DC WIC POLICY & PROCEDURE MANUAL

Policy 2.002 1 | P a g e Title: Local Agency Nutrition Services Plan Category: Nutrition Services Plan and Evaluation

CFR Reference: 7 CFR § 246.11(d)(2) Policy Number: 2.002 Effective Date: 1/1/16 Revised Date: 8/15/23

POLICY STATEMENT The Local Agency must develop an annual Local Agency Nutrition Services Plan, including breastfeeding promotion and support, consistent with the State Agency's Nutrition Services Plan in accordance with DC WIC policy 2.001 State Agency Nutrition Services Plan. The annual Local Agency Nutrition Services Plan is referred to as the DC WIC Local Agency Workplan & Narrative (see attachment 10.001B) and is submitted according to the deadlines set forth in DC WIC policy 10.001A Local Agency Reporting Deliverables. PROCEDURE 1. The Local Agency will develop, implement, and evaluate its Local Agency Workplan in partnership with the State Agency. 2. The State Agency must specify the format and set submission dates of the Local Agency Workplan. REFERENCES 7 CFR § 246.11(d)(2) FNS WIC Nutrition Services Standards, Standard #1 DC WIC policies 2.001 State Agency Nutrition Services Plan, 10.001 Local Agency Reporting Procedures ATTACHMENTS & FORMS 10.001A Local Agency Reporting Deliverables 10.001B Local Agency Workplan & Narrative

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.003 1 | P a g e Title: Nutrition and Breastfeeding Assessment Category: Nutrition Assessment CFR Reference: 246.7 Policy Number: 2.003 Effective Date: 1/1/2016 Revised Date: 8/15/23

POLICY STATEMENT All participants deemed geographically, financially, and categorically eligible in accordance with DC WIC policies 8.004 Categorical Eligibility, 8.005 Residency Eligibility, and 8.006 Income Eligibility will have a nutrition assessment completed by a CPA/CPPA. The nutrition assessment is necessary to identify the fourth WIC-eligibility criteria of nutritional risk. All pregnant and postpartum participants must have a breastfeeding assessment completed as part of the nutrition assessment. The nutrition assessment must be completed at the participant’s initial certification and mid- certification appointments. PROCEDURE 1. The nutrition assessment is conducted via the VENA approach and assesses nutritional risk based on the following categories: • Anthropometric • Biochemical • Clinical • Dietary • Environmental Nutritional risk may be assigned manually by the CPA/CPPA and/or automatically assigned in the MIS based on responses of required fields within the participant’s record. 2. The CPA / CPPA must conduct a breastfeeding assessment for all pregnant and postpartum participants. The breastfeeding assessment can include the participant’s thoughts, feelings, goals, and support towards breastfeeding. The CPA/ CPPA must document this portion of the assessment in the participant’s care plan in the MIS. 3. At minimum, nutritional risk must be assessed and documented in the MIS at the time of certification and mid-certification for all WIC participants. The CPA/ CPPA shall document the nutrition education provided from the nutrition assessment in accordance with DC WIC policy 2.006 Nutrition Education Documentation. 4. All high-risk participants must be referred to a CPA in accordance with DC WIC policy 2.008 Serving High Risk Participants. DEFINITIONS CPA *– Competent Professional Authority; a licensed nutritionist, registered dietitian (RD), or other staff approved by the State Agency to provide nutrition services to “high” and “low” risk DC WIC participants. CPPA *– Competent Paraprofessional Authority; staff approved by the State Agency to provide nutrition services to “low risk” DC WIC participants.

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.003 2 | P a g e MIS – management information system; an information and data collection system that allows the State and Local Agency to perform and manage WIC services. The MIS used in DC WIC is called the Health and Nutrition Delivery System (HANDS). VENA – Value Enhanced Nutrition Assessment; a standardized process for conducting the nutrition assessment in a WIC setting leading to improved tailoring and delivering of nutrition services. VENA sets participant-centered standards for the nutrition assessment that determines eligibility, enabling local agency nutritionists to personalize WIC nutrition education, provide more relevant referrals, and tailor food packages to the individual participant’s needs. *See DC WIC policies 4.002 Position Descriptions and 8.007 Nutrition Risk Identification for further detail on the roles and responsibilities of CPA and CPPA REFERENCES 7 CFR § 246.7(e) FNS WIC Nutrition Service Standard # 6 FNS WIC Value Enhanced Nutrition Assessment Guidance (VENA) DC WIC policies 2.008 Serving High Risk Participants, 4.002 Position Descriptions, 8.004 Categorical Eligibility, 8.005 Residency Eligibility, 8.006 Income Eligibility, 8.007 Nutrition Risk Identification

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.004 1 | P a g e Title: Determining Nutritional Risk Category: Nutrition Assessment CFR Reference: 246.7e Policy Number: 2.004 Effective Date: 8/15/16 Revised Date: 8/15/23

POLICY STATEMENT WIC staff will perform anthropometric and biochemical screening at the time of certification, as required in accordance with DC WIC policy 8.010 Anthros and Bios. This information will be assessed along with clinical, dietary, and environmental responses collected during the nutrition assessment to determine appropriate nutritional risk code(s) for each participant. PROCEDURE 1. For all allowed nutrition risk criteria outlined in DC WIC Nutritional Risk Manual, the documented risk condition must apply to an applicant's current or most recent nutrition risk condition, as opposed to any history of the condition, unless otherwise stated in the specific definition of the nutrition risk criterion. 2. The CPA/CPPA will follow the steps in DC WIC’s Anthropometric and Lab Manuals to collect anthropometric and biochemical data on WIC participants. This data will be documented in the MIS. 3. A risk code may not be assigned based on a self-diagnosis (i.e., without a medical diagnosis), however it is appropriate for WIC staff to provide referral services to participants who report having symptoms so that a medical provider can confirm or rule out the presence of a medical condition. a. Self-reported medical diagnosis should be documented appropriately. b. A self-reported medical diagnosis should prompt the CPA/CPPA to validate the presence of the condition by asking more probing questions related to the self-reported professional diagnosis, such as: • Whether the condition is being managed by a medical professional. • The name and contact information for that medical professional (to allow communication and verification if necessary). • Whether it is being controlled by diet, medication, or other therapy; and • What types of medications, if any have been prescribed, are being taken to address the condition. 4. Non-traditional health care providers such as shamans, medicine men or women, acupuncturists, chiropractors, or holistic health advisors are not considered to be physicians whose diagnoses can be accepted for purposes of this policy or for establishing the eligibility of an applicant for WIC Program benefits. 5. The CPA/CPPA must utilize VENA techniques to further probe and tailor the nutrition assessment to be participant-centered. The CPA/ CPPA may utilize attachment 2.004A VENA_ABCDE Guide to assist in collecting nutritional risk data and selecting appropriate nutritional risk codes. REFERENCES 7 CFR 246.7e WIC Policy Memorandum 2011-5

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.004 2 | P a g e DC WIC policy 8.010 Anthros and Bios ATTACHMENTS & FORMS 2.004A VENA and ABCDE Guide DC WIC Nutrition Risk Manual DC WIC Anthropometric Manual DC WIC Lab Manual

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.005 1 | P a g e Title: Nutrition Education Overview Category: Nutrition and Breastfeeding Education CFR Reference: 246.11 Policy Number: 2.005 Effective Date: 1/1/16 Revised Date: 8/15/23

POLICY STATEMENT: Nutrition education, including breastfeeding promotion and support, must be made available to all WIC participants and their Authorized Representatives. The nutrition education provided will meet the health, cultural, and language needs of the participant and be consistent with the current science and recommendations of recognized national health organizations such as the American Academy of Pediatrics, the Center for Disease Control and Prevention, and the Dietary Guidelines for Americans. PROCEDURE 1. The Local Agency must establish protocols for conducting nutrition education contacts based on caseload and participant needs. a. At minimum, two nutrition education contacts must be attempted and documented per six-month certification period and four nutrition education contacts per one-year certification period. b. The Local Agency must utilize different delivery methods for hosting and conducting nutrition education in accordance with DC WIC policy 2.007 Nutrition Education Choice. 2. The State Agency must ensure all staff participate in activities to stay current in nutritional sciences and recommendations in accordance with DC WIC policy 4.004 Staff Training. 3. Nutrition education should be participant-centered and emphasize the relationship between nutrition, physical activity, and health outcomes. 4. Nutrition education is provided in either a primary or secondary manner: a. Primary nutrition education - education provided at the initial certification, high-risk follow- up, mid-certification, /or subsequent certification appointments. The education is tailored specifically to each participant based on their nutritional risk factors and focuses on the individual’s capacities, strengths, and developmental needs. The CPA/CPPA will document this form of nutrition education contact in the TGIF format: • Thoughts – a summary of the participant or authorized representative’s chief health concern. • Goals – an agreed upon action the participant or authorized representative plans to achieve. The CPA/CPPA should try to establish SMART goals with the participant when possible. • Information – the CPA/CPPA can expand in greater detail any pertinent information relevant to the nutrition assessment and education that occurred. This is the section for the CPA / CPPA to include breastfeeding assessment information. • Follow-Up- list of specific referrals made or areas to discuss at the participant’s next appointment. b. Secondary nutrition education – this manner of education is reserved for low-risk participants and is offered only after a primary nutrition education contact has been made. The content of this type of nutrition education is more generalized and can be reserved for a broader audience of WIC participants. Topics selected must be relevant to participant category and take into consideration individual risk factors or those common to the

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.005 2 | P a g e population served in the Local Agency, as appropriate. See DC WIC policy 2.007 Nutrition Education Choice for further details. 5. The Local Agency must consider the health, cultural, and language needs of participants when procuring nutritional education materials (e.g., handouts, recipes cards, etc.). a. The Local Agency may procure from approved vendors listed in attachment 2.005A Nutrition Education Resource List. b. The Local Agency must obtain approval from the State Agency for any nutrition education materials created in-house. REFERENCES 7 CFR 246.11 WIC Policy Memo # 2008-4 FNS WIC Nutrition Service Standard 7 DC WIC policies 2.007 Nutrition Education Choice, 4.004 Staff Training ATTACHMENTS & FORMS DC WIC policy 2.004A VENA and ABCDE Guide DC WIC policy 2.005A Nutrition Education Resource List

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.006 1 | P a g e Title: Nutrition Education Documentation Category: Nutrition and Breastfeeding Education CFR Reference: 7 CFR 246.11(e)(4) Policy Number: 2.006 Effective Date: 1/1/2016 Revised Date: 8/15/23

POLICY STATEMENT Nutrition education, including breastfeeding promotion and support, must be thoroughly integrated into participant health care plans, the delivery of supplemental foods, and other Program operations. All nutrition education contacts, or attempts to contact, must be documented in the MIS and in accordance with DC WIC policy 2.005 Nutrition Education Overview. PROCEDURE 1. Primary nutrition education contacts must be documented in the TGIF format (see DC WIC policy 2.005 Nutrition Education Overview). 2. Required education topics include the following for the initial primary nutrition education contact of a participant’s certification: a. Drug use, tobacco, and alcohol screening and appropriate education given in accordance with DC WIC policy 8.020 Substance Use Screening & Referrals. b. All pregnant participants will be encouraged to breastfeeding, unless contraindicated for health reasons. 3. Exit counseling must be provided to all pregnant, postpartum, and breastfeeding women prior to the end of their certification period. 4. All primary nutrition education contacts must be documented in the MIS on the same day the contact occurred. 5. The Local Agency must establish protocols for documenting secondary nutrition education in accordance with DC WIC policy 2.007 Nutrition Education Choice. 6. The Local Agency must establish protocols for documenting all attempts to conduct nutrition education in accordance with DC WIC policies 2.005 Nutrition Education Overview and 2.007 Nutrition Education Choice. 7. All notes should be: a. Consistent – establishes standards/protocols to which all staff must adhere. b. Clear – easily understood by other staff members; using documentation abbreviations, etc., as established by the State and/or Local Agency. c. Organized – follows an established order and minimizes duplication. d. Complete – creates a picture of the participant, describes or lists the services provided over time, and outlines a plan for future services. e. Concise – contains minimal extraneous information. f. Include timeframe and documentation of completing care plan. REFERENCES 7 CFR 246.11(e)(4) WIC Policy Memo 2008-4 WIC Policy Memo 1994-9 FNS WIC Nutrition Service Standard #7

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.006 2 | P a g e DC WIC policies 2.005 Nutrition Education Overview, 2.007 Nutrition Education Choice, 8.020 Substance Use Screening & Referrals

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.007 1 | P a g e Title: Nutrition Education Choice Category: Nutrition and Breastfeeding Education CFR Reference: 246.11 Policy Number: 2.007 Effective Date: 8/15/23 Revised Date: 8/15/23

POLICY STATEMENT Nutrition education, including breastfeeding promotion and support, must be available to all participants through either individual or group sessions appropriate to the individual participant’s nutritional risks, needs, and interests. Contacts must be designed to meet the cultural and language needs of Program participants. The Local Agency must offer at least two delivery methods of secondary nutrition education in accordance with DC WIC policy 2.005 Nutrition Education Overview. PROCEDURE The Local Agency must establish delivery methods for participants eligible for secondary nutrition education. Delivery methods may be in-person, by phone, or online. Criteria for delivery methods are outlined in the table below. Delivery method of nutrition education Risk level Participant category Individual: in-person High risk (by CPA) Low risk All categories Individual: phone High risk (by CPA) Low risk All categories Individual: telehealth/video call High risk (by CPA) Low risk All categories Individual: self-paced online or in-person Low risk All child categories All pregnant and postpartum categories Infants between 6-12 months Group: online or in- person Low risk All categories

Individual In-person: The participant or authorized representative must come to the WIC clinic to receive this delivery method. Telephone: WIC staff engage the participant and maintain confidentiality. WIC staff should offer to send reinforcements (e.g., handouts, website links, etc.) to the participant in their preferred format (electronic, text message, mail). Telehealth/video call: WIC staff engage the participant and maintain confidentiality. The Local Agency must ensure a quiet space to conduct the telehealth/video call. WIC staff should offer to send reinforcements (e.g., handouts, website links, etc.) to the participant in their preferred format (electronic, text message, mail).

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.007 2 | P a g e Self-paced online nutrition education platform: Online, self-paced, and interactive nutrition education modules/lessons are an appropriate format for participants to complete secondary nutrition education. The Local Agency should ensure procedures for reviewing module completion and contacting participants for benefit issuance. Allowable online platforms are specified by the State Agency. Group In-person: The participant or authorized representative must come to the WIC clinic to receive this delivery method. The Local Agency must ensure a private and large enough space to host a group education session. Online: WIC staff engage the participant and maintain confidentiality. WIC staff should offer to send reinforcements to the participant in their preferred format. The Local Agency must ensure a quiet and private space to conduct the group education session. The Local Agency should ensure procedures that allow for timely documentation and benefit issuance to all attendees. Missed Nutrition Education Appointments and Non-Denial of WIC Benefits The Local Agency must make a reasonable effort to provide nutrition education to each participant. The Local Agency must set guidelines for what constitutes a reasonable effort. Participants cannot be denied program benefits for failure to attend an educational activity or for lack of willingness, readiness, or ability to participate in the activity. If a participant does not attend or participate in a scheduled nutrition education contact, the Local Agency must ensure staff document all attempts to contact in the MIS. REFERENCES 7 CFR 246.11 FNS WIC Nutrition Service Standard # 7, # 14 DC WIC policy 2.005 Nutrition Education Overview ATTACHMENTS & FORMS DC WIC State Agency-provided hand-outs

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.008 1 | P a g e Title: Serving High-Risk Participants Category: Nutrition and Breastfeeding Education CFR Reference: 246.11 Policy Number: 2.008 Effective Date: 1/1/2016 Revised Date: 8/15/23

POLICY STATEMENT The State Agency must establish procedures to ensure adequate documentation and timely follow-up for participants designated high-risk. PROCEDURE 1. The State Agency establishes criteria for identifying participants with certain nutritional risk factors that require monitoring and follow-up by a CPA, see DC WIC policy 2.003 Nutrition and Breastfeeding Assessment. These risks are flagged in the MIS and are listed on DC WIC’s CPA Cheat Sheet.

2. At minimum, participants identified as high-risk must receive two individual nutrition education contacts by a CPA within three months of the initial identification of the high-risk condition. CPAs shall document the nutrition education contact in TGIF format, see DC WIC policy 2.005 Nutrition Education Overview.

3. The CPA may use their professional judgment to determine the frequency of monitoring and follow-up for each participant with a high-risk nutritional status.

4. In lieu of a CPA, a CPPA may complete a high-risk certification, but cannot provide education for risk codes that are deemed high-risk. The CPPA can counsel the participant on basic nutrition education and risk codes that are non-high risk. A high-risk participant may receive up to two months of food benefits between the certification and high-risk visit per the Local Agency discretion.

5. If a CPA determines through a subsequent nutrition assessment that a participant is no longer high-risk, the CPA may remove the high-risk designation in the MIS. The CPA must document the rational for removing the high-risk status. REFERENCES 7 CFR 246.11(c)(4) 7 CFR 246.11(e)(5) DC WIC policies 2.003 Nutrition and Breastfeeding Assessment, 2.005 Nutrition Education Overview ATTACHMENTS & FORMS DC WIC Nutrition Risk Manual CPA Cheat Sheet CPPA Cheat Sheet

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.009 1 | P a g e Title: Breastfeeding Education and Support Overview Category: Nutrition and Breastfeeding Education CFR Reference: 7 CFR § 246.11(e)(1) 7 CFR § 246.2 Policy Number: 2.009 Effective Date: 1/1/2016 Revised Date: 8/15/2023

POLICY STATEMENT Breastfeeding education, promotion, and support must be thoroughly integrated into the State and Local Agency operations and made available to all pregnant and breastfeeding participants. All pregnant participants must be encouraged to breastfeed unless contraindicated for health reasons. PROCEDURE 1. The State Agency and Local Agency ensure that all staff receiving initial and ongoing training in breastfeeding promotion and support in accordance with DC WIC policy 4.004 Staff Training. 2. Breastfeeding promotion and support activities must be outlined in the State and Local Agency’s Nutrition Services Plans in accordance with DC WIC policy 2.001 State Agency Nutrition Services Plan and 2.002 Local Agency Nutrition Services Plan. The Local Agency may provide breastfeeding promotion and support in one or more of the following ways: • Implement WIC’s Breastfeeding Peer Counseling Program in accordance with DC WIC policy 2.011 Breastfeeding Peer Counselor Program. • Provide online breastfeeding education via recorded (asynchronous) classes, articles, videos, or other modules. • Provide live breastfeeding classes or support groups, virtually or in-person. • Provide live app-based consultation for breastfeeding support. • Enter into an agreement with an organization to provide CLC, IBCLC, or other advanced breastfeeding support to WIC participants. • Any other breastfeeding promotion and support delivery method approved by the State Agency. 3. The Local Agency monitors that all staff provide breastfeeding education, promotion and support to participants appropriate to their job roles and responsibilities in accordance with DC WIC policy 4.002 Position Descriptions. a. The Local Agency provides initial breastfeeding education and support training as part of new employee orientation. b. The Local Agency establishes procedures for yielding/referring participants to the proper supporting authority when breastfeeding concerns fall out of scope of practice for staff members. c. For participants in which breastfeeding is not possible or contraindicated, the CPA must document this information in the participant’s care plan note in this MIS.

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.009 2 | P a g e 4. The State and Local Agency ensure staff provide accurate and up-to-date breastfeeding messages from reputable sources including Academy of Breastfeeding Medicine (ABM), the American Academy of Pediatrics (AAP), and the Centers for Disease Control (CDC). REFERENCES 7 CFR 246.11(e)(1) 7 CFR 246.2 FNS WIC Nutrition Services Standard # 8 FNS WIC Breastfeeding Policy and Guidance DC WIC policies 2.001 State Agency Nutrition Services Plan, 2.002 Local Agency Nutrition Services Plan, 2.013 Breastfeeding Aids and Supplies, 4.002 Position Descriptions, 4.004 Staff Training

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.010 1 | P a g e Title: Breastfeeding Promotion in WIC Clinics Category: Nutrition and Breastfeeding Education CFR Reference: 7 CFR § 246.11(c)(7) Policy Number: 2.010 Effective Date: 1/1/2016 Revised Date: 8/15/2023

POLICY STATEMENT The State Agency ensures that the Local Agency adheres to the following: 1. Maintain a positive clinic environment which endorses breastfeeding as the preferred method of infant feeding. 2. Designate an appropriate staff member to coordinate breastfeeding promotion and support activities in accordance with DC WIC policy 4.002 Position Descriptions. 3. Ensure that women have access to breastfeeding promotion and support activities during the prenatal and postpartum periods. PROCEDURE 1. The Local Agency must, at minimum, ensure a positive clinic environment for breastfeeding by: a. Posting breastfeeding promotion, information, and resources in plain view of all participants. b. Welcoming participants to breastfeed anywhere in the WIC clinic, as they feel comfortable, and providing a private space to breastfeed or express milk. c. Refrain from using or posting any products, supplies, or promotional materials branded with infant formula company information, products, or logos. 2. The Local Agency must designate a breastfeeding coordinator to assist in the implementation and adherence of the Local Agency Nutrition Services Plan breastfeeding activities, and to assist with employee training in breastfeeding education and support. 3. The Local Agency ensures adequate staffing and/or procedures to provide breastfeeding education, promotion, and support activities to all pregnant and postpartum participants at each of its clinic sites.

REFERENCES 7 CFR 246.11(c)(7) FNS WIC Nutrition Service Standard #8 FNS WIC Breastfeeding Policy and Guidance DC WIC Policy 4.002 Position Descriptions

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.011 1 | P a g e Title: Breastfeeding Peer Counselor Program Category: Breastfeeding Peer Counseling CFR Reference: n/a Policy Number: 2.011 Effective Date: 1/1/2016 Revised Date: 8/15/23

POLICY STATEMENT The Breastfeeding Peer Counselor (BFPC) program must be made available to participants and adhere to the standards set by the State Agency. PROCEDURE The Local Agency must ensure the following: 1. All BFPCs complete the required training in accordance with DC WIC policy 2.009 Breastfeeding Education and Support Overview and 4.004 Staff Training. Additional training and support should be offered to BFPCs as needed. 2. The BFPC works under the direction of the Local Agency Breastfeeding Coordinator, Designated Breastfeeding Expert (DBE), Lactation Consultant, or the designated CPA at her site. All matters should be directed toward the on-site supervisor or State Breastfeeding Coordinator as appropriate. 3. The BFPC follows established yielding/referring procedures for issues outside of their scope of practice in accordance with DC WIC policy 4.002 Position Descriptions and attachment 2.011A BFPC Scope of Practice. 4. All BFPCs document in accordance with DC WIC policy 2.012 BFPC Contact Requirements. 5. Monthly records related to breastfeeding contacts must be submitted to the State Agency by the 10th of the following month via email to info.wic@dc.gov. 7. BFPCs will be available to participants outside of regular clinic hours, as needed. DEFINITIONS Designated Breastfeeding Expert (DBE) – an individual who is an expert with special experience or training in helping breastfeeding mothers and who provides breastfeeding experience and care for more complex breastfeeding problems when WIC staff face situations outside of their scope of practice. Individuals with this designation can be WIC staff including Breastfeeding Coordinators, IBCLCs, CLCs, or nutritionists. REFERENCES FNS WIC Nutrition Service Standard # 9 FNS WIC Breastfeeding Policy and Guidance DC WIC Policies 2.009 Breastfeeding Education and Support Overview, 2.012 BFPC Contact Requirements, 4.002 Position Descriptions, 4.004 Staff Training ATTACHMENTS & FORMS 2.011A Scope of Practice for Breastfeeding Peer Counselors

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.012 1 | P a g e Title: Breastfeeding Contact Requirements Category: Nutrition and Breastfeeding Education CFR Reference: 7 CFR § 246.11 Policy Number: 2.012 Effective Date: 8/15/23 Revised Date: 8/15/23

POLICY STATEMENT The Local Agency establishes procedures for BFPCs to contact and refer pregnant and postpartum participants to ensure adequate breastfeeding care and support. PROCEDURE 1. The Local Agency ensures that the initial breastfeeding assessment is performed by a CPA/CPPA and is documented in the participant’s record in accordance with DC WIC policy 2.003 Nutrition and Breastfeeding Assessment. The CPA/CPPA is responsible for referring participants into the Breastfeeding Peer Counselor (BFPC) program. If a participant declines to participate in the BFPC program, the WIC staff member must document as such in the participant’s record. 2. The Local Agency determines the frequency of BFPC contacts with the following minimum standards: a. Participants should have at least one contact with a BFPC during their pregnancy, and b. Participants should have at least one contact with a BFPC after delivery. 3. The Local Agency must ensure BFPCs document: a. All successful contacts and contact attempts in the Peer Counselor Screen of the MIS. b. Future callback dates within appropriate timeframes established by the Local Agency. c. The content of the successful contact in the participant’s note section of the MIS at the discretion of the BFPC for continuity of care. 4. The State Agency recommends more frequent breastfeeding contact and support for high-risk pregnant and postpartum participants (e.g., pregnant with multiples, history of preterm or early term delivery, etc.) in accordance with DC WIC policy 2.008 Serving High Risk Participants. a. The Local Agency DBE or breastfeeding authority will determine the need for more frequent breastfeeding contact and support. b. The BFPC may continue to contact participants with breastfeeding concerns outside of their scope but may not provide counseling or education on these issues. REFERENCES FNS WIC Nutrition Service Standard # 9 FNS WIC Breastfeeding Policy and Guidance (2016) DC WIC Policies 2.003 Nutrition and Breastfeeding Assessment, 2.008 Serving High Risk Participants

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.013 1 | P a g e Title: Breastfeeding Aids and Accessories Category: Nutrition and Breastfeeding Education CFR Reference: 7 CFR § 246.14(c)(1) Policy Number: 2.013 Effective Date: 12/29/2000 Revised Date: 8/15/23

POLICY STATEMENT The Local Agency must make breastfeeding supplies available to participants to assist in managing breastfeeding concerns. PROCEDURE The Local Agency must: 1. Maintain a supply of breast pumps (manual and electric), as well as breast pads and other appropriate supports as determined by the State Agency. 2. Ensure that breastfeeding participants are instructed on hand expression of breast milk, breast milk handling and storage, and pump cleaning before issuing a breast pump. 3. Provide participants with resources to procure a breast pump from their insurance (if applicable) while pregnant or after delivery. 4. Provide training to staff on how to use and distribute breastfeeding aids and accessories. 5. Ensure staff document the aid in the MIS. 6. Nipple shields, if provided, must only be distributed under the guidance of a WIC-designated DBE or IBCLC as a short-term solution to breastfeeding issues. NUTRITION SERVICE ADMINISTRATION (NSA) FUNDS Local Agency allowable costs on NSA funds: • Breast pumps, • Breastfeeding aids that directly support the efforts of breastfeeding parents to remove milk from the breast and/or provide human milk to their infants, • Breastfeeding accessories are devices or products that, while not directly aiding the removal of milk from the breast, may facilitate breastfeeding. Unallowable NSA costs: • Breastfeeding aids/accessories that do not directly support the initiation and continuation of breastfeeding cannot be purchased with WIC funds. • Examples include topical creams, foot stools, baby bottles, nursing blouses, etc. (See the USDA Breastfeeding Policy and Guidance, 2016, for more information.) BREAST PUMPS The State Agency has discretion to determine under what conditions breast pumps may be issued to WIC participants (USDA Breastfeeding Policy and Guidance, 2016). The DC WIC State Agency allows breast pumps to be issued to any WIC participant who is breastfeeding. Breast pumps should not be issued to pregnant participants unless they are breastfeeding a WIC participant infant. DC WIC encourages participants to obtain a breast pump through their health insurance. The Local Agency must obtain approval from the State Agency prior to procuring breast pumps to align with cost containment measures. To be compatible with the MIS, the State Agency recommends that

DC WIC POLICY & PROCEDURE MANUAL

Policy 2.013 2 | P a g e the breast pumps purchased by the Local Agency have the serial number on the outside of the pump box. The State Agency recommends that participants be counseled on proper use of a breast pump, proper cleaning, and milk storage according to CDC guidelines. The State Agency recommends the Local Agency staff follow up with the participant after issuance of a pump. BREAST PUMP RELEASE LIABILITY FORM: The Local Agency must ensure each participant issued a breast pump signs the Breast Pump Release of Liability form (see attachment 2.013A Breast Pump Release of Liability Form). The signed form must be scanned in the participant’s record in the MIS. Retention of paper records is not required. NOTES ON BREASTFEEDING AIDS: 1. The Local Agency is not permitted to charge participants for a breast pump or any other breastfeeding aid or accessory. Breast pumps are not a guaranteed program benefit but are aids that the State Agency may choose to offer WIC participants. 2. DC WIC does not distribute multi-user breast pumps, nor does DC WIC accept returns of breast pumps once issued. 3. Provision of a breast pump or breastfeeding aid(s) must accompany appropriate breastfeeding education and support. The following are general circumstances when WIC staff may issue breast pumps to participants: a. The participant is having difficulty establishing or maintaining an adequate milk supply due to maternal/infant illness. b. During mother/infant separation (such as infant hospitalization or mother’s return to work or school); and c. To mothers who have temporary breastfeeding problems, such as engorgement. REFERENCES 7 CFR 246.14(c)(1) FNS WIC Nutrition Service Standard #8 FNS WIC Breastfeeding Policy and Guidance WIC Policy Memo #1995-05 Centers for Disease Control and Prevention (CDC), Proper Storage and Preparation of Breast Milk. Accessed at: https://www.cdc.gov/breastfeeding/recommendations/handling_breastmilk.htm ATTACHMENTS & FORMS 2.013A Breast Pump Release of Liability Form Refer to a thorough guide to allowable costs in the Peer Counseling Program from Minnesota WIC, accessed at: https://www.health.state.mn.us/docs/people/wic/localagency/program/finance/peerallowable.pdf (2023, Minnesota Department of Health – WIC Program, health.wic@state.mn.us)

DC WIC POLICY & PROCEDURE MANUAL

Policy 3.001 1 | P a g e Title: MIS Security Overview Category: MIS CFR Reference: 2 CFR 200.313(d)(1) 2 CFR 200.333 CFR 246.25(a)(2) CFR § 246.26(d) Policy Number: 3.001 Effective Date: 01/01/2016 Revised Date: 11/30/2023

POLICY STATEMENT: The DC WIC State and Local Agency must ensure the security and integrity of participant and program data within the MIS by adhering to the following:

1. Confidentiality Agreements -Upon hiring, the Local Agency requires each staff member to sign and submit attachment 3.001A MIS Confidentiality Agreement – New User Account to ensure WIC participant data privacy. The signed form must be submitted to the State Agency before the new employee can receive access to the MIS.

Additionally, each staff member* must complete the Online Annual DC WIC Data Confidentiality/ Security Agreement as provided by the State Agency.

*Staff within their first year of hire are not required to submit the additional Online Annual DC WIC Data Confidentiality/Security Agreement.

2. MIS User ID Requests - Each State and Local Agency staff member must be given a unique user identifier (ID) to access the MIS. User access must be assigned based on the staff member’s title and role within the DC WIC program. See attachment 3.001B HANDS Permission Settings for access levels and permission settings.

If a staff member’s title and role within the DC WIC program changes, including termination of employment from the DC WIC program, the Local Agency must request a change in MIS user access.

3. IT Security Awareness Training - All State and Local Agency staff receive ongoing IT security awareness training. The State Agency will provide IT security awareness training annually (see DC WIC policy 4.004 Staff Training).

4. Protection of DC WIC IT Equipment - The Local Agency ensures that DC WIC program IT resources (e.g. computers, cell phones, laptops, scanners, etc) are secured against theft, intrusion, and unauthorized access and use. The State Agency will perform a biennial security review of the Local Agency to ensure that data files and computer programs are protected.

5. Ensuring Participant Privacy - Participant data is kept secure at employee workstations by locking computer screens when not in use, securing any loose documents that contain personal identifiable information (PII), and ensuring a private and secure space when speaking with WIC participants.

DC WIC POLICY & PROCEDURE MANUAL

Policy 3.001 2 | P a g e PROCEDURE Confidentiality Agreements

The Local Agency must maintain a record of all signed initial Confidentiality Agreements for auditing purposes.

The State Agency will maintain a record of all annual employee Confidentiality Agreements for auditing purposes.

MIS User ID Requests 1. The Local Agency must submit all MIS User ID requests, including change in employee’s title and role, to info.wic@dc.gov and contain the following:

Full Name

Email Address

Phone Number (if applicable)

Clinic Roles / Job Title

MIS Permission #

MIS environments (Production and/or Training)

Local Agency and Clinic Codes (“All Clinics” for access to all clinics within LA)

Reason of the request

Additionally, all new user requests must submit a signed attachment 3.001A – MIS Confidentiality Agreement – New User Account. 2. Termination of MIS user IDs – The employee’s full name, email address, and effective date of termination.

3. The State and Local Agency must maintain a record of all MIS user ID requests for auditing purposes. IT Security Awareness Training The State Agency provides annual IT security awareness training and is responsible for maintaining an annual record of staff who have completed the training.

Protection of DC WIC IT Equipment The Local Agency is responsible for monitoring staff’s use of DC WIC program IT equipment to ensure proper use. If local agency staff mishandle DC WIC IT equipment (e.g., conducting personal business, download or install unapproved software, etc.), the Local Agency must promptly notify the State Agency. The State Agency will provide directives on the course of action. Ensuring Participant Privacy In addition to locking computer screens when not in use, using screen protectors when in use, securing any loose documents that contain PII, and ensuring a private and secure space when speaking with WIC participants, State and Local Agency staff must be mindful of what information is shared and with whom and where. See DC WIC policy 12.019 Confidentiality for additional guidance.

DC WIC POLICY & PROCEDURE MANUAL

Policy 3.001 3 | P a g e The State Agency recommends the following: • The Local Agency provides annual training on participant data privacy. • In written correspondence, using the participant’s WIC Client ID in place of name or other PII. • Disposing of participant and/or program information via shredders or use of locked shred bins. • The Local Agency ensures facility security by establishing or following Local Agency protocols for limiting access to buildings, rooms, and equipment that store DC WIC participant and program data.

The Local Agency is responsible for notifying the State Agency promptly if a breach of confidentiality occurs.

DC WIC IT Equipment Configuration and Updates

The Local Agency must ensure all DC WIC IT equipment is regularly updated and protected against malware. See DC WIC policy 3.003 MIS Configurations and Equipment Inventory for additional guidance.

REFERENCES 2 CFR 200.313(d)(1) 2 CFR 200.333 CFR 246.25(a)(2) CFR § 246.26(d) DC WIC policies 3.003 MIS Configurations and Equipment Inventory, 4.004 Staff Training, 12.019 Confidentiality ATTACHMENTS & FORMS 3.001A MIS HANDS Confidentiality Agreement - New User Account 3.001B HANDS Permission Settings

DC WIC POLICY & PROCEDURE MANUAL

Policy 3.002 1 | P a g e Title: Help Desk Procedures Category: MIS CFR Reference Policy Number: 3.002 Effective Date: 7/28/2016 Revised Date: 11/30/2023

POLICY STATEMENT: The State and Local Agency must ensure staff direct all IT concerns to the appropriate authority as outlined below. The State Agency annually provides the Local Agency with updated contact information for Help Desk services, as needed. PROCEDURE Local Agency IT Support Local Agency staff should contact their Local Agency IT support for concerns related to or in the likeness of: • Local network outages • Email, phone, and/or other local agency account-specific security • WIC Laptops and IT peripherals (i.e card reader, scanner, signature pad)

State Agency IT Support State and Local Agency staff should contact the State Agency IT support via info.wic@dc.gov for concerns related to or in the likeness of: • MIS equipment and its peripherals and function only after consult with the Local Agency IT support. • Permissions and role settings in accordance with DC WIC policy 3.001 MIS Security Overview.

