supports the Colorado WIC Program and its short- and long-term health benefits. Here are the key advantages of maintaining a consistent brand: • Strengthens the Program: Promotes a unified and professional image for local agencies, the Colorado WIC Program, and the WIC program as a whole. • Increases Public Awareness: Provides instant and consistent recognition for the Program statewide. • Increases Public Support: Creates an identity for the Program that people can relate to and trust. • Communicates Benefits: Highlights the proven health and development impact that the Program offers to participants, the community, the state, and the country.
Outreach Materials: To ensure consistency in design and messaging, local agencies should use Colorado WIC outreach brochures and posters, NWA’s pre-made templates, posters, ads, icons, logos, etc., or discuss new concepts and campaign strategies with the State Office. Materials can be reviewed for statewide consistency, branding, messaging and presentation. Refer to the National WIC Branding Guidelines for guidance on logo and color usage, typography, tone, etc. Access NWA’s pre-made templates, icons, logos, etc., in the WIC Branding materials folder. Social Media: Local agencies interested in creating social media accounts should seek approval from their leadership and follow your organization’s social media standards and practices. When posting or responding to WIC social media accounts, adhere to your organization’s policies, as well Colorado WIC’s Social Media guidelines. To maintain consistency across the brand, utilize NWA’s social media graphics, logos, etc. and repost Colorado WIC’s Facebook and Instagram posts whenever possible. Accessibility: Colorado WIC is committed to making all information and resources accessible to everyone in our community. Local agencies should consider accessibility when creating public facing materials and follow the latest Web Content Accessibility Guidelines (WCAG) when creating digital content. These guidelines help enhance the accessibility of web content for users with sensory, cognitive, and mobility disabilities, ultimately benefiting all users regardless of ability. Refer to the Colorado WIC Accessibility Checklist and WCAG for detailed guidelines.
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WIC Compass User Access
Policy: Local WIC Agency Directors must complete necessary forms to ensure that Compass user access is granted to Compass users who actively work at a specific WIC clinic. The Compass Access Request Form must be completed and submitted each time a new staff person is hired, when their position responsibilities change and when their WIC employment ends.
Regulation: Colorado WIC Policy
Procedure/Additional Guidance: Compass Application and Data Security The Compass system requires a user to log into the system using credentials created by the WIC Compass Care Team. The Compass Access Request Form includes the data security, use, and confidentiality agreement that each employee must read and sign. Signatures from the WIC supervisor and WIC employee are required and the printed copy can be faxed or scanned & emailed to the WIC Compass Care Team
Staff can change their passwords after a successful log on using the provided User ID and Password. User IDs and passwords are not to be shared with others. Every 120 days, Compass prompts the user that the old password is about to expire and a new password must be entered. Passwords must be strong to be secure. Strong passwords are at least 8 characters in length, have a mixed case (some capitals and some lowercase letters), have at least one number, and have a special character.
For data security purpose and to ensure that only active user’s have access to the Compass sytem, the Colorado WIC State Office will deactivate any user who has not been active in Compass for 8 weeks. Staff that are inactive for 8 weeks due to situations such as medical leave, can be reactivated by submitting a ticket in Elementool.
Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 03/01/2026 Page 1 of 4 WIC Endorser & Proxies Policy: WIC staff must identify an endorser for every WIC participant. The endorser is either the active participant (woman category only) or a primary caregiver of the WIC participant who usually brings the participant to WIC for certifications, recertifications, and nutrition education. The endorser represents and signs for the WIC participant(s) in qualifying them for eligibility. The endorser has the best knowledge of the participant’s health/nutrition history and current lifestyle habits. WIC endorsers may allow another individual to attend a WIC appointment as their proxy. Regulation: CFR 246.7(2)(i), 7 CFR 246.2 Colorado WIC Policy Procedure/Additional Guidance: There are two categories of endorsers: Primary Endorser ● Women participants (pregnant, breastfeeding, or postpartum): The participant must always serve as the primary endorser, regardless of age. If she is no longer an active WIC participant, she must remain listed as the primary endorser for her household. In situations where she will not serve as the primary endorser for her children, the children must be assigned to a separate household in Compass, with the new designated endorser added as the primary endorser. ● Infants and children: The primary endorser is typically a parent or legal guardian. In some cases, the primary endorser may be another caregiver (for example, a grandmother caring for a child while the mother is working). o When the primary endorser is not a parent or legal guardian, he or she must provide written documentation as to why they have been selected as an endorser. This documentation is scanned into the participant’s Compass record or is maintained in a central file. Examples of acceptable documentation are: ▪ Written permission - from the adult participant or parent naming the caretaker as endorser. ▪ Self-statement – from a caregiver. In unusual situations, such as child abandonment, or the incarceration or incapacitation of the parent or legal guardian, the caregiver may write a self- statement describing the circumstances surrounding the parent or legal guardian and why they have been selected to be the endorser. Additional Endorser ● Person designated by the primary endorser as a second person who can sign for the WIC participant(s) in qualifying them for eligibility. The additional endorser is typically the other parent or a legal guardian of the WIC participant. The additional endorser can be the child’s primary caregiver. ● A woman who has previously or is currently a WIC participant cannot be changed to an additional endorser under the same Family Identification (FID) household in Compass (see Primary Endorser, Women participants section above, for requirements on assigning or maintaining the primary endorser in Compass). Note: Pregnant, postpartum, and breastfeeding minors, whether they are in foster care or not, have the option to decide whether or not to add an additional endorser. Endorsers’ Rights and Responsibilities Either endorser may participate in the participant’s nutrition assessment and education, obtain food benefits, change WIC appointments, and update participant information. Both endorsers have ownership of the WIC participant’s information and may receive copies of WIC participant information during the time period that each was an endorser without the consent of the other endorser. When an endorser represents a WIC participant, WIC staff and the endorser(s) agree to partner towards providing optimal WIC benefits to the participant. Responsibilities are identical for both types of endorser. Procedure to Add an Additional Endorser ● WIC staff can decide whether or not to ask the primary endorser if they choose to identify the additional endorser. ● The primary endorser is not required to designate an additional endorser.
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● When the primary endorser indicates that they would like to add an additional endorser, WIC staff enter the additional endorser’s name on the Family panel. The endorser may designate an additional endorser at any time. The additional endorser does not need to be present. o When the additional endorser attends an appointment, they must show acceptable proof of identification, which may be captured on the Certification panel and/or the Food Benefits panel. ● By signing on the Certification panel during the participant’s certification or recertification, the primary endorser/additional endorser acknowledges his/her Rights and Responsibilities. ● Either endorser’s signature on the Food Benefits panel verifies receipt of food benefits and acknowledgement of the Rights and Responsibilities. ● In the majority of situations, the primary endorser decides whether to add or remove the additional endorser. Changing Endorsers Every effort should be made to maintain established endorsership. When either the primary or the additional endorsers are unable to attend a WIC appointment, it is best to designate a proxy as opposed to changing endorsers. WIC staff should problem-solve with the endorser before opting to change endorser (e.g., offer alternate appointment times, Education Choice, or a different clinic location, use a proxy, and/or an alternate shopper). Nevertheless, certain situations require changing the endorser (see Primary Endorser, Women participants, and Additional Endorser sections on page 1, for requirements on assigning or maintaining the primary endorser in Compass).
● Primary Endorser Choice: The primary endorser voluntarily requests a change or removal of either endorser by providing the WIC clinic staff signed and dated permission. Staff can request that the primary endorser present legal documentation before changing endorsership. Staff scan this written permission to relinquish/change endorsership into the participant’s Compass record. When scanning is unavailable, this written permission is maintained in a WIC clinic central file. Proof of residence and income must be presented when the participant has moved and/or the economic unit has changed.
● Change of Custody: If at any time a caregiver or additional endorser arrives at the WIC clinic with legal proof of full (100%) custody of a child participant, endorsership may be changed with accompanying proof of identification. Proof of income and residence from the new endorser must also be provided if the participant has moved and/or the economic unit has changed. If the family unit previously had two endorsers, the endorser with full custody may choose to either maintain or remove the other endorser. When a caregiver provides legal proof of partial (less than 100%) custody, it is the caregiver’s role to determine if one or both will be the WIC endorser. WIC staff should not take sides or make decisions regarding endorsership. In difficult situations, staff can refer caregivers to the Department of Human Services for assistance.
● Foster Care: A foster parent becomes the WIC endorser of a foster child with proof of custody by a welfare agency or Department of Human Services. If foster parent designation changes, the new foster parents become the new WIC endorser with proof of custody, income, residence, and identification. For specific procedures involving moving foster children and their eWIC cards between families in different situations, staff should refer to the How Do I section of the Mini-Manual.
