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.

Colorado WIC Program Policies and Procedures Section 8: Certification, Eligibility and Coordination Revised: 10/01/2018

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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.