Arizona (AZ) WIC Service Desk State and Local Agency staff should contact the AZ WIC Service Desk via wicservicedesk@azdhs.gov or 1-855-432-7220 for concerns related to or in the likeness of: • MIS password authentication such as locked accounts, etc. • MIS functionality • DC WIC participant accounts as they relate to assigned roles/titles, only after contact with the State Agency IT Support WIC staff must provide the following information when contacting the WIC Service Desk: • Staff’s name • Clear description of question/problem, concern, suggestions to improve the system, etc. • WIC Client or Family ID, as necessary

DC WIC POLICY & PROCEDURE MANUAL

Policy 3.002 2 | P a g e • Screen shot of error, if possible • Steps user performed to generate the error

eWIC Card and Account Assistance DC WIC participants may experience issues related to or in the likeness of their eWIC card, food benefits, and/or their eWIC mobile app account (i.e., EzWIC). See DC WIC policy 9.001 Food Benefit Issuance Overview for additional guidance. REFERENCES DC WIC policies 3.001 MIS Security Overview, 9.001 Food Benefit Issuance Overview

DC WIC POLICY & PROCEDURE MANUAL

Policy 3.003 1 | P a g e Title: MIS Configurations and Equipment Inventory Category: MIS CFR Reference: § 3016.32 (d)(1)(2) Policy Number: 3.003 Effective Date: 8/30/2009 Revised Date: 11/30/2023

POLICY STATEMENT: The State and Local Agency ensure that all IT equipment provided to perform the functions of the DC WIC program are properly configured, regularly maintained, and inventoried on an ongoing basis in accordance with § 3016.32 (d)(1)(2). State Agency • The State Agency provides the mandatory configuration file for use on Local Agency laptops used to perform the functions of the DC WIC program. • The State Agency is responsible for communicating IT equipment configuration and specification updates to the Local Agency. • The State Agency provides the Local Agency troubleshooting assistance of the mandatory configuration file only if specified equipment is used, see attachment 3.003A HANDS Equipment and Peripherals. Equipment used outside of that specified by the State Agency may not receive troubleshooting assistance. • The State Agency will provide the Local Agency with Pin Pads needed to perform eWIC card issuance in the MIS. Local Agency • The Local Agency is responsible for purchasing, installing, configuring, and maintaining IT equipment to the preferred specifications provided by the State Agency. See 3.003A HANDS Equipment and Peripherals for additional details. • The Local Agency must successfully test all IT equipment and its peripherals before deploying for use to perform the functions of the DC WIC program. See attachment 3.003B HANDS Peripheral Testing for equipment testing procedures. • The Local Agency must maintain IT equipment inventory and inventory records for auditing purposes. Records must be kept on file for three years.

PROCEDURE IT equipment The State Agency will provide the Local Agency with a listing of required IT equipment and peripherals needed to perform the functions of the DC WIC program. This includes IT equipment such as: • Networked printers • Card readers • Desktop scanners • Laptops • Signature pad

DC WIC POLICY & PROCEDURE MANUAL

Policy 3.003 2 | P a g e • Pins Pads – only to use those provided by the State Agency • USB hub • Docking station See 3.003B HANDS Peripheral Testing for IT equipment testing procedures. IT Equipment Configuration The State Agency provides the Local Agency the most current mandatory configuration file to be installed on all laptops that are used to perform the functions of the DC WIC program. For Local Agency procured laptops, the Local Agency may add its own imaging if it does not interfere with the most current MIS configuration file. IT Equipment Inventory The Local Agency must annually review and verify their equipment inventory and submit an inventory log to the State Agency at the end of September of each year. See attachment 3.003C Equipment Inventory Reporting Template for logging and inventorying IT equipment. The Local Agency must dispose of any IT equipment that is lost through theft, irreparable or obsolete according to the Local Agency’s electronic equipment disposal procedures. Disposal of equipment must be accompanied by a completed copy of the Local Agency’s Disposal Report internal to the organization, or a police report for stolen equipment. REFERENCES § 3016.32 (d)(1)(2) ATTACHMENTS & FORMS 3.003A HANDS Equipment and Peripherals, 3.003B HANDS Peripheral Testing, 3.003C Equipment Inventory Reporting Template

DC WIC POLICY & PROCEDURE MANUAL

4.001 1 | P a g e Title: Staffing Requirements Category: Nutrition Services Staffing CFR Reference: 7 CFR § 246.3 (e) 7 CFR § 246.11(c) Policy Number: 4.001 Effective Date: 11/30/2016 Revised Date: 8/15/23

POLICY STATEMENT The Local Agency must appropriately recruit, hire, and train staff to administer an efficient and effective Program including, but not limited to, the functions of nutrition education, breastfeeding promotion and support, certification, food delivery, fiscal reporting, monitoring, and training. PROCEDURE 1. The Local Agency must develop staffing practices to ensure Program benefits are delivered in the most effective and efficient manner, and must comply with the USDA regulations governing nondiscrimination, citation §246.8 Nondiscrimination and OMB regulations governing the administration of grants, 2 CFR part 200, FNS guidelines and instructions. 2. The Local Agency must outline their staffing each year in the budget and budget narrative in accordance with DC Health Office of Grants Management requirements and DC WIC policy 10.001. 3. The Local Agency must fulfill staffing needs according to position standards in DC WIC policy 4.002. The State Agency recommends a staffing ratio of 1:300 participants. The State Agency reserves the right to advise the Local Agency on staffing ratios if guidance is obtained from USDA on a national or regional level. 4. All Local Agency staff must complete task-specific training as outlined in policies 4.002 Position Descriptions and 4.004 Staff Training. REFERENCES 7 CFR § 246.3 (e) 7 CFR § 246.11(c) DC WIC policy 4.002 Position Descriptions, 4.004 Staff Training, 10.001 Local Agency Reporting Procedures

DC WIC POLICY & PROCEDURE MANUAL

Policy 4.002

1 | P a g e Title: Position Descriptions Category: Nutrition Services Staffing CFR Reference: 7 § 246.3(e) 7 § 246.11 (c)(7)(ii) 7 § 246.8 Policy Number: 4.002 Effective Date: 11/30/2016 Revised Date: 6/15/2026

POLICY STATEMENT The Local Agency must ensure that sufficient staff is available to administer an efficient and effective Program including, but not limited to, the functions of nutrition education, breastfeeding promotion and support, certification, food delivery, fiscal reporting, monitoring, and training. PROCEDURE Qualified staff must be employed or on contract with the Local Agency to provide WIC services in accordance with federal regulations, the DC WIC State Plan, and DC WIC policies. Program budget, participation, and Local Agency needs should be considered when determining staffing levels for WIC services. The Local Agency is responsible for hiring WIC staff according to the guidelines set forth in this policy and their own Local Agency organizational policies for hiring and credentialing. In accordance with the DC Code, paraprofessionals (such as dietetic technicians or assistants) must work under the supervision of a licensed dietitian or nutritionist. The State Agency recommends that the Local Agency have adequate bilingual staff to serve their participant population. The State Agency provides minimum requirements for each Local Agency position (outlined below). The Local Agency must ensure their job descriptions and postings align with the minimum requirements set forth below. The State Agency requires that Local Agency have a Local Agency WIC Director (LAD) to administer the program. Not all positions listed below are required; the positions that each Local Agency requires for operations is at the discretion of the Local Agency. The State Agency reserves the right to advise the Local Agency on staffing ratios if guidance is obtained from USDA on a national or regional level (see DC WIC policy 4.001 Staffing Requirements). REFERENCES FNS WIC Nutrition Services Standards 3 and 4 Code of the District of Columbia § 3–1207.01. Qualifications for licensure. Code of the District of Columbia § 3–1201.02. Definitions of health occupations.

DC WIC POLICY & PROCEDURE MANUAL

4.002 2 | P a g e MINIMUM REQUIREMENTS FOR EACH LOCAL AGENCY POSITION The following describes the minimum requirements for each Local Agency position title. WIC Local Agency Leadership Position Title Qualifications Roles and Responsibilities Local Agency Director (LAD) • Master’s degree in public health, nutrition science, dietetics, or other health related field or bachelor’s degree with at least 3 years of professional experience in a public health setting. • Supervisory experience preferred. • Experience in administrative or operations management in a health care setting preferred. • Registered Dietitian (RD/RDN) and/or Licensed Dietitian or Nutritionist (LD/LN) in the District of Columbia preferred. If the Local Agency does not employ a licensed CPA, the LAD must maintain licensure. • Supervises Local Agency staff; ensures staff are trained and performing job roles in accordance with DC WIC policy and procedures. Conducts annual performance reviews. • Develops the Local Agency Nutrition Services Plan and completes required documents and reports as requested by the State Agency. • Assesses program data to analyze trends and make informed program decisions. • Participates in monthly LAD meeting and quarterly technical assistance meetings with the State Agency. • Develops and maintains the Local Agency WIC Program budget. • Plans and coordinates outreach and other program activities with program partners and community-based organizations. Local Agency Nutrition Coordinator (NC) • Must meet minimum qualifications of a CPA. • Minimum 2 years of job-related experience. • Completes a competency-based training program on performing duties of CPA. • Performs duties of the qualified nutritionist and • Participates in the development of the Local Agency Nutrition Services Plan • Participates in professional development activities. • Provides in-service training to local agency staff on nutrition services. • Assists in supervision of local agency staff who provide nutrition services. • Provides technical assistance to local agency staff and community partners, as warranted. • Coordinates with the Local Agency Breastfeeding Coordinator to plan breastfeeding activities for the local agency and community partners.

DC WIC POLICY & PROCEDURE MANUAL

4.002 3 | P a g e WIC Local Agency Leadership Position Title Qualifications Roles and Responsibilities • Conducts QA/QI activities that ensure the local agency operates in accordance with DC WIC policies and procedures. • Assists the LAD in development and management of the nutrition services budget.

Nutrition Position Title Qualifications Roles and Responsibilities Competent Paraprofessional Authority (CPPA) CPPAs must meet one of the following qualifications: o Bachelor’s degree in nutrition or other health-related field or o A minimum of two years of WIC experience or other relevant healthcare experience and a minimum completion of at least three* of the following accredited health-related courses:  Intro to Nutrition or Nutrition Basics  Community or Public Health Nutrition  Health Education or Health Sciences  Lifecycle Nutrition  Nutrition Assessment or Diet Assessment & Planning  Nutrition or Health Counseling, or Health Communication *Certified lactation coursework (i.e. CBS or CLC) will be credited towards • Screens for program eligibility; assesses and documents a participant’s nutrition risk(s), provides nutrition and breastfeeding education to low-risk participants, identifies the need for individual care plans, refers participants to other health and social services and provides appropriate follow-up referrals. • Responds to participant inquiries, answers phone and emails, schedules appointments. • Conducts individual and/or group nutrition education appointments. • Participates in professional development activities.

DC WIC POLICY & PROCEDURE MANUAL

4.002 4 | P a g e Nutrition Position Title Qualifications Roles and Responsibilities the minimum coursework completion.

• Customer service and computer skills preferred. • Completion of a competency-based training program from the State Agency. Qualified Nutritionist; Competent Professional Authority (CPA) • Bachelor’s or Master’s degree in dietetics, nutrition, or nutritional science or physician, physician assistant (PA) or registered nurse (RN); or State Agency- approved health official.lIC • Licensed Dietitian or Nutritionist (LD or LDN) in the District of Columbia required. • Registered Dietitian (RD/RDN)* or Certified Nutrition Specialist (CNS) required. *RD registration-eligible candidates may qualify only with verified exam eligibility status. Continued employment is contingent on passing the RD exam and obtaining DC licensure within 6 months of hire. Failure to meet these requirements will result in demotion or separation from employment. • Completion of a competency-based training program from the State Agency on performing duties of CPA. • Screens for program eligibility; assesses and documents a participant’s nutrition risk(s), identifies the need for individual care plans, refers participants to other health and social services and provides appropriate follow-up referrals. • Provides nutrition and breastfeeding education to participants identified as high-risk; implements individual care plans and conducts follow-up to monitor/evaluate health outcomes and need for additional services. • Reviews requests for special formulas and WIC-eligible nutritionals; coordinates care with participant’s health care team, as appropriate • Conducts individual and/or group nutrition education appointments. • Participates in professional development activities. • May assist in the planning and coordination of the Local Agency Nutrition Services Plan. • May assist in training of local agency staff; performing staff observations, and/or reviewing program metrics to assist in the development of the Local Agency Nutrition Services Plan

DC WIC POLICY & PROCEDURE MANUAL

4.002 5 | P a g e Breastfeeding Position Title Qualifications Roles and Responsibilities Local Agency Breastfeeding Coordinator • Meets minimum qualifications of a CPA or DBE • Minimum 1 year experience counseling breastfeeding participants. • CLC or IBCLC preferred. • At minimum, completes WIC Breastfeeding Curriculum levels 1-4 • Coordinates with the LAD and NC breastfeeding promotion and support activities for the local agency and community partners. • Conducts QA/QI activities related to breastfeeding promotion and support in the local agency. • Ensures local agency staff are trained and kept up to date on breastfeeding education and promotion; ensures staff provide breastfeeding support within scope of practice. • Provides supervision to breastfeeding peer counselors (BFPCs) • Ensures that breast pump issuance, inventory, and maintenance are logged and monitored. • Reports on BFPC program activities to LAD and the State Agency • Participates in professional development activities. • May serve as the local agency’s designated breastfeeding expert (DBE) if qualified according to the DBE requirements. Breastfeeding Peer Counselor (BFPC) • Has personal experience with breastfeeding, having breastfed at least one baby. • Ideally is a paraprofessional (without extended professional training in health, nutrition, or clinical management of breastfeeding) who shares characteristics found in the WIC population served at the local agency. • Completion of competency-based training and WIC Breastfeeding Curriculum levels 1-2. • Provides mother-to-mother support to prenatal and postpartum WIC mothers by providing basic BF information and encouragement. • Is available to participants outside of usual clinic hours and the WIC clinic environment. • Follows issuance guidelines of breastfeeding aids in accordance with DC WIC policy 2.013 Breastfeeding Aids and Accessories. • Counsels prenatal and postpartum participants by telephone as well as face-to-face visits at the home, hospital, and/or WIC clinic at regularly scheduled intervals. • Refers participants to the WIC DBE, CPA, or other appropriate health or social service agency, including outside community breastfeeding resources, for situations outside the peer counselor’s scope of practice. • Participates in professional development activities.

DC WIC POLICY & PROCEDURE MANUAL

4.002 6 | P a g e Breastfeeding Position Title Qualifications Roles and Responsibilities Designated Breastfeeding Expert (DBE) • Meets minimum qualifications of CPA or has completed a minimum of 8 college courses in health sciences (will require State-Agency approval). • CLC or IBCLC strongly preferred. • At least 1 year experience counseling breastfeeding participants. • Completion of USDA WIC Breastfeeding Curriculum levels 1-4. • Assists breastfeeding participants with complex breastfeeding challenges. • Provides follow-up support to breastfeeding participants. • Documents breastfeeding support in the participant’s record; coordinates with health care team of participant, as warranted; provides and documents appropriate referrals for participants. • Participates in professional development activities. • May serve as a breastfeeding resource and mentor for local agency staff. • May provide breastfeeding training for local agency staff. • May participate in breastfeeding activities in the community.

Administrative Support Position Title Qualifications Roles and Responsibilities Nutrition Education Technician (NET) /Administrative Clerk • High school diploma or GED • Demonstrated customer service, time management, and computer skills. • At least 6 months of experience in a community health setting preferred. • Bilingual preferred. • Screens for program eligibility. • Greets and receives new program applicants; answers telephone, responds to email requests, schedules appointments. • Responds to participant inquiries, provides referrals for participants; documents according to establish DC WIC and the Local Agency policy and procedures. • Conducts secondary nutrition activities in accordance with DC WIC policy 2.007 Nutrition Education Choice. • Participates in professional development activities.

4.003 - 1 Organization and Management

Revised June 2019 IX. Organization and Management – Time Study

PROCEDURE 4.003 Implementing Office: Community Health Administration Revised July 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 7/26/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.11 – Nutrition Education CFR § 246.14 –Program Costs (1)

III. Applicability DC WIC State and Local agencies. IV. Policy Statement 1. Federal regulations require that time studies be conducted to document the amount of time each staff devotes to nutrition education, breastfeeding, program management , and client services in their time allocated to WIC. 2. The time study must be conducted for a one (1) month period per calendar quarter. All persons who perform WIC functions, including students, volunteers and WIC staff (paid and in-kind), should complete the time study.

V. Definitions & Acronyms  Nutrition Education means individual or group education sessions and the provision of information and education materials designed to improve health status, achieve positive change in dietary habits, and emphasize relationships between nutrition and health, all in keeping with the individual’s personal, cultural, and socio-economic preferences.  Program Management means oversight of activities within the clinic to ensure program success including providing certification assessments, scheduling appointments, monitoring training and reports, etc  Client Services means any interactions with Program participants including administrative activities (answering phones, issuing food benefit checks, pulling and filing charts, etc) and taking participants anthropometric / biochemical measurements.  Breastfeeding means time spent performing breastfeeding promotion and support activities including providing counseling to breastfeeding mothers, and documenting breastfeeding contacts in CARES, etc.

For more detailed descriptions of activities per each staff functional category, see appendix 4.003B Category Descriptions.

4.003 - 2 Organization and Management

Revised June 2019 VI. Procedures for Conducting a Time Study 1. Receive a memorandum from State Agency with details regarding the time study 2. Refer to appendix 4.003A- Local Agency Time and Effort Form (excel sheet). Follow instructions for completing the various worksheets that are to be submitted to the State Agency. A Category description (Appendix 4.003B) is provided to describe categories of duties. 3. Use the Time Study Worksheet Tab in 4.003A to conduct the time study for the one-month period per quarter. The month that will be tested from each quarter will be randomly assigned by the State Agency each fiscal year. 4. Complete the Time Study Worksheet tab for all persons who perform WIC functions, including students, volunteers and WIC staff. Each person must complete a worksheet for a one-month period to fulfill the time study requirements. 5. Local Agency Directors or a designated authority must complete the Local Agency Site Summary and the Local Agency Summary Sheet tabs . 6. Submit first, second, third and fourth quarter time studies on January 15, April 15, July 15 and October 15 of each fiscal year.

VII. Appendix

4.003A Local Agency Time and Effort Form (excel document) 4.003B Category Description of Tasks 4.003C Time Study Instructions pdf

VIII. Reference N/A

DC WIC POLICY & PROCEDURE MANUAL

Policy 4.004 1 | P a g e Title: Staff Training Category: Nutrition Services Staffing CFR Reference: 7 CFR 246.11(c)(2) and 246.11(c)(7) Policy Number 4.004 Effective Date Revised Date 8/15/23 POLICY STATEMENT The State and Local Agency provide all staff initial and ongoing training specific to their job roles and responsibilities in accordance with DC WIC policy 4.002 Position Descriptions. All DC WIC staff must attend the State Agency New Employee Training within the first 6 months of hire. PROCEDURE 1. The State Agency recommends that the Local Agency designates a Local Agency Trainer to assist in overseeing staff training activities including new employee onboarding, identifying staff training needs, and conducting training sessions at the Local Agency in-service meetings. 2. The Local Agency ensures timely completion of all new employee training materials as provided by the State Agency. Each staff member must receive task-specific training as in accordance with DC WIC policy 4.002 Position Descriptions. 3. The Local Agency ensures all new staff attend the State Agency New Employee Training within the first 6 months of hire. Prior to attending State Agency New Employee Training staff must: a. Have worked at the Local Agency for a minimum of 6 weeks. b. Completed all required training and observation logs as provided by the State Agency. 4. The State Agency conducts quarterly all-staff meetings to provide program updates, professional development, and ongoing technical assistance. All staff are strongly encouraged to attend. If staff are unable to attend the quarterly meetings, it is the responsibility of the Local Agency to ensure that the staff member receives all updates and performs their job in accordance with the most recent program directives. The State Agency reserves the right to change the schedule of training according to Program needs. 5. The State Agency will provide ongoing breastfeeding technical assistance to Local Agency staff. The Local Agency is responsible for ensuring the appropriate staff attend these meetings and perform their job in accordance with the most recent State Agency requirements. REFERENCES 7 CFR 246.11(c)(2) 7 CFR 246.11(c)(7) FNS WIC Nutrition Service Standard # 5 DC WIC policy 4.002 ATTACHMENTS & FORMS New Employee Online Training Guide New Employee Competency Checklist New Employee Observation Checklist New Employee Workbook

5.001 - 1 Nutrition Services + Admin

Revised August 2019 V. Nutrition Services & Administration (NSA) - Overview of Financial Management PROCEDURE 5.001 Implementing Office: Community Health Administration (CHA) Revised: July 2019 Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 11/23/2015

I. Authority USDA

II. Reason for the Policy CFR § 246.16(d) Distribution of funds to local agencies

III. Applicability DC WIC State and Local Agencies IV. Policy Statement Financial Management of the District of Columbia’s WIC Program shall ensure that all local agencies develop and implement a financial management system consistent with requirements prescribed by FNS and the State Agency pursuant to the requirements of this section. The regulations, circulars and policies that govern operations of the WIC state and local agencies are: 1. Federal a) Federal Register 7 CFR Part 246 WIC Program Consolidated Regulations

b) 2 CFR 200 Uniform Administrative Requirement, Cost Principals, and Audit Requirements for Federal Awards

c) FNS Memo SFP 10-017, Updated Prior Approval Guidance 2. District a) Local Agency Policy and Procedure Manual b) WIC Conditions of Grant Award c) WIC and Breastfeeding Peer Counselor Budget Package All of the above referenced federal and state regulations are available on-line and should be on file at the local agency. The WIC Conditions of Grant Award and the WIC and Breastfeeding Peer Counselor (BPC) Budget Package and WIC Budget Instructions are revised annually. These updated files are issued as attachments to the annual local agency grant award letter.

5.001 - 2 Nutrition Services + Admin

Revised August 2019 The applicable regulations and policies should be consulted whenever a question is raised concerning allowable costs or procedures. If further clarification is needed, the DC WIC State Agency should be contacted. If necessary, the appropriate federal or state authority will be contacted for explanation or clarification.

V. Definitions & Acronyms Breastfeeding Peer Counselor (BPC) VI. Procedures 1. Accountability / Program Costs

a. General

Each WIC local agency must maintain an accounting system and separate records relating to the WIC grant which conform to all state and federal regulations as well as generally accepted accounting principles. Any expenditure charged to a WIC grant must be traceable to source documentation.

Federal regulations require that records be retained for at least three years from the filing of the final closeout report as outlined in section B.3 of this policy. USDA has the option of requiring a longer record retention period if it is felt to be justified, or if any of those conditions specified in Section 246.25 (a) (2) of the federal regulations exist.

WIC funds are divided into two broad categories: Food funds and Nutrition Services and Administration (NSA) funds. Local agencies are not awarded Food funds. NSA funds are further subdivided into the following cost categories i. Certification ii. Nutrition Education iii. Breastfeeding Promotion and Support iv. Breastfeeding Peer Counselor Support v. Program Operations Separate accumulation of costs under each of these categories must be maintained. The WIC local agency shall not have expenditures that exceed the award for the current fiscal year. Expenditures in excess of the current fiscal year award will be disallowed and not reimbursed by the Program.

5.001 - 3 Nutrition Services + Admin

Revised August 2019 b. Nutrition Education and Breastfeeding Spending Requirement At least 20% of NSA funds expended by each local agency must be for nutrition education. In addition, at least 5% of NSA funds expended by each local agency must be for breastfeeding promotion and support. c. Time Studies Local agencies are required to perform time studies during the first month of each quarter of the State Fiscal Year (July, October, January and April) or on a daily basis under certain circumstances. See Policy and Procedure 4.03 (Time Study Requirements for Staff Paid with WIC or BPC Funds) for further guidance. Salary and fringe cost expenditures for each quarter are allocated to the appropriate cost category based on the time study percentages. d. Other Costs Costs other than those for nutrition education and breastfeeding promotion and support must be allocated to the appropriate cost category on the monthly/quarterly expenditure report. Indirect costs are those costs incurred for a common purpose benefiting more than one program and not readily assignable to the program benefited. The WIC Program limits indirect costs to a specified percentage of actual expenditures for eligible salary line items (not including fringe benefits). This is further explained in the WIC Budget Instructions that are included with the annual local agency grant award letter. e. Inventory Records Local agencies are required to maintain equipment inventory records for all equipment items that are purchased with WIC grant funds. These records should allow easy identification of each item and its location. f. Items Requiring Specific WIC State Agency or USDA Approval Items purchased using WIC Program funds after the original budget was approved must be approved in writing by the State WIC Financial Officer. All requests are to be submitted via email. It is the responsibility of the Local Agency to retain approvals for recordkeeping purposes. • Purchases Over $1,000.00: Written approval for purchases of sensitive equipment costing $1,000.00 or more is required by the State WIC Financial Officer. Sensitive equipment includes capital or non-capital items such as all computer equipment such as laptops and notebook computers. Portable items such as tools, hand radios and cameras that are prone to theft and concealable in a handbag or briefcase are also considered sensitive items. Equipment items that are too large for concealment, such as typewriters and projectors, shall be considered sensitive items if there is a history

5.001 - 4 Nutrition Services + Admin

Revised August 2019 of loss or theft within a particular local agency. Firearms and other law enforcement type weapons are always considered sensitive regardless of acquisition cost. • Purchases Over $5,000: The USDA must be notified in writing by the State WIC Office of any automation services or equipment purchase totaling $5,000 to $99,999 within 60 days of the expenditure or contract execution. USDA approval is required prior to the purchase of any non- computer equipment item with a unit cost of $25,000 or greater. WIC State Office and USDA approval is required prior to the start of any capital improvement project (including repairs) if the total cost is $5,000 or greater. Refer to Policy and Procedure 5.002 (Administrative Costs) for instructions. • Travel: Expenses for travel, lodging, meals, conference fees, etc. for agency staff that work for both WIC and another program must be approved in advance by the local agency WIC Coordinator. Travel requests for the local agency WIC Coordinator that works for both WIC and another program must be approved in advance by their supervisor. • Incentive/Outreach Items: Prior written approval from the State WIC Financial Officer is required for the purchase of all incentive / outreach items if the unit cost exceeds $4.00. • Documentation: For the items that require approval, a copy of the approval from the State WIC Financial Officer must be maintained in the local agency files. When budget modifications are submitted, the approved items must be included in the modified budget. • Budget Line Item Revisions Any line item revision more than 10% above the original amount budgeted requires justification for the additional costs to be submitted with the budget revision , and requires prior approval from the State WIC Financial Officer. g. Audits In accordance with the provisions in Federal Register 2 CFR 200, all non-federal entities that expend $750,000 or more in a year in federal awards shall have a single or program-specific audit conducted for that year. WIC local agencies must submit a copy of the annual single audit report to the WIC State Office upon its completion. USDA and other Federal and State agencies reserve the right to audit a Local Agency's operations at any time.

5.001 - 5 Nutrition Services + Admin

Revised August 2019 h. Financial Review The DC WIC Program routinely performs Management Evaluations of local agencies. Prior to the start of the Management Evaluation, an electronic letter will be sent to the local agency fiscal staff and local agency director requesting that documentation be submitted. The requested documentation is to include, but is not limited to, cost allocation plans, proof of payment, records for costs reported to the WIC program, spending approvals and records for time studies. Documents should be submitted in electronic or paper form in the timeframe stated in the letter. Expenditures may be disallowed if supporting documentation cannot be provided. Disallowed expenditures are subject to repayment to the state WIC office. WIC funds shall not be used for the repayment of disallowed expenditures. During the Management Evaluation, the WIC financial management staff will schedule an on-site appointment with the local agency coordinator to perform a physical inventory of equipment. The on-site visit may also include a review of certain accounting records and procedures. Individual training sessions on WIC financial management policies, recordkeeping, reporting and time studies are provided to all new agency directors and fiscal officers. Additional training will be provided to any local agency staff upon request.

2. Funding, Caseload Assignments and Reporting Requirements a. WIC Grant Local agency NSA funding is awarded on a Federal fiscal year basis (Oct. 1st through Sept. 30th). Funding is awarded using the caseload assigned to each local agency, the rate per participant and base funding (based on caseload assignment). Funding rates may be adjusted annually and are subject to availability of funding. NSA Funding formula (per participant rate x caseload assignment) + Base Funding = FY Award b. Breastfeeding Peer Counselor (BPC) Funding Local agency BFPC funding is awarded on a Federal fiscal year basis (Oct. 1st through Sept. 30th). BFPC funding acceptance is voluntary for local agencies and is not required. BFPC awards are determined by using the estimated number of pregnant and breastfeeding women participants in each participating local agency and the rate per participant. Funding rates may be adjusted annually and are subject to availability of funding.

5.001 - 6 Nutrition Services + Admin

Revised August 2019 BPC Funding formula (per participant rate x estimated pregnant and breastfeeding women participants) = FY Award c. Caseload Assignments Local agency caseload assignments are determined each year in October for the Federal fiscal year starting October 1st. Assignments are based on participation from the previous year, special populations served, percent of target population being served, and any other relevant information that is available. Caseload assignments and actual participation are reviewed on a monthly basis. Caseload assignments are normally adjusted once during the year, if indicated, based on actual participation but may be adjusted more frequently at the discretion of the DC WIC State Agency. Local agencies are required to serve an average of at least 97% of their caseload assignment during the year. If a local agency does not meet this requirement, their caseload assignment may be reduced for the following year. d. Local Agency Budgets Local agencies should refer to the WIC Budget Instructions when preparing their annual budgets and budget modifications. Local agency budgets are due at the end of September each year. Budget modifications are usually limited to one per year which is due with the third quarter expenditure report. The DC WIC State Agency requires an agency Cost Allocation Plan for each budget line item that is a shared cost. The cost allocation sample format in attachment 5.007A (Budget Schedule) can be modified, as needed, to meet this requirement. e. Monthly/Quarterly Expenditure Reports The DC WIC State Agency requires the submission of expenditure reports on a monthly basis. The format for the monthly expenditure report is included in the WIC Budget Instructions and WIC Budget Package. Expenditure reports must be submitted electronically to the DC WIC State Agency through the Department of Health’s, Electronic Grants Management System (EGMS) within 30 days after the end of the preceding month being reported. If this deadline cannot be met, a request for an extension, with justification stating the reason for lateness, must be made to the State WIC Financial Officer or the WIC Program Manager in advance of the 30 day deadline. The WIC Financial Officer or the WIC Program Manager will approve or deny the request in writing f. Compliance 1) Adherence to all instructions and due dates listed in the WIC Program Budget Package is required to maintain compliance with the terms and conditions of the Federal Award. If found non- compliant, one or more of the following actions will be taken in accordance with the 2 CFR 200.338 Remedies for Noncompliance:

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Revised August 2019 i. Temporary withholding of cash payments pending correction of the deficiency by the non-Federal entity or more severe enforcement action by the Federal awarding agency;

ii. Disallowance of all or part of the cost of the activity or action not in compliance:

a. Costs determined unallowable will be charged back to the agency; b. Late submissions will have a portion of funding disallowed according to the following formula:

Disallowed Cost = (Total budgeted Indirect Cost ÷ number of business days in the fiscal year) × (number of business days past the assigned due date) × 15%. iii. Wholly or partly suspending or terminating the Federal award;

iv. Initiating suspension or debarment proceedings as authorized under 2 CFR part 180 and Federal awarding agency regulations;

v. Withholding further Federal awards for the project or program;

vi. Other remedies that may be legally available. g. Local Agency Payments Local Agency payments will be made upon receipt and verification of a monthly expenditure reports.

3. Record Retention Schedule Program records must be retained for at least three (3) years following the date of filing the final closeout report for the period to which the report pertains. For example, the closeout report for Federal Fiscal Year 2010 was filed at the end of September 2011. All records for FFY 2010 must be retained for a period of three (3) years after the filing date. The following dates indicate when program records may be destroyed for each of the applicable Federal Fiscal Years: Federal Fiscal Year Dates Records May Be Destroyed FFY 2015 (10/14 – 9/15) September 30, 2019 FFY 2016 (10/15 – 9/16) September 30, 2020 FFY 2017 (10/16 – 9/17) September 30, 2021 FFY 2018 (10/17 – 9/18) September 30, 2022 FFY 2019 (10/18 – 9/19) September 30, 2023

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Revised August 2019 FFY 2020 (10/19 – 9/20) September 30, 2024 FFY 2021 (10/20 – 9/21) September 30, 2025 An audit may extend the three (3) year requirement. If a particular Federal fiscal year has been audited and there are issues to be resolved, the program records must be retained until all issues have been resolved or until the end of the three (3) year period, whichever is later.

VII. Contacts

5.002 Administrative Costs VIII. Reference CFR § 246.13 (j) Local Agency Financial Management CFR § 246.14 (a)(1) Program Costs

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Revised July 2019 V. Nutrition Services and Administration (NSA) – Administrative Costs (General) PROCEDURE 5.002 Implementing Office: Community Health Administration (CHA) Revised July 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 04/12/2017

I. Authority USDA

II. Reason for the Policy CFR § 246.13(j) Local Agency Financial Management CFR § 246.14(a) Program Costs

III. Applicability DC WIC State Agency and DC WIC Local Agencies IV. Policy Statement The State agency shall maintain a financial management system, which provides accurate, current and complete disclosure of the financial status of the Program. This shall include an accounting for all property and other assets and all Program funds received and expended each fiscal year.

Allowable Administrative Costs 1. Direct Charges – Allowable administrative costs per personal compensation; personnel benefits; postage/shipping; travel expenses; equipment purchase and rental; communications and utilities; printing and reproduction; office supplies; building and facilities space rental; maintenance; outreach services; translators and interpreters; fair hearings; transportation and other expenses directly related to WIC activities. 2. Personnel – The cost of personnel time directly involved in WIC Program operation. Time sheets or a time study must be available to support the charge of employees who spend only a portion of their time on WIC. The time of personnel employed in general capacity, such as agency directors, manager, receptionists, etc., is not an allowable direct charge. 3. Travel – The cost of local agency staff, including transportation, lodging, subsistence, and related items incurred by employees due to WIC-related business. Use of WIC funds for local agency staff to attend meetings, workshops, or continuing education sessions directly related to WIC duties may be allowed when they fall within the definition of maternal and child health or provide for the professional development of staff.

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Revised July 2019 4. Equipment – All equipment including computer require State Agency approval as follows:

Non - computer equipment up to $24,999 a. Purchase or rental of equipment with a unit cost of up to $24,999 requires State Agency approval before the equipment can be purchased or rented. State Agency will respond within two (2) weeks. Non - computer equipment costing over $25,000 b. Major equipment or any other capital-related costs in excess of $25,000, must be submitted in writing to the State Agency. State Agency will respond within approximately six (6) weeks after receiving prior approval from FNS. Computer equipment up to $5,000 c. Purchase or rental of equipment with a unit cost of up to $5,000 requires State Agency approval before the equipment can be purchased or rented. State Agency will respond within two (2) weeks.

Computer equipment costing between $5,000 and $25,000 d. Major equipment or any other capital-related costs between $5,000 and $25,000 must be submitted in writing to the State Agency. State Agency will respond within approximately six (6) weeks after receiving prior approval from FNS. Guidance for equipment purchase is provided in FNS Handbook 901. e. Medical Equipment – Medical equipment purchase is limited to the following: Spectrophotometer, centrifuge and scale for measuring cell volume, scale (pediatric or adult), and measuring boards. Guidance for equipment purchase is provided in FNS Instruction 815-1, Purchase of Medical equipment 5. Equipment Documentation – Documentation of equipment purchase must be sent to the WIC Manager at the State Agency. 6. Program Incentive Items – Prior approval is required from the State Agency to purchase program incentive items. Program incentives may include promotion items given to applicant, potentially eligible persons, participants, or persons closely associated with the Program for outreach purposes to encourage program utilization and redemption. 7. Costs Associated with Childhood Immunizations – WIC participant immunization assessment, referral, education and caseload management are allowable WIC costs. The State Agency will obtain and distribute materials on immunization for clients. Local agencies with special needs must notify the State Agency for

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Revised July 2019 assistance in acquiring suitable educational materials. WIC funds cannot be used to purchase or administer vaccines. 8. Building and Facilities Space Rental – Space cost is allowable when supported by justification. 9. Expenses Shared Between WIC and Other Programs – Direct charges must be based on WIC’s actual expenses or an equitable prorata charge. Documentation outlining the procedure for charging costs allowable to WIC and other programs must be on file at the main site or readily available. 10. Audits Performed by Outside Agencies – Direct charges for audits are not allowable unless accepted by the State Agency as a replacement for the USDA- required audit. The State Agency requires prior written approval for such cost. 11. Management Studies Performed by Outside Agencies – The State Agency must obtain prior written approval from the Food and Nutrition Services (FNS) for management studies performed by agencies or departments other than the State or local agency, or those performed by outside consultants under contract with the State.

Unallowable Administrative Costs 1. Indirect Costs – Some items commonly included under indirect costs may be allowable if they are itemized as a direct cost. 2. Physician and Nurse Salaries – Costs associated with these professionals are not allowed unless the WIC Manager approves them. 3. Medical and Automated Data Processing (ADP) Equipment – Except as provided for in FNS Instruction 815-1.