● Endorser is Unreachable: In unusual situations such as child abandonment, or the incarceration, or serious illness of the endorser, an interim endorser can be designated. An interim endorser can be approved by the clinic supervisor if permission from the endorser is not obtainable. However, when a parent, who is not listed as the endorser or additional endorser, indicates the other parent (endorser) is not available due to child abandonment, incarceration, or serious illness, clinic staff must attempt to contact the endorser unless the endorser is deceased. However, if after attempted contacts with the endorser are unsuccessful, legal documentation is not required by the parent seeking WIC services unless custodial rights between the parents are in question. When custodial rights between the parents are NOT in question, the clinic supervisor may use professional discretion to add the other parent as an additional endorser without the permission of the endorser. This must be documented in Compass. When and if the endorser reestablishes caretaker responsibility of the child, he/she may remove the additional endorser. This does not apply if the current endorser is a non- parent, such as a foster or kinship caregiver. If the endorser is deceased and the other parent is seeking WIC services, the other parent should be added as an additional endorser to the original account. If the deceased parent was a participant, they should be documented in COMPASS as terminated – deceased on the certification panel.
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Procedure to Change an Endorser: ● WIC staff should attempt to obtain written or verbal permission from the endorser, if possible, and scan or document this permission in Compass. ● In the event permission is not obtained from the endorser, the interim endorser must write a self-statement identifying him or herself as the primary caregiver of the child, relationship to the child and why the endorser is unavailable. ● The self-statement must be dated and scanned into Compass. A self-statement is not acceptable documentation of custody. (See Referrals to Assist with Legal Custody). ● The interim endorser shows proof of identification. ● WIC staff enter the interim endorser’s name and proof of ID in the Comments/Alerts field on the Family panel and document the situation in Compass. ● The interim endorser must bring their proof of income to determine eligibility to complete recertification if needed. ● WIC staff determine if the current household eWIC card needs to be deactivated and a new card issued. Interim endorser signs electronically to indicate that he/she acknowledges that the WIC benefits have been issued. o Typically, one month’s worth of food benefits is issued to the interim endorser until legal documentation of guardianship/custody is provided. The clinic supervisor can use professional discretion to allow an interim endorser to receive more than one month’s benefits at a visit. ● WIC staff reviews the Colorado WIC Food List & Shopping Guide, explains how to use the eWIC card at the store, participants’ Rights & Responsibilities, and the purpose of the WIC program. ● The caregiver will continue to be an interim endorser with the current endorser’s name left on all WIC records. ● Upon providing legal documentation, the interim endorser may become the endorser, and up to three months of food benefits can be issued per visit. Once legal custody is established, the new endorser is added to Compass, and the child is retrieved into the new Family ID. o Acceptable proofs of guardianship/custody may include: ▪ Legal custodial/guardianship agreement. ▪ Documentation from the Department of Social Services, Department of Corrections, court orders, or a professional statement on institutional letterhead. o Documentation must reasonably establish the following: ▪ The name of the child. ▪ The name of the individual granted guardianship/custody. ▪ The authority or agency that conferred guardianship/custody. ▪ The effective start date of the custody change and, if applicable, the end date.
Referrals to Assist with Legal Custody In situations where the endorser “abandons” the participant without leaving forwarding contact information, recommend to the present caregiver that it is to the child’s benefit to identify who is legally responsible for the child. WIC can refer the family for assistance through programs such as the Legal Aid Society, Probate Court, a Chaplain or Information Officer at a jail, and the Department of Social Services.
Release of WIC Records to Endorser The WIC Program releases participant records to the current primary and/or additional WIC endorser(s) only for that period of time they are the endorser. Endorser must show proof of identification to obtain the records. Records should not be released to others, including the Department of Social Services (DSS), without written approval from the endorser. Records of a child in foster care may only be released to DSS for the time while the child was in foster care. Staff may not release records to proxies, past or interim endorsers, relatives, or nonlegal guardians. Details of records inquiries and releases must be documented in the participant’s care plan (see Data Sharing for Participants and Applicant Data policy in Section 4: Organization and Management).
WIC Proxies Proxy means any person designated by a woman participant, or by a parent or caretaker of an infant or child participant, to obtain food benefits on behalf of a participant. Parents or caretakers applying on behalf of child and infant participants are not proxies.
