Updated 6-2017 Connecticut WIC Program Manual

WIC 200-21 SECTION: Certification

SUBJECT: Applicant/Participant Ineligibility, Termination and Disqualification

Federal Regulations: §246.2; §246.7 (h)(1)(ii) and §246.7 (h)(2) POLICY Ineligibility

The WIC local agency staff shall determine a WIC applicant is ineligible to receive program benefits for the following reasons:

• If the individual is not in a WIC approved category

• If family income exceeds the income guidelines, or unless the individual was determined to be automatically (adjunctively) income-eligible*

• Participant resides in an unapproved facility for the homeless

• If the WIC program can no longer serve certain categories due to funding shortages

The local agency may choose to deem applicants ineligible when:

• There is insufficient timeframe to effect change, i.e. less than 90 days before a child applicant turns 5 years old, essentially that individual will only be on the program for 3 months. Rather than making a blanket decision for the agency, it is encouraged that if a child applicant is still within the eligible time frame, the situation be explained to the family i.e. duration of benefits and the Authorized Person can then determine if they want to make the time investment in applying for the Program.

• In the experience of State Nutrition staff, many parents found value in joining the Program for such a short period of time for an individual if it was recertification, or if other members of the family were also being certified (e.g. mom is pregnant and/or other children in family).

Complete and provide a Notice of Participant Action form to applicants that are determined to be ineligible to receive program benefits if they inquire/apply in person for benefits or at their initial certification appointment. A copy of the completed NOPA form must be scanned into the participant’s electronic file.

Participant Ineligibility and Termination

If information becomes available at any point during the certification period, the WIC local agency staff shall terminate a WIC participant during that certification period for any of the following reasons:

• If the individual is no longer in a WIC approved category

Updated 6-2017 • If family income exceeds the income guidelines, unless this is determined during the eleventh month of a standard certification period or unless the individual was determined to be automatically (adjunctively) income-eligible*

• If the participant requests to end participation in the program

• For misuse or abuse of WIC benefits (may first require a verbal/written warning and suspension See 104-04 Participant Abuse for more details)

• Participation in more than one local WIC Program

• Participant resides in an unapproved facility for the homeless

• If the WIC program can no longer serve certain categories due to funding shortages

*Persons determined to be adjunctively income-eligible for the Program who then have their benefits under Temporary Family Assistance (TFA), Supplemental Nutrition Assistance Program (SNAP), or HealthCare for Uninsured Kids and Youth (HUSKY) end may not be terminated from the Program for solely this purpose. If adjunctive income-eligible benefits are no longer valid mid-certification, such participants and other household members currently receiving WIC benefits may be terminated during a certification period only after their income eligibility has been reassessed based on the income screening procedures used for applicants who are not adjunctively eligible.

For active participants, a Notice of Participant Action form shall be provided no less than 15 days before the termination or disqualification, except that participants’ terminated for residing in an unapproved facility for the homeless shall be provided 30 days notice.

Persons that are terminated by CT-WIC due to failure to re-certify do not need to be issued the Notice of Participant Action form. Notice of this policy is provided on the certification form for all new applicants and returning participants to review.

If the WIC state agency instructs the WIC local agency to institute a waiting list (See WIC Policy 200- 30), due to funding shortages, which would require participants to be terminated in the middle of their certification periods, a Notice of Participant Action form shall be provided no less than 15 days before WIC participation and benefits end.

Clarification: In several State agency policies and in the Federal regulations the terms, terminate, disqualify or disqualification and ineligibility are all used, at times interchangeably.

Ineligibility mainly refers to applicants or participants that are not eligible to receive or continue to receive program benefits.

Terminate or terminated is a local agency action that occurs when an existing participant is no longer eligible to receive WIC program benefits. This can happen at the start or in the middle of a certification period.

Disqualification refers to a State agency action in response to participant abuse of the WIC Program.