V. Procedures The following process must be followed concerning requests of items and services relating to administrative costs:

Equipment 1. Submit a written request to the State Agency that includes: a. A description of the equipment; b. Justification of the need; c. At least two (2) bids (including sales tax, shipping and handling); and d. Equipment specifications that include information pertaining to the model, serial number, size, quantity, and any other enhancements that can be identified as appropriate. . 2. For non-computer equipment costing up to $24,999 and computer equipment costing up to $5,000 await written notification from the State Agency within two (2) weeks.

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Revised July 2019 3. For computer equipment costing over $25,000, await facilitation of approval from FNS. Upon FNS approval, the State Agency will provide a written notification within six (6) weeks.

4. Upon receipt of the equipment, send the following information to the WIC Program Manager: a. Description of the item(s); b. Cost; c. Date of acquisition; d. Manufacturer’s or other serial number; e. Source of the item; f. Use and location; and g. A copy of the bill of sale.

5. Label equipment with the inventory number.

6. Update the inventory report form and submit it to the State Agency with the monthly invoice.

Program Incentive Items 1. Complete the Incentive Approval Request Form in Appendix 5.002A. 2. Submit to the State Agency. 3. Allow two (2) weeks for review and response from State Agency.

Building and Facilities Space Rental

Submit a request to the State Agency with the following information: 1. Justification of need; 2. Name and address of lease-holder; 3. The location; 4. The number of square feet allocated to WIC; 5. The cost per square foot per year; 6. The total monthly and annual rent costs; 7. What the rental includes (utilities, maintenance, etc.); and 8. A statement that the space will be used for WIC Program purposes only. Audits Performed by Outside Agencies

Submit a request to the State Agency with the following:

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Revised July 2019 1. Scope of the audit; 2. Time period covered; 3. Cost allocation method to be used to distribute cost (when the audit covers other Programs); and 4. Certification to confirm the independence of the audit entity.

Management Studies Performed by Outside Agencies 1. Submit written request to the State Agency. 2. Upon receipt, the State Agency will review and determine if request is necessary and appropriate. 3. After the internal review, the State Agency will forward the request to FNS for review and response. 4. Await written notification from the State Agency.

VI. Appendix

5.002A Incentive Approval Request Form

VII. Reference N/A

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Revised July 2019 V. Nutrition Services and Administration (NSA) – Administrative Costs: Certification

PROCEDURE 5.003 Implementing Office: Community Health Administration (CHA) Revised July 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 04/11/207

I. Authority USDA

II. Reason for the Policy CFR § 246.14 (c)(2)(1-iv) – Specific Allowable Nutrition Services and Administration Costs

III. Applicability DC WIC State Agency and DC WIC Local Agencies IV. Policy Statement 1. The cost of Program certification, nutrition assessment and procedures and equipment used to determine nutritional risk, including the following: a. Laboratory fees incurred for up to two hematological tests for anemia per individual per certification period b. Expendable medical supplies c. Medical equipment used for taking anthropometrical measurements, such as scales, measuring boards, and skin fold calipers; and for blood analysis to detect anemia, such as spectrophotometers, hematofluorometers and centrifuges d. Salary and other costs for time spent on nutrition assessment and certification 2. Documentation of the cost per certification/re-certification is required based on a time study. The Local Agency is responsible for updating the clinic cost when a change occurs within the fiscal year.

3. Documentation, including the methods used to conduct the time study, of the charge for expendable medical supplies and personnel costs must be filed at the local agency

V. Procedures N/A

VI. Appendix N/A

5.003 - 2 NSA

Revised July 2019

VII. References 4.003 Time Study 4.003C Time Study Instructions and Forms

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Revised July 2019 V. Nutrition Services and Administration (NSA) – Outreach, Nutrition Education, and Breastfeeding Promotion Items

PROCEDURE 5.004 Implementing Office: Community Health Administration (CHA) Revised July 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 07/01/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.16(d) Distribution of funds to local agencies

III. Applicability DC WIC State Agency and DC WIC Local Agencies

IV. Policy Statement WIC Program outreach or promotional items refers to a class of goods, usually of a nominal value, that are given to applicants, participants, potential participants, or persons closely associated with the WIC Program (such as staff) for the specific program purposes of outreach, nutrition education, and breastfeeding promotion. The local agency shall determine whether an item meets the criteria for a specific program purpose as outlined below. They shall also give careful consideration to the public perception of program funds spent on items even when the connection to outreach, nutrition education, and breastfeeding promotion and support is clear.

V. Definitions & Acronyms Outreach means promotional efforts to encourage and increase participation in the WIC Program.

Nutrition Education means “individual or group education sessions and the provision of information and educational materials designed to improve health status, achieve positive change in dietary habits, and emphasize relationships between nutrition and health, all in keeping with the individual’s personal, cultural, and socio-economical preferences” (7 CFR 246.2).

Breastfeeding promotion means strategies, initiatives, and services to encourage and increase the initiation and support the duration of breastfeeding among WIC participants.

VI. Procedures 1. The local agency shall purchase and distribute outreach or promotional items according to procurement Policies and Procedures provided they meet the guidelines in one of the following categories:

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Revised July 2019 a. Outreach - Outreach efforts must be consistent with the goals of the WIC Program. Outreach may be a local or statewide effort, directed at increasing the number of participants at a local agency or reaching a group of potential participants who are unaware of the WIC Program or unsure how to access it. Program outreach items for outreach shall:

a. Contain a WIC specific message that targets the potentially eligible population; b. normally be seen in public; c. contain the USDA nondiscrimination statement on publications or other printed materials that include program information; d. have value as outreach devices that equal or outweigh other uses; e. include WIC contact information such as the state or local agency name, address and/or telephone number; f. constitute or show promise of an innovative or proven way of encouraging WIC participation; and g. be reasonable and necessary costs with a total cost per item of less than $4.00

If you are unsure if an item is allowable or if the cost per item exceeds $4.00, please contact the DC WIC Financial Manager before the item is purchased for their review and approval.

b. Nutrition Education c. Breastfeeding Promotion

2. Monitoring - Purchase of outreach items will be reviewed during the management evaluation process. If the State Agency determines through a review of the local agency’s reports, program or financial analysis, monitoring, or audits that an outreach or promotion item fails to meet the criteria outlined in this policy, or the purchase did not comply with procurement policies and procedures, a formal claim may be assessed against the local agency in accordance with & CFR 246.23 (a) (1).

VII. Examples of Allowable and Unallowable WIC Program Outreach or The determination of an allowable item is more dependent upon the context of an item’s use and the message it conveys than the item itself. Using the criteria listed in the preceding paragraphs for specific Program purposes, the following are some examples of allowable and unallowable program outreach or promotional items.

1. Examples of Some Allowable Items

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Revised July 2019 Promotional Items a. Outreach – T-shirts, buttons, diapers, bibs, toothbrushes, pens, cups or other items of nominal value with reasonable opportunity for public display that contain a WIC promotional message b. Nutrition education – books, calendars that contain important nutrition education messages, refrigerator magnets picturing the MyPlate, and sippy cups that are provided to mothers of infants who are learning how to drink from a cup as reinforcement of a relevant nutrition education c. Breastfeeding promotion and support – t-shirts, buttons or other items of nominal value with a breastfeeding promotion or support message printed on the item (e.g. “Breast Fed is Best Fed”)

2. Examples of Some Unallowable Items a. celebratory items or items designed primarily as staff morale boosters, generally for the personal use of the staff, with minimal public display b. items of nominal value which have no outreach, nutrition education, or breastfeeding message c. any program outreach item intended for persons who are not participants, potential participants or their parents/guardians, or for persons with no connection to the WIC Program, such as staff and cooperating agency representatives d. items not of nominal value such as diaper bags, infant slings, or ponchos (regardless of any outreach, nutrition education, or breastfeeding promotion messages). These items would not meet the “reasonable and necessary” test.

If you are unsure if an item is allowable or if the cost per item exceeds $4.00, please contact the DC WIC Financial Officer before the item is purchased for their review and approval.

VIII. WIC Program Staff and Outreach Items Recognizing that program staff travel throughout the general community and participate in various cooperative functions with the target WIC population or agencies that also service the WIC target population, it may occasionally be appropriate to provide some types of program incentive items to program staff. The items must present a WIC outreach, nutrition education or breastfeeding message and contain the local WIC agency name and contact information (telephone number or web site) as opposed, for example, to an agency logo and must be items that would be widely seen by the general population or the target population. Items whose exposure will likely be limited to the office surroundings of the staff members will generally not be allowable costs. Items purchased specifically for staff must meet the criteria above.

IX. Appendix

N/A X. Reference 5.005A Allowable Costs for Program Materials

5.005 - 1 NSA

Revised July 2019 V. NUTRITION SERVICES & ADMINISTRATION (NSA) – Allowable Costs for Program Support Materials

PROCEDURE 5.005 Implementing Office: Community Health Administration (CHA) Revised July 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 04/10/2017

I. Authority USDA

II. Reason for the Policy CFR § 246.16(d) Distribution of funds to local agencies

III. Applicability DC WIC State Agency and Local Agency Staff IV. Policy Statement USDA allows Nutrition Services and Administration (NSA) funds to be spent on incentive items and other goods and services that directly and indirectly support outreach, nutrition education, and breastfeeding. Program incentive items refer to a class of goods of nominal value that are given to applicants, participants, potential participants, and/or WIC staff persons for the purpose of outreach, nutrition education, or breastfeeding promotion. To be allowable, incentive items and other goods and services must be both necessary and reasonable for the proper administration of the WIC Program; that is, they are necessary to carry out essential Program functions, provide a benefit commensurate with the cost incurred, be consistent with the costs of similar items from other vendors, be a priority expenditure relative to other demands on available administrative resources, and have a proven or intuitive positive impact.

V. Procedures The following process must be followed by local agencies concerning claims for reimbursement:

1. Incentive items and other goods and services shall be intended primarily for participants or potential participants. Incentive items may not be given during a certification to participants’ family members who are not enrolled in the WIC Program. Incentive items can, on occasion, be provided to WIC staff provided they contain a WIC outreach, nutrition education or breastfeeding message and can be widely seen by the general or target population.

2. Local agencies shall follow these additional guidelines when purchasing program support materials:

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Revised July 2019

a. Outreach: Items shall be intended to encourage and increase participation in the WIC Program, contain a WIC-specific message that targets the potentially eligible population, normally be seen in public, include the WIC contact information such as the State or local agency name, address, and/or telephone number, and constitute an innovative or proven way to encourage WIC participation.

b. Nutrition Education, including Physical Activity: Items shall be targeted to participants and be distributed to the appropriate participant category in conjunction with a relevant nutrition education contact to reinforce nutrition and physical activity messages. Items shall include messages that link nutrition and physical activity and, where possible, use or adapt existing materials such as the MyPlate materials available through the DCWIC.org website.

Examples of allowed incentive items include: an infant weaning cup or infant spoon provided to the caregiver of an infant participant at the mid- certification visit; a wall calendar with important nutrition messages; a MyPlate refrigerator magnet; a water bottle or ball given to participants to promote physical activity.

c. Breastfeeding Promotion: There are two types of program support materials for breastfeeding—breastfeeding incentives and breastfeeding aids.

1) Breastfeeding incentives shall be targeted to participants and, when applicable, be distributed to the appropriate category of participant (for example, water bottles to pregnant or breastfeeding women or diaper wipe containers to breastfed infants). If a dual nutrition education and breastfeeding message is present, the incentive shall be provided at an appropriate time for the participants’ usefulness and in conjunction with relevant nutrition education.

2) Breastfeeding aids directly support the initiation or continuation of breastfeeding (for example, breast pumps or nursing pads). They cannot be provided to participants solely as an inducement to consider or continue breastfeeding, yet should be offered to breastfeeding participants based on established need.

d. Reading Readiness: Books may be provided to participants or potential participants as an incentive item. The DC WIC Program may purchase inexpensive books that contain clear, age-appropriate nutrition education or health promotion messages.

3. Local agencies shall describe how they use or plan to use incentive items in their Annual Nutrition Services Plan.

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Revised July 2019 VI. Appendix N/A

VII. Reference 5.008 Claims for Reimbursement

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Revised July 2019 V. Nutrition Services and Administration (NSA) – Claims for Reimbursement

PROCEDURE 5.008 Implementing Office: Community Health Administration (CHA) Revised July 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 08/23/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.16(d) Distribution of funds to local agencies

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement 1. The State Agency shall distribute the funds based on monthly claims submitted by the local agency. 2. The local agency must submit program expenditures through the Department of Health’s Electronic Grants Management System (EGMS). 3. When the invoice indicates equipment expenditures, the WIC Program Inventory Report must be included. 4. Expenditures must align with the approved annual budget. Actual reimbursement will not exceed the annual budget for approved WIC expenditures. 5. The State Agency shall offset the advances made against incoming claims as they are submitted to ensure that funding levels reflect the actual expenditures reported by the local agency. 6. If awarded, claims for special projects will be invoiced and tracked separately.

V. Procedures The following process must be followed by local agencies concerning claims for reimbursement:

1. Submit the WIC Program Invoice via EGMS, and the Quarterly Staffing Report on a quarterly basis. See Appendix 5.008A for the forms and instructions. 2. Attach copies of supporting documentation for all expenses. 3. Attach the WIC Program Inventory Report (See Policy and Procedure 5.011) if equipment has been purchased during that billing period. 4. Submit the complete package to the State Agency by the due date.

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Revised July 2019 5. Receive reimbursement check from the District of Columbia Department of Health. 6. On a quarterly basis, receive information from the State Agency on how the adjustment amount was derived.

VI. Appendix

5.008A WIC Program Invoice Form VII. Reference 5.011 Equipment Inventory Report

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Revised July 2019 V. Nutrition Services and Administration (NSA) - Equipment Inventory, Security and Disposal

PROCEDURE 5.011 Implementing Office: Community Health Administration Revised July 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 03/28/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.13(j) Local agency financial management

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement 1. The Local Agency shall maintain an equipment inventory of non-computer equipment items purchased with WIC Program funds. 2. The Local Agency shall complete the non-computer equipment inventory form whenever equipment is obtained. 3. The Local Agency must maintain all non-computer equipment inventory items in a secure manner. 4. The Local Agency shall notify the State Agency of any non-computer equipment that is stolen. 5. The Local Agency shall dispose of non-computer equipment that is broken, too costly to repair or obsolete.

NOTE: Local Agency shall follow Policy 3.003 for managing computer and multi-media equipment. V. Procedures The following process must be followed by local agencies concerning equipment inventory, security and disposal:

Non-computer Equipment Inventory: 1. Complete the WIC Program Inventory Report with all existing items purchased since the beginning of the local WIC Program. This report is submitted as part of the Local Agency Workplan and Quarterly Narrative Report (See Appendix 10.001C). 2. Update the inventory report as new items are purchased.

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Revised July 2019 3. Submit the updated inventory report to the State Agency with the Claims for Reimbursement (Policy and Procedure 5.008) for the month that the purchase was made. 4. Keep a copy on file at the Local Agency. 5. Make provision for verification of the inventory by State Agency staff during Local Agency site visits.

Non-computer Equipment Security: 1. Maintain equipment in a secure manner. 2. Notify the State Agency in writing when equipment has been stolen.

Non-computer Equipment Disposal: 1. Submit a request to dispose of equipment using the Equipment Disposal Report Form in Appendix 5.011B. 2. Send a copy to the State Agency for approval. 3. Receive written response from the State Agency within 14 business days. 4. Take action based on State Agency response.

VI. Appendix

5.011A Non-Computer WIC Program Inventory Report and Instructions 5.011B Equipment Disposal Report Form

VII. Reference 3.003 Equipment Inventory & Maintenance – WIC Information System 5.008 Claims for Reimbursement 10.001C Local Agency Workplan and Quarterly Narrative Report

7.001 - 1 Caseload Management

Revised August 2019 VII. Caseload Management – Appointment Scheduling, Overview and Definition

PROCEDURE 7.001 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.2 Definitions CFR § 246.7(f)(2) Timeframe for Processing Applicants

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement 1. The local agency shall begin the processing standards for providing services to applicants at the initial point of contact, that is, when the applicant visits or makes an oral or written request for benefits to any clinic. 2. The local agency staff must schedule assessment appointments according to Policy and Procedure 7.002-7.006 of this functional area. 3. The Local agency shall provide early morning and evening appointment hours at a minimum of 50% of its clinics, or all clinics if the local agency has two or less sites. 4. The local agency shall provide certification, re-certification appointments and check pick-up availability at all times during the hours of operation. 5. When there is sufficient staff, the local agency should stagger their individual lunch hours to ensure that coverage is provided for WIC services between the hours of 11:00am - 2:00pm. 6. The Local agency shall notify the State Agency of any changes in clinic hours and operations that affect appointment scheduling at least 14 days in advance of the effective date.

V. Caseload Management Definitions Local agency shall use the following definitions of caseload management terms: a. Accessibility – The ease with which WIC information and services can be obtained by the public. b. Appointment no-show rate – The number of persons who fail to keep a scheduled appointment for WIC services divided by the total number

7.001 - 2 Caseload Management

Revised August 2019 scheduled, multiplied by 100 and expressed as a percent (e.g., 10/30 = no show rate of 33%). c. Applicant – Anyone who contacts the local agency to request WIC benefits. d. Capacity – The optimum or maximum number of participants who can be served in a given setting and with a given staff configuration. e. Certification – Documentation of the eligibility of an applicant for WIC services using the specified criteria. f. Eligibility assessment – The review of categorical, residential, financial and nutrition/medical risk criteria to determine the eligibility of WIC applicants. g. Priority appointments – Appointments made within 10 calendar days of telephone or on-site request for pregnant and breastfeeding women, infants and children (potential Priority I-III), and migrant farm workers and their family members. See Policy and Procedure 8.002 Priority System for definitions of Priorities I-VI. h. Walk-in – A person who comes to the WIC clinic without an appointment or referral from a health professional and is assessed for WIC services on the same day. i. Reserved appointments – Time held to assess high-risk patients referred from clinics within health or medical center, hospital or outreach event

VI. Procedures The following process must be followed by local agency coordinators and supervisors concerning establishing caseload: 1. Ensure that all WIC employees understand the caseload management definitions. 2. Establish customer convenient early, evening, and Saturday hours for appointments at a minimum of 50% of all sites. If a Local Agency has two or fewer sites, all sites must establish customer convenient hours as indicted above. 3. Notify the State Agency of changes in clinic hours and operations that affect appointment scheduling at least 14 calendar days in advance of the effective date. 4. The State Agency must be informed as soon as possible whenever there are Local Agency site closures as the result of building maintenance issues (such as no air conditioning). Every attempt possible must be employed to alert participants who have scheduled appointments during the emergency closure of the site location. The WIC Local Agency Director can also coordinate with the State Agency IT Help Desk to generate a mass text message to alert participants of the closure and indicate the expected day/date of re-opening. Participants must be directed to a nearby WIC site during the closure of their regular WIC site.

VII. Appendix N/A

7.001 - 3 Caseload Management

Revised August 2019

VIII. Reference 7.002 Appointment Scheduling – Screening Applicants for Assessment Appointments 7.003 Appointment Scheduling – Minimum Number of Assessments 7.004 Appointment Scheduling by Priorities 7.005 Appointment Scheduling Sheet 7.006 Appointment Scheduling – Emergency Situations 8.002 Priority System

7.002 - 1 Caseload Management

Revised August 2019 VII. Caseload Management – Appointment Scheduling, Screening Applicants for Assessment Appointments

PROCEDURE 7.002 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date:01/01/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.7(f)(2) Timeframe for Processing Applicants III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement The State and local agencies shall use the standardized protocol for screening applicants seeking assessment appointments. See Appendix 7.002A “Script for Screening Applicants By Phone” for guidance on prescreening applicants.

V. Procedures Processing standards - Local Agencies shall process applicants within the following timeframes:

1. Timeframes begin when the individual visits the local agency during clinic hours to make an oral or written request for Program benefits. To ensure accurate records of such requests, local agencies shall record the applicant’s name, address and the date. The remainder of information necessary to determine eligibility shall be obtained by the time of certification. 2. When the local agency is not serving its maximum caseload, it shall accept applications, make eligibility determinations, notify applicants of decisions made and if applicants are to be enrolled, issue WIC food instruments, cash value vouchers or farmers’ market seasonal food instruments. 3. If not enrolled the day of the first visit, special nutritional risk applicants shall be notified of their eligibility or ineligibility within 10 days of the date of the first request for Program benefits. The State agency shall establish criteria for identifying categories of persons at special nutritional risk who require expedited services. 4. All other applicants shall be notified of their eligibility or ineligibility within 20 days of the date of the first request for Program benefits, if not enrolled during the first visit.

7.002 - 2 Caseload Management Revised August 2019 The following process must be followed by local agency staff when screening WIC applicants: 1. Determine residency in the District of Columbia. 2. Determine category (pregnant, breastfeeding or postpartum woman, infant or child) of potential applicant. 3. Determine financial status using adjunctive programs or current income guidelines. 4. Local agencies shall consider the income of the family during the past 12 months and the family's current rate of income to determine which indicator more accurately reflects the family's status. §246.7 (d)(2)(i) 5. Individuals conducting financial eligibility should check income table (appendix 8.006A) to verify if applicant is eligible for the program. 6. If deemed potentially eligible, make an assessment appointment and record the information in the appointment scheduling sheet. Inform the applicant what documents to bring and remind them to bring the child(ren) to be assessed. VII. Appendix 7.002A Script for Screening Applicants by Phone VIII. Reference 8.006A Income Guidelines

7.003 - 1 Caseload Management

Revised September 2019 VII. Caseload Management – Appointment Scheduling, Minimum Number of Appointments

PROCEDURE 7.003 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 07/28/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.7(f)(2) Timeframe for Processing Applicants

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement 1. Local agencies shall use the statewide show-rate to determine the minimum number of daily appointments. Appointments are defined as initial certifications, nutrition education/check pick-up, re-certifications, and medical updates. Each local agency shall calculate monthly show-rates. See chart listed in section V. Procedures. 2. The State agency shall review the show rate quarterly and make the necessary adjustments to reflect the rise and fall of the show-rate statewide. 3. Upon request, the State agency will provide the local agency with a print-out of the monthly summary of calls made, by the auto dialer voice messaging system. 4. The local agency should correlate the monthly enrollment average against the monthly closeout average to ascertain the utilization of the services rendered. 5. Assessment appointments shall be available eighty percent (80%) of the clinic opening hours. 6. Check pick-up/nutrition education appointments shall be available during one hundred percent (100%) of the clinic opening hours. 7. At least ninety percent (90%) of the daily, weekly, and monthly assessment appointments should be held for potential Priorities I, II and III applicants and participants: a. Whose current certification period will soon expire, b. Who call the clinic for an appointment, or c. Who visit the clinic for an appointment

7.003 - 2 Caseload Management

Revised September 2019 8. Appointments slots shall not be held for lower priorities. If, however, no appointments have been scheduled a week prior to Priority I, II and III applicants, an appointment can be given to any applicant regardless of potential priority.

V. Procedures

1) Local Agencies should refer to 4.003A to determine the number of CPA and CPPA’s that are needed to support their caseload 2) Local agencies must have adequate CPA coverage to cover the high-risk portion of their caseload 3) CPA’s should be assigned to sites with higher high-risk participation

Targeted Number of Clients to be Assessed Targeted Number of Clients to be Scheduled

Staffing Pattern*

Per Hour

Per Hour 1 CPA/CPPA – 1 Clerk 3 4 1 CPA/CPPA – 2 Clerks 5 6 2 CPA/CPPA – 2 Clerks 6 8 2 CPA/CPPA – 3 Clerks 8 10 3 CPA/CPPA – 3 Clerks 9 12 3 CPA/CPPA – 4 Clerks 12 16 VI. Appendix

N/A VII. Reference 4.001A – Staffing Requirements and Salary Ranges

7.004 - 1 Caseload Management

Revised August 2019 VII. Caseload Management – Appointment Scheduling by Priorities

PROCEDURE 7.004 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date:

I. Authority USDA

II. Reason for the Policy CFR § 246.7(f)(2) Timeframe for Processing Applicants

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement New Assessment Appointments:

a. New pregnant and breastfeeding women, and infants and children who are potentially Priority I - III, or members of migrant households are to be given priority for WIC assessment appointments. Appointments for these priorities must be made available for these individuals within 10 calendar days of telephone or on-site requests.

b. Applicants who are not potential Priority I, II, or III are to be scheduled for an eligibility assessment appointment within 20 calendar days of telephone or on- site requests. These appointments are to be scheduled in priority order.

Subsequent Assessment Appointments:

a. Participants must receive at least 15 days advance notification of the end of their certification period.

b. Participants must be scheduled for subsequent assessment appointment within 30-days before or after the end of their current certification period based on priority (See letters “c” and “d” below).

c. The WIC clinic must designate sufficient appointment slots for women and children expected to fall within Priorities I, II, or III for subsequent assessment appointments.

d. Priorities I, II, and III participants will be scheduled for subsequent assessment appointments before the end of the current certification period.

7.004 - 2 Caseload Management

Revised August 2019

e. Priority IV - VI participants, with the exception of Priority IV pregnant women who plan to breastfeed their infants, will not be scheduled for subsequent assessment appointments before the end of the current certification period, but must be informed to call for an assessment appointment at or near the end of the certification period.

V. Procedure for new assessment appointments The following procedure should be followed when scheduling new assessment appointments:

1. Schedule potential Priority I, II, and III applicants within 10 days of initial request or earlier.

2. Schedule potential Priority IV, V, and VI applicants within 20 days of request or earlier.

If appointment cannot be made within 20 days of initial request, start a wait list. See Policy and Procedure 7.007-7.009 for instructions on starting a wait list.

VI. Procedure for Subsequent Assessment Appointments The following procedure should be followed when scheduling new assessment appointments:

1. At the last check pick-up before the certification period ends, or at least 15 days before the end of the current certification period, inform the participant or authorized representative verbally when the current certification period will expire.

2. Automatically schedule the following participants for subsequent assessment appointments: Priority I, II, and IV pregnant women who plan to breastfed their infants; Priority I pregnant women whose current risk criteria would place them in Priority III postpartum; Priority I and II infants; and Priority III children. Give a Notice of Assessment Appointment (See Appendix 7.004A).

3. Use the following document Check Pick-Up Report to identify potential Priority I, II, and III participants for subsequent assessment appointments.

4. Record appointments in the appointment scheduler and give a written appointment notice to the participants.

5. Inform participants in Priorities IV-VI to call for a subsequent assessment appointment at least two weeks before the end of their certification period.

VII. Appendix 7.004A Notice of Assessment Appointment

7.004 - 3 Caseload Management

Revised August 2019

VIII. Reference 7.007 Waiting List Overview 7.008 Non-Pre-Certified Waiting List 7.009 Pre-Certified Waiting Lists

7.006 - 1 Caseload Management

Revised August 2019 VII. Caseload Management – Appointment Scheduling, Emergency Situations

PROCEDURE 7.006 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.7 (f)(2) Timeframes for processing applicants

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement WIC staff shall provide services to clients who are unable to obtain certification and check issues services due to emergencies (e.g., inclement weather, clinic closings, and other emergencies). V. Procedures The following procedure should be followed by local agency staff concerning emergency situations: 1. Use open scheduling for missed assessments (initial and subsequent). Do not restrict assessments based on status. Set up blocks of time for the assessment. 2. Double appointments for a specified period to accommodate missed certifications and mid-certification assessments. 3. Implement special extended hours (e.g., early morning, evenings, shift schedules and Saturday hours). 4. Allow walk-ins for check pick-up and certification. The Local Agency can designate specific days and times for walk-ins. 5. In some cases, vouchers can be mailed. Voucher mailing will be handled on an individual basis. Contact the State Agency for approval. Explore overtime pay, shift schedules, or compensatory and flexible time options to comply with the extended hours policy. VI. Appendix

N/A VII. Reference N/A

7.007 - 1 Caseload Management

Revised August 2019 VII. Caseload Management – Wait List Overview

PROCEDURE 7.006 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.7 (f)(1) Waiting List

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement When the local agency is serving its maximum caseload, the local agency shall maintain a waiting list of individuals who visit the local agency to express interest in receiving Program benefits and who are likely to be served.

V. Procedures 1. The local agency shall maintain waiting lists of individuals who contact the local agency to express interest in receiving Program benefits when: a. There are no funds available to provide Program benefits, b. The agency has exceeded assigned caseload, or c. The agency or site has not yet achieved the assigned caseload, but is unable to provide individuals with appointments within 20 days of the date of request. 2. The waiting lists shall include the following: a. Name of the applicant, b. Date the applicant was placed on a waiting list, c. Address or phone number of the applicant and d. Status of the applicant (e.g., pregnant, breastfeeding, age of applicant) 3. The local agency shall notify individuals of their placement on a waiting list within 20 days after the initial contact. 4. The local agency shall use two types of waiting list: (a) Non-Pre-certified and (b) Pre-certified. Within each type of list, the local agency shall maintain separate sheets for the following three (3) statuses:

7.007 - 2 Caseload Management

Revised August 2019 a. Pregnant women, breastfeeding women and infants – potential Priorities I, II and III; b. Children – potential Priority III and V; and c. Non-breastfeeding, postpartum women – potential Priority VI. 5. The Non-Pre-certified Waiting List is the list of individuals who have contacted the local agency, but are unable to receive an assessment appointment because of a reason listed in 1a-c above. This is the main waiting list. See Policy and Procedure 7.008 for detailed information regarding the Non-Pre-certified Waiting List.

6. The Pre-certified Waiting List is the list of pregnant, breastfeeding and postpartum women, infants and children under five years of age who have been: (a) participants on the WIC Program during the last 6 months and whose Priority is not being served at that time, but have a valid certification or (b) participants who have been pre-certified for WIC for the first time, but unable to receive benefits due to one of the reasons listed in 1a-c above. See Policy and Procedure 7.009 for detailed information regarding the Pre-certified Waiting List.

VI. Appendix

N/A

VII. Reference 7.008 Non-Pre-Certified Waiting Lists 7.009 Pre-Certified Waiting Lists

7.008 - 1 Caseload Management

Revised August 2019 VII. Caseload Management – Non Pre-Certified Waiting Lists PROCEDURE 7.008 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.7(f)(1) Waiting lists

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement 1. The local agency shall start a Non-Pre-certified Waiting List for pregnant, breastfeeding, and postpartum non-breastfeeding women, infants and children under 5 years of age who contact the WIC clinic by phone or in person to request Program benefits. 2. The local agency shall use the CARES Applicant Prescreening data entry screen and the “Non-Pre-certified” Waiting List Form in Appendix 7.008B to maintain the waiting list. 3. Individuals on the Non-Pre-certified Waiting List must be transferred from one Non-Pre-certified Waiting List to another for the following status changes: a. Infant to child, b. Pregnant to non-breastfeeding postpartum women or c. Breastfeeding to non-breastfeeding postpartum woman. 4. Individuals on the Non-Pre-certified Waiting List must be removed for the following reasons: a. Categorical ineligibility: i. Child who has reached his/her 5th birthday, ii. A non-breastfeeding six (6) month postpartum woman, or iii. A woman who was breastfeeding and is no longer breastfeeding. b. The applicant no longer desires WIC benefits. c. The applicant failed to keep a confirmed assessment appointment without notification or good cause after being contacted by WIC staff.

7.008 - 2 Caseload Management

Revised August 2019 d. The applicant has been certified for WIC. e. Death of the applicant. f. The applicant has been pre-certified and placed on the appropriate Pre- Certified Waiting List. g. The applicant transferred to another “Non-Pre-certified” Waiting List.

5. The local agency shall review the Non-Pre-certified Waiting List to determine if persons should be removed for any of the reasons listed above (No. 4a-g) on a monthly basis.

V. Procedures The following procedures must be followed by local agency staff concerning utilization of the Non-Pre-certified Waiting List: 1. Complete the Non-Pre-Certified Waiting List Form. See Appendices 7.008B and 7.008A for form and instructions. To manage the Waiting List of Applicants in the CARES system refers to chapter twelve in the Service Site WIC Training Manual. 2. Transferring Between Non-Pre-certified Waiting Lists a. Review the Non-Pre-certified Waiting List to determine if the status of any applicant has changed, i.e., infant to child, pregnant to non-breastfeeding postpartum women, breastfeeding postpartum women to non- breastfeeding postpartum woman. b. Determine which Non-Pre-certified Waiting List the person should be placed on based on the new potential priority of the person and enter the Action Taken on the original Non-Pre-certified Waiting List Form in Field 11. c. Record all the information from the original waiting list onto the appropriate new Non-Pre-certified Waiting List. 3. Removing Individuals from the Non-Pre-certified Waiting List i. Review the Non-Pre-certified Waiting List to determine person(s) to be removed. ii. Send the applicant a Notice of Removal from the Waiting List at least 15 days prior to removal. See Appendix 7.008C for a copy of the notice. Place a copy of the notice in a “Removal from the Non-Pre-certified Waiting List” file. iii. Complete Field 11: Action Taken and Date on the Non-Pre-certified Waiting List as follows: i. Action Taken. Use the codes at the bottom of the form and indicate the reason for removing the applicant from the waiting list, and

7.008 - 3 Caseload Management

Revised August 2019 ii. Date Action Taken. Record the date that the applicant was notified of removal from the waiting list. 4. Removing Individuals from the Non-Pre-certified Waiting List

a. Begin this function with one of the following screens displayed: i. Participant List ii. Participant Folder iii. Participant Certification b. Click the Wait List toolbar button. The Manage Waiting List screen will display. c. Select an applicant to remove in the Waiting List table. d. Click Remove from Waiting List to remove the applicant from the Waiting List. A confirmation message displays confirming your request. e. Click, Yes to confirm the removal of the applicant from the Waiting List.

VI. Appendix

7.008A Instructions for Completing the Non-Pre-Certified Waiting List 7.008B Non-Pre-Certified Waiting List Form 7.008C Notice of Removal from the Waiting List

VII. Reference N/A

7.009 - 1 Caseload Management

Revised August 2019 VII. Caseload Management – Pre- Certified Waiting Lists

PROCEDURE 7.009 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.7 (f)(1) Waiting Lists

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement When the local agency is serving its maximum caseload, the local agency shall maintain a waiting list of individuals who visit the local agency to express interest in receiving Program benefits and who are likely to be served.

V. Pre- certified Waiting List 1. The local agency shall implement a Pre-certified Waiting List when a waiting list is in effect and upon the request or inquiry of an applicant. 2. Pregnant, breastfeeding and postpartum women, infants and children under five years of age who have been (a) participants on the WIC Program during the last six (6) months whose Priority is not being served at this time, or (b) have been pre-certified for WIC (for the first time). 3. Applicants who have a valid Verification of Certification (VOC) card shall be placed on the Pre-certified Waiting List when no space is available on the Program. 4. The local agency must notify Priority I VOC applicants of vacant slots before any other person on the Pre-certified Waiting List. 5. The local agency shall place the applicant on the Non-Pre-certified Waiting List if the certification period expires before removal/transfer from the Pre-certified Waiting List. 6. The local agency shall use the “Pre-certified” Waiting List Form in Appendix 7.009B to maintain the waiting list. 7. The local agency shall transfer individuals from one Pre-certified Waiting List to another for the following status changes: a. Infant to Child, b. Pregnant to non-breastfeeding postpartum woman, or c. Breastfeeding to non-breastfeeding postpartum woman

7.009 - 2 Caseload Management

Revised August 2019

8. The local agency shall remove individuals from the Pre-certified Waiting List for the following reasons: a. Categorically Ineligible i. A child who has reached his/her 5th birthday, ii. A non-breastfeeding six (6) month postpartum woman or, iii. A woman who is not breastfeeding b. The applicant no longer desires WIC benefits c. The applicant failed to keep a confirmed assessment appointment without notification or good cause after being contacted by WIC staff d. The applicant has been certified for WIC (transfer) e. Death of the applicant f. The applicant has been on the Pre-certified Waiting List for longer than six (6) months and the pre-certification has expired

VI. Procedure for Completing the Pre- Certified Waiting List The following procedure must be followed when completing the Pre-certified waiting list: 1. Complete the Pre-certified Waiting List form. See Appendix 7.009A and 7.009B for instructions and form.