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The Role of the Proxy: ● The endorser/participant can choose a proxy to attend the WIC appointment and receive the household’s food benefits on their behalf. ● A proxy can only pick-up benefits and receive nutrition education; they are not allowed to certify or recertify participants. ● Participant auto-termed during a certification period may be reinstated with a Proxy. ● Use of a proxy is limited to twice in a six-month period. Professional discretion may be used to allow a proxy to attend more than twice in a six-month period. If a proxy is needed more than two times in a six-month certification, it is an indication for staff to problem solve with the endorser and determine if the endorser needs to be changed and/or determine if the participant is eligible for an Education Choice option for follow up visits.
Proxy Procedure: ● When a proxy is used, issue 1-3 months’ food benefits (loaded to the household account). o Compass allows up to 3 proxies to be listed on the Family panel. If additional proxy names are needed, previously listed proxy names should be changed to “inactive.” 1. Staff must verify endorser authorization by either a signed note, an email from the endorser’s email address on file, or a verbal approval. 2. The Proxy attending the WIC appointment shows proof of identification. 3. WIC staff enters the proxy’s name in the proxy field on the Family panel. 4. WIC staff issues benefits. Proxy signs electronically or provides a verbal acknowledgement if remote to indicate that he/she acknowledges that the WIC benefits have been issued to the WIC participant’s household account. 5. WIC staff record the proxy’s proof of identification in the food benefit screen in Compass.
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WIC Funding Formula & Local Agency Contracts
Policy: The state WIC program shall allocate federal WIC funds to local public health agencies to administer the program throughout Colorado.
Regulation: 7 CFR 246.16, 7 CFR 246.4 (a)(5), 7 CFR 246.5 (c)(1)
Procedure/Additional Guidance: Nutrition Services and Administration funds (NSA) are distributed to local agencies based on a funding formula that was developed by a committee comprised of Local Agency WIC Directors, Local Agency Directors of Administrative Services, and State Office staff. The objective of using a formula is to distribute funding to local agencies in a fair, impartial, and efficient manner.
The formula uses the following factors to distribute available funds by county: 1) Number of participants served, 2) Geographic Density of Service area, 3) Percent of Non-English Speaking Participants served, 4) Number of high-risk participants, 5) Churn: Monthly average number of participants living in one county but serviced in another county 6) Partnership funds 7) Hold harmless adjustment – This adjustment places limitations on how much an agencies funding can decrease from year to year. A subsequent cap is also placed on percentage of increase depending upon funding available.
Information for each component of the funding formula is found within the COWIC system data, with the exception of population density. Local agencies are required to submit an annual budget, which includes personnel costs and full time equivalent (FTE) caclucations for all employees. This budget is due by December 1st of each contract year to the Fiscal Unit Supervisor.
The Colorado WIC Program runs the funding formula prior to the start of a fiscal year based upon projected awards. It may also be run after USDA announces the Colorado WIC Program’s level of funding (depending upon timing of the receipt of annual budget), and awards adjusted accordingly. Contracts are issued to the local health agencies on behalf of the Colorado Department of Public Health and Environment. If it is determined that additional funding is available for local agency contracts, the state office may opt to implement a supplemental funding process. This process will either be calculated by running the extra funding through the funding formula or allowing local agencies to submit an application for supplemental funds to help with additional budgetary needs, special projects to improve caseload, or capital improvement costs. Amendments are then made to the local agency contracts.
Termination of Local Agency Contracts The State WIC Office may disqualify a local agency and terminate the contract: When the State determines noncompliance with Federal and/or State regulations. When the State's Program funds are insufficient to support the continued operation of all its existing local agencies at their current participation level. When the State determines, following a review of local agency operations, that another local agency can operate the Program more effectively and efficiently. When the State determines abuse of Program funds. When the State determines greater need in another area according to the Affirmative Action Plan. When another agency in the area of a higher priority according to the local agency priority system (see 7CFR Part 246, January 1995) is available to administer the Program. When another WIC agency in the area is capable of accepting the local agency's participants in order to consolidate local WIC Programs.
The right of appeal shall be granted when, during the course of the contract, a local agency is disqualified or any adverse action which affects participation is taken. Should the need arise to schedule an administrative hearing,
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the Regulations provide that the local agency shall have one opportunity to reschedule the hearing date upon specific request. EXPIRATION AND SUBSEQUENT NON RENEWAL OF A CONTRACT SHALL NOT BE SUBJECT TO APPEAL.