VII. Procedure to Pre-Certify an Applicant

The following procedure must be followed to pre-certify an applicant: 1. Determine if the applicant or participant is a DC resident. 2. Determine if the applicant or participant is income eligible. 3. Determine if the applicant or participant meets the medical/nutritional risk criteria established by the Program. 4. If the applicant meets all of the above criteria and their Priority category is no longer being served, add their name and all other information to the appropriate Pre-certified Waiting List. See Appendix 7.009A for instructions on completing the Pre-Certified Waiting List. 5. If the applicant is ineligible based on the above criteria, give the applicant a Notice of Ineligibility. Enter the appropriate code on the waiting list. 6. When the above steps (a-d) are completed, record the information on the WIC Certification Form or turnaround document. 7. Place all Certification Forms for the Pre-certified Waiting List in the holding file which is a separate file kept for pre-certified persons.

7.009 - 3 Caseload Management

Revised August 2019 VIII. Procedure for Transferring between Pre-Certified Waiting Lists The following procedure must be followed when transferring applicants between Pre-certified waiting lists: 1. Review the Pre-certified Waiting List on a monthly basis to determine if the status of any applicant has changed. 2. Determine which Pre-Certified Waiting List the person should be placed on based on the new potential priority. Enter the transfer code (see codes at the bottom of the form) in Field 9 on the original Waiting List. 3. Record all the information from the original waiting list onto the appropriate new Pre-certified Waiting List.

IX. Procedure for Removing Individuals from the Pre-Certified Waiting List The following procedure must be followed when removing individuals from the Pre- certified waiting list: 1. Review the Pre-certified Waiting List on a monthly basis to determine if persons should be removed. 2. Send the applicant a Notice of Removal from the Waiting List within 15 days of removal. See Appendix 7.008C for a copy of the notice. Place a copy of the notice in the individual’s pre-certification file. Place the file in the inactive files. 3. Complete Field 9: Action Taken and Date as follows: a. Action Taken: Use the codes at the bottom of the for m and indicate the reason for removing the applicant from the waiting list. b. Date Action Taken: Record the date that the applicant was notified or removed from the waiting list.

X. Procedure for Transferring Applicants from the Pre-Certified Waiting List to Active Certification The following procedure must be followed when removing applicants from the Pre- certified waiting list to active certification: 1. Contact the pre-certified applicant and inform him/her of the availability of Program benefits. 2. Confirm an appointment time for the applicant to come in to sign the rights and obligations statement and to pick-up the first set of WIC vouchers. 3. Check that the date of pre-certification, which is the date of certification, has been entered on the Certification Form. 4. Issue WIC vouchers. 5. Complete Field 9: Action Taken and Date as follows: a. Action Taken: Use the codes at the bottom of the Pre-certified Waiting List and indicate the reason for removing the applicant from the waiting list. b. Date Action Taken: Record the date that the applicant was notified of removal from the waiting list for placement on the Program.

7.009 - 4 Caseload Management

Revised August 2019 XI. Appendix 7.009A Instructions for completing the Non-Pre-Certified Waiting List 7.009B Pre-Certified Waiting List Form

XII. Reference 7.008C Notice of Removal from Waiting List

7.010 - 1 Caseload Management

Revised August 2019 VII. Caseload Management – Outreach

PROCEDURE 7.010 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date:01/01/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.6 (b)(3) Agreements with local agencies/Provisions of agreement

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement 1. The local agency shall make available appropriate health services to participants and inform applicants of the health services that are available. 2. The local agency shall recruit and accept any potentially eligible person who meets the standards for eligibility and applies for WIC. 3. The local agency shall establish close collaborations within each of their respective facilities; pre-natal OB-GYN and pediatric clinics. At least two walk-in appointment slots should be made available for each clinic (OB-GYN and pediatric) each day. WIC staff should provide the clinics with WIC outreach materials to attract potentially eligible persons. 4. The local agency shall establish close collaborations with one (1) child care center within their geographical proximity. During FY 2018 and 2019 the State Agency has established relationships with the following child care centers:  Apple Tree  KIPP  Bryia  La Clínica Del Pueblo  Rosemount  Centro Nia The State Agency can provide the contact persons and facilitate the initial stages of the collaboration.

7.010 - 2 Caseload Management

Revised August 2019 5. The local agency shall develop an outreach plan for each fiscal year with measurable goals, objectives, activities and methods. This plan shall be in accordance with the State Agency outreach goals and submitted as part of the local agency Annual Plan of Operations. 6. The local agency should also project its caseload each year based on their enrollment data; specifically targeting the category (women, infants, children) that have shown a steady decline. 7. The local agency shall project its caseload for each fiscal year based upon closeout participation from the previous fiscal year, and other demographic data. The projected caseload shall be submitted as part of the local agency Annual Plan of Operations.

V. Procedures 1. Using the Local Agency Workplan and Quarterly Narrative Report (see 10.001B), provide information on: a. Caseload projection for upcoming fiscal year using closeout data from previous fiscal year(s) and other demographic data b. Total population served c. Benefit targeting plan d. Develop an outreach plan with measurable goals, objectives and activities e. Perceived challenges f. Deviations from workplan 2. Submit these plans as part of the Local Agency Workplan to the State agency (see home 10.001 for reporting procedures). 3. Monitor and report progress, using the Status Report Form in Appendix 7.010D, on achieving outreach goals and attaining authorized caseload in the Quarterly Program Report (Appendix 10.001B) to the State Agency.

VI. Appendix

N/A VII. Reference 10.001 Reporting Procedures 10.001B Local Agency Workplan and Quarterly Narrative

7.011 - 1 Caseload Management

Revised August 2019 VII. Caseload Management – Performance Standards

PROCEDURE 7.011 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 06/13/2017

I. Authority USDA

II. Reason for the Policy CFR § 246.25 Records and Reports III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement 1. The local agency shall use these performance standards to manage all aspects of the caseload 2. The local agency shall report on the performance standards as indicated in Policy and Procedure 10.001

Performance Standards – Fiscal Year 2020 AREA STANDARD GOAL Priority I * 19.5% 30% Priority II * 12.8% 17% Priority III * 29.4% 40% Priority I – III * 61.7% 90% Utilization Rate 90% 95% Caseload Achievement 97% 100% Show Rate 75% 80% Nutrition Contacts (low risk) 2 percertification period 4 per certification period High Risk Secondary Contacts 2 per certification period 4 per certification period Breastfeeding (% increase) 1% 2%

7.011 - 2 Caseload Management

Revised August 2019

AVERAGE MONTHLY ENROLLMENT ATTAINMENT

GOAL 5 day week site 1,000 enrolled 4 day week site 800 enrolled 3 day week site 600 enrolled 2 day week site 400 enrolled 1 day week site 300 enrolled * Participation by Priority Report

Local agencies will be cited on their management evaluations and other monitoring reviews if standards are consistently not met.

VI. Procedures 1. Use performance standards to develop caseload management plan 2. Report on performance standards as indicated in Policy and Procedure 10.001

VII. Appendix

N/A VIII. Reference 10.001 Reports and Reporting Procedures

VIII. Certification December 2021 8.001-1 b. Health and Nutrition Assessment o Risk Code Identification o Nutrition Education and Goal Setting o Referrals c. Food Package d. Documentation

8.001 - Certification Overview CFR § 246.7(c) Eligibility Criteria and Basic Certification Procedure; CFR § 246.7(e) Nutritional risk; CFR § 246.7(f) Processing Standards; CFR § 246.7(g) Certification Periods; WIC Policy Memorandum#2016-5 Separation of Duties at WIC Local Agencies I. Policy Statement When funding permits, WIC Program benefits must be disseminated to low-income pregnant, postpartum, and breastfeeding women; infants, and children up to age 5 who exhibit nutritional or medical risks, and who meet the established income eligibility criteria. DC WIC local agencies must make WIC services available to any individual who meets the eligibility requirements and applies for participation. LAs must provide WIC services to participants at no cost or financial burden to the participant. Local Agencies shall not: a. Limit participation to those persons who participate in that local agency’s health services b. Require applicants to enroll in the local agency’s health care system c. Require participants to be currently receiving health care from a private physician or other health care provider All participants will be screened and certified using the Health and Nutrition Delivery System (HANDS) automated system. HANDS will automatically document the date of initial contact in the system. WIC staff are expected to input accurate information into HANDS. By entering and saving data in HANDS, WIC staff validate and confirm that what has been entered is accurate and truthful. LAs shall not give participant information to a third party unless a signed agreement has been established between the WIC State Agency and the party in question. Such agreements will be made with the approval of DC Health. Such agreements may only be between the WIC Program and agencies that serve the WIC-eligible population. Participant records may be released to the participant, or parent/legal guardian of a participant. If the participant or parent/legal guardian wishes to share information from WIC records with a third party, they may do so without involving the WIC LA. II. Components of the Certification

a. Intake / Eligibility Screening o Physical Presence o Identity Verification o Residency Verification o Income Verification o Categorical Eligibility o WIC Rules and Regulations / Participant Rights and Obligations

VIII. Certification December 2021 8.001-2 Discussion III. Separation of Duties In order to maintain the integrity of the WIC Program, adequate safeguards must be in place to prevent fraud and abuse. At minimum, the staff person who determines income eligibility and medical or nutritional risk cannot be the same person. Either person may issue food benefits. This policy ensures that one employee does not solely perform certification and issuance food benefits. In instances where adherence to this policy is not achievable, such as sites with only one staff member on duty, the LA WIC Director or Nutrition Coordinator must perform a supervisory review of all non- breastfeeding infant certification records (food packages that contain infant formula), and at least 20% of a random sample of the remaining certification records, within two (2) weeks of certification. It is recommended that staff rotate so that the same staff person is not the only person that is known to the satellite service site. Documentation of file reviews must be maintained at the LA for review during Management Evaluations. IV. Certification of WIC Staff and/or Family Members LA staff and/or their family members may apply for WIC benefits at a service site where they, or their family member, are employed. In these cases, additional Program integrity measures must be implemented. LA staff: a. Shall not conduct any aspect of the eligibility determination or certification process for immediate family members, or themselves b. Shall not certify immediate family members, or themselves c. Shall not issue food benefits to an immediate family member, or to themselves d. May not be an AAR for more than two individuals at any given WIC service site, either for immediate family members or non-related persons Failure to adhere to this policy will result in a serious offense, subject to the maximum sanctions allowed by Federal regulations.

V. Eligibility Determination LA Staff determine if the applicant meets each of the following eligibility criteria: a. Residence b. Income c. Category d. Nutrition Risk

Image 1. Visual Map of the WIC Certification Process

VIII. Certification December 2021 8.001-3 VI. Basic Certification Guidelines The following guidelines pertain to certification appointments. a. All certification data for each applicant certified shall be documented in the participant’s HANDS record. b. All applicants must be physically present. See Policy 8.003 – Physical Presence and Identification, for more information. c. Every applicant or caretaker shall be informed of the illegality of dual participation. d. Every applicant or caretaker shall read, or have read to them, the “Rights and Obligations” statement. See Policy 8.002 – Intake Guidelines, for more information. e. During the initial certification, each participant, parent, or caretaker shall receive an explanation of how the local food delivery system operates and shall be advised of the types of health services available, where they are located, how they may be obtained, and why they may be useful. f. LAs must obtain anthropometric measurements (height or length and weight), hematological tests (blood work), and dietary and medical information using the ABCDE process for VENA appointments. g. The CPA/CPPA must analyze the following to identify appropriate nutritional and/or medical risk factors to assign corresponding risk codes and priority: o Anthropometric data using appropriate growth or weight grids o Hematological test results o Other health and dietary information obtained through the VENA process h. The CPA/CPPA will provide basic nutrition education and referrals based upon the comprehensive VENA results and identified medical/nutritional risks. i. The CPA/CPPA will tailor the food package based on risks, nutritional needs, and participant preference. j. Participants shall be issued appropriate food benefits during initial certifications and subsequent visits, which they can use at DC WIC authorized vendors. Food benefits may be issued remotely. k. LAs shall allow a 30-day certification period for individuals who do not present the necessary proof of residency, identity, or income at the time of assessment. Therefore, 30 days of food benefits should be provided to the participant. If the participant has not submitted the required documentation within the 30 days provided, they shall be terminated. l. Applicants failing to provide verification of eligibility data within the 30-day grace period will be denied participation in the program. They may reapply as soon as they have the necessary documentation. m. LAs shall provide a 15-day written or oral notice of certification due date for the participant. n. LAs will schedule applicants/participants for appropriate follow-up appointment(s). o. LAs shall attempt to contact all applicants who miss appointments. Contact attempts shall be made only if they have agreed to receive communication from the WIC Program.

VIII. Certification December 2021 8.001-4 VII. Certification Timeframes A: Will be certified for: Pregnant Woman (PG) Up to six (6) weeks postpartum. A pregnant woman enrolled in WIC who has had an abortion, spontaneous (miscarriage) or therapeutic, is eligible to receive food benefits up to six (6) weeks past the date the pregnancy ended and can continue up to six (6) months from the date her pregnancy ended as a postpartum participant. A pregnant woman who would have been eligible for the program during her pregnancy, who has had an abortion, spontaneous (miscarriage) or therapeutic, can also apply for food benefits. She is eligible for a total of six months of food benefits from the date the pregnancy ended. Postpartum Woman (P) Up to six (6) months postpartum. Breastfeeding Woman Exclusively Nursing (EN) Partially Nursing (PN) Partially Nursing Plus (PN+) Up to the infant’s first birthday or until the woman ceases breastfeeding, whichever occurs first. A breastfeeding woman who requests, after the sixth month postpartum, more than the maximum amount of formula allowed for a mostly-breastfed infant will no longer receive supplemental foods, but will continue to count as a WIC participant receiving nutrition and breastfeeding education, support, and referrals. If a woman ceases to breastfeed prior to six months postpartum, she shall have her category changed to a postpartum woman. Staff shall update the Breastfeeding Surveillance screen and the postpartum woman shall be reassessed to identify Risk Codes. Infant (I) Approximately every six (6) months. LAs may certify an infant under six (6) months of age up to the last day of the month in which the infant turns one (1) year old, if the quality and accessibility of health care services are not diminished. Child (C) Approximately every six (6) months ending with the last day of the month in which a child reaches their fifth (5th) birthday. LAs may certify a child for a period of up to one (1) year, provided the LA ensures that the child receives the required health and nutrition assessments, as set forth in § 246.11(e)(3).

VIII. Certification December 2021 8.001-5 Special Conditions The certification period may be adjusted from the original ending certification date for several reasons. It can be shortened as much as needed or extended by 30 days. Some reasons for adjusting certification end dates include:

i. Difficulty in appointment scheduling or getting to the service site for certification due to extreme hardship, e.g., illness, imminent childbirth, inclement weather conditions, distance to travel, high cost of travel, or documented physical disability that prevents travel ii. Holiday schedules impacting service site operations or the participant’s ability to make it to the service site If the participant is found eligible to continue receiving program services, the new certification period begins on the date the participant is certified again and receives the first set of food benefits in the new certification period. VIII. Priority All participants will automatically be assigned a priority level, triggered by the risk codes assigned by the MIS system or manually assigned by the CPA/CPPA. The priority which indicates the greatest level of risk will be used to certify the applicant. A detailed list of DC WIC risk codes and their priorities are located on the Local Agencies page of the DC WIC website at dcwic.org. Priority levels are described below: Priority I Pregnant women, breastfeeding women, and infants at risk based upon hematological or anthropometric measurements, or other documented nutrition- related medical conditions. Women who are breastfeeding Priority I infants with risk other than 702, or infants breastfed by Priority I women with risk other than 601. Out-of-state VOC are priority 0, all VOC are Priority I if there is waiting list in effect. Priority II Infants up to 6 months of age whose mothers participated in WIC during pregnancy. Infants up to 6 months of age born to women who would have been WIC-eligible based upon hematological or anthropometric measurements or other documented nutrition-related medical conditions. Women who are breastfeeding a Priority II infant with risk other than 702, or breastfeeding women who are eligible due to inadequate dietary patterns. Priority III Children at risk based upon hematological or anthropometric measurements or other documented nutrition-related medical conditions. High-risk postpartum women. Priority IV Pregnant women, breastfeeding women, and infants at risk due to inadequate dietary patterns. Priority V Children at risk because of an inadequate dietary pattern. Priority VI Postpartum women at nutritional risk. Priority VII Individuals certified for WIC solely due to homelessness or migrancy. Previously certified participants who might regress in nutrition status without continued provision of supplemental foods.

NOTE: Regression may not be used for initial certification, may not be used for infants, and may not be used consecutively as a reason for subsequent certification. Regression can only be used twice in a five-year period.

VIII. Certification December 2021 8.001-6 IX. Service Timeframes Applicants who fall into identified categories must be informed of their eligibility, ineligibility, or placement on a waiting list within the following number of days following the date of their request for WIC services: 10 Days 20 Days Priority I pregnant women All other applicants Infants < 6 months of age Homeless Migrants

X. Waiting Lists The CPA/CPPA shall begin a waiting list after the LA has reached its maximum participation level by applying priority system described above to the LA’s wait list. Further restrictions of categorical eligibility beyond that permitted by this policy is not allowed. See policy 7.007 for more information on waiting lists. Visit Local Agencies, Policies & Forms at dcwic.org for the Waiting List Form. XI. Food Delivery Discussion At certification, LA staff shall discuss the food delivery system with the participant/AR in their preferred language. This discussion shall include the following:

i. Which foods are authorized for purchase with WIC food benefits ii. Encourage the participant to look for the ‘We Accept DC WIC’ decal when going to a vendor to use their eWIC card. If the participant would like to see the list of currently authorized vendors, they may view it on the “Locations - Vendors” section of www.dcwic.org, or the “Vendor Search” section of the EzWIC App. If the participant requests a printed version of the vendor list, staff shall provide a current printed list of vendor names, addresses, and phone numbers. iii. How to use their food benefits – see policy 9.001 for more information

Staff shall assess participants’ understanding of allowable WIC foods and the proper use of food benefits. For additional details regarding frequency of discussing the Food Delivery System requirements, refer to Policy 9.001.

XII. DC WIC Program eWIC Card Participants will be issued one eWIC card per family. Participants will select a 4-digit personal identification number (PIN). The eWIC card and PIN can be used at all DC WIC authorized vendors to access assigned food benefits. Refer to policy chapter IX. Food Delivery, for more information on eWIC cards. Note: If the family includes a foster child, please refer to Policy 8.008 - Eligibility and Certification for Special Cases, for additional details regarding issuance of eWIC cards to families with foster children.

VIII. Certification December 2021 8.001-7 XIII. Infant/Child with Safety Plan A family with a child may present with a safety plan. A safety plan is a written agreement that a social worker from the Child and Family Services Agency (CFSA) developed with the family which clearly describes the safety services that will be used to manage threats to a child’s safety for a temporary period of time. This child is not considered a foster child and shall be included in the family’s eligibility determination. Up to two months (60 days) of food benefits may be issued and eligibility shall be reassessed at the next appointment. The safety plan shall be scanned into the participant’s HANDS record. Note: After the safety plan expires, the participant may present as a foster child with a Notice to Provider or may return to a parent’s custody. If they return to a parent’s custody, documentation may not exist as the safety plan expires. See policy 8.008 for additional details. XIV. WIC Education, Rules and Regulations Education WIC staff will follow the Nutrition Education guidelines as outlined in the policies of Section II. Nutrition Services. This section includes: Program Education Requirements for Participants; Participant- Centered Nutrition Education for Participants; Nutrition Education Care Standards; and High-Risk Nutritionist Consults.

At each certification, participants will be informed of the WIC Rules and Regulations, which include:

• The duration of the Certification period • The participant is qualified due to income, category, and nutrition risk • Option to register to vote • An explanation of the food package and how these foods can improve their health status • Food Benefits, VOC, and eWIC card security • Option to report problems with a DC WIC authorized vendor, WIC participant, WIC employee, or WIC fraud by calling: 202-442-9397, emailing info.vendor@dc.gov, or completing the online form at www.dcwic.org/contact-us • Participants/ARs will keep scheduled appointments or notify LA staff if unable to do so • Verification of marks if the applicant cannot write his or her name (See Appendix A)

XV. Referrals Documentation of referrals shall be performed at every certification by selecting the “referred” status for mandatory referrals (generated by the mandatory referral list) in the Referral section of the Care Plan screen in HANDS. By documenting “referred,” staff confirm that they have discussed referral programs with the participant or AR.

Refer to Policy 8.018 - Referrals Overview, and 8.020 - Substance Use Screening, Education, and Referrals for additional details regarding required referrals.

VIII. Certification December 2021 8.001-8 XVI. Release of Information

An applicant or participant requesting for information to be sent to a third party or organization (e.g., a doctor or a health maintenance organization) shall sign a release form. The release form shall not be signed until the Certification process is completed and the applicant has been informed of their eligibility determination.

Refer to Section 12 of the Local Agency Policy & Procedure Manual for more information on releasing WIC client information.

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.002 1 | P a g e

Title: Separation of Duties Category: Certification CFR Reference: 7 CFR 246.4(a)(27) Policy Number: 8.002 Effective Date: 7/28/2016 Revised Date: 6/15/2026

POLICY STATEMENT: The Local Agency must ensure: 1. That each participant certification is performed with separation of duties, meaning that the staff person who determines income, categorical, and residential eligibility and the staff person who determines medical or nutritional risk and issues food benefits cannot be the same person. It is prohibited for one employee to determine eligibility for all certification criteria and issue food instruments, cash-value vouchers or supplemental foods for the same participant. 2. A staff member must not certify themselves for WIC services. 3. A staff member must not certify relatives or friends for WIC services. These actions are to prevent Program abuse and fraud in accordance with DC WIC policy 8.015 Violations and Sanctions. PROCEDURE Separation of Duties for Certifications The Local Agency will designate one staff member to determine income, categorical, and residential eligibility and a different staff member to determine nutritional risk and issue food benefits at each WIC clinic site when possible (see below for when separation of duties is not possible). The State Agency recommends each WIC clinic site designate a CPA and/or CPPA, to ensure timely determination of nutritional risk and food package tailoring and issuance, in accordance with 9.001 Food Benefit Issuance Overview. When Separation of Duties is Not Possible When separation of duties is not possible due to staffing limitations and/or conducting remote WIC services, the Local Agency must designate a staff member with a supervisory role (i.e. Local Agency Director, Nutrition Coordinator, Breastfeeding Coordinator, etc) to conduct a record review of all Infant Formula Feeding (IFF) certifications performed and at least 20 percent of a random sample of the remaining certification records within two weeks of the certifying period performed without separation of duties, in accordance with WIC Policy Memorandum #2016-5 Separation of Duties at WIC Local Agencies. Attachment 8.002A Separation of Duties Audit Form must be completed for each audit, maintained at the local agency for three years, and be made available for State Agency review as requested. Each completed record audit must have a note entered by the performing audit staff stating the record review has been completed. This audit list can be accessed by the “Cert List for Audit” in HANDS > Reports > Program Integrity. Staff Certifying Themselves, Relatives or Friends These actions are prohibited for all WIC staff. If a WIC staff member requests to be certified in DC WIC, the State Agency recommends that the staff member be certified in a different local agency other than the local agency from which they are employed.

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.002 2 | P a g e

Certification Monitoring Each quarter, the State and Local Agency will review staff activity utilizing the following reports in HANDS: • Average Certifications Per Day • Certifications By User • eWIC Benefits Issued Outside of Business Hours • Families With Five or More • Multiple Births

REFERENCES 7 CFR 246.4(a)(27) WIC Policy Memorandum #2016-5 Separation of Duties at WIC Local Agencies DC WIC policy 8.015 Violations and Sanctions, 9.001 Food Benefit Issuance Overview ATTACHMENTS & FORMS 8.002A – Separation of Duties Audit Form

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.003 1 | P a g e Title: Physical Presence and Identification Category: Certification CFR Reference 7 CFR § 246.7(c) 7 CFR 246.7(c)(2)(i) 7 CFR 246.7(o)(1) Policy Number 8.003 Effective Date: 08/01/2021 Revised Date: 8/15/23

POLICY STATEMENT Applicants to the WIC Program are required to be physically present at the time of certification in accordance 7 CFR 246.7(o)(1). In special cases, applicants meeting one of the exception criteria below may be certified without being physically present at the time of certification.

Applicants must present proof of identity (ID) at the time of certification. For infants and children, the ID of the Authorized Representative (AR) or Alternate Authorized Representative (AAR) must also be checked.

PROCEDURE Exceptions In special cases, applicants who meet one of the exceptions below may be exempt from being physically present at the time of certification: a. Infants less than 8-weeks-old – if they cannot be present at the time of certification for a reason determined appropriate by the Local Agency and for whom all necessary certification information is provided. b. Disabilities – applicants or applicants whose parents or caretakers have a disability and are unable to be physically present because of the disability. Examples include: • A condition which requires medical equipment that is not easily transportable • A medical condition that requires confinement to bed rest • A serious illness that may be exacerbated by coming to the WIC clinic • A serious or contagious illness c. Receiving ongoing health care – Only if an infant or child was present at their initial WIC certification and has documented ongoing health care from a provider other than the WIC Local Agency, they may be exempt if being physically present would pose an unreasonable barrier.

d. Working parents or caretakers – an infant or child who was present at the initial WIC certification and was present at a WIC certification or re-certification determination within the 1-year period ending on the date of the most recent certification or re-certification determination (example – present for initial certification in July 2021 and present for recertification in July 2022, they could be exempt from physical presence for recertification in July 2023 [if all other criteria is met and proofs provided]); and is under the care of one or more working parents or one or more primary working caretakers whose primary working status presents a barrier to bringing the infant or child into the WIC clinic.

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.003 2 | P a g e NOTE: If an applicant is hospitalized on an in-patient basis at the time of certification, they may not be issued food benefits.

Physical Presence for Mid-Certification The Local Agency may offer hybrid services for mid-certification appointments as outlined in attachment 8.003A Hybrid Services. Anthropometric and hematological data must be obtained in accordance with DC WIC policy 8.010 Anthros and Bios. Documentation of Exceptions If the applicant meets an exception and is not physically present at the time of certification, staff must document this accordingly under the “Reason Client Not Present” on the Cert screen in HANDS.

Applicants may provide referral anthropometric (within the past 60 days) or hematological (within the past 90 days) at the time of their certification in accordance with DC WIC policy 8.010 Anthros and Bios.

Acceptable forms of anthropometric and/or hematological documentation include: • Doctor’s prescription form • Doctor’s letterhead with prescription • DC WIC medical prescription form • Printed medical records from a provider that includes the date of measurements and the provider’s name • Verbal medical data from a provider

NOTE: Self-reporting of height and weight is not permitted, except in the case of infant birth data. Infant birth data can be self-reported by a caregiver or obtained from hospital records/crib card and can be used for the certification of an infant if they were taken less than 60 days prior to certification. Measurements must be entered in the MIS using the date the measurement was initially taken. Documentation of Identity Applicants must present proof of ID at the time of certification. For non-certification appointments (e.g. mid-certification, CPA follow-up, etc.,) staff must verify identity by either reviewing the AR/AAR’s ID or using identifiers such as having the AR/AAR verify their date of birth, address, and/or phone number. The eWIC card is not an acceptable form of ID. Acceptable proofs of ID are listed below: Documents Accepted for Proof of ID Birth Certificate or Baptismal Certificate Military Records / ID Cards or Discharge Papers Clinic / Hospital record or ID Notice to Provider / CFSA Paperwork Driver’s License / Government ID / State ID Passport / Visa / other country ID** Immigration or Naturalization Record School Photo ID Immunization Record* Voter Registration Marriage License Verification of Certification (VOC)

* Participant name and DOB may be completed by the AR. ** A passport/visa/other country ID that lists the name field as First Name Unknown (FNU) or Last Name Unknown (LNU) is an acceptable form of documentation.

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.003 3 | P a g e

Applicants with No Proof of Identity If at the time of certification an applicant did not provide proof of ID, they may receive up to one month of food benefits and must provide proof of ID before subsequent months of food benefits are issued. The applicant or AR/AAR must sign for the missing proof under “Forgot Documentation” in HANDS. The AR/AAR must provide the proof within 30 days from the date of the certification. If an applicant has no proof of ID for reasons such as theft, loss, disaster, or an asylum seeker/refugee or recent immigrant, then the applicant or AR/AAR must sign for the lack of proof under “No Proof Exists” in HANDS. The applicant, if otherwise determined to be eligible for WIC, may receive normal issuance of food benefits for their certification period. REFERENCES 7 CFR 246.7 DC WIC policy 8.010 Anthros and Bios DC WIC attachment 8.003A Hybrid Services

VIII. Certification August 2021 8.004 - 1 8.004 Categorical Eligibility CFR 246.7 (C) Eligibility Criteria I. Policy Statement To qualify for the Program, infants, children, and pregnant, postpartum, and breastfeeding women must reside within the jurisdiction of the District of Columbia and meet the income and nutritional risk criteria as outlined in Policies 8.005, 8.006 and 8.007, respectively. II. Categories for Eligibility

Category Description Pregnant Woman A pregnant woman. Proof of pregnancy is not required. If there is reason to suspect that a participant has falsely claimed to be pregnant, the Local Agency can request proof of pregnancy be provided within 60 days of certification. Staff will have to choose “bi-monthly issuance” in the Issuance tab under the Benefits screen in HANDS. Breastfeeding Woman A woman who breastfeeds an infant at least one time per day, up to infant’s first birthday or until she completely stops breastfeeding before the infant turns one year old.

A breastfeeding assessment shall be done before the issuance of food benefits at each certification, mid-cert assessment, when a breast pump is issued, and/or whenever the amount of formula the woman is requesting changes. The results of the assessment shall be documented in Notes in TGIF format, be used to provide individualized breastfeeding support, and to determine the appropriate food packages for her and her infant.

NOTE: When a breastfeeding woman who is more than 6 months postpartum stops breastfeeding, she becomes categorically ineligible. Postpartum Woman Postpartum non-breastfeeding women up to 6 months after the birth or the end of the pregnancy.

See below for more information on categorical eligibility for women who present after fetal or neonatal loss. Infant An infant until their 1st birthday (age one).

Child A child between the ages of one year and the last day of the month in which the child turns five (5) years old. NOTE: Participants shall be verbally informed of the length of certification at the time of certification. If the length of certification changes (i.e. change to estimated or actual delivery date) or if the category changes (i.e. breastfeeding category change), participants shall be verbally informed of the revised length of certification when it occurs.

VIII. Certification August 2021 8.004 - 2 III. Cases of Fetal or Neonatal Loss If a woman presents with a case of spontaneous abortion (miscarriage), induced abortion, fetal death or neonatal death, the applicant/participant may receive 6 months of food benefits from the date of loss. Definitions: • Fetal Death – Spontaneous termination of gestation at > 20 weeks • Induced Abortion – Elective termination of pregnancy • Neonatal Death – The death of an infant within 0-28 days of life • Spontaneous abortion – Spontaneous termination of a gestation at < 20 weeks, or a fetus that weighs < 500 grams Policies related to classifying women with fetal or neonatal loss as Postpartum Woman: • Proof of loss (i.e. doctors note) is preferable, and can be mandatory at the LA’s discretion. • A participant arriving to the LA post-loss may be recertified as a Postpartum Woman to receive benefits up to 6 months from the date of loss, as noted on proof of loss or as stated by the participant if no proof is available. • LAs reserve the right to refuse benefits and services to participants with suspected, or with a past history, of Program abuse. • If the participant was certified as pregnant without proof, and then returns to certify as post- loss, proof of either pregnancy or loss will be required. • Risk Code 321 shall be assigned to women who have had a spontaneous abortion, fetal death, or neonatal death. These participants are considered high-risk; refer to policy 8.007 for guidance on high-risk participants.

IV. Participants who misrepresent themselves as pregnant or postpartum

Policy 8.015 – Participant Violations and Sanctions indicates that misrepresenting oneself as pregnant and/or as having incurred the loss of a pregnancy (or infant) is considered a misrepresentation of health status - the participant could be sanctioned with having to repay the monetary value of benefits received and incur a one-year disqualification from Program eligibility.

VIII. Certification August 2021 8.004 - 3 Table 1. Summary of HANDS participant category codes Pt Code Description PG1 Pregnant woman < 18 years old

PG2 Pregnant woman > 18 years old

P Post Partum Woman

PN+ Woman Partially Nursing Plus (more formula provided than PN) PN Woman Partially Nursing

EN Woman Exclusively Nursing

IEN Infant Exclusively Nursing

IPN Infant Partially Nursing

IPN+ Infant Partially Nursing Plus (More formula provided than PN) IFF Infant Fully Formula Feeding

C1 Child 12-23 months old

C2

Child 24-35 months old C3

Child 36-47 months old C4

Child 48-59 months old

VIII. Certification August 2021 8.005 - 1 8.005 Residency Eligibility CFR 246.7 (C) Eligibility Criteria

I. Policy Statement At each certification appointment, each applicant is required to present proof of residency within the District of Columbia. This is the location or address where a potential participant routinely lives or spends the night. NOTE: Staff shall not make photocopies of an applicant’s proof of residency, nor scan residency documentation into HANDS. LAs shall not require an applicant to be a citizen or have residency status in the United States. LAs shall not attempt to determine an immigrant’s status or to confirm their status with the Immigration and Naturalization Service (INS). II. Acceptable Documents to Verify Residency Documentation of residency is required at each certification and when there is a change of address during a certification period. PO Boxes are not acceptable proof residency. The following documents may be used to verify an applicant’s residency within the District of Columbia. Address Confidentiality Program Income Tax Return / W-2 Rent or Mortgage Receipts (Housing) (From within 60 days) Bank Statements (From within 60 days) Letter from homeowner that person resides in their home (Issued within 60 days) Shelter Letter on Letterhead (Issued within 60 days) Bill (Utility, Cable, Phone, etc) (Issued within 60 days) Mail with postmark (no PO box) TANF/SNAP Award Letter Clinic / Hospital Record or ID Notice to Provider / CFSA Paperwork Vehicle Registration Driver’s License / Government or State issued ID Pay stubs with current address (Issued within 60 days) Voter Registration Card

VIII. Certification August 2021 8.005 - 2 III. Residency Considerations

a. DC Address Confidentiality Program (ACP)

If the participant provides an ACP card for proof of residency, staff shall: - Document the new address as listed on the ACP card in the Mailing and Street Address fields in HANDS. If no address is listed, staff shall use the service site’s address - Select “Address Confidentiality Program” for Proof of Address - Verify phone number and request permission to contact them if necessary - If applicable, breast pump release forms (loan agreements) for a family will be completed using the ACP card address, or if applicable, the service site’s address

NOTE: Staff may not ask ACP participants to disclose their actual address

b. Institutional Residence If the participant resides in an institution (e.g., homeless shelter, shelter for victims of domestic violence, penal institution), the following conditions shall be met: - WIC foods benefit the participant, not the institution (i.e., the institution shall not accrue financial or in-kind benefit from the resident’s participation in WIC) - WIC foods are used by the WIC participant only - The institution allows and encourages the participant to purchase and consume WIC foods, and participate in all associated WIC services made available to participants by the Local Agency (e.g., education, referrals)

c. Non-Compliant Institutions If the institution where a participant is staying is found to be noncompliant with any of the above three conditions: - During the initial certification, the participant will continue to receive all WIC benefits - The participant applies for continuing benefits and still resides in the institution, the LA will discontinue provision of food items other than infant formula and the participant will continue to be eligible for WIC education and health care referrals - The LA will refer the participant to other accommodations, if possible - The State Agency will inform the institution of the required conditions listed above and that eligible residents will not be able to participate on WIC unless the conditions are met

d. Applicants with No Proof of Residency at Certification (Forgot Documentation) When an applicant has proof of residency but did not bring it to the certification appointment and is found eligible to receive benefits, they are to be informed that they can receive benefits for one month and will need to provide proof of residency before more benefits are issued. The applicant shall sign the “Forgot Documentation – ID/Address/Income” signature type accessible through the Family, Client, or Income screens. They are to be issued one month of food benefits and shall provide proof of residency within 30 days.

VIII. Certification August 2021 8.005 - 3 e. No Proof of Residency due to Theft, Loss, or Disaster When an applicant has no proof of residency as a result of being a victim of theft, loss, or disaster, the applicant shall sign the “No Proof Exists – ID/Address/Income” signature type found on the Family screen in HANDS. Staff will choose “No Proof Exists- ID/Address/Income” as the type of residency documentation. Staff may issue up to three months of Food Benefits. Note: Food benefits shall not be withheld for failure to provide updated proof of residency during a certification. f. Homeless Applicants/Participants For homeless applicants/participants, the address of a friend, relative, or homeless institution through which the applicant/ participant could be contacted shall be collected, if possible. If this is not possible, the word “HOMELESS” or the service site’s address shall be used. When an applicant has no proof of residency as a result of homelessness, the applicant shall sign the “No Proof Exists – ID/Address/Income” signature type found on the Family screen in HANDS, which will become a part of their permanent record. Staff will choose “No Proof Exists-ID/Address/Income” as the type of residency documentation. Staff may issue up to three months of food benefits. Note: Food benefits shall not be withheld for failure to provide updated proof of residency during a certification. g. Refugees In order to meet the WIC Program residency requirement, an applicant must live in the District of Columbia at the time of application. Refugees may not have a permanent place to live and, therefore, may be considered homeless. The applicant shall sign the “No Proof Exists – ID/Address/Income” signature type found on the Family screen in HANDS. Staff will choose “No Proof Exists-ID/Address/Income” as the type of residency documentation. Staff may issue up to three months of food benefits. h. Applicants with a Change of Address during a Certification If there is a change of address during a certification period and the participant does not have proof of the new address with them, staff shall enter the new address and select “Forgot Documentation” as the proof of residency. The participant shall sign the “Forgot Documentation – ID/Address/Income” signature type accessible through the Family, Client, or Income screens. Staff may issue up to three months of food benefits and have the participant provide proof at the next appointment. When proof of the new address is provided, staff shall update the proof of residency with the type of documentation provided. Note: Food benefits shall not be withheld for failure to provide updated proof of residency during a certification. IV. Procedures The following procedure shall be followed to determine and document residential eligibility: 1. Determine residential eligibility based on the above criteria 2. Record the type of documentation provided on the Family screen in the participant’s HANDS record

VIII. Certification August 2021 8.006 - 1 8.006 Income Eligibility CFR § 246.7(d) Income Criteria and Income Eligibility Determinations SFP 02-080 WIC Income Eligibility Determining for Households Affected by Privatization of On-base Military Housing

I. Policy Statement The State Agency must establish income guidelines, definitions, and procedures for LAs to use when determining an applicant’s income eligibility. WIC applicants will have their income evaluated at each certification using procedures outlined in this policy.

The State Agency will adopt the income standard of 185% of the current Federal Poverty Guidelines as its eligibility standard. LAs will implement the federally-established income eligibility standards for their program (see Appendix 8.006A – Income Eligibility Guidelines).

All data used to determine income eligibility will be reflective of the applicant’s total household income and applicant’s status at the time of certification. All applicants will provide documentation of income through:

a. Proof of participation in an adjunctively eligible program, or b. Proof of income

II. Determining Household Size / Economic Unity Household/economic unit is defined as a group of related or non-related individuals who are living together as one economic unit.

Household/economic unit members share economic resources and consumption of goods and/or services. The terms “economic unit” or “household size” can be used interchangeably. However, “economic unit” is a more appropriate term to use because it conveys that familial relationship is not relevant to the determination of family size and income. The following are examples of how the economic unit discussion can be framed to gather more accurate information from the applicant:

• If the applicant(s) lives with their parent(s) or other family member(s) and they provide financial support such as food, bills, etc., include them in the household/economic unit. • If the applicant(s) lives with others who provide financial support such as food, bills, etc., include them in the household/economic unit. • If the applicant(s) lives with their boyfriend, girlfriend, fiancé, domestic partner, etc., and share any expenses, include him or her in the household/economic unit. Include opposite and same sex partners. • If the applicant(s) lives with their parents or other family member(s) and they do not provide financial support such as food, bills, etc., do not include them in the household/economic unit. • If the applicant(s) lives with others who do not provide financial support such as food, bills, etc., do not include them in the household/economic unit. • If the applicant(s) lives with their boyfriend, girlfriend, fiancé, domestic partner, etc. and do not share any expenses, do not include him or her in the household/economic unit. Include opposite and same sex partners.

VIII. Certification August 2021 8.006 - 2 III. Household/Economic Unit Considerations The following guidelines serve to direct LA staff on specific household/economic unit income circumstances. a. Adopted Child When a child has been adopted by a family, the child is counted in the household of the family. The size and total income of that economic unit will be used to determine if the child is income eligible for WIC. b. Foster Child If an infant or child is in the care of foster parents, the Child & Family Services Agency (CFSA), or other child welfare authorities, the infant or child will be considered a family of one; this income is to be documented in the Income screen in HANDS. The foster child will be the only family member selected to which the income will apply. If the foster child is the only participant in the file, the family size will be one. HANDS will automatically count the foster child as a family of one when the ‘Foster Care’ box is checked. The placement paper, commonly called “Notice to Provider,” or an official notification of placement from a temporary adoption organization is required to make the foster parents the Authorized Representatives. The payments made by the welfare agency or received from other sources for the care of that child will be considered to be the only income. This documentation can be scanned and saved in the participant’s file for future reference. If a foster parent has not yet received payments from the welfare agency or from other sources for the care of the child, staff shall document $1 as the income amount for that child and create a Staff Alert in the Notes screen to have WIC staff ask about changes in income at each recurring appointment, or until it is determined that no income will ever be received on behalf of the foster child. NOTE: If the foster child is a member of a WIC family with other non-foster children, the family size for the non-foster children applying for WIC will be the actual size of the AR’s family minus the foster child. HANDS will automatically count the foster child as a family of one when the ‘Foster Care’ box on the Client screen is checked, regardless of number in the Family Size field.

NOTE: Families with multiple foster children can share a Family ID number and eWIC card in HANDS. Each foster child will have a separate income documented in the Income screen as a household size of one. If the foster parent prefers, each foster child can be divided into separate family files and have individual eWIC cards issued. See Policy 9.001 for additional details.

c. Military Families Military personnel serving overseas or assigned to a military base, even though they are not living with their families, shall be considered members of the economic unit. Military dependents (i.e., infant, child, or woman) placed in the temporary care of friends or relatives who are dependent on that household to provide food, utilities, etc., shall be considered a part of that household/economic unit during certification. If the applicant receives funds to sustain themselves (beyond in-kind housing), they may be counted as a separate economic unit. When military personnel use alternative methods of depositing paychecks (waiving military income documentation) and/or receive combat/hazardous duty pay, the income over the last 12 months can be used. NOTE: Basic Allowance for Housing (BAH) is not considered income.

VIII. Certification August 2021 8.006 - 3 d. Pregnant Woman A pregnant woman’s household is assessed by increasing it by the number of expected infants (unless the applicant has religious or cultural objections which preclude this). e. Resident of Institutions The resident of an institution is assessed as a separate economic unit from the institution. The institution shall meet the conditions as outlined in the previous section on institutional residency. f. Co-living Two separate households/economic units residing at the same address under the same roof shall be considered separate households/economic units. Each household shall have an adequate source of income to cover expenses, such as rent, food, utilities, and other, to be determined as separate households/economic units. When unmarried individuals reside together as an economic unit, the income and household size of both parties shall be used in determining income eligibility. g. Separated Family When a family separates, the child is counted in the family with whom the child lives. h. Custody The parent(s) with whom the child spends a majority of their time can claim the child in reporting household size. Child support payments are considered income for the family with whom the child lives, but cannot be deducted from the income of the person making the payments. i. Teen An applicant who is under 18 years of age will have her income eligibility assessed following the rules which apply to any other economic unit (see Determining Household/Economic Unit above). j. In-stream Migrant Worker In-stream migrant farm workers with expired Verification of Certification (VOC) cards are income eligible as long as their income is determined at least once every 12 months. k. Refugees As part of the assessment process, LA staff will ask clarifying questions to determine the size of the economic unit for refugee applicants living in the residence of another individual. LAs shall require all applicants to provide documentation of income at the time of certification. If this requirement would present an unreasonable barrier to participation in the WIC Program, a self- declaration of income may be accepted. l. Qualified Aliens The LA shall not count the income of sponsors of qualified aliens (as the term is defined in the Immigration and Nationality Laws (8 U.S.C. 1101 et seq.) in determining the income eligibility of the qualified alien, except when the alien is a member of the sponsor’s family or economic unit. IV. Adjunctive Eligibility

VIII. Certification August 2021 8.006 - 4 When an applicant or a household family member participates in a federal or state program with eligibility guidelines that are equal to or below the WIC income guidelines, the applicant is allowed to enroll in the WIC Program without duplication of their initial income screening.

An applicant is adjunctively income eligible for WIC if documentation shows that the individual or an immediate household member is certified as fully eligible to receive benefits from:

- Supplemental Nutrition Assistance Program (SNAP/Food Stamps) - Temporary Assistance for Needy Families (TANF) program - Medicaid (Pending adjunctive eligibility) o DC Medicaid Programs exist which apply higher income eligibility guidelines than allowed by WIC. DC WIC is working with the Department of Healthcare Finance (DCHF) to allow WIC clinic staff limited access to the DCHF eligibility system so they can verify the Medicaid beneficiaries’ household income. An applicant is automatically eligible for WIC if documentation shows that the individual or an immediate household family member is certified as fully eligible to receive benefits from:

- The National School Lunch Program (NSLP)

Documentation of Adjunctive Eligibility Applicants determined to be adjunctively or automatically income eligible are required to provide documentation of their participation in one or more of the programs listed above. The Adjunct Eligibility table in HANDS can only be updated on the date of certification. Acceptable forms of adjunctive eligibility documentation (which must include eligibility dates) are: o TANF approval letter o SNAP (Food Stamps) – most recent certification letter o Medicaid (pending adjunctive eligibility, may not be used until further notice) o NSLP – most recent certification letter

NOTE: TANF/SNAP cards are not proof of adjunctive program participation unless the card shows a current period of eligibility.

Procedure to Document Adjunct Eligibility: 1. Open the Adjunct Eligibility screen under the Income screen in HANDS 2. Select “Part. Proof” for each of the adjunct eligibility programs the applicant shows proof of participation in 3. If they show documentation that a member of their household is a TANF recipient, select “Fam Elig Proof” for those programs

NOTE: Documentation showing proof of participation in adjunctive eligibility programs may be used within 30 days as documentation of income. In addition, self-declaration is not allowed for adjunctive eligibility.

VIII. Certification August 2021 8.006 - 5 V. Reportable Income Types Income for the purposes of this part means gross cash income before deductions for income taxes, employees' social security taxes, insurance premiums, bonds, etc. LA staff shall consider all of the following to determine reportable income: a. Monetary compensation for services, including wages, salary, commissions, or fees b. Net income from farm and non-farm self-employment c. Social Security benefits d. Dividends or interest on savings or bonds, income from estates or trusts, or rental income e. Public assistance or TANF / welfare payments f. Unemployment compensation g. Government civilian employee or military retirement or pensions or veterans’ payments h. Private pensions or annuities i. Alimony or child support payments j. Regular contributions from persons not living in the household k. Net royalties l. Other cash income – includes, but is not limited to, cash amounts received or withdrawn from any source including savings, investments, trust accounts, and other resources which are readily available to the family

VI. Documentation of Income Acceptable types of documentation of income include, but are not limited to: Employment pay stubs (Issued within 30 days) Alimony or child support award letter Tax reporting forms showing total gross income Income tax return/W-2 forms Foster care placement letter Retirement pension letter/stub

Unemployment letter/notice Social Security benefits letter

Contribution letter

Statement signed and dated by employer Military pay stubs/LES

Adjunct Eligibility Program enrollment notification Note: staff shall not make photocopies or scan applicant’s proof of income.

Documentation Procedure Staff shall document income eligibility in the Income screen in HANDS as follows:

1. Enter the appropriate family size (economic unit) 2. Enter name or source of income provider if desired, or leave default as “Primary Provider” 3. Enter the dollar amount of current gross income based on income documentation provided 4. Enter the interval for that amount of income (i.e., hourly, weekly, monthly, annually) 5. If hourly is selected, enter the number of hours per week 6. Enter correct type of income documentation from drop-down menu 7. If income proof is brought in, select all family members to which the income applies, regardless of whether they are being certified today 8. If the AR forgot to bring income proof to certification, “Forgot Documentation” is to be selected and staff shall only apply income to the applicant(s) being certified today

VIII. Certification August 2021 8.006 - 6 NOTE: Do not apply income to a participant who has less than 90 days left in their certification period, unless they are being recertified.

If applicant presents multiples of the same income documentation type (e.g., employment pay stubs), staff shall utilize the “Income Averaging” feature on the Income Screen in HANDS. VII. Applicants with No Proof of Income If an applicant does not provide proof of income on the day of certification because they forgot it, the applicant is to self-declare their current income amount and corresponding interval; the applicant will be certified and receive only one month of food benefits if they are within income guidelines. They will be instructed to provide proof of income to the service site within the next 30 days. This will be documented in the Income screen in HANDS by selecting “Forgot Documentation” from the drop-down menu as the type of income documentation. The participant will then sign the “Forgot Documentation- ID/Address/Income” signature type accessible from the Family, Client, or Income screen.

If the applicant provides proof of income within 30 days, WIC staff will verify the amount and update the documentation type by editing the income line in the Income screen in HANDS and may issue multiple months of food benefits. VIII. Exceptions Lack of income documentation cannot be a barrier to receiving WIC services, such as in the case of the homeless, migrant farm workers, or people who work for cash. If the applicant cannot provide documentation of income, the applicant shall sign the “No Proof Exists-ID/address/income” signature type accessible from the Income screen. This signature serves as income documentation for the entire certification period and will allow more than one month of food benefits to be issued. This will be recorded in HANDS under the documentation type by selecting “No Proof Exists/Zero Income Signature Form” from the drop-down menu. IX. Zero Income If an applicant reports zero income or declares no income exists, the applicant shall be asked to describe, in detail, their living circumstances and how they obtain basic living necessities such as food, shelter, medical care, and clothing to determine if they shall be counted as part of a larger economic unit. If it is determined that the applicant is truly without resources, the applicant shall sign the “Zero Income” signature type accessible from the Income screen. This will be recorded in HANDS under the documentation type by selecting “No Proof Exists/Zero Income Signature Form” from the drop-down menu. X. Migrant Farm Workers Determination of income eligibility will be made once every 12 months for migrant field workers and their families. The migrant status will be documented in HANDS, indicating exemption from having income determination repeated within a 12-month period.

VIII. Certification August 2021 8.006 - 7 XI. Reassessment of Income The participant’s income eligibility during a current certification shall be reassessed if: • The Program receives information indicating the individual may have misrepresented income and/or household size when applying for services • The Program receives new information indicating the participant’s income has changed • The participant reports a change in income or household size, while in an active certification • The LA receives information that the participant(s) is no longer adjunctively eligible • The LA receives information that there is a change in custody which results in change of income or household size If the reassessment indicates the family is over income and has > 90 days remaining in their certification period, they are to be provided one month of food benefits, and provided a Notification of Ineligibility. Refer to Policy 8.014 or additional information about the Notification of Ineligibility. If there are < 90 days before the certification period expires, WIC staff shall issue the remaining food benefits through the end of the certification. NOTE: When a participant is in a current certification and there is reason to suspect that they have provided false information, the LA shall report the concern to the State Agency Nutrition Services team for further investigation. Reassessment of Income During an Existing Certification and Adding New Family Members When a new family member is certified while there are existing certifications for other members within the household, the proof of income shall be applied to all participants within the household unless the participant has < 90 days remaining in the certification. Refer to” Reassessment of Income” section above if the family has > 90 days remaining in their certification period. No Longer Adjunctively Eligible During a Certification Period A reassessment may identify that a participant/household is no longer adjunctively eligible. However, such persons cannot be disqualified from WIC solely on the basis of cessation of benefits from TANF, SNAP, or other State-administered programs. They will be reassessed under other income criteria before being disqualified. XII. Household Income Ineligible Termination If a LA evaluates income for another member of the participant’s household, and the evaluation indicates that household income is above the income guidelines, all members of the household shall be terminated from WIC services to include participants in a current certification (refer to Reassessment of Income section). The participants in a current certification are eligible for one month of food benefits. The applicants are not eligible for food benefits. All participants and applicants in the family will be provided with a Notification of Ineligibility and informed of their right to a fair hearing. NOTE: If a participant’s current certification period has < 90 days before it expires, they shall not be terminated and may receive their remaining food benefits until their certification expires.

VIII. Certification August 2021 8.006 - 8 XIII. Non-Eligible Income Sources The following sources of income must be excluded when determining income eligibility: a. Basic Allowance for Housing (BAH) received by military services personnel residing on or off of military installations b. Cost-of-living allowance provided under 37 U.S.C. 405, to a member of a uniformed service who is on duty outside the contiguous states of the United States c. The value of in-kind housing and other in-kind benefits d. Payments or benefits provided under certain Federal programs or acts, including (but not limited to): i. Reimbursements from the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970 ii. Any payment to volunteer under Title I (VISTA and others) and Title II (RSVP, foster grandparents, and others) of the Domestic Volunteer Service Act of 1973 to the extent excluded by that Act iii. Payment to volunteers under section 8(b)(1)(B) of the Small Business Act iv. Income derived from certain sub-marginal land of the United States that is held in trust for certain Indian tribes v. Payments received under the Job Training Partnership Act vi. Income derived from the disposition of funds to the Grand River Band of Ottawa Indians vii. Payments received under the Alaska Native Claims Settlement Act viii. The value of assistance to children or their families under the National School Lunch Act, as amended, the Child Nutrition Act of 1966, and the Food Stamp Act of 1977 ix. Payments by the Indian Claims Commission to the Confederated Tribes and Bands of the Yakima Indian Nation or the Apache Tribe of the Mescalero Reservation x. 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 xi. Payments under the Low-Income Home Energy Assistance Act, as amended xii. 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 that is used for costs described in section 472 (1) and (2) of that Act xiii. Payments under the Disaster Relief Act of 1974 as amended by the Disaster Relief and Emergency Assistance Amendments of 1989 xiv. 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 xv. Payments pursuant to the Agency Orange Compensation Exclusion Act xvi. Payments received for Wartime Relocation of Civilians under the Civil Liberties Act of 1988 xvii. Value of any childcare payments made under section 402(g)(1)(E) of the Social Security Act, as amended by the Family Support Act

VIII. Certification August 2021 8.006 - 9 xviii. Value of any “at-risk” block grant childcare payments made under section 508 of Pub. L. 101-508, which amended section 402(i) of the Social Security Act xix. Value of any childcare provided or paid for under the Child Care and Development Block Grant Act, as amended xx. Mandatory salary reduction amount for military service personnel that is used to fund the Veteran’s Educational Assistance Act of 1984 as amended xxi. Payments received under the Old Age Assistance Claims Settlement Act, except for per capita shares in excess of $2,000 xxii. 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 xxiii. Payments received under the Housing and Community Development Act of 1987, unless the income of the family increases at any time to not less than 50 percent of the median income of the area xxiv. Payments received under the Sac and Fox Indian claims agreement xxv. Payments received under the Judgment Award Authorization Act, as amended xxvi. Payments for relocation assistance of members of Navajo and Hopi Tribes xxvii. Payments to the Turtle Mountain Band of Chippewas, Arizona xxviii. Payments to the Blackfeet, Grosventre, and Assiniboine tribes (Montana) and the Papago (Arizona) xxix. Payments to the Assiniboine Tribe of the Fort Belknap Indian community and the Assiniboine Tribe of the Fort Peck Indian Reservation (Montana) xxx. Payments to the Red Lake Bank of Chippewas xxxi. Payments received under the Saginaw Chippewa Indian Tribe of Michigan Distribution of Judgment Funds Act xxxii. Payments to the Chippewas of Mississippi xxxiii. Military Combat Pay is excluded when it is considered income as a result of deployment to a combat zone under FDPIR (FD-042: Food Distribution Program on Indian Reservations- Pay Received by Military Personnel as Result of Deployment to a Combat Zone. Combat pay is excluded if it is: 1. Received in addition to the service member’s basic pay, 2. Received as a result of deployment to or service in an area designated as a combat zone, and 3. Not received prior to the service member’s deployment

VIII. Certification August 2021 8.007 - 1 8.007 Risk Code Identification CFR § 246.7 (e) and WIC Policy Memorandum May 2011, Transmittal of New and Revised Nutrition Risk Criteria I. Policy Statement DC WIC has adopted the risk criteria developed by the Risk Identification and Selections Collaborative (RISC) Committee for the National WIC Association (NWA) and the Food and Nutrition Service (FNS) divisions of the USDA. DC WIC implements the Nutrition Risk Criteria located on the Local Agencies > Trainings page at www.dcwic.org. Applicants will be assigned all risk codes that apply, according to HANDS and the Nutrition Risk Manual. To ensure participant-centered education, it is highly recommended for staff NOT to tell participants their risk(s) directly; instead, it is preferred for staff to offer nutrition education topics related to the risk(s). II. Staff Responsible for Determining Nutrition Risk LA Staff responsible for determining nutrition risk include: a. Competent Professional Authorities (CPAs) – may determine risk, provide nutrition education, and prescribe supplemental foods for all participants; must counsel participants indicated as high-risk. b. Competent Para-Professional Authorities (CPPAS) – may determine risk, provide nutrition education, and issue supplemental foods to low-risk participants. If a CPPA identifies a participant as high-risk during any part of the health and nutrition assessment, they must refer the participant to the CPA for follow-up.

III. Procedures for Determining Nutrition Risk The Nutrition Risk Manual (NRM), located on www.dcwic.org under Local Agencies > Trainings, is a comprehensive guide to each nutrition risk code. LA staff may refer to this manual online, or may print it for on-site reference if desired. In addition to the NRM, which is over 350 pages, there are “cheat sheets” for LA staff to use with the expectation that staff are familiar with risk code indications. If staff have questions related to risk code descriptions or indications, they should refer to the NRM and to their Local Agency Director, as needed. The CPA shall use the “CPA Risk Codes Cheat Sheet (Appendix 8.007A) for determining nutritional/medical risk for program eligibility. The CPPA shall use the “CPPA Risk Codes” (see Appendix 8.007B) for determining nutritional/medical risks for program eligibility. NOTE: Risk codes are not final in the participant’s record until they clicks “Complete Assessment” in the Nutrition Care Plan screen. Risk codes can be added at any time throughout the certification as they are identified as HANDS will capture the date the risk was added to the record.

VIII. Certification August 2021 8.007 - 2 IV. Self-Reporting or Self- Diagnosis Self-reporting of a diagnosis by a medical professional shall not be confused with self-diagnosis, where a person reports to have or have had a medical condition, without any reference to a professional diagnosis. A self-reported medical diagnosis such as, “My doctor says that I have/my son or daughter has…” shall prompt the CPA to validate the presence of the condition by asking more in-depth questions related to the diagnosis. Self-reporting of “History of” conditions shall be handled in the same manner as self-reporting of current conditions that require a physician’s diagnosis. The applicant may report to the CPA that they were diagnosed by a physician with a given condition in the past. Again, self-diagnosis of a past condition shall not be confused with self-reporting. V. Determining Nutrition Risk The participant’s health and nutrition assessment, including collection of anthropometric and biochemical data, identifies the nutritional needs and interests of the participant. The nutrition assessment provides the basis for the nutrition care plan, including nutrition education/counseling, food package assignment, referrals, and follow-up plans. During the assessment process, heights, weights, biochemical information, dietary information, medical information, and family situation are assessed and any potential risk codes are identified. Individuals applying for enrollment in DC WIC must have at least one risk code to be eligible for participation. Women’s Nutrition Risk Determination: All data used to determine nutritional risk will be reflective of the woman’s categorical status at the time of certification. For example, a woman certified during pregnancy as at risk for anemia cannot be certified in the postpartum period using any hemoglobin or hematocrit value that was obtained during her pregnancy.

VIII. Certification August 2021 8.008 - 1 8.008 Eligibility for Special Cases CFR § 246.7(c) Eligibility Criteria and Basic Certification Procedure I. Policy Statement The State Agency must have a plan to provide Program benefits to unserved infants and children under the care of foster parents, protective services, or child welfare authorities, including infants exposed to drugs perinatally. Infants and children living with temporary caretakers, and minors (under age 18) seeking WIC services and benefits are also covered in this policy. II. Children in Foster Care or Protective Services Local Agencies shall provide WIC benefits to children in foster care or protective services who meet the eligibility criteria for the Program. The foster parent(s) with whom the child is placed must reside in the District of Columbia. The LA shall accept only official documents from the Department of Human Services, the Child and Family Services Agency, or other appropriate agency indicating that the child has been placed in their care. The child’s monthly foster care stipend shall be used to determine income eligibility, not that of the foster parent(s). The child shall be considered a “family of one.” The foster care or protective services parent(s) shall be the AR(s) for the child participant, with all the rights and responsibilities assigned to that position. Children in foster care who are residents of the District of Columbia, but have been placed in homes in Maryland, Virginia, or another state must apply for WIC benefits in that state. Children in foster care who are residents of the District of Columbia and live in Maryland or Virginia, but receive primary health care in the District of Columbia may be served by DC WIC.

a. A letter from the participant’s doctor must be sent to the designated clinic prior to the delivery of WIC services.

Note: For changes in custody that take place during a valid certification period, see policy 8.012– Authorized Representatives.

LA Staff shall contact the State Agency for guidance in cases where custody is questioned or challenged by a biological parent. Procedures: 1. Use the child’s monthly foster care stipend to determine income eligibility – see policy 8.006 for more information 2. Verify and document the foster parent’s identity and residency

III. Legal Guardians LAs shall provide WIC benefits to children who reside with a legal guardian other than the parent and meet the eligibility criteria for the Program. The legal guardian with whom the child lives must reside in the District of Columbia and provide proof of residency. The legal guardian must prove that the child resides with them. This documentation must be a notarized statement from the court or an attorney, and must be scanned into the participant’s HANDS record at the time of certification.

VIII. Certification August 2021 8.008 - 2 The child’s income shall be used to determine income eligibility, not that of the legal guardian. The child shall be considered a “family of one.” The legal guardian shall be the AR for the child participant, with all the rights and responsibilities assigned to that position. Note: For changes in custody that take place during a valid certification period, see policy 8.012 – Authorized Representatives. LA staff shall contact the State Agency for guidance in cases where custody is questioned or challenged by a biological parent.

Procedures: 1. Use the child’s sources of income to determine income eligibility 2. Verify and document the legal guardian’s identity, residency, and custody 3. Scan the legal guardian’s custody documentation into the child’s HANDS record IV. Temporary Caretaker LAs shall make every effort to provide WIC benefits to children who reside with a temporary caretaker and meet the eligibility criteria for the Program. The temporary caretaker must provide documentation indicating that they are providing for the child due to the parent or legal guardian not being able to care for the child, and that the child is residing with the caretaker. Documentation must indicate the length of this arrangement and be one of the following: a. Notarized statement from the child’s parent; OR b. Proof of a child’s Medicaid, TANF, or SNAP benefits mailed in care of the caretaker; OR c. Written statement from a social service or health care agency to include (1) the name and address of the child, (2) the name, address, and telephone number of the caretaker, and (3) the length of time that the child will be in the care of the caretaker The temporary caretaker with whom the child lives must reside in the District of Columbia and provide proof of residency. This child is not considered a foster child and shall be included in the family’s eligibility determination. One month of food benefits shall be issued and eligibility shall be reassessed at the next appointment. The temporary caretaker shall be the AR for the child participant, with all the rights and responsibilities assigned to that position. LA staff shall contact the State Agency for guidance in cases where custody is questioned or challenged by a biological parent. Procedures 1. Obtain documentation that the temporary caretaker has legal custody of the child 2. Verify the identity and residency of the temporary caretaker 3. Use the child’s source(s) of income to determine income eligibility

VIII. Certification August 2021 8.008 - 3 4. Scan the temporary caretaker’s documentation of custody into the child’s HANDS record Note: If the temporary caretaker does not have documentation that the infant/child has been knowingly and willingly placed in their care by the court or the child’s parent/legal guardian, staff may issue 1- month (30 days) of benefits. In this case, the temporary caretaker must sign the “Self-Declaration of Relationship to Minor” form and must provide appropriate documentation of custody – either legal custody or temporary custody - within 30 days, at which point the full certification can be completed and additional benefits issued. Add a staff alert in the participant’s HANDS record that documentation of guardianship is needed. “Self-Declaration of Relationship to Minor” forms must be scanned into the infant/child’s HANDS record. Note: For changes in custody that take place during a valid certification period, see policy 8.012 – Authorized Representatives.

V. Ward of the District of Columbia LAs shall provide WIC benefits to children who are “Wards of the District of Columbia” and reside in DC. In situations where children in the DC foster care program are placed in homes in Maryland or Virginia, but receive primary health care in the District of Columbia they may be served by DC WIC. A letter from the participant’s doctor must be sent to the designated service site prior to delivery of WIC services. The same procedure for shall be followed for “Wards of the District of Columbia” as stated in section II of this Policy (Foster Children). VI. Minors LAs shall provide WIC benefits to applicants who are minors and meet the eligibility criteria. A minor who is not receiving support from their family shall be considered a separate economic if they can provide documentation of majority of financial support for himself/herself. A minor would be considered an "Emancipated minor" which is defined as any minor who is living separate and apart from their parent(s) or legal guardian, with or without the consent of the parent(s) or legal guardian and regardless of the duration of such separate residence, and who is managing his or her own personal and financial affairs, regardless of the source or extent of their income. A minor shall be considered part of an economic unit other than their parent(s) if he/she shares income, and goods and services generated by that income with those persons. LA Staff shall accept the standard proof of eligibility criteria, including exceptions for assessment of minors. Contact the State Agency for guidance if there are questions concerning eligibility for WIC for an emancipated minor.

VIII. Certification August 2021 8.008 - 4 VII. Military Temporary Care of Friends/Relatives LAs shall provide WIC benefits to children in temporary care of friends and/or relatives due to military obligations of their parent(s). The child’s income shall be calculated based on the economic unit. The economic unit shall be determined by using one of the following: a. The child and their military parent(s) may be considered an economic unit and the gross pay of the parent(s) therefore determines the income. The caretaker must provide adequate documentation that the parent(s) is sending money to support the child(ren) and that this support is sufficient to provide for the majority of support. b. The child(ren) may be considered as a separate economic unit if the child’s source of income provides the majority of support and it is adequate to sustain them as a separate economic unit. LA Staff shall use the monetary guidelines of the Department of Human Services Foster Care Program to determine the adequacy of the child’s income. c. The child(ren) may be considered as part of the economic unit of the temporary caretaker with whom they reside - the gross pay of the temporary caretaker therefore determines the income. Staff shall consider all sources of income for military families, except those excluded in Policy 8.006. The LA shall accept standard proof of income documentation, including exceptions, for military families listed in Policy 8.006. LAs shall consider the past 12 months of income for a military family whose income temporarily increases due to short-term hazardous duty, combat or other temporary situations. The current rate of income shall be considered when a military family’s income decreases due to a temporary situation. Military families are eligible for DC WIC if they physically live in the District of Columbia, but do not have to be residents of the District of Columbia.

VIII. Certification August 2021 8.008 - 5 Table 1. Summary of Special Cases Documentation and Certification Lengths Situation Documentation Required Certification Length No documentation of legal guardianship / temporary placement Signed “Self-Declaration of Relationship to Minor” form 30 days AR must follow up with appropriate documentation of legal guardianship or temporary custody Legal Guardian Notarized statement from court or attorney Full certification Temporary Caretaker Notarized statement from court or legal guardian; OR Proof of a child’s Medicaid, TANF, or SNAP benefits mailed in care of the caretaker Full Certification

Written statement from a social service or health care agency to include: 1. Child’s name and address 2. Caretaker’s name, address, phone number 3. Length of time the child will be in the care of the caretaker This can include “Safety Plans” from CFSA, provided the above information is included. The length of the caretaker’s arrangement, at which point the caretaker can provide documentation of extension or change in status to legal guardian, or the new guardian will need to provide their information and appropriate documentation. Foster Care or Protective Services Paperwork from appropriate Government agency. Full certification Ward of the District Paperwork from appropriate Government agency. Letter from child’s healthcare provider if guardians live outside DC. Full certification Note: See policy 8.012 – Authorized Representatives, for procedures on updating an infant or child’s primary AR during a certification period, in cases when there is a change of legal guardianship or custody.

VIII. Certification September 2021 8.009 - 1 8.009 Certification of Homeless, Migrants, Refugees CFR § 246.7(n) Certification of persons in homeless facilities and institutions I. Policy Statement Pregnant, breastfeeding and postpartum women, infants and children who meet WIC eligibility criteria and who live in a homeless facility, shelter, or institution shall be considered eligible for the WIC Program and shall be treated equally with all other eligible applicants at the local agency where they apply for WIC benefits. Refugees without residence and income may be certified along the guidelines for certifying homeless applicants, including refugees residing with sponsors as long as the sponsor is not providing the refugee with financial support. II. Procedures Regarding Facilities, Shelters, or Institutions that House WIC Participants

A. LAs shall take reasonable steps to:

• Establish to the extent practicable that the facility, shelter, or institution meets the following conditions with respect to resident WIC participants: i. The facility, shelter, or institution does not accrue financial or in-kind benefit from a person’s participation in the Program ii. Foods provided by the WIC Program are not included in a communal food service, but are available exclusively to the WIC participant for whom they were issued iii. The facility, shelter, or institution places no constraints on the ability of the participant to partake of the supplemental foods and nutrition education made available by the Program • Contact the facility, shelter, or institution periodically to ensure continued compliance with these conditions • Request the facility, shelter, or institution to notify the State or Local Agency if it ceases to meet any of these conditions B. LA staff shall inform participants who reside in facilities, shelters, or institutions that WIC food:

• Must only be consumed by the participant; • Must not be used by any other residents, and • Must not be stored in the facility or institution’s general storage area

C. LAs shall attempt to establish, to the best of its ability, whether a facility, shelter, or institution complies with the conditions set forth above with respect to the WIC participants.

D. If a homeless facility or institution has been determined to be non-compliant during the course of a participant’s initial certification period, participants applying for continued benefits may be certified again but LA staff shall not issue WIC food benefits except infant formula until the accommodation’s compliance is achieved or alternative shelter arrangements are made. If certified, such participants

VIII. Certification September 2021 8.009 - 2 shall continue to be eligible to receive all other WIC benefits, such as nutrition education and health care referral services.

E. Upon determination that a facility, shelter, or institution does not meet the conditions set forth above, LA staff shall refer all participants using such accommodation to any other accommodations in the area which meet these conditions.

F. The State Agency will notify LAs if it becomes aware that a facility, shelter, or institution does not comply with the conditions set forth above.

G. Correspondence from a facility, shelter, or institution shall be accepted as proof of residency.

H. LA Staff shall use the HANDS codes “does not exist” for proof of residency, identification, and/or if the homeless, migrant or refugee applicant cannot produce documentation. See policies 8.002 to 8.007 for more information on intake documentation.

I. LA Staff are not required to document a nutritional risk for homeless, migrant, or refugee applicants other than the risk code for homelessness (801).

J. LA Staff shall consider the cooking and storage capabilities of facilities, shelters, or institutions when prescribing supplemental foods and may tailor the food prescription as needed. K. LA staff must instruct the AR(s) of infants residing in facilities, shelters, or institutions regarding sanitary procedures to use in formula preparation and storage.

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.010 1 | P a g e Title: Anthropometric and Biochemical Data Collection Category: Certification CFR Reference: 7 CFR 246.7 Policy Number 8.010 Effective Date: December 1st 2021 Revised Date: April 30th 2024

POLICY STATEMENT: Anthropometric and Biochemical Collection Height, weight, and hemoglobin measurements must be performed and/or documented in the applicant’s record at the time of certification in accordance with 7 CFR 246.7(e)(1)(i)(A). Additional anthropometric and hemoglobin screening may be required depending on the participant’s category, certification length and/or nutritional risk. See Procedures section below for assessment frequency. Data submitted by a healthcare provider may be used to establish nutritional risk but must have been taken within the last 60 days for anthropometric data or last 90 days for blood work data. Hemoglobin screening may be deferred at the time of certification only if another qualifying nutritional risk is identified (see DC WIC Nutritional Risk Manual) and the participant or Authorized Representative (AR) agrees to submit the results of an outside blood test performed within 90 days of the certification. For women participants, the anthropometric and hemoglobin measurements must be reflective of her status (i.e., pregnant women must have their data taken during pregnancy; postpartum women must have data taken following the termination of pregnancy). Acceptable forms of anthropometric and biochemical documentation include: • Medical provider’s prescription form • Medical provider’s letterhead with measurements • DC WIC Medical Prescription Form • Medical records that include the date of measurements and the provider’s name • Verbal measurements from a medical provider The Local Agency staff must include the name of the provider organization in which the anthropometric and/or biochemical data was obtained in the “I” portion of the TGIF note. Blood Lead Screening and Referral Local Agency staff are to screen for blood lead testing for all participants at the time of certification. If the blood lead value is known, this value is to be documented in the participant’s record as part of the TGIF note. If the blood lead value is unknown or if a blood lead test has not yet been performed for a child participant, then a referral to the participant’s healthcare provider must be made in accordance with DC WIC policy 8.018 Referrals Overview.