The State Office shall provide the affected local agency with written notice not less than 60 days in advance of the pending disqualification which includes an explanation of the reasons for disqualification, the date of disqualification, and except in cases of the expiration of a local agency's contract, the local agency's right to appeal as set forth in Federal Regulations 7CFR 246.18.
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WIC Service Accessibility
Policy: Local WIC Programs must ensure that service delivery meets the Colorado WIC Service Standards and that clinic locations and clinic operations are accessible to all clients.
Regulation: Colorado WIC Policy, CFR 246.4(a)(23)
Procedure/Additional Guidance Colorado WIC Local Agency - Clinic Locations Local clinic locations must be assessed by the local agency to ensure they best serve the WIC-eligible populations. This means considering factors such as accessibility, proximity to public transportation, hours of operation, and the nearby availability of other community and/or public health services. Colorado WIC local agencies must inform the State Office of all WIC clinic locations, including when a new clinic opens, closes, or moves to another location.
WIC Service Accessibility To ensure that applicants and clients encounter fewer barriers in accessing WIC services, agencies are encouraged to: ∙ Ensure that service delivery hours and clinic sites are accessible to working parents and isolated rural residents. This includes offering services during lunch times, some evenings, and weekend hours as possible. Agencies may need to allow staff to work flexible schedules (e.g., starting early or staying late) or hire new staff (e.g., when turnover occurs) willing to work non-traditional hours. Provide decentralized or mobile clinics, if able. ∙ Utilize various scheduling methods to ensure clients can easily make appointments. This includes scheduling clients ahead of time, allowing clients to call in for appointments, and accommodating walk-ins when possible. ∙ Allow clients to choose their WIC clinic. ∙ Reschedule client's appointment to the next available time slot within the same month if they miss their scheduled appointment. If rescheduling, due to clinic appointment availability, would result in delayed or missed food benefits, agencies should issue enough monthly food benefits to ensure there are no gaps in the client’s benefits until their next scheduled appointment whenever possible. Offer remote appointment to provide more flexibility. ∙ Promote and offer wichealth.org for follow up appointments. ∙ Set aside weekly or monthly time slots for clients to make up missed appointments. ∙ Extend an infant’s or child’s certification period when possible.
Colorado WIC Service Standards The Colorado WIC Services Standards are predefined criteria that ensure access, equity, and quality in COWIC core services for all clients. Service standards and staff roles serve as frameworks for maintaining consistency, accountability and excellence in service delivery and contract accountability; considered to be the minimum required as a Colorado WIC local agency. ∙ Clients must be able to contact their assigned agency (directly or through partnership) at least four hours per day, five days a week. Ideally, this is through access to trained Program staff via phone. This requirement can also be met by providing the option to leave a phone message with next- business-day response or by referring clients to another agency that is open. ∙ Clients must be scheduled within the required processing standards as outlined in the Processing Standards policy. ∙ Clients who are assigned a high nutrition risk factor are scheduled with the high risk counselor within the required time frame according to the High and Low Risk Protocols policy. ∙ Referrals received from the WIC Referral System must be contacted within ten days from the date of submission. ∙ Clients and staff of each agency are served directly or via partnership with the following roles as defined in the Local Staffing policy:
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o Director o High Risk Counselor o Educator o Breastfeeding Coordinator o Retail Coordinator
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WIC Text Message Program
Policy: WIC provides automated text messages to clients. Messages sent to the endorser/client may include appointment reminders, missed appointment notifications, food benefit reminders, WIC service reminders, requests for client feedback, or other critical information/alerts as authorized by the State WIC Director (ie. government shutdown, natural disaster, etc.).
Regulation: Colorado WIC Policy
Procedure/Additional Guidance: Staff must notify all clients of the Colorado WIC Text Messaging Program when the client’s phone number is collected at the initial WIC appointment or updated at subsequent appointments. If a participant would like to receive WIC text messages, the “Allow Calls” and “Allow Texts” check boxes must both be checked on the Contact/Address panel.
After the initial WIC appointment, Colorado WIC sends a “Welcome to WIC” text message to those opting to receive texts. The text contains instructions on how to opt out of the text message program. If a client chooses to opt out, they will be removed from any future texts immediately.
To Opt Out at Any Time Clients can text “STOP” directly to the WIC text message.
To Opt Back In If a client opts out of the WIC text messages and wants to opt back in, the client can text “START” to the WIC text message. If they do not have a WIC text message, they can text “START” to 1-888-974-2684.
The State WIC Office does not send out text messages at request on behalf of local WIC agencies or WIC partners.