Risk code 211 Elevated Blood Lead should be assigned if the blood lead value is higher than established cut-offs (see DC WIC Nutrition Risk Manual for more details).

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.010 2 | P a g e Clinic Laboratory Improvement Amendments (CLIA) Certificate A current CLIA certificate must be posted in each WIC clinic where hemoglobin assessments are performed. For WIC clinics with more than one lab, only one CLIA certificate needs to be posted. WIC clinic sites must have one of two types of CLIA certificates posted in laboratory space where hemoglobin screening is performed. The Local Agency should obtain a copy of the certificate from DC Health or the Local Agency’s lab director. Visit https://www.cms.gov/regulations-and-guidance/legislation/clia?redirect=/clia/ for more information on CLIA certificates and waivers. PROCEDURE Medical Consent Before taking anthropometric measurements and/or conducting a hemoglobin screening, the Local Agency staff member must inform the participant or AR the reason for performing these actions and obtain consent. The Local Agency staff member will collect the participant or AR’s signature under “Consent” on the Medical Screen in HANDS. If a participant or AR does not consent to the anthropometric collection or hemoglobin screening, then the Local Agency staff must request that these measurements be provided in accordance with this policy, or the participant may risk a delay in receiving WIC services. Anthropometric Collection Refer to the DC WIC Anthropometrics Manual for performing and collecting anthropometric measurements. All infant, children, and breastfeeding women must have height and weight measurements collected at certification and mid-certification appointments (approximately six months from the certification date) unless one of the exception criteria is met in DC WIC policy 8.003 Physical Presence. Biochemical Data Collection Refer to the DC WIC Lab Procedure Manual for performing hemoglobin testing for DC WIC participants. Frequency of Assessment Additional anthropometric and hemoglobin assessments are required at minimum based on the category and age of participant below (next page):

Biochemical Data Collection Chart Category Infant’s age at time of certification Frequency of hemoglobin testing Exceptions to Certification Blood Work Required

For all categories – at least one qualifying nutritional risk is present at certification and blood test result is obtained within 90 days of certification. Pregnant Women N/A One blood test per certification

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.010 3 | P a g e Postpartum Women 0-6 months *One blood test per certification, ideally between 4 to 6 weeks after end of pregnancy Breastfeeding Women 0 - 5 months One blood test per certification, ideally between 4 to 6 weeks after end of pregnancy

6 – 12 months No blood test required if a test was taken after end of pregnancy (documentation needed) Staff may accept a blood test result more than 60 days old (7 CFR 246.7(e)(1)(ii)(B)(3)). Infants 0-5 months Not required

6-8 months Not required at time of certification. The blood test may be performed after the infant is at least 9 months of age 9-11 months One blood test per certification

Children 12-24 months N/A Two blood tests needed by 24 months of age

If an infant blood test was performed, then only one additional blood test needed per certification

Children 24-60 months N/A At least one blood test per certification

Women less than 4 weeks postpartum Local Agency staff must use the pending lab code “LESS THAN 4 WEEKS POSTPARTUM” for women less than four weeks postpartum as HANDS does not allow a hemoglobin value to be entered at this time. The Local Agency may choose to perform the following: • Request the participant return between four to six weeks postpartum to have a hemoglobin test performed. • Request the participant submit hemoglobin test results obtained within 90 days of certification. • Perform the hemoglobin test at the time of certification and document this value in the participant’s TGIF note. Once the participant is more than four weeks postpartum, the Local Agency staff may enter this value into the participant’s Medical screen in HANDS using the date the test was initially performed.

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.010 4 | P a g e Low Hemoglobin Readings If the hemoglobin reading is below 10.0 g/dL, the Local Agency staff must perform a subsequent hemoglobin test. The subsequent test must be performed at a different site, preferably with a finger on the other hand. The higher of the two hemoglobin values is entered into HANDS and should be used for referral purposes.

Frequency of Testing for Low Hemoglobin Results A hemoglobin reading at or below 7.0 g/dL requires an immediate referral to the CPA and for medical attention. The CPA must ensure appropriate nutrition education and referrals are provided to address the low hemoglobin reading and conduct a high-risk follow-up appointment for retesting of the hemoglobin value in accordance with 2.008 Serving High Risk Participants. Exemptions from Hemoglobin Testing Hemoglobin testing may be waived for a participant that has one of following: • Religious objection • Medical condition such as hemophilia, thalassemia, or sickle cell anemia • If performing the test will cause physical harm to the participant or staff member If a participant meets the exemption criteria, the CPA/CPPA must document this in the participant’s TGIF note in accordance with DC WIC policy 2.005 Nutrition Education Overview. Blood Work Data Not Received in 90 Days If a participant is not able to provide the required hematological data within 90 days of certification, the Local Agency must require the participant to come to the clinic to obtain this data unless the participant falls under the existing exemptions in DC WIC policy 8.003 Physical Presence and Identification.

The participant will not be terminated for failure to provide the hematological data within 90-day time frame, provided that the CPA/CPPA has identified a nutrition risk for eligibility, in accordance with FNS WIC Policy Memo 2001-2 WIC Bloodwork Requirements and DC WIC policy 8.001 Certification Overview. REFERENCES 7 CFR 246.7(e)(1)(i)(A) DC WIC policy 2.005 Nutrition Education Overview, 2.008 Serving High Risk Participants, 8.003 Physical Presence and Identification, 8.018 Referrals Overview ATTACHMENTS & FORMS Policy Memo 2001-2 WIC Bloodwork Requirements (Attachment D) DC WIC Nutrition Risk Manual DC WIC Anthropometric Manual DC WIC Laboratory Manual

VIII. Certification September 2021 8.011 - 1 8.011 Certification Risk Determination & Considerations CFR § 246.7(e)(1) and (g) Nutritional Risk and Certification Periods; CFR § 246.2 Definitions

This policy provides considerations and reminders for each category of applicable WIC participants. Please see the DC WIC Program Certification Map for a full description of each step in the certification process, including rationale for each of the requirements.

I. Road to Certification Step Description Part of the: Notes & Greeting Begins the applicant’s appointment Intake & Eligibility Screening Intake / Eligibility Collecting, determining, and documenting eligibility based on category, residency, and income A, B, C, & E Anthropometric, Biochemical, Clinical, and Environmental data gathering Health & Nutrition Assessment D Diet/nutrition data gathering

Nutrition Education & Goal Setting Providing participant centered nutrition education based on the Health and Nutrition Assessment VENA / Participant Centered Counseling Summarize / New Appt Closing out the Assessment and planning for the next visit Food Package Assigning, tailoring, and issuing the food package; Discussing where and how to use WIC benefits Food Benefits Delivery TGIF Documenting in the participant’s HANDS record

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VIII. Certification September 2021 8.011 - 2 II. Pregnant women (PG1/PG2) Intake & Eligibility Screening i. A pregnant woman does not have to prove she is pregnant. If the LA has good reason to suspect the applicant of fraud or abuse, or if the applicant has a history or fraud or abuse, the LA may refuse service to the applicant. ii. A pregnant woman’s household is assessed by increasing it by the number of expected infants (unless the applicant has religious or cultural objections which preclude this). iii. Pregnant applicants under the age of 18 years must be assessed for income eligibility using income information from their parent(s), guardian(s), or other household members that provide financial support to the applicant, if possible. Health & Nutrition Assessment iv. Anthropometric and biochemical assessments shall reflect the applicant’s current participant status (i.e., pregnant women should have height, weight, and hgb assessed while pregnant) v. Evaluate maternal weight status using the prenatal weight grid (see the DC WIC Anthropometrics Manual, or Table 1., below) a. Weight status assessment and weight gain recommendations for pregnant teenagers will be based on the IOM’s nutrition during pregnancy Body Mass Index (BMI) categories vi. Income-eligible pregnant women are presumed to be at nutritional risk and can be certified immediately to receive program benefits for 60 days if the initial certification does not include a health & nutrition assessment. However, the health & nutrition assessment must be performed within 60 days and include anthropometric and hematological data vii. A pregnant woman shall be considered at risk if she meets at least one risk code criterion described in Policy 8.007 – Determining Nutrition Risk. If no risk is found after a complete assessment has been performed (including risk #427 - Inappropriate Nutrition Practices for Women), risk #401 - Failure to Meet Dietary Guidelines for Americans, must be assigned. Participant Centered Counseling viii. Offer an appointment and/or class with a breastfeeding peer counselor ix. Consider the applicant’s due date when scheduling their next appointment(s) Food Benefits x. Women pregnant with multiples and Pregnant women who are also breastfeeding an infant from a previous pregnancy receive the “fully breastfeeding” food package.

Table 1. Prenatal Weight Gain Grid Pre-pregnancy BMI : Underweight (BMI <18) Normal Weight (BMI 18-25) Overweight (BMI 25-30) Obese (BMI >30) A woman pregnant with one baby should gain: 28-40 lb 25-35 lb 15-25 lb 11-20 lb A woman pregnant with twins should gain: 50-62 lb 37-54 lb 31-50 lb 25-42 lb Source: https://www.cdc.gov/reproductivehealth/maternalinfanthealth/pregnancy-weight-gain.htm

VIII. Certification September 2021 8.011 - 3 III. Breastfeeding Women (EN, PN, PN+) Intake & Eligibility Screening No special notes Health & Nutrition Assessment i. Anthropometric and hematological data submitted by a health care provider may be used to establish nutritional risk but must be taken during the postpartum period and within 60 days of the certification date. ii. A breastfeeding woman may be determined to be at nutritional risk if her breastfed infant has been determined to be at nutritional risk. Select the highest priority level for which a mother or infant is qualified for the mother-infant dyad. iii. If no risk is found after a complete assessment has been performed (including for risk #427 - Inappropriate Nutrition Practices for Women), risk #401 - Failure to Meet Dietary Guidelines for Americans, must be assigned. iv. A breastfeeding assessment shall be performed before the issuance of Food Benefits at every visit. The results of the assessment shall be used to provide individualized breastfeeding support and to determine the appropriate food package. v. Review breastfeeding notes, as well, and refer participants to BPCs as needed Food Benefits vi. Breastfeeding women are eligible for the “fully breastfeeding” food package or the “partially breastfeeding” food package depending on the number of daily breast milk feedings provided to the infant.

IV. Postpartum Women (P) Intake & Eligibility Screening i. A woman who would have been eligible for the Program during her pregnancy who has had an abortion, spontaneous (miscarriage) or therapeutic, can also apply for Food Benefits. She is eligible for a total of six (6) months of food benefits from the date the pregnancy ended. Health & Nutrition Assessment ii. Anthropometric and hematological data submitted by a health care provider may be used to establish nutritional risk but must be taken following termination of pregnancy and within 60 days of the certification date. iii. A postpartum woman shall be considered at nutritional risk if she meets at least one risk criterion described in Policy 8.007- Determining Nutrition Risk. If no risk is found after a complete assessment has been performed (including for risk #427 - Inappropriate Nutrition Practices for Women), risk #401 - Failure to Meet Dietary Guidelines for Americans, must be assigned. Food Package No special notes

VIII. Certification September 2021 8.011 - 4 V. Infants (IEN, IPN, IPN+, IFF) Intake & Eligibility Screening i. Infants < 6 months of age shall be certified until their first birthday. Infants 6 to 12 months of age are certified for a 6-month interval. ii. Hospitalized infants cannot receive WIC benefits until discharged. Health & Nutrition Assessment iv. Anthropometric data submitted by a health care provider may be used to establish nutritional risk, but must be taken within 60 days of the certification date. v. All infants > 9 months of age and older shall have a hematological screening performed between 9-12 months of age if not previously conducted. Results may be obtained from a referral source. This hematological screening does not have to occur within 90 days of the certification date. vi. If an infant does not receive hematological screening during the infant certification period, the screening performed for the first child certification may be used to satisfy the requirement but must be performed by the age of 15 months. When this substitution is used, the screening data cannot be counted for the child certification period. vii. A breastfed infant can be certified based on the mother’s health & nutrition assessment. Staff should assign a breastfeeding mother and her infant to the highest priority level for which either is qualified. viii. An infant < 6 months of age may be determined to be at nutritional risk if the infant’s mother was a WIC participant during pregnancy or if medical records document that the woman was at nutritional risk during pregnancy due to detrimental or abnormal nutritional conditions detectable by biochemical or anthropometric measurements or other documented nutritionally related medical conditions. ix. An infant shall be considered at-risk if they meet at least one of the risk codes described in Policy 8.007 Determining Nutrition Risk. If no risk can be identified following a complete assessment (including for risk #411 - Inappropriate Nutrition Practices for Infants), risk #428 - Dietary Risk Associated with Complementary Feeding Practices, must be assigned for infants 4-12 months old. The CPA/CPPA must identify which Complimentary Feeding Practices are of concern in the participant’s HANDS record. Food Benefits x. Infants may receive standard infant formula tailored to their level of breastfeeding. For more information on breastfeeding assessment, see policy 9.006 xi. All special formulas require a prescription – see policy 9.009 xii. Powder formula should be issued unless the infant or caregiver meets conditions listed in policy 9.009; when RTU formula is issued, the reason must be documented in HANDS. xiii. At 6 months of age, infants may begin to receive infant food fruits, vegetables, and cereal; infants who are fully breastfed may also receive infant food meats. xiv. Infants 9-11 months of age receive CVB dollars in lieu of ½ the benefit of infant food fruits and vegetables ($4 CVB for infants fed formula, $8 CVB for fully breastfed infants) Medical Updates Medical updates shall be scheduled ~ 6 months following the initial certification for an infant who was certified at < 6 months of age. Income and eligibility do not need to be assessed at this appointment, but a complete health & nutrition should be performed. If the infant is determined to be high-risk by a CPPA during this appointment, a follow-up by a CPA is necessary.

VIII. Certification September 2021 8.011 - 5 VI. Children (C1 – C4) Intake & Eligibility Screening i. For children who reside with someone other than their biological parent, see Policy 8.006 for information about income eligibility. The child may either be counted as a household of one (1) or be included in the household of the guardian (legal or temporary). ii. Children enrolled in Free and Reduced Meal programs, such as the National School Lunch Program, are considered adjunctively eligible. Health & Nutrition Assessment iii. Anthropometric and hematological data submitted by a health care provider may be used to establish nutritional risk, but must be taken within 60 days of the certification date. iv. Staff shall evaluate the growth grids available in HANDS during the health assessment v. A child shall be considered at nutritional risk if they meet at least one risk criterion described in Policy 8.007 Determining Nutritional Risk. vi. If no risk is found after a complete assessment, to include for risk #411 - Inappropriate Nutrition Practices for Infants and #425 - Inappropriate Nutrition Practices for Children, then one of the following risk codes must be assigned: a. Risk #428 - Dietary Risk Associated with Complementary Feeding Practices (age 1-2), or b. Risk #401 - Failure to Meet Dietary Guidelines for Americans (ages 2-5)

Food Benefits Delivery vii. Children 12-24 months: a. Receive whole milk and yogurt unless contraindicated by a CPA’s assessment b. May receive peanut butter – staff should discuss the signs of peanut allergy with caregivers viii. Children 2-5 years: a. Receive low-fat milk (1% or skim) and yogurt unless the CPA assessment indicates the need for 2% milk (no Rx needed) or whole milk (Rx from medical provider is needed)

VIII. Certification December 2021 8.012 - 1

8.012 Authorized Representatives CFR § 246.7(j) Notification of participant rights and responsibilities; CFR § 246.12(r)(l) Parents/Caretakers and proxies I. Policy Statement

An Authorized Representative (AR) may apply for Program benefits for themselves or on behalf of an infant or child applicant. The AR is considered the primary person responsible for the participant enrolled in the Program. Adult participants are usually their own AR, but for infants and children the AR can be one of the following: • Parent • Caretaker • Legal guardian • Relative with whom the participant lives • Spouse or significant other • Individual who has significant knowledge of family history of the participant

The primary AR has the right to identify an Alternative Authorized Representative (AAR) during any point while in a valid certification but is not required to designate one. Both the AR and AAR shall have access to the family’s WIC records. In order to have rights and access to the family’s WIC records, an individual shall be recorded as an AAR in participant’s HANDS record.

ARs and AARs shall be instructed on the Rules and Regulations of the WIC Program, including how to use WIC Food Benefits. Refer to Policy Section IX – Food Benefits, for additional details.

The designated AR, and AAR if applicable, is required to sign the “WIC Rights and Obligations” signature type in HANDS. II. Procedures for Naming Authorized Representatives

A. If two ARs are present at certification: • Request identification from both Representatives and enter their names into HANDS on the Family screen, including what proof of ID was seen • “Rights & Obligations” signature type in HANDS shall be signed by one or both Authorized Representatives • Explain the WIC Rules and Regulations to the Authorized Representatives, including WIC-eligible foods and how to use the eWIC card to redeem Food Benefits. Staff shall ask questions to verify the AR’s understanding of how to use the eWIC card.

B. If the AR names an AAR who is not present: • Staff will add the first and last names of the AAR in the appropriate fields on the Family screen, and will select the “Other” from the Proof of Identity drop-down list • Staff will enter a Staff Alert stating AAR needs to show ID and sign R&O. However, no names shall be entered into the note, in order to ensure confidentiality.

VIII. Certification December 2021 8.012 - 2

C. If one AR is present and the AAR is not present at a subsequent certification: • Request identification (ID) from the present AR and update in HANDS what proof of ID was seen • For the AR who is not present, select “OTHER” from the Proof of Identity drop-down list • “Rights & Obligations” signature type in HANDS shall be signed by the present AR • When the AR who was not present at Certification returns to the clinic at a subsequent visit, ID will be verified and staff shall update the ID provided in the appropriate field on the Family screen in HANDS, and have the AR sign the R&O signature type in HANDS

Note: If the AAR is present and the primary AR is not present, the AAR can continue to sign the “Second AR Rights & Obligations” signature type in HANDS.

D. If the AR is contacting WIC remotely for non-certification appointments and names an AAR: • For non-certification appointments, staff shall verify identity by either reviewing the AR’s ID or using identifiers such as having the AR verify their date of birth, address, and/or phone number • Staff will add the first and last name of an AAR in the appropriate fields on the Family screen and will select “OTHER” from the Proof of Identity drop-down list • Staff will enter a Staff Alert stating that the AAR needs to show ID and sign the R&O; no names shall be entered into the note in order to ensure confidentiality

III. Change of AR during a Certification period (i.e., Change of Guardianship and/or Custody)

When an AR changes during a certification period (i.e., change in guardianship and/or custody) stating that the infant/child is currently under their care, the clinic may issue up to three (3) months of food benefits to the infant/child if ALL five (5) of the following conditions are met:

1. The new AR shall bring the infant/child participant to the WIC appointment. If they do not bring the infant/child to the clinic, they are to be rescheduled. 2. The new AR shall show proof of the infant/child’s ID. If ID is not available, staff can issue one (1) month Food Benefits and have the AR return the following month with the appropriate documents. 3. The new AR shall sign the “Change of Authorized Representative” Form declaring that they are caring for the infant/child and an explanation of the circumstances that led them to becoming the caretaker (visit “Policies & Forms page under Local Agencies on www.dcwic.org for the Change of Authorized Representative Form). 4. LA staff will assist the new AR with the written statement if they are unable to write, and he or she shall sign the statement or make their identifying mark (see Appendix 8.001a). 5. The income of the new AR shall be verified by WIC staff to ensure it meets the WIC eligibility criteria.

Procedure: A new Family ID number will be created in HANDS to accommodate the new AR’s demographic information. This procedure needs to occur even when the former and new AR(s) are from the same household. The infant/child will be transferred into this new family. The procedure is as follows:

1. In HANDS, identify the correct participant to be moved into the new family. Go to the Client screen.

VIII. Certification December 2021 8.012 - 3

2. If the new AR already has a HANDS record, select “transfer client” from the Client screen of the person to be transferred and select “existing family.” Search for the family you wish to transfer them into. Click the correct family and select “transfer client.” The participant is now in the new family. 3. If the new AR does not have an existing record in HANDS, select “transfer client” from the Client screen of the person to be transferred, and select “new family.” You will then be taken to a blank Family screen. Enter all information for the new AR. Click Save. The participant is now in the new family. 4. Proceed with the transaction. NOTE: Verify and document the new AR’s income. 5. The new AR shall sign the “WIC Rights and Obligations” signature type in HANDS. 6. If the new AR does not currently have an eWIC Card, an eWIC card will be issued to the family. The new AR shall sign the “eWIC Card Received” signature type in HANDS, if applicable. 7. The WIC staff member shall scan the completed Change of Authorized Representative form into the participant’s HANDS file.

VIII. Certification December 2021 8.013 - 1 Policy 8.013 Transfers and VOCs CFR § 246.7(k) Transfer of Certification I. Policy Statement

Transfers that are currently in a valid certification period shall be placed on the program when present at the receiving clinic.

II. Out of State Transfers

For our-of-state transfers within a valid certification period, the LA to which the participant is transferring shall:

• Confirm that at least one AR is present in the clinic at the time of transfer. Agencies utilizing a secured online platform such as Zoom, the transfer shall be completed when the staff and at least one AR begin the appointment. • Ensure that the participant was never participating in DC WIC by using HANDS to do a statewide search. o If the participant was once a DC WIC participant, staff shall transfer the participant(s) into their clinic first. o If the participant was certified in DC, transferred out of state, and then returned to DC WIC within the timeframe in which the certification is still current, the previous certification shall be reinstated. • Verify approved forms of ID and proof of residency for all transferring WIC participants. o If neither proof of ID nor residency are brought in at time of transfer, staff shall input “Forgot Documentation” and issue one month of Food Benefits. o Additional benefits shall NOT be issued until proof of ID and/or residency have been received. • Complete the Out-of-State Transfer screen in HANDS. o For participants transferring from another state WIC Program, clinic staff will select priority 0. • For the unique VOC number in the Transfer screen, use the 2-letter state abbreviation followed by the unique identifier on the actual VOC. If there is no unique identifier on the VOC, use the state abbreviation followed by the Participant or Family ID that is provided on the VOC. • Have AR(s) sign the “Rights and Obligations” signature type in HANDS and scan the VOC into the participant’s file in HANDS. • LA staff shall obtain the food instruments or eWIC card issued by the sending agency if still in the participant’s possession, if applicable. The receiving LA shall destroy the unused food benefits or eWIC card from the transferring participant.

III. Verification of Certification

LAs receiving transfers shall accept Verification of Certification (VOC) documents from other states.

A document containing the following information is to be considered a valid VOC:

VIII. Certification December 2021 8.013 - 2 • Name of participant • Beginning date of Certification • Ending date of Certification • Date of income determination • Participant’s nutrition risk • Normal signature and full printed/typed name of the certifying Local Agency official • Name and address of the certifying Local Agency • An identification number or other means of accountability • Identification of migrant status

IV. Partially Complete Verification of Certification (VOC)

A partially complete VOC will be considered proof of WIC eligibility if it contains the following information:

• Name of participant • Beginning date of Certification • Ending date of Certification period • Name and address of the certifying Local Agency

NOTE: Participants who arrive in a new service delivery area showing a partially complete VOC will be treated as if the VOC contained all the information.

V. Retention of VOC/Rights and Obligation

LAs will retain the VOC from the transferring agency by scanning it into the participant’s file in HANDS and having the AR sign the “Rights and Obligations” signature type in HANDS.

VI. Transfer When a Waiting List Exists

An individual transferring from out-of-state into a DC WIC Local Agency will be allowed to participate (unless there is a waiting list for all priorities) until the designated end of their current certification period.

VII. Special Conditions

Participants that transfer to DC WIC and present a VOC which indicates they are transferring from a State Agency with a shorter certification period than DC, but they are still in a current Certification, shall have their Certification period extended.

• Infants who have a Certification start date on the VOC that was prior to the infant turning six months old shall have their Certification extended to their first birthday.

• Children with six-month Certification periods on the VOC will have their Certification extended to one year from the Certification start date that appears on the VOC.

• Breastfeeding women with six-month Certification periods on the VOC will have their Certification extended to the infant’s first birthday.

VIII. Certification December 2021 8.013 - 3 VIII. In-State Transfers

For transfers within the DC WIC Program, the LA to which the participant is transferring shall do the following:

• Confirm that at least one AR is present in the clinic at the time of transfer. In agencies utilizing a secure online platform such as Zoom, the transfer shall be completed when the staff and at least one AR begin the appointment. • Verify the identity by either reviewing the AR’s ID or using identifiers such as having the AR verify their date of birth, address, and/or phone number. • Perform a statewide search using HANDS to locate the participant/family. • Assess the type of service(s) the participant/family needs by asking questions of the AR and evaluating the Certification information on the search screen in HANDS. If additional information is needed, contact the clinic in which the participant is transferring from for more details. • Inform the participant that transferring will automatically cancel any appointments they may have at the other clinic and request permission to transfer the participant/family. • Complete the In-State Transfer process in HANDS.

NOTE: Transfers over the phone are NOT permitted for the sole purpose of making an appointment in HANDS.

Once the transfer in HANDS is completed:

• If the participant/family is not in a current Certification, a Certification shall be completed. • If the participant/family is in a current Certification, the following will be completed in addition to providing the rest of the required services for that appointment: o Update Address and Voter Registration status on the Family screen in HANDS o Provide an updated Local Agency referral list

NOTE: A transfer from Navajo Nation WIC or Inter Tribal Council of Arizona, Inc. (ITCA) WIC programs is considered an out-of-state transfer.

IX. Transferring out of DC WIC

If a participant is transferring to a WIC Program in another state, staff shall provide the participant/AR with the VOC. If the participant/AR does not obtain a VOC ahead of time, the other state may request information about the incoming participant. The requested information will be faxed to the requesting program upon receipt of the request from the other state’s WIC Program.

NOTE: If the participant is in a “Conditional Certification” status and has pending eligibility documentation, staff shall write “30 Day Conditional Certification-Missing Eligibility Documentation” on the VOC before providing it to the participant or agency to which the participant is transferring. Staff shall specify which eligibility documentation was missing by writing it on the VOC.

VIII. Certification December 2021 8.013 - 4 X. WIC Overseas

When participants are transferring from WIC Overseas, DC WIC will utilize their signed VOC (also called a Participant Profile Report), and transfer them into DC WIC. The Out-of-State Transfer screen in HANDS shall be completed, the Rights and Obligation Form signed, and the Local Agency will scan the VOC Form into the participant’s HANDS record.

If the participant does not have a VOC, contact WIC Overseas at 1 (877) 267-3728. If the applicant is not in a valid Certification period, they will begin a new Certification period if still eligible.

When participants are transferring to WIC Overseas, participants will use their DC WIC Program VOC printed from HANDS.

VIII. Certification December 2021 8.014 - 1 8.014 Ineligibility CFR § 246.7(j) Notification of participant rights and responsibilities I. Policy Statement Persons found ineligible for the Program during a certification visit must be advised in writing of the ineligibility, of the reasons for the ineligibility, and of the right to a fair hearing. The reasons for ineligibility must be properly documented and must be retained on file at the local agency.

II. Notification of Ineligibility The Notification of Ineligibility form notifies applicants and participants of their right to a fair hearing, of the reason they were determined ineligible for the program and/or the reason for a program disqualification. This form is available in HANDS or under “Policies and Forms” page under Local Agencies at www.dcwic.org. A signature is not required.

Persons found ineligible at the time of certification shall be issued the DC WIC “Notification of Ineligibility” form. Staff shall ensure the name of the participant is on the form. It is not necessary or required to issue this form when category changes are made, as category changes do not lead to appeal rights. Those who change categories after a certification shall be notified verbally of their new certification dates.

A person who will be disqualified from the program by the State Agency shall be issued the Notification of Ineligibility form no less than 15 days before the disqualification.

NOTE: Staff shall not make photocopies of applicants’ proof of income. LA Staff shall use the termination codes listed in Appendix 8.001c when terminating certifications. III. Information About Reapplication

Applicants will be informed on how to reapply if conditions change or if they obtain the necessary documentation.

IV. Referrals

Applicants will be given written information regarding other food assistance programs for which they may be eligible.

VIII. Certification 8.015 - 1 December 2021 Policy 8.015 Violations and Sanctions CFR §246.12 (u) Participant violations and sanctions

I. Policy Statement

DC WIC will implement policies and procedures for the detection of fraud and abuse within the Program, and may disqualify, terminate, and/or assess fines as outlined in this policy.

II. Definitions:

a. Abuse - An intentional infliction of physical harm and/or to attack with verbal words. This can include, but is not limited to, ridiculing or being demeaning, making derogatory remarks toward or verbally harassing another.

Abuse is also defined as misuse: to use something in an improper, illegal, or harmful way.

b. Fraud - An intentional misrepresentation of the truth to deceive others for the purpose of acquiring something of value, such as a financial gain or WIC benefits. Anything calculated to deceive, whether it be by a single act or combination, by the suppression of truth, or by a suggestion of what is false, whether it is by a direct lie (deception), silence, omission, a look, or a gesture. An example of fraud could be the selling of an issued food instrument (i.e. eWIC card or Farmers’ Market Nutrition Program check) and/or state issued equipped (i.e. breast pump, accessories) for personal gain; an act which intentionally deceives the WIC program and abuses one’s benefits.

c. Intent to Violate - Any intentional action of a participant, parent or caretaker of an infant or child participant that violates Federal or State statutes, regulations, policies, or procedures governing the Program.

• For the purposes of DC WIC, an intentional violation is defined as a participant making a verbal offer to sell to another individual or providing the posting of WIC foods, WIC items or any other issued WIC benefits for sale, given away or traded online, in any type of printed manner (newspapers, etc.), or allowing someone else to conduct this act for them (knowingly or unknowingly), would be evidence that the participant has intentional, whether direct or indirect, committed a participant violation.

d. Participant Violation - Intentional activities or actions of DC WIC participants or their ARs taken to obtain benefits to which they are not entitled and/or to misuse benefits they receive. Activities and actions include, but are not limited to:

• Misrepresenting facts used to determine eligibility (e.g. total household income, age of children, existence of children, custody of children, address, etc.) • Exchanging/substituting food benefits for non-approved items (e.g., cash, alcohol, or tobacco products, sundries, etc.) • Selling or giving away foods obtained with WIC issued food benefits

VIII. Certification 8.015 - 2 December 2021 • Selling or attempting to sell (either in person, online, or through any other means available), WIC foods or WIC items (i.e. Breast pump, breast milk storage bags, and/or other accessories) received through the WIC Program. • Participating at more than one WIC agency simultaneously (dual participation) • Verbally/physically abusing WIC vendors and/or WIC staff

III. Participant Disqualification for Program Fraud

DC WIC participants shall receive written warning or be disqualified when an investigation and supporting evidence/documentation verifies that participant fraud has occurred.

The State Agency reserves the right to disqualify participants for other actions not listed herein if the participant violates any program policies and/or regulations.

Disqualification Without Warning Serious substantiated violations of program integrity, such as the sale of WIC food benefits or breast pumps will result in disqualification without any prior warning. Warnings before sanctions are at the sole discretion of the State Agency and are conducted on a case by case basis.

Participants Rights and Responsibilities When Disqualified Participants have the right to appeal any denial, claim or disqualification at a fair hearing or an informal dispute resolution conference. Participants shall be provided, within a minimum of 15 calendar days, written notice prior to a disqualification. For more information on hearing and informal dispute resolution procedures, see Local Agency Policy and Procedure Manual section 12.

Exception for Disqualification The State Agency may decide not to impose a mandatory disqualification if, within thirty (30) days of receipt of the notice of repayment, full restitution is made or a repayment schedule is agreed upon. A participant will have the opportunity to provide a personal statement explaining the circumstances surrounding the loss of the pump. All decisions are at the discretion of the State Agency.

Reapplication A participant may be permitted to reapply for the program before the end of a disqualification period if full repayment is made or a repayment schedule is agreed upon.

IV. Dual Participation within DC WIC

When Local Agencies are faced with factors/situations that include participants traveling routinely between local services located across the State Agency Borders, dual participation must be evaluated and consequences discussed when a participant received benefits from more than one (1) State WIC Agency. Examples of these factors/situations may include the following: lack of geographic barriers and common vendors. If Dual Participation is determined, the sanctions in Section VII, #14 and #15, are to be followed. The State Agency will produce Dual Participation Reports. The purpose of Dual Participation Reports is to detect potential dual participation within DC WIC.

VIII. Certification 8.015 - 3 December 2021 A. State Agency Responsibilities The State Agency will:

• Coordinate efforts with LAs when potential dual participation has occurred • Request supporting documentation from LAs to include, but not limited to, signature receipts and signed Rights and Obligations forms • Conduct an exhaustive investigation to determine if dual participation occurred and will inform LAs of the necessary course of action and/or sanction

B. Local Agency Responsibility Local Agencies will:

• Request information from applicants about previous participation in other WIC programs • Appropriately handle potential dual participants when prompted by HANDS • Notify the State Agency, in writing, of any identified possible dual participation within 15 business days of discovery • Provide information as requested by the State Agency • Coordinate with the State Agency to impose appropriate sanction when dual participation has been determined

V. Responsibilities

State Agency Local Agency Consult with the Attorney General’s Office in cases of alleged fraud and abuse, and if appropriate, the USDA Office of the Inspector General and/or Local Law Enforcement. Document all allegations of Program abuse or fraud. Responsible for incoming reports of Program abuse or fraud to the State Agency by email, phone, or www.dcwic.org, and any/all information obtained. In all cases where Program abuse or fraud is alleged against a participant, the Local Agency shall immediately contact the Nutrition Services team and provide supporting documentation to the State Agency. Verify information regarding alleged participant abuse and/or fraud, and will retain documentation. Consult with the State Agency prior to taking any action regarding participant abuse and fraud. Following a thorough investigation, the State Agency will determine the appropriate participant sanction (if applicable). If there is a sanction, the Local Agency will advise the participant of the Program requirements they violated (i.e. what they did wrong, and the correct procedure). Determine the amount of funds improperly received by the participant. Assist the participant in preparation and submission of their written request for an appeal of a claim and/or a Program disqualification. (See Appendices B and C for appeal procedure forms). Assist the participant with completing a repayment schedule for claims.

VIII. Certification 8.015 - 4 December 2021 When an investigation has verified fraud or abuse, the State Agency will send a certified letter to the participant regarding the sanction and, if appropriate, the amount of repayment requested. A copy of the certified letter will be sent to the Local Agency. Provide the participant with Program benefits (i.e. food package) as stated below. Inform the participant of their right to appeal a claim or a Program disqualification. Provide program benefits to participants who appeal disqualification within fifteen (15) calendar days of the written notification of disqualification until the appeal is decided, the participant becomes categorically ineligible, or the certification periods expires, whichever occurs first. Provide an informal dispute resolution meeting and/or a fair hearing.

VI. Claims If the State Agency determines that Program benefits have been obtained or disposed of improperly as the result of a participant violation, the State Agency will establish a claim against the participant for the full value of the improperly received benefits, in addition to applying any appropriate sanctions per the sanction schedule. Following an investigation that has confirmed there was a participant violation, the State Agency will: • Determine the amount of any improperly received benefits. • Establish a claim against the participant for the full value of the improperly received benefits. • Send the claim by certified mail to the participant and an electronic copy to the Local Agency If the participant chooses to appeal the claim, the Local Agency may assist in completing the appeal request. If the participant chooses a repayment plan for claims, the Local Agency will assist in developing a payment schedule.

If the participant has not paid the State Agency directly within 15 days of the notice, the participant’s account will be flagged internally and benefits will be restricted until the claim is paid. If full payment or a payment schedule has not been established after two (2) letters demanding repayment, the State Agency will not pursue further collection sanctions under $500.00. If the sanction exceeds $500, the Office of Inspector and Compliance (OIC) will assist the State Agency in recovering the claim.

VIII. Certification 8.015 - 5 December 2021 VII. Types of Violations and Sanctions

ABUSE SANTION 1. Using Food Benefits to buy unauthorized food equaling $99 or less 1st – 90 day disqualification and repayment 2nd – Disqualification of 1-year and repayment 2. Using Food Benefits to buy unauthorized food equaling $100 or more 1-year disqualification and repayment 3. Exchanging food benefits for credit or non- food items 1st – 90 day disqualification and repayment 2nd – Disqualification of 1-year and repayment 4. Direct or indirect theft of food benefits 1-year disqualification, repayment, referral to the appropriate Law Enforcement Authorities, and possible referral to SNAP authorities 5. Deliberate misrepresentation of any intake criteria to obtain WIC benefits, including: • Income • Residency • Family size • Health status

Immediate termination, 1-year disqualification, and repayment 6. Attempting to sell WIC foods, WIC items or any other WIC-issued benefits either verbally, online, in any type of printed manner (newspapers, etc.), or knowingly allowing someone else to conduct this act for them, with or without that person’s knowledge of WIC participant fraud, abuse and misuse

1st – 90-day disqualification and possible referral to SNAP authorities 2nd – 1-year disqualification and possible referral to SNAP authorities 7. Selling supplemental food that was purchased with WIC food benefit(s) (to include infant formula) and/or WIC-issued items (i.e., personal or hospital-grade breast pumps). 1-year disqualification, repayment, and possible referral to the appropriate Local Enforcement Authorities, and possible referral to SNAP authorities 8. Attempting to give away or trade WIC foods, WIC items or any other WIC-issued benefits either verbally, online, in any type of printed manner (newspapers, etc.), or knowingly allowing someone else to conduct this act for them, with or without that person’s knowledge of WIC participant fraud, abuse and misuse 1st - Written Warning 2nd - 30-day disqualification 3rd - 90-day disqualification 9. Giving away or trading supplemental food that was purchased with WIC food benefit(s) (to include infant formula) and/or WIC- issued items (i.e., personal or hospital-grade breast pumps). 1st - 30-day disqualification 2nd - 90-day disqualification

VIII. Certification 8.015 - 6 December 2021 10. Using food benefit(s) at unauthorized stores and/or through any other unauthorized channels. 1st - 90-day disqualification and repayment and possible referral to SNAP authorities 2nd - 1-year disqualification and repayment and possible referral to SNAP authorities 11. Creating a public nuisance, or disrupting normal activities through verbal misconduct at the Local Agency or at any DC WIC- authorized vendor. 1st - Warning letter 2nd - 30-day disqualification 3rd - 1-year disqualification 12. Threatening harm to Local Agency or Vendor staff. 1-year disqualification and possible referral to the appropriate Law Enforcement Authorities 13. Physically abusing Local Agency or Vendor staff or property 1-year disqualification and reported to Law Enforcement 14. Dual participation: using food benefits(s) from two programs/agencies in the same month, includes WIC programs from surrounding states (VA, MD, PA, WV, etc). Immediate termination from all but one (1) program/agency received, full repayment of the dual benefits to other Programs, and possible referral to SNAP authorities 15. Dual Participation resulting from intentional misrepresentation. 1-year disqualification from all Programs, repayment of all benefits, and possible referral to SNAP authorities 16. Assessed a claim for $100 or more. 1-year disqualification and repayment. 17. Assessed a 2nd claim or subsequent claim, for any amount 1-year disqualification and repayment. 18. Trafficking WIC food benefits, WIC benefits, or other WIC-issued items and/or collusion with an authorized vendor. 1-year disqualification and repayment referral to the appropriate Law Enforcement Authorities and possible referral to SNAP authorities

Note: Combined sanctions may be applied when more than one kind of violation, actual or attempted, is involved in an instance of abuse.

VIII. Certification December 2021 8.016 - 1 8.016 Rights & Obligations 7 CFR 246.7(j) Notification of Participant Rights & Obligations I. Policy Statement

Participants and ARs shall be informed of their WIC Rights and Obligations (R&O) at every Certification and out-of-state transfer(s), in their preferred language. WIC staff shall read out loud, at minimum, the highlighted sections of the R&O to the applicant/AR (in a language they understand). The highlighted sections include:

• Health Information • Fair Treatment • Honesty • Accurate information • Good Use of the Program • Protect your Benefits

WIC staff shall inform the participant or AR that the complete R&O can be found online at dcwic.org and offer a copy (paper or electronic) each time the R&O are signed.

II. Documentation

Documentation of WIC R&O shall be completed at every certification and out-of-state transfer by having the participant/AR sign the signature type “Rights and Obligations” on the signature pad in HANDS.

III. Paper Rights and Obligations Form

If, for some reason, HANDS is not available to capture signatures on the “Rights and Obligations” signature type and/or the “Consent” signature type, a paper copy of the R&O Form shall be used. This form can be found on dcwic.org under Local Agencies > Policies & Forms. The form can be used for all members of the WIC family if desired.

1. The form shall be signed and dated at each certification by the AR and the certifier or income verifier. LAs are required to have systems in place to obtain a signature if an AR forgets to sign. 2. The AR’s initials are necessary and serve as permission that staff can weigh/measure and check hemoglobin status for each participant listed on the form. Additionally, the AR can agree to receive assistance with breastfeeding, if applicable. 3. Fill in the Family ID # in the table. 4. Fill in only the names of participants being certified on that particular day. 5. The height/weight/hemoglobin fields are not mandatory; however, LAs may choose to create a LA policy to make those fields mandatory. 6. The vertical bubbles for Family ID # and Authorized Representative Name are not mandatory; however; LAs may choose to create a LA policy to make those fields mandatory. The fields will prefill if the form is printed from HANDS. 7. Signed R&O forms must be scanned into the participant’s HANDS record.

VIII. Certification September 2021 8.017 - 1 8.017 - Voter Registration National Voter Registration Act (NVRA) (1973), Pub L, 103 931 §7(a)(5); DC Official Code § 1-1001.07; 11 CFR 8.2; 11CFR 8.3(c), and 7 CFR 246. I. Policy Statement LA staff shall provide each applicant, participant, or - in the case of infants and children – authorized representatives (ARs) the opportunity to register to vote:

• With each application for Certification or Recertification • With each transfer, including a change of address • When the participant or AR reports a change of address

LA staff providing voter registration assistance shall not:

• Seek to influence an applicant’s or participant’s or AR’s political preference or party registration • Wear or display any material that o Identifies past, present, or future seekers of partisan elective office o Contains logos or other graphics that may be identified with a political party or preference o Would reasonably be associated with a political party or preference o Identifies a political issue or ballot measure • Make any statement to an applicant, participant, or AR or take any action, the purpose or effect of which is to discourage the applicant from registering to vote

LA Staff shall advise applicants, participants, or ARs that: • The voter registration process is separate from the WIC Program eligibility process • An interview is not necessary to register to vote

LA Staff shall ensure the confidentiality of the Voter Registration process

LA Staff shall complete training developed by the State Agency upon hire and annually thereafter.

II. Voter Registration Procedures

LA Staff will follow use the following procedure when offering an applicant, participant, or AR the opportunity to register to vote:

1. Ask the applicant, participant, or AR if they are registered to vote at their current address a. If they say “yes” – document in HANDS b. If they say “no” – go to step 2

2. Ask the applicant, participant, or AR if they are interested in registering to vote today. Inform them that they can complete the voter registration form at the clinic or they may take it with them and mail it in later (postage is paid). Also inform them that applying/denying to register to vote will not affect their application or enrollment in DC WIC.

VIII. Certification September 2021 8.017 - 2 a. If they say “no” – document in HANDS record. If the applicant does not provide a reason for saying no, staff may use their best judgment in whether or not to probe for why the applicant is not interested in registering to vote. Staff may select “not interested”, or “not yet 18” in the HANDS record. b. If they say “yes” and want to complete the form later – provide a physical copy of the form and/or show the applicant a link or QR code to where they can find the voter registration form online. Document using “refused, gave form” in HANDS record. Using this code will help DC WIC identify between participants who were not interested in registering to vote and those who were interested but did not do so on site. c. If they say “yes” and want to complete the form onsite – see step 3

3. Provide the applicant with a DC Voter Registration Form to complete. Staff shall also inform the applicant, participant, or AR of the availability of the Federal Voter Registration Form. a. Staff will assist the applicant, participant, or AR when requested. Assistance provided shall be to the degree that assistance is provided for completing a WIC form. b. When the client has completed the voter registration form, review it completely to ensure that it contains all of the information required for voter registration, including the applicant’s signature. c. Inform the client that you will send the voter registration form to the DC Board of Elections (DCBOE) and that they should receive their voter registration card within three weeks if the form was accepted. If they do not receive their voter registration card within three weeks, they should contact DCBOE. d. Mail the voter registration form to DCBOE within five (5) calendar days i. LA Best Practice: Mail voter registration forms the day they are completed, or store them in a secure location and mail any collected forms on Friday morning each week.

III. HANDS Documentation

LA staff shall indicate in the Voter Registration field in HANDS the response given by the applicant, participant, or AR either. HANDS will not allow a certification appointment to be completed until Voter Registration status has been documented. The following table lists HANDS documentation codes for Voter Registration, and when to use them:

Code Explanation When to Use CR Currently Registered If client states they are registered already at their current address NO Not Interested If client is not currently registered and does not want to register NA Not yet 18 years of age If client is under 18 years old and is not eligible to register RG Refused, gave form If client took a form home with them or said they would register online YG Yes, Gave Form If client completed form onsite and LA staff mailed it to DCBOE

VIII. Certification September 2021 8.017 - 3 IV. State Agency Responsibilities

The DC WIC State Agency will assume the responsibilities of both the “Voter Registration Site Coordinator” and the “Voter Registration Agency Coordinator”. The HANDS MIS allows the State Agency to pull reports for each LA, by clinic site, on certification appointments and voter registration indication. The State Agency will use such reports to chart the following information on a monthly basis for reporting to DCBOE:

LA 1 LA 2 LA 3 LA 4 Total # Certification appointments

# Clients currently registered (CR)

# Clients not interested (NO)

# Clients not yet 18 (NA)

# Clients took form offsite (RG)

# Clients completed form onsite (YG)

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.018 1 | P a g e Title: Referrals Overview Category: Certification CFR Reference 7 CFR 246.7 7 CFR 246.11 Policy Number: 8.018 Effective Date: December 1st, 2021 Revised Date: April 30th, 2024

POLICY STATEMENT: In accordance with 7 CFR 246.7(b) the Local Agency must provide program applicants and participants with information on other health-related and public assistance programs and when appropriate, shall refer applicants and participants to such programs. Each referral provided to the participant must be documented in the participant’s record in the MIS. The Local Agency must also ensure that: 1. Each participant is made known of adjunct eligibility programs and provided appropriate referrals as applicable to the Supplemental Assistance Nutrition Program (SNAP), Medicaid, the National School Lunch Program (NSLP), and Temporary Assistance for Needy Families (TANF). 2. Each participant under the age of two is provided screening for immunization status and appropriate referrals for immunization (FNS WIC Policy Memorandum #2001-7). 3. All participants are screened for blood lead testing (FNS Policy Memorandum 93-3A – WIC’s Role in Screening for Childhood Lead Poisoning) in accordance with DC WIC policy 8.010 Anthropometric and Biochemical Data Collection and refer all child participants to their healthcare provider if testing has not been performed or if the Authorized Representative (AR) is unsure of the child participant’s blood lead value. 4. A listing of community resources for substance abuse is maintained and available for distribution in accordance with 7 CFR 246.7(a) and DC WIC policy 8.020 Substance Use Screening and Referral. 5. Referral procedures are established for high-risk participants in accordance with DC WIC policy 2.008 Serving High Risk Participants and participants needing breastfeeding support in accordance with DC WIC policy 2.009 Breastfeeding Education and Support Overview. PROCEDURE 1. Each referral provided to the participant must consider their individual needs based on the nutrition assessment, environmental concerns, and/or living conditions. Referrals to other health-related and public assistance programs can include: • Local food banks, pantries, or other food assistance programs • Housing assistance • Early childhood services • Childcare • Dental care • Prenatal care • Shelters and other services for domestic violence • Infant care supplies • Mental health services

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.018 2 | P a g e Local agency staff are encouraged to use approved online referral resources such as https://linkudmv.org/. 2. Any referral that is made to directly assist the participant in achieving their health outcome- based goal must be documented in the “I” portion of the TGIF note in accordance with DC WIC 2.005 Nutrition Education Overview. • For example, a referral to the Produce Plus Program is made to the participant to assist in achieving their goal of consuming a fresh fruit and vegetable at least once per day. 3. See additional DC WIC policies for more information on referral procedures for: • Immunization Screening and Referral – 8.019 • Substance Use Screening and Referral – 8.020 • Domestic Violence and Neglect – 8.021 REFERENCES 7 CFR 246.7(b) FNS WIC Policy Memorandum #2001-7 DC WIC policies 2.005 Nutrition Education Overview, 2.008 Serving High Risk Participants, 2.009 Breastfeeding Education and Support Overview, 8.020 Substance Use Screening and Referral ATTACHMENTS & FORMS

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.019 1 | P a g e Title: Immunization Screening and Referral Category: Certification CFR Reference Policy Number: 8.019 Effective Date December 1st, 2021 Revised Date: April 30th, 2024

POLICY STATEMENT: The Local Agency must screen all infants and children under age two for DTaP immunization status, document according to the procedures below in the participant’s record in the MIS, and provide appropriate referrals, as needed. PROCEDURE Immunization Screening At each initial certification and subsequent certification appointments, the Local Agency staff member will verify with the Authorized Representative (AR) if the infant or child is up to date on DTaP vaccinations based on the schedule below (also available in HANDS): Age Recommended number of DTaP doses 2-3 months 1 dose 4-5 months 2 doses 6-17 months 3 doses 18-24 months 4 doses

Immunization Documentation Acceptable forms of immunization status verification include a documented record that lists both the vaccination type administered and date received. This can include: • An immunization record from a medical provider • An immunization registry • An electronic medical record Missing Immunization Documentation If the immunization record is missing at the time of certification: 1. Encourage the caretaker to provide the immunization record at their next WIC appointment. 2. Provide the recommended immunization schedule for the infant or child. 3. Refer the participant to their healthcare provider or local immunization program and document this referral in the participant’s record in the MIS. Immunization Referral A referral should be provided if the AR is unsure of their infant or child’s immunization status or if the child is under-immunized (i.e. not up to date on the recommended number of DTaP doses). A referral is not needed if the AR states the family does not vaccinate. This reason must be documented both on the “Immunization” screen (under “No Assess Code”) and in the “I’ portion of the TGIF note in accordance with DC WIC policy 2.005 Nutrition Education Overview. It is additionally recommended to place a Staff Alert for the family that does not vaccinate.

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.019 2 | P a g e REFERENCES FNS WIC Policy Memo #2001-7 DC WIC policy 2.005 Nutrition Education Overview ATTACHMENTS & FORMS

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.020 1 | P a g e Title: Substance Use Screening and Referral Category: Certification CFR Reference: 7 CFR 246.7(a) 7 CFR 246.7(n)(2) Policy Number: 8.020 Effective Date: September 1st 2021 Revised Date: April 30th, 2024

POLICY STATEMENT: In accordance with 7 CFR 246.7(a), 7 CFR 246.7(n)(2), and 7 CFR 246.11(a)(3) the Local Agency must ensure: 1. Local Agency Resource List - A listing of local resources for drug and other harmful substance abuse counseling and treatment is maintained and made available for distribution to all pregnant, postpartum, and breastfeeding women and to parents or caretakers of infants and children in the DC WIC program, as required by Public Health Law 101-147. 2. Screening - Drug and other harmful substance abuse screening is performed at certification as part of the nutritional assessment for all pregnant, postpartum, and breastfeeding women and to parents or caretakers of infants and children. 3. Brief Intervention (Education) and Referral - Education on the harmful effects of drug and other harmful substances is provided at certification, and if needed, a referral is made to the participant or to the parent or caregiver of an infant or child. Education needs to be provided once per certification. 4. Documentation - The CPA/CPPA documents the education and referral (if provided) in the participant’s record in the MIS (see DC WIC policy 2.006 Nutrition Education Documentation). PROCEDURE Substance Abuse Screening Substance abuse screening must be performed at certification for all pregnant, postpartum, and breastfeeding participants and to parents or caretakers to infant and child participants as part of the nutrition assessment. The CPA/CPPA should ensure privacy and conduct the screening process in a nonjudgemental manner. Screening questions can include: 1. Have you ever had difficulties in your life because of alcohol, smoking, or other drug use, including unprescribed medications? 2. Do you have any concerns about the use of drug, alcohol, or other harmful substances for yourself or someone who spends a significant amount of time with you and/or your child? If the participant or parent or caretaker of an infant or child participant responds “no” to either screening question above, then general substance use education must be provided (see below). If the participant or parent or caretaker of an infant or child participant responds “yes” to either screening question above, then the CPA/CPPA must further evaluate if any nutritional risk codes should be applied to the participant (see DC WIC Nutrition Risk Manual) and provide tailored substance use education (see below).

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.020 2 | P a g e Substance Use Brief Intervention (Education) and Referral All participants and caretakers must receive brief intervention education on the harmful effects of substance use at the time of certification. Depending on the response provided by the participant or caretaker above, the CPA/CPPA must provide one of the following forms of education: 1. General education – if the participant or caretaker responds “no” to the substance use screening questions and/or if the participant does not appear to need tailored substance use education. The CPA/CPPA may perform the following: a. Provide brief education related to the dangers of substance use. Staff may reference the “Give Your Baby a Healthy Start” handout or the “Substance Use: Risk to You and Your Family” handout created by DC WIC (handouts are available on www.dcwic.org). b. Provide the local agency listing of substance use resources. Staff may describe how to access resources online. 2. Tailored Education – if the participant or caretaker responds “yes” to the substance use screening questions and/or if a substance use related nutrition risk code has been identified for the participant. The CPA/CPPA should discuss the answers provided to the substance use screening questions and the potential substance abuse problem. The CPA/CPPA should provide the brief intervention in a positive framing, such as below:

Accentuate the Positive and Avoid the Negative (Source – FNS Substance Use Prevention Guide) Positive Negative If you stop drinking now, you have a better chance of having a healthy baby. Your drinking has already damaged your baby. Your concern for your baby will help you be a good mother. If you really loved your baby, you would not drink so much. You will feel better when you are sober and so will your child. Continued drinking will ruin your health and prevent your child from developing normally.

Substance Use Referral The information collected from the substance use screening and nutrition assessment must be used as the basis of providing a general or tailored substance use referral to the participant: • Informal (general) – the referral can be considered general if the participant receives general education related to substance use and its harmful effects. • Semi-formal (tailored) – the referral can be considered semi-formal if the participant responds “yes” to the substance use screening questions and the CPA/CPPA works with the participant to identify specific resources that may best address the substance use concern. A tailored referral must be documented in the “I” portion of the TGIF note. • Formal (tailored and action-based) – the referral can be considered formal if the participant responds “yes” to the substance use screening questions and the CPA/CPPA initiates contact

DC WIC POLICY & PROCEDURE MANUAL

Policy 8.020 3 | P a g e with an assessment, counseling, treatment, legal, or any substance use-related agency on behalf of the participant. This type of referral is generally considered outside the normal practice for WIC staff and requires a Release of Information form to be signed by the participant or Authorized Representative in accordance with DC WIC policy 12.019 Confidentiality. • No referral – there may be cases where no referral is made for the participant at the time of certification such as if the participant or caretaker denies the request for a referral to substance use services. A referral denial must be documented in the “I” portion of the TGIF note for the participant in accordance with DC WIC policy 2.005 Nutrition Education Overview. Documentation The CPA/CPPA must ensure that the brief intervention (education) and referral (if applicable) are documented in the participant’s record at the time of certification as follows: • The education provided (either general or tailored) must be documented in the “I” portion of the TGIF note for the participant at the time of certification. • If a referral is provided, it must be documented under the “Referrals” tab of participant’s record in the MIS. o If the referral is a tailored (i.e. formal) referral, this information must be documented in the “I” portion of the TGIF note. o If the participant or caretaker refuses a referral for substance use, this must be documented in the “I” portion of the TGIF note. REFERENCES 7 CFR 246.7(a) 7 CFR 246.7(n)(2) 7 CFR 246.11(a)(3) DC WIC policy 2.005 Nutrition Education Overview, 2.006 Nutrition Education Documentation, 12.019 Confidentiality ATTACHMENTS & FORMS Substance Use Prevention Guide (USDA – WIC) Substance Use Screen / Educate / Refer Cheat Sheet DC WIC Nutrition Risk Manual

VIII. Certification December 2021 8.021 - 1 8.021 - Domestic Violence And Neglect District of Columbia law (see D.C. Code §22-3020.52[a]); D.C. Code §4-1321.02)

I. Policy Statement

Abuse is most often perpetrated by one person to another with whom they have an intimate or family relationship. While domestic violence of an adult is not considered a reportable offence, state law requires reporting suspected child sex abuse. Reporting suspected physical abuse or negligence of children is also encouraged.

II. Abuse of adult participants

In the HANDS participant Assessment screen under letter E (Environmental/Other Factors) probing questions, there is a question on abuse that must be asked at every certification, unless the safety of the participant would be at risk with a potential abuser present. If the participant or authorized representative answers “yes,” Local Agency Policy and Procedures must be followed.

The safety of the client must be the first priority. Some questions that can be asked include: • “Do you have a safe place to go?” • If client is residing in a safe place, ask, “Do you want to talk to someone about your abusive situation?” • “Do you want a referral to a safe house, program, or hotline for abuse?” • “Is it safe to give you information on abuse to read?” o In many cases, if the abuser sees materials on the subject, the safety of the client could be jeopardized. o If the client does not want the referral materials, WIC staff can offer to write down telephone numbers or addresses for the clients.

Staff must have information available on domestic violence service providers in their area. Domestic Violence resources for DC residents can be found on the Metropolitan Police Department’s web page at https://mpdc.dc.gov/page/domestic-violence-resources

III. Child Abuse Everyone Has an Obligation to Report Child Sex Abuse Under District of Columbia law (see D.C. Code §22-3020.52[a]), any person 18 or older who knows, or has reasonable cause to believe, that a child under the age of 16 is a victim of sexual abuse must immediately report such knowledge or belief to the police (911) or the DC Child and Family Services Agency (202-671-7233). Reporting Child Abuse or Neglect DC requires “mandated reporters” who interact with children up to age 16 on a regular basis to complete training on the signs of child abuse and neglect, and to make reports to the Child and Family Services Administration. See be below for more information on mandated reporters.

VIII. Certification December 2021 8.021 - 2 How Can WIC Help?

Sometimes, people fear that reporting child abuse or neglect will destroy a family. The truth is that getting help can protect children from further harm and assist the family in overcoming problems.

Staff should be familiar with the following signs of child abuse and neglect: • Infants excessive crying or with developmental delay • Unexplained bruising, burns, or welts in different stages of healing • Red flags with injuries: o Explanation of injury doesn’t fit as to pattern, timing, or developmental ability of child o Explanation keeps changing o Delay in seeking medical care o Repeated injuries of any kind • Malnutrition • Poor hygiene, matted hair, dirty skin, or body odor

If staff have reason to suspect child abuse or neglect, they are encouraged to make a confidential phone call to the District hotline at (202)-671-7233.

A trained hotline worker will ask for: • The name, address, age, and gender of the child. • Who is caring for the child and whether other children live in the home. • The nature and extent of the abuse or neglect, as you know it—and any previous abuse or neglect you know about. • Any additional information that may be helpful.

Staff should not document making this phone call in the participant’s HANDS record.

Resources to Learn More About Child Abuse and Reporting

DC’s Child and Family Services Agency: https://cfsa.dc.gov/service/report-child-abuse-and-neglect

Office of the Attorney General for the District of Columbia: https://oag.dc.gov/public-safety/reporting-child-abuse-what-know

Stanford Medicine https://childabuse.stanford.edu/screening/signs.html

VIII. Certification December 2021 8.021 - 3 Helpful information about mandated reporting in the District

Mandated Reporters Must Report All Child Abuse or Neglect Mandatory reporting requirements help protect children from harmful situations and ensure that law enforcement officials and social workers can immediately begin investigating. In addition to the general obligation to report suspected sexual abuse, DC law also requires certain people who regularly work with children to be “mandated reporters” for suspected child abuse or neglect of any kind and for certain other injuries to children under the age of 18 (see below). This means they have a legal obligation to report any kind of suspected mistreatment of children to law enforcement and social services immediately and without delay.

Who Is a Mandated Reporter? Mandated reporters are defined by law (see D.C. Code §4-1321.02) as people who must report suspicions of child physical or sexual abuse or neglect. These are people who work in certain professions where they come into regular close contact with children, such as: • School officials, teachers, and athletic coaches; • Department of Parks and Recreation employees; • Public housing resident managers; • Social service workers; • Daycare workers; • Persons involved in the care and treatment of patients, including: physicians, psychologists, medical examiners, dentists, chiropractors, registered nurses, and licensed practical nurses; • Law-enforcement officers; • Humane officer of any agency charged with the enforcement of animal cruelty laws; • Child and Family Services Agency employees, agents and contractors; • Human trafficking counselors as defined in D.C. Code §14-311(2); • Domestic violence counselors as defined in D.C. Code §14-310(a)(2); and • Mental health professionals as defined in D.C. Code §7-1201.01(11). When and What Kind of Information Must Mandated Reports Provide to Authorities? Mandated reporters must report when they know or suspect that a child whom they have encountered through their professional work: • Is being neglected (his or her parent or guardian is not providing adequate housing, food, clothing, hygiene) • Is being abused (physically or mentally) • Is being exposed to domestic violence • Is in imminent danger of being abused due to the abuse of a sibling or other child living in the same household • Has a parent who is intoxicated, incarcerated, or suffering from a fault in their mental or physical capacity (i.e. drug use or mental illness) and is unable or unwilling to provide care • Is being regularly exposed to illegal drug activity • Has been or is in immediate danger of being the victim of sexual abuse or attempted sexual abuse; is a victim of human trafficking; or has been injured by a bullet, a knife or other sharp object by non-accidental means – regardless of whether the perpetrator was a family member, acquaintance, or stranger

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.001 1 | P a g e Title: Food Benefit Overview Category: Food Delivery CFR Reference 7 CFR § 246.12 Policy Number: 9.001 Effective Date: 04/2022 Revised Date: 8/15/2023

POLICY STATEMENT The State Agency is responsible for the financial management of, and accountability for, the food delivery system utilized in the DC WIC program.

The Local Agency is responsible for the issuance, inventory, and security of the food delivery instruments (i.e. eWIC cards) in accordance with DC WIC policy 9.003 Food Benefit Security and for educating DC WIC participants on food benefit use and security.

PROCEDURE The Local Agency will utilize the MIS to issue food delivery instruments and food benefits for DC WIC participants.

eWIC Card Issuance Once a participant is deemed eligible for WIC, the Local Agency must issue an initial eWIC card to the Authorized Representative (AR). The AR must sign indicating that they received their initial eWIC card. Only one eWIC card is issued per Family ID (FID).

The Local Agency staff must instruct the AR on: • eWIC card PIN security, including to not write the PIN on the eWIC card • How an eWIC card account can become locked • How to reset the PIN • How and where to shop for WIC approved foods using the eWIC card • How to determine family benefits balance • How to report the eWIC card as lost or stolen and how to request a new eWIC card (see below)

Lost/Stolen eWIC Cards A lost or stolen eWIC card may be replaced via three methods: the Interactive Voice Response (IVR), visiting their WIC clinic, or visiting www.ebtedge.com.

IVR The IVR can be used by calling the number on the back of the eWIC card (877-559-0912). The AR can • report the eWIC card as lost or stolen • change their PIN • lock their eWIC card • deactivate their eWIC card • request a replacement eWIC card. Once requested, the previous eWIC card will be inactivated. A replacement eWIC card is delivered to participants via USPS and can take up to 7 days to be delivered.

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.001 2 | P a g e

Visiting the WIC clinic The AR may visit their WIC clinic to request a new eWIC card. When the AR arrives, the Local Agency staff must: • Verify the identity of the AR in accordance with DC WIC policy 8.003 Physical Presence and Identification. • Verify the current eWIC card associated with the FID (i.e. check if the eWIC card has already been deactivated or if the eWIC card is locked). o eWIC cards that have been deactivated require the AR to select a new PIN. • Issue a replacement eWIC card; informing the AR that any prior eWIC cards are no longer active and cannot be reactivated. • Review with the AR the PIN: o If the previous eWIC card was not deactivated (i.e. only replaced) – the previous PIN is still associated with the new card. o If the previous eWIC card was deactivated – the AR will need to select a new PIN.

*A note on deactivated eWIC cards – the option to deactivate an eWIC card may be appropriate if the AR knows the eWIC card is with an unauthorized user and does not want benefits to be used until a new eWIC card can be obtained by the AR, or if the AR is transferring their WIC participation to another State.

EbtEdge The AR may visit www.ebtedge.com to: • report the eWIC card as lost or stolen • change their PIN • lock their eWIC card • deactivate their eWIC card • request a replacement eWIC card. Once requested, the previous eWIC card will be deactivated. A replacement eWIC card is delivered to participants via USPS and can take up to 7 days to be delivered.

Mailing of eWIC Cards The Local Agency may replace an eWIC card by mail if the AR is unable to come to the WIC clinic. The Local Agency must verify the identity of the AR in accordance with DC WIC policy 8.003 Physical Presence / Identification before the replacement card can be mailed.

The Local Agency will cover the cost of mailing replacement cards. When replacing an eWIC card by mail, the Local Agency must: • Inform the AR that they may continue to use their PIN only if the card was replaced and not deactivated (see above – Visiting the WIC clinic). o If deactivated, inform the AR that they can set a new PIN by calling IVR, visiting www.ebtedge.com or coming to the WIC clinic. • Verify the AR’s mailing address. • Place in an envelope that prevents the identification of the eWIC card • Stamp/write clearly “DO NOT FORWARD – RETURN TO SENDER” on the front of the envelope.

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.001 3 | P a g e

Food Benefit Issuance The CPA/CPPA must tailor and issue food benefits to the participant based on nutritional risk and dietary assessment in accordance with DC WIC policies 2.003 Nutrition and Breastfeeding Assessment and 2.004 Determining Nutritional Risk. Food benefits may be issued on a monthly, bimonthly, or trimonthly basis. Food benefits may be issued remotely in accordance with DC WIC policy 8.003A Hybrid Services.

The Local Agency must provide food benefit education to the AR/AAR on: • DC WIC authorized foods list and DC WIC authorized vendors and how to identify authorized vendors (this information can be found at www.dcwic.org/wic-families ). • The Family Balance Summary; the quantity of foods issued to the participant(s); aggregated benefits if more than one participant in the FID; first date to use (FDTU) and the last date to use (LDTU) of benefits. • How to check their current food benefit balance via: o the EzWIC app o www.ebtedge.com o IVR o Calling the WIC clinic o Requesting the cashier to print off a receipt of their food benefit balance at an authorized vendor (the AR will need to swipe the card for this to print). • eWIC card security – anyone with the eWIC card and PIN can use it as ID is not checked at the POS at authorized DC WIC stores. • Food benefits cannot be exchanged for cash, non-authorized food items, or credit in accordance with DC WIC policy 8.015 Violations and Sanctions. • The PIN must be entered prior to completing the eWIC transaction. • Prior to completing the transaction, the cashier will hand the eWIC card user a mid-transaction receipt that lists the food items to be deducted from the food benefit balance on their eWIC card. • The receipt received after the completed transaction will list the remaining food benefit balance for that month’s benefit cycle. Frequency of Food Benefit Issuance The Local Agency may only issue eWIC cards and food benefits during established clinic hours. The Local Agency must issue food benefits in accordance with DC WIC policy 9.002 Accountability of Food Benefits.

Early Issuance The Local Agency may issue benefits prior to the FDTU to accommodate participant availability but must educate the AR that food benefits cannot be redeemed prior to the FDTU.

Mid-Benefit Cycle Issuance The Local Agency may adjust food benefits for a participant mid-cycle (i.e. a date in between the FDTU And LDTU) and in accordance with DC WIC policy 9.005 Food Package Responsibilities:

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.001 4 | P a g e • Voiding/reissuing food benefits - The Local Agency staff can void the food benefits, tailor the food package, and reissue food benefits only if none of the food benefits have been redeemed for the current month. • Adding formula to food benefits – If partial food benefits have been redeemed for the current month, depending on the type of food adjustment needed, the Local Agency may add a special formula or WIC-eligible nutritional by utilizing the “Add Formula” button on the Family Balance Screen in this MIS. • Contacting WIC Service Desk – in special cases, the WIC Service Desk can adjust food benefits for a participant mid-cycle. Examples include when new food benefits are medically warranted or in cases of a change in custody. See DC WIC policy 3.002 Help Desk Procedures for contacting the WIC Service Desk.

Missed Appointments and Food Package Proration (Late Pickup) The Local Agency must make reasonable efforts to ensure a participant attends their scheduled appointment. Food benefits cannot be withheld for a participant who attended their initial certification appointment but did not attend a subsequent nutrition education appointment in accordance with DC WIC policy 2.007 Nutrition Education Choice.

A “late pickup” or issuance of food benefits after the FDTU for a participant will not result in a prorated food package.

Food Benefits Expungement Any food benefits remaining on the eWIC card on the LDTU can be redeemed up until 11:59:59 PM (local time). Any remaining food benefits will be expunged by the EBT processor after this time.

Changes in Custody WIC food benefits are aggregated when more than one participant is issued benefits within the same FID. If a participant is transferred to a new FID, benefits are de-aggregated and transferred with the participant to the new FID. If the participant is transferring to a FID that has not previously been issued an eWIC card, the Local Agency staff must follow procedures for issuing an eWIC card as outlined previously (se above – eWIC Card Issuance). See examples for guidance:

Issue a new eWIC card: If the participant has food benefits remaining for the month, they will receive a prorated package automatically calculated by HANDS to sync with the new family’s benefit dates (FDTU and LDTU).

Multiple cards for an Authorized Representative: An AR with multiple foster children enrolled in WIC has the option to request that each child have their own eWIC card assigned to them. In this case, benefits are not aggregated for the family. To do this, the Local Agency staff will need to create a unique FID for each child. The AR may use the same PIN for each card.

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.001 5 | P a g e

Example of the eWIC Card The State Agency reserves the right to change the design of the food instrument based on Program needs.

Front of Card • eWIC card number assigned to family

Back of Card • Signature panel (no signature required) • Participant portal web address • Interactive Voice Response (IVR) toll-free number: 1-877-559-0912

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.001 6 | P a g e REFERENCES 7 CFR § 246.12 DC WIC policies 2.003 Nutrition and Breastfeeding Assessment, 2.004 Determining Nutritional Risk, 2.007 Nutrition Education Choice, 3.002 Help Desk Procedures, 8.003 Physical Presence / Identification, 8.015 Violations and Sanctions, 9.002 Accountability of Food Benefits, 9.003 Food Benefit Security, 9.005 Food Package Responsibilities DC WIC attachment 8.003A Hybrid Services

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.002 1 | P a g e Title: Replacement of Food Benefits Category: Food Delivery CFR Reference 7 CFR 246.12(bb)(2) Policy Number 9.002 Effective Date 6/15/2026 Revised Date

POLICY STATEMENT: WIC participants needing a replacement of full or partial food benefits prior to their current Last-Date- To-Use (LDTU) must meet one of the following criteria to have food benefits reissued to their eWIC account: • Impacted by a disaster event or a declared emergency event • Change in custody for a WIC participant • Medically warranted (and documented) change of food benefits • Lost, stolen, or damaged WIC foods documented with appropriate documentation (see below for additional guidance) Any request to replace purchased WIC food benefits after the LDTU will not be authorized. All requests for food benefit replacements must be approved by the State Agency. In accordance with 7 CFR 246.12(bb)(2), all approved requests for the replacement of EBT cards and the transfer of participant benefit balances must be completed within no more than seven business days following notice by the participant or Authorized Representative to the State Agency. PROCEDURE Local Agency staff will ensure that one of the following scenarios applies to request a replacement for current WIC food benefits: Disaster or Declared Emergency Event The need for a replacement of purchased WIC food benefits during a disaster or declared emergency event will be considered on a case-by-case basis. The WIC participant or Authorized Representative (AR) must submit a written request to info.wic@dc.gov and the State Agency will coordinate efforts to reissue WIC food benefits lost due to a disaster event or declared emergency event if determined appropriate. See DC WIC Emergency Plan for more details. Change in Custody Documentation of the change of custody for the WIC participant must be provided in accordance with DC WIC policy 8.008 Eligibility Special Cases. Once documentation is provided, Local Agency staff may complete the participant transfer to the new Family ID (FID) and, if needed, issue an eWIC card to the new AR (see DC WIC policy 8.012 Authorized Representatives). Food benefits may be prorated for the current month if the participant is transferring to an existing FID in the MIS (based on the existing family’s LDTU). See DC WIC policy 9.001 Food Benefit Issuance Overview for more details. Medically Warranted Change of Food Benefits If a WIC participant has a completed DC WIC Medical Prescription Form and/or other acceptable documentation provided by a healthcare provider in accordance with 9.008 Qualifying Medical Conditions, then Local Agency staff may contact the State Agency to request a reissuance of food benefits to the participant’s account. If the request is related to a change in formula, the AR must return

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.002 2 | P a g e the purchased formula to their WIC clinic and staff are to follow the procedures under “Exchange of Purchased Formula” below. Lost, Stolen, or Damaged WIC foods An AR or participant reporting lost, stolen, or damaged purchased WIC foods must provide documentation of the event or circumstances leading to the loss of WIC foods for a reissuance of benefits to be considered. Examples of acceptable documentation include a police report or statement, insurance claim, or other documentation that may be considered on a case-by-case basis. These items must be sent to the State Agency at info.wic@dc.gov. Miscellaneous Scenarios Additional scenarios may exist that prompt a request to replace or adjust food benefits during the current benefit cycle, including the following: Breastfeeding status change Mother-infant food packages typically cannot be adjusted during the current month’s benefit cycle if partial food benefits have been redeemed, unless medically warranted. A request to add additional amounts of formula to the infant’s food package will not be approved unless the infant has a qualifying medical condition (see DC WIC policy 9.008 Qualifying Medical Conditions). Food package tailoring error If a CPA/CPPA mistakenly tailor a participant’s food package and partial food benefits have been redeemed, the State Agency may approve requests to adjust the participant’s food package. Please note that this can only be accommodated for partial food benefit redemption. If the food item from which the tailoring mistake was made has been redeemed for the month (e.g. a request to add yogurt if all the participant’s milk benefit has been redeemed) then the request cannot be approved. EXCHANGE OF PURCHASED FORMULA For a participant that has purchased their formula food benefit in the current month’s benefit cycle and needs an exchange to a different formula due to medical, dietary, and/or environmental concern (i.e. product safety or recall, contaminated water supply, etc), staff should ensure the following: 1. The staff member speaks with the AR to validate the need for formula exchange and then refers the participant to the appropriate WIC staff member as needed (i.e. CPA for medical or dietary concerns, DBE for breastfeeding concerns, etc). 2. The staff member informs the AR that an exchange for the purchased formula can be completed only if the AR returns all unopened cans/containers to their WIC clinic prior to the LDTU. The staff member and AR must sign attachment 9.002B Returned Formula Form that details the type and amount of formula returned. This form must be scanned into the participant’s record. 3. Once the AR has returned all unopened cans/containers of formula, the staff member may send a request to the State Agency to request a reissuance of the formula amount returned to the clinic onto the participant’s account. 4. The Local Agency ensures the returned formula is discarded per attachment 9.002A Processing Returned Formula. REFERENCES WIC Policy Memorandum #2020-1

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.002 3 | P a g e DC WIC Emergency Plan DC WIC policies 8.008 Eligibility Special Cases, 8.012 Authorized Representatives, 9.001 Food Benefit Issuance Overview, 9.008 Qualifying Medical Conditions ATTACHMENTS & FORMS 9.002A Processing Returned Formula 9.002B Returned Formula Log DC WIC Medical Prescription Form

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.003 1 | P a g e Title: Food Benefit Security Category: Food Delivery CFR Reference: CFR 246.12 Policy Number: 9.003 Effective Date: 1/2022 Revised Date: 1/31/2026

POLICY STATEMENT: The State Agency is responsible for the ordering and distribution of food instruments, i.e. eWIC cards, to the Local Agency and will maintain a backstock supply for emergency distribution and/or other program operations (e.g. vendor monitoring/compliance buys). The Local Agency must maintain an inventory of eWIC cards and ensure these items are kept secure from theft and loss. The Local Agency must report its eWIC card inventory to the State Agency on a quarterly basis. PROCEDURE State Agency Ordering of eWIC Cards DC WIC’s eWIC card supplier and distributor are Custom Data Processing (CDP) and Fidelity National Information Services, Inc (FIS), respectfully. Orders are processed through CDP and fulfilled through FIS. Purchasing eWIC cards from CDP entails the following: Quantities for Ordering • eWIC cards are packaged in quantities of 250 per sleeve and are purchased in increments of 250, with a minimum purchase order of 500 cards (i.e. two sleeves). • Orders for less than 5,000 cards are processed and shipped within 5 to 10 business days. • Orders for more than 5,000 cards are considered Large Order Files (LOF) and require advanced notice. o For LOFs, the State Agency must coordinate with CDP to contact FIS State Support o FIS State Support will coordinate with CardPro to identify a date when CDP can send the card file ▪ CardPro requires 30-day notice for LOFs ▪ CardPro typically processes and ships purchase orders within 5 to 10 business days Requesting eWIC cards The Local Agency must communicate in advance to the State Agency its need for additional eWIC cards to ensure that ordering and shipping of supplies can be accommodated within the established timeframes listed above. The Local Agency must request additional eWIC cards when the designated WIC clinic site has a minimum of three unissued card sleeves. The State Agency will review eWIC card issuance and replacement data in HANDS to verify that the request is justified. CDP Shipping Notes • CDP uses the United Postal Service (UPS) for shipping requests • Packages do not require a signature upon delivery

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.003 2 | P a g e Local Agency Responsibilities The Local Agency must ensure the following for inventorying its eWIC cards: Security of eWIC cards The Local Agency must designate one of its WIC clinic sites as its main location for storing and distributing unopened eWIC card sleeves to its remaining WIC clinic locations as a measure to prevent the loss and theft of these items. The designated WIC clinic must have a locked safe where the cards are stored and kept secured from the public and unauthorized staff. This location should be specified on the eWIC card inventory log. The State Agency recommends that the remaining WIC clinic sites maintain only two sleeves of eWIC cards at a time – one to be used for distribution within the clinic and the other to remain unopened as an inventory backup. These sleeves must also be protected from loss and theft by securing them in a locked safe at the WIC clinic site. Daily eWIC card inventorying at each WIC clinic site Daily inventory of eWIC cards must be performed at each of the Local Agency’s WIC clinic sites to include the number of: • opened sleeves with the number of individual eWIC cards remaining within that sleeve, and • unopened sleeves This data will be used to assist in tracking and accounting for the fiscal year eWIC card inventory log that must be submitted to the State Agency on a quarterly basis. The Daily eWIC Card Inventory Log (see attachment 9.003A) requires daily documentation of all cards removed and returned and includes an end-of-month audit conducted by someone other than the card remover or returner. The auditor must complete the review and sign off within three (3) business days following the close of the month. The Local Agency Director must review the completed audit and sign off within five (5) business days. The Local Agency is required to maintain all daily eWIC card inventory logs for a minimum of three years for auditing purposes. Fiscal Year eWIC card inventorying at each WIC clinic site The Local Agency Director must use the Fiscal Year eWIC Card Inventory Log (see attachment 9.003B) to maintain monthly counts of unissued, unopened, open and finished sleeves at each of its WIC clinic sites and submit this log to the State Agency each quarter. The end-of-month auditor (attachment 9.003B) must be a different individual than the daily card remover or returner (attachment 9.003A). If staffing constraints require the auditor to also serve as the card remover or returner at a site, a replacement auditor must be assigned if that individual performed daily inventory coverage for more than 15% of the site’s monthly operating hours. REFERENCES

ATTACHMENTS & FORMS 9.003A Daily eWIC Card Inventory Log 9.003B Fiscal Year eWIC Card Inventory Log

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.004 1 | P a g e Title: Federal Food Packages Category: Food Delivery CFR Reference: 246.10 Policy Number 9.004 Effective Date 4/2022 Revised Date: 03/01/2026

POLICY STATEMENT The State Agency is responsible for ensuring that all federally authorized WIC supplemental foods are available in quantities that meet and do not exceed the Maximum Monthly Allowances (MMAs) to DC WIC participants established by the seven federal WIC food packages in accordance with 7 CFR 246.10(e). A Food Package Committee at the State Agency determines which foods shall be authorized for inclusion in the DC WIC Approved Food List. Each authorized supplemental food must align with the federal minimum requirements and nutrition specifications in accordance with 7 CFR 246.10(e)(12). The Local Agency is responsible for ensuring each WIC participant receives the appropriate federal food package based on category and nutritional risk as part of performing a comprehensive nutrition and breastfeeding assessment in accordance with DC WIC policy 2.003 Nutrition and Breastfeeding Assessment. DEFINITIONS Maximum Monthly Allowance – MMA; the maximum quantity of any WIC supplemental food that can be assigned to a participant each month based on the seven federal food packages. Supplemental foods- each federally authorized food item available in DC WIC for issuance to participants. Examples include whole grains, yogurt, infant cereal, and cow’s milk. PROCEDURE The seven federal food packages are described below and may only be assigned to WIC participants by a CPA or CPPA that meets the categorical and/or nutritional risk requirements in accordance with DC WIC policies 8.001 Certification Overview and 9.008 Qualifying Medical Conditions.

Though only a CPA or CPPA may tailor a food package for a participant, additional staff roles (i.e. Nutrition Education Technicians or Administrative Clerks) may be allowed at the Local Agency’s discretion to issue food benefits onto a participant’s account.

Each authorized DC WIC participant category and their allowable supplemental food substitution options can be found in DC WIC policies 9.005 Infant Food Packages, 9.006 Children Food Packages, 9.007 Women Food Packages, and 9.008 Qualifying Medical Conditions.

Federal Food Package Description *HANDS Participant Categories I Infants 0 – 5 months of age IEN, IFF, IPN+, IPN II Infants 6 – 11 months of age IEN, IFF, IPN+, IPN III Any participant with a qualifying medical condition who is prescribed a special formula or WIC-eligible nutritional IFF, IPN+, IPN, C1, C2, C3, C4, PG1, PG2, P, PN, PN+, EN IV Part A - Children 12 to 23 months of age C1

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Policy 9.004 2 | P a g e Part B – Children 2 to 4 years of age C2, C3, C4 V Part A – Women pregnant with singleton pregnancies PG1, PG2 PG1 & PN+, PG2 & PN+ Part B – Partially (mostly) breastfeeding women and women pregnant with two or more fetuses PN, PG1 (Multiples), PG2 (Multiples) VI Women up to 6 months postpartum, women breastfeeding partially (some), and women who have experienced pregnancy loss P, P (Multiples), PN+, PN+ (Multiples) VII *Fully breastfeeding women, women partially (mostly) breastfeeding multiple infants from the same pregnancy; and pregnant women who are also fully or partially (mostly) breastfeeding singleton infants. EN, PN (Multiples), PG1 & PN, PG2 & PN 1.5xs MMA - Women who are fully breastfeeding multiples from the same pregnancy are prescribed 1.5 times the maximum allowances for Food Package VII. EN (Multiples) *See DC WIC policy 8.004 Categorical Eligibility for definitions on HANDS participant categories and fully breastfeeding term.

MMAs of Federal Food Packages This section provides details for Federal Food Packages I, II, IV, V, VI, and VII. See the next section for details of Federal Food Package III – For participants issued a special formula or medical food.

Federal Food Package I Infants 0-5 Months Age Infant Exclusively Nursing (IEN) Infant Partially (Mostly) Nursing (IPN) Infant Partially (Some) Nursing + Formula (IPN+) or Infant Formula Fed (IFF) 0-3 months

N/A - 435 fl oz reconstituted powder or - 388 fl oz reconstituted liquid concentrate or - 384 fl oz RTF/RTU - 870 fl oz reconstituted powder or - 823 fl oz reconstituted liquid concentrate or - 832 fl oz RTF/RTU 4-5 months N/A - 522 fl oz reconstituted powder or - 460 fl oz reconstituted liquid concentrate or - 474 fl oz RTF/RTU - 960 fl oz reconstituted powder or - 896 fl oz reconstituted liquid concentrate or - 913 fl oz RTF/RTU

Federal Food Package II Infants 6 -11 Months Age Infant Exclusively Nursing Infant Partially (Mostly) Nursing Infant Partially (Some) Nursing Formula (IPN+) or

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.004 3 | P a g e (IEN) (IPN) Infant Formula Fed (IFF)

6-11 months - 128 oz infant food fruits and vegetables or - 64 oz infant food fruits and vegetables + $11 CVB or - $22 CVB

- 40 oz infant meats

- 16 oz infant cereal

- 128 oz infant food fruits and vegetables or - 64 oz infant food fruits and vegetables + $11 CVB or - $22 CVB

- 8 oz infant cereal

- 384 fl oz reconstituted powder, or - 315 fl oz reconstituted liquid, or - 338 fl oz RTF/RTU formula - 128 oz infant food fruits and vegetables or - 64 oz infant food fruits and vegetables + $11 CVB or - $22 CVB

- 8 oz infant cereal

- 696 fl oz reconstituted powder, or

- 630 fl oz reconstituted liquid, or

- 643 fl oz RTF/RTU formula

Federal Food Package IV Children 1 – 4 years old Part A 12 – 23 months (C1) - 4 gallons whole milk (i.e. 16 quarts) - 64 oz juice - 1 dozen eggs - 6 oz canned fish (tuna, salmon, sardines, mackerel) - 1 lb dry beans or 64 oz canned beans or 16 to 18-oz jar peanut butter - 36 oz breakfast cereal - 24 oz whole grains - $26* CVB for fruits and vegetables Part B 2 – 4 years (C2, C3, C4) - 4 gallons of low-fat (1%) or fat-free milk (i.e. 16 quarts) - 64 oz juice - 1 dozen eggs - 6 oz canned fish (tuna, salmon, sardines, mackerel) - 1 lb dry beans or 64 oz canned beans or 16 to 18-oz jar peanut butter - 36 oz breakfast cereal - 24 oz whole grains - $26 CVB* for fruits and vegetables

*CVB amounts may be adjusted annually Additional tailoring options for Food Package IV can be found in DC WIC policy 9.006 Children Food Packages

Federal Food Package V Pregnant and Mostly Breastfeeding Women Part A Pregnant with singleton fetus (PG1 / PG2)

- 5.5 gallons of low-fat (1%) or fat-free milk (i.e. 22 quarts) - 64 oz juice - 1 dozen eggs - 10 oz canned fish (tuna, salmon, sardines, mackerel) - 1 lb dry beans or 64 or oz canned beans and 16 to 18 oz jar peanut butter* - 36 oz breakfast cereal

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.004 4 | P a g e - 48 oz whole grains - $47** CVB for fruits and vegetables

Part B - Woman partially (mostly) breastfeeding and - pregnant woman with two or more fetuses (PN, PG1 Multiples, PG2 Multiples) - 5.5 gallons of low-fat (1%) or fat-free milk (i.e. 22 quarts) - 64 oz juice - 1 dozen eggs - 15 oz canned fish (tuna, salmon, sardines, mackerel) - 1 lb dry beans or 64-oz canned beans and 16 to 18 oz jar peanut butter* - 36 oz breakfast cereal - 48 oz 100% whole grains - $47** CVB for fruits and vegetables

*Participants may choose from any of the three options for each of their legume selections (dry beans, canned beans, peanut butter and/or nut and seed butters) **CVB amounts may be adjusted annually Additional tailoring options for Food Package V can be found in DC WIC policy 9.007 Women Food Packages

Federal Food Package VI Postpartum Women - Woman postpartum and not breastfeeding, - Woman who experienced pregnancy loss within last 6 months, and - Woman partially (some) nursing (P, PN+) - 4 gallons of low-fat (1%) or fat-free milk (i.e. 16 quarts) - 64 oz juice - 1 dozen eggs - 10 oz canned fish (tuna, salmon, sardines, mackerel) - 1 lb dry beans or 64 oz canned beans or 16 to 18 oz jar peanut butter* - 36 oz breakfast cereal - 48 oz whole grains - $47** CVB for fruits and vegetables

*Participants may choose from any of the three options for each of their legume selections (dry beans, canned beans, peanut butter and/or nut and seed butters) **CVB amounts may be adjusted annually Additional tailoring options for Food Package V can be found in DC WIC policy 9.007 Women Food Packages

Federal Food Package VII Women Fully Breastfeeding - Woman fully breastfeeding - Woman partially (mostly) breastfeeding multiple infants from the same pregnancy - Pregnant woman who are fully or partially (mostly) breastfeeding singleton infants (EN, PN (Multiples), PG1 and EN, PG1 and PN, PG2 and EN, PG2 and PN)

- 6 gallons of low-fat (1%) or fat-free milk (i.e. 24 quarts) - 64 oz juice - 2 dozen eggs - 20 oz canned fish (tuna, salmon, sardines, mackerel) - 1 lb dry bean or 64 oz canned beans and 16 to 18-oz jar peanut butter* - 36 oz breakfast cereal - 48 oz whole grains - $52** CVB for fruits and vegetables

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.004 5 | P a g e 1.5xs MMA Woman fully breastfeeding multiples (EN Multiples)

- 9 gallons of low-fat (1%) or fat-free milk (i.e. 36 quarts) - 96 oz juice - 3 dozen eggs - 30 oz canned fish (tuna, salmon, sardines, mackerel) - 1 lb dry beans and 64 oz canned beans and 16 to 18-oz peanut butter* - 54 oz breakfast cereal - 72 oz whole grains - $78** CVB for fruits and vegetables

*Participants may choose from any of the three options for each of their legume selections (dry beans, canned beans, peanut butter and/or nut and seed butters) **CVB amounts may be adjusted annually Additional tailoring options for Food Package V can be found in DC WIC policy 9.008 Women Food Packages

Authorized Supplemental Foods The following lists the supplemental food categories authorized in the DC WIC program. See the DC WIC Authorized Foods List for a full listing of approved brands and item restrictions.

Breakfast cereals Cow’s milk • Whole, reduced fat, lowfat, skim • Buttermilk • Kefir • Shelf stable • Evaporated • Dry

Plant-based milk Approved brands of: • Soy milk

Goat’s milk Yogurt Cheese Tofu Eggs Whole wheat bread/whole wheat bread products Intact whole grains (e.g. oats, brown rice, quinoa, corn masa, etc) Tortillas Whole wheat and corn tortillas Whole wheat pasta Whole grain breads 100% Juice Dry or canned beans Peanut butter Nut and seed butters Fruit and Vegetables Canned fish

Infant formula Infant cereals Infant fruits and vegetables Infant meats

ADDITIONAL FOOD PACKAGE CONSIDERATIONS Food package tailoring in the MIS defaults to issuing the MMA for each supplemental food category. The CPA or CPPA may tailor and issue amounts less than the MMA if: - It is medically or nutritionally appropriate (e.g. removing a food item due to an allergy) - A participant requests to receive less than the MMA for a food item - The quantities necessary to supplement another program’s contribution to fill a medical prescription would be less than the MMA (e.g. a participant is receiving assistance on infant formula from another food program).

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.004 6 | P a g e REFERENCES CFR 246.10 DC WIC policies 2.003 Nutrition and Breastfeeding Assessment, 8.001 Certification Overview, 8.004 Categorical Eligibility, 9.005 Infant Food Packages, 9.006 Children Food Packages, 9.007 Women Food Packages, 9.008 Qualifying Medical Conditions ATTACHMENTS & FORMS DC WIC Authorized Foods List

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.005 1 | P a g e Title: Infant Food Packages Category: Food Delivery CFR Reference: 7 CFR 246.10 Policy Number: 9.005 Effective Date: 04/2022 Revised Date: 11/17/2025

POLICY STATEMENT: The State Agency will make available in the MIS infant food packages based on infant age and categories (see DC WIC policy 8.004 Categorical Eligibility) that allow up to the Monthly Maximum Allowance (MMA)* of authorized infant foods in accordance with 7 CFR 246.10(b)(2)(ii). Each infant will receive a tailored food package based on a breastfeeding and nutrition assessment conducted in accordance with DC WIC policy 2.003 Nutrition and Breastfeeding Assessment. Mother- infant dyads must have corresponding categories that best characterize the infant’s feeding status. *See DC WIC policy 9.004 Federal Food Packages for definition of MMA. DEFINITIONS Mother Infant Dyad – refers to the WIC participant category assignment of a mother to her infant based on infant feeding status. A mother infant dyad must have corresponding participant categories for a singleton birth (e.g. a PN category for a woman must have an infant assigned IPN). Standard Contract Infant Formula – refers to the milk-based and soy-based infant formulas offered in DC WIC as part of the program’s foods cost containment contracts in accordance with 7 CFR 246.16a. Noncontract Infant Formulas – refers to all other infant formula offerings in DC WIC intended to meet the nutritional and medical needs of WIC participants that are not included in the program’s food cost containment contracts in accordance with 7 CFR 246.16a. PROCEDURE The CPA or CPPA must provide each infant with a tailored food package based on the MMAs established for each infant age range and category: Infant Exclusively Nursing (IEN) (Fully Breastfeeding) For infants fully breastfeeding, the following food packages, including food items and amounts, are available based on the infant’s age at the time of issuance:

Federal Food Package I (0-5 Months) Federal Food Package II (6-11 Months) Infant Cereal N/A – infants fully breastfeeding do not receive any WIC foods 16 oz Infant Fruits and Vegetables* 128 oz Infant Meats 40 oz *CVB may be substituted in place of jarred infant fruits and vegetables at either 64 oz for $11 or 128 oz for $22. Monthly CVB amounts may be adjusted annually.

Infant Partially Nursing (IPN) (Mostly Breastfeeding) For infants partially nursing (mostly), the following food packages, including food items and amounts, are available based on the infant’s age at the time of issuance:

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.005 2 | P a g e

Federal Food Package I (0-3 Months) Federal Food Package I (4-5 Months) Federal Food Package II (6-11 Months) Infant Formula May receive up to: • 388 fl oz reconstituted liquid concentrate, or • 384 fl oz RTF, or • 435 fl oz reconstituted powder May receive up to: • 460 fl oz reconstituted liquid concentrate, or • 474 fl oz RTF, or • 522 fl oz reconstituted powder May receive up to: • 315 fl oz reconstituted liquid concentrate, or • 474 fl oz RTF, or 522 fl oz reconstituted powder Infant Cereal N/A N/A 8 oz Infant Fruits and Vegetables* N/A N/A 128 oz *CVB may be substituted in place of jarred infant fruits and vegetables at either 64 oz for $11 or 128 oz for $22. Monthly CVB amounts may be adjusted annually.

Infant Partially Nursing (IPN+) (Some Breastfeeding) For infants partially nursing (some), the following food packages, including food items and amounts, are available based on the infant’s age at the time of issuance:

Federal Food Package I (0-3 Months) Federal Food Package I (4-5 Months) Federal Food Package II (6-11 Months) Infant Formula May receive up to: • 823 fl oz reconstituted liquid concentrate, or • 832 fl oz RTF, or • 870 fl oz reconstituted powder May receive up to: • 884 fl oz reconstituted liquid concentrate, or • 913 fl oz RTF, or • 960 fl oz reconstituted powder May receive up to: • 630 fl oz reconstituted liquid concentrate, or • 643 fl oz RTF, or • 696 fl oz reconstituted powder Infant Cereal N/A N/A 8 oz Infant Fruits and Vegetables* N/A N/A 128 oz *CVB may be substituted in place of jarred infant fruits and vegetables at either 64 oz for $11 or 128 oz for $22. Monthly CVB amounts may be adjusted annually.

Infant Formula Fed (IFF) For infants’ formula-fed, the following food packages, including food items and amounts, are available based on the infant’s age at the time of issuance:

Federal Food Package I (0-3 Months) Federal Food Package I (4-5 Months) Federal Food Package II (6-11 Months) Infant Formula May receive up to: • 823 fl oz reconstituted liquid concentrate, or • 832 fl oz RTF, or • 870 fl oz reconstituted powder May receive up to: • 884 fl oz reconstituted liquid concentrate, or • 913 fl oz RTF, or • 960 fl oz reconstituted powder May receive up to: • 630 fl oz reconstituted liquid concentrate, or • 643 fl oz RTF, or • 696 fl oz reconstituted powder Infant Cereal N/A N/A 8 oz

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.005 3 | P a g e Infant Fruits and Vegetables* N/A N/A 128 oz *CVB may be substituted in place of jarred infant fruits and vegetables at either 64 oz for $11 or 128 oz for $22. Monthly CVB amounts may be adjusted annually.

INFANT FORMULA ISSUANCE DC WIC authorizes several types of infant formulas in powdered, liquid concentrate, and/or ready-to- feed (RTU/RTF) forms that support the nutritional and medical needs of DC WIC participants. Authorized infant formulas are classified as one of the following: • Standard contract infant formulas • Non-contract infant formulas: o Includes DC WIC-authorized exempt infant formulas (see DC WIC policy 9.008 Qualifying Medical Conditions), and o Competitive infant formulas that may be available on a limited and temporary basis A listing of all currently authorized DC WIC formulas and their classifications can be found in the DC WIC Formula Guide. Standard Contract Infant Formulas Standard contract infant formulas authorized in DC WIC may be issued without a DC Medical Prescription Form to any infant with an assigned category of IFF, IPN+, or IPN in powdered or liquid concentrate form by a CPA or CPPA. Ready-to-feed (RTF) Formulas RTU/RTF formulas may only be authorized by a CPA and must meet one of the following conditions in accordance with 7 CFR 246.10(e)(1)(iv): • The participant’s household has an unsanitary or restricted water supply or poor refrigeration; • The person caring for the participant may have difficulty in correctly diluting concentrated or powdered forms; or • The WIC infant formula is only available in RTU/RTF. The CPA must document the justification for issuing a RTU/RTF formula in the participant’s record. Non-Contract Infant Formulas Non-contract infant formulas available in DC WIC may be assigned by a CPA when one of the following conditions applies: a. Religious Beliefs – a participant who cannot use a standard contract infant formula due to religious reasons or other circumstances may be issued a non-contract comparable infant formula. The CPA must contact the State Agency for approval and document the exception in the participant’s TGIF note.

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.005 4 | P a g e b. Qualifying Medical Condition – a participant with a qualifying medical condition (see DC WIC policy 9.008 Qualifying Medical Conditions) may receive an exempt infant formula with the completion of a DC WIC Medical Prescription Form and approval by a CPA. Tailoring Infant Formula for Partially Nursing Infants Partially nursing infants (IPN or IPN+ categories) must have food packages tailored and issued that meet but do not exceed the infant’s daily formula needs. CPA/CPPAs must conduct a comprehensive nutrition and breastfeeding assessment that ensures the following: 1. The CPA/CPPA identifies the frequency of infant formula and breastfeeding intake in a 24-hour period and probes the infant’s caretaker on formula preparation methods (e.g. formula type and mixing ratios, bottle heating, bottle cleaning, formula storage, etc). 2. The CPA/CPPA identifies the mother’s breastfeeding goals and provides appropriate education, anticipatory guidance, and/or breastfeeding support to help her achieve these goals. Staff may reference the WIC Breastfeeding Check-In Tool to provide breastfeeding education and support information. 3. The CPA/CPPA calculates the total amount of formula the infant receives in a 24-hour period and determines the amount of formula to issue based on the DC WIC Formula Tailoring Guide (see below). 4. The CPA/CPPA tailors the infant’s food package to reflect the above formula calculation and provides food benefit education to the Authorized Representative (AR) in accordance with 9.001 Food Benefit Issuance Overview. MOTHER-INFANT DYAD CATEGORY CHANGES For a mother-infant dyad with a change in breastfeeding status, staff must ensure the following to complete the category change: 1. The CPA/CPPA probe to determine the change in breastfeeding and/or categorical status* and document this information accordingly on the infant’s Breastfeeding Surveillance Tab in HANDS. 2. The CPA/CPPA identify the new corresponding infant/mother categories that best characterize the infant’s feeding status and update the category on the Cert Tab in HANDS for the infant and mother**. 3. The CPA/CPPA reviews the category changes with the participants including updates to the certification period(s), appropriate risk codes, and food packages. Please note that food packages typically cannot be adjusted for mother-infant dyads during the current month’s benefit cycle if partial benefits have been redeemed. See DC WIC policies 9.001 Food Benefit Issuance Overview and 9.002 Replacement of Food Benefits for more details. *For a postpartum woman with an active certification that is now pregnant, staff must complete a new certification reflecting her pregnancy status in accordance with DC WIC policy 8.001 Certification Overview. ** For an infant 6 months or older who is no longer breastfed, staff only need to update the infant’s category, risk codes, and food package. The infant’s mother will no longer be considered categorically

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.005 5 | P a g e eligible and will be terminated from the program. Additionally, PN+ (Some Breastfeeding) participants are no longer eligible to receive a food package at 6 months postpartum but continue to receive breastfeeding support and participant-centered nutrition education, up to one year postpartum.

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.006 6 | P a g e

DC WIC FORMULA TAILORING GUIDE The following tables can assist the CPA/CPPA in tailoring the amount of formula issued to Infants Partially Nursing (Some/Mostly). Maximum Monthly Allowance (MMA) per month for fluid ounces of infant formula: Standard Contract Formula Form Reconstituted Ounces per Container Infants Partially Nursing (Mostly) # of cans/containers to issue Infant’s Partially Nursing (Some) # of cans/containers to issue 0-3 mo. 4-5 mo. 6-11 mo. 0-3 mo. 4-5 mo. 6-11 mo. Similac Advance 20 calories per oz 12.4 oz Powdered 90 1-4 1-5 1-4 5-9 6-10 5-7 13 oz Concentrate 26 1-14 1-17 1-12 15-31 18-34 13-24 32 oz RTF 32 1-12 1-14 1-10 13-26 15-28 11-20 Similac Sensitive 20 calories per oz 12.5 oz Powdered 90 1-4 1-5 1-4 5-9 6-10 5-7 32 oz RTF 32 1-12 1-14 1-10 13-26 15-28 11-20 Similac Soy Isomil 20 calories per oz 12.4 oz Powdered 90 1-4 1-5 1-4 5-9 6-10 5-7 13 oz Concentrate 26 1-14 1-17 1-12 15-31 18-34 13-24 32 oz RTF 32 1-12 1-14 1-10 13-26 15-28 11-20 Similac Total Comfort 20 calories per oz 12.6 oz Powder 90 1-4 1-5 1-4 5-9 6-10 5-7

Standard Contract Formulas - Daily Formula Intake Amounts and Issuance Daily Formula Amount Powdered Daily Formula Amount Concentrate (13 oz can) Daily Formula Amount RTF (32 oz container) Up to 3 oz 1 can < 5 oz Not recommended to issue concentrate < 5 oz Not recommended to issue concentrate 4 to 6 oz 2 cans 6 oz 8 cans 6 oz 6 containers 7 to 9 oz 3 cans 8 oz 10 cans 8 oz 8 containers 10 to 12 oz 4 cans 10 oz 12 cans 10 oz 10 containers 13 to 15 oz 5 cans or up to MMA 12 oz 14 cans 12 oz 12 containers

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.006 7 | P a g e

16 to 18 oz 6 cans or up to MMA 14 oz 16 cans 14 oz 14 containers 19 to 21 oz 7 cans or up to MMA 16 oz 18 cans 16 oz 16 containers 22 to 24 oz 8 cans or up to MMA 18 oz 20 cans 18 oz 18 containers 25 to 27 oz 9 cans or up to MMA 20 oz 23 cans or up to MMA 20 oz 20 containers or up to MMA > 28 oz 9 or 10 or up to MMA 22 oz 25 cans or up to MMA 22 oz 22 containers or up to MMA

24 oz 28 cans or up to MMA 24 oz 24 containers or up to MMA

26 oz 31 cans or up to MMA 26 oz 26 containers or up to MMA

28 oz 32 cans or up to MMA 28 oz 28 containers or up to MMA

30 oz 34 cans or up to MMA 30 oz

Noncontract Formulas – Daily Formula Intake Amounts and Issuance Refer to DC WIC policy 9.008 Qualifying Medical Conditions for formula tailoring amounts. REFERENCES 7 CFR 246.16a DC WIC policy 8.001 Certification Overview, 9.001 Food Benefit Issuance Overview, 9.002 Replacement of Food Benefits, 9.004 Federal Food Packages, 9.008 Qualifying Medical Conditions ATTACHMENTS & FORMS DC WIC Formula Guide DC WIC Medical Prescription Form

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.006 1 | P a g e Title: Children Food Packages Category: Food Delivery CFR Reference: 246.10 Policy Number 9.006 Effective Date: 3/2022 Revised Date: 03/01/2026

POLICY STATEMENT: The State Agency will make available in the MIS children food packages based on the child’s age that allow up to the Maximum Monthly Allowance (MMA)* of authorized supplemental foods in accordance with 7 CFR 246.10(e)(4). Each child will receive a tailored food package based on a nutrition assessment conducted in accordance with DC WIC policy 2.003 Nutrition and Breastfeeding Assessment that meets the cultural, medical, and dietary needs of the DC WIC participant. *See DC WIC policy 9.004 Federal Food Packages for definition of MMA. PROCEDURE The CPA or CPPA must provide each child with a tailored food package based on the MMAs established and allowable substitutions for each age and category below: Child 1-year-old (C1) Authorized Supplemental Food Food Package IV, Part A Juice 64 fl oz full substitution: - $3 CVB Whole milk 4 gallons (i.e. 16 quarts) partial substitutions: - 1 lb of cheese (in place of 3 quarts of milk) - Up to 64 oz of yogurt* (32 oz per 1 quart of milk) - Up to 4 quarts of kefir (1 quart of kefir per 1 quart of milk) full substitutions: - 1 lb of tofu for each quart of milk - Any additional authorized milk (e.g. dry powdered milk, lactose-free, soy, goat’s milk, UHT milk, etc) for each quart of milk** Breakfast cereal 36 oz Eggs 1 dozen full substitution: - 1 lb of tofu or - 1 CTR of dry or canned beans, peas, lentils, or 16 to 18 of peanut butter or nut or seed butter Fruits and vegetables $26*** CVB Whole wheat bread or other whole grain option 24 oz Canned fish 6 oz Mature legumes 1 lb dry beans or 64 oz canned beans or 1 CTR of 16 to 18 oz peanut butter or nut and seed butters

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.006 2 | P a g e WIC formula (see DC WIC policy 9.008) Up to 455 fl oz of liquid concentrate (powdered and RTF may be substituted at equivalent rates). *Yogurt – whole fat or low-fat yogurts are standard issuance when substituting yogurt. Nonfat yogurt may be issued to 1-year-old children for whom overweight or obesity is a concern as determined by a CPA **Authorized milk – see a full listing of authorized milks in the DC WIC Authorized Foods List *** CVB amounts may be adjusted annually.

Reduced-fat milk issuance to 1-year-olds Reduced fat (2%) milks can be issued to 1-year old children only when determined appropriate by a CPA. The need for reduced fat milk must be based on an individual nutritional assessment and if issued, must be documented in the participant’s TGIF note. A DC WIC Medical Prescription form is not required to issue reduced-fat milk to 1-year-olds as part of Food Package IV, Part A. Nonfat yogurt issuance to 1-year-olds Nonfat yogurt may be issued to 1-year-old children only when determined appropriate by a CPA. The need for nonfat yogurt must be based on an individual nutritional assessment and if issued, must be documented in the participant’s TGIF. A DC WIC Medical Prescription form is not required to issue nonfat yogurt to 1-year-olds as part of Food Package IV, Part A. Additional food package tailoring options for 1-year-olds Additional food item tailoring options may be considered as part of Food Package III issuance including infant fruits and vegetables, infant cereal, and special formula as determined appropriate by a healthcare provider per medical documentation. See DC WIC policy 9.008 Qualifying Medical Conditions for more information. Child 2 years to 4 years (C2, C3, C4) Authorized Supplemental Food Food Package IV, Part B Juice 64 fl oz full substitution: - $3CVB Low-fat or nonfat milk 4 gallons (i.e. 16 quarts) partial substitutions: - 1 lb of cheese (in place of 3 quarts of milk) - Up to 64 oz of yogurt* (32 oz per 1 quart of milk) - Up to 4 quarts of kefir (1 quart of kefir per 1 quart of milk) full substitutions: - 1 lb of tofu for each quart of milk - Any additional authorized milk (e.g. dry powdered milk, lactose-free, soy, goat’s milk, UHT milk, etc)** Breakfast cereal 36 oz Eggs 1 dozen full substitution: - 1 lb of tofu or - 1 CTR of dry or canned beans, peas, lentils, or 16 to 18 of peanut butter or nut or seed butter

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.006 3 | P a g e Fruits and vegetables $26*** CVB Whole wheat bread or other whole grain option 24 oz Canned fish 6 oz Mature legumes 1 lb dry beans or 64 oz canned beans or 1 CTR of 16 to 18 oz peanut butter or nut and seed butters WIC formula (see DC WIC policy 9.008) Up to 455 fl oz of liquid concentrate (powdered and RTF may be substituted at equivalent rates). *Yogurt – low-fat and nonfat yogurts are standard issuance for 2 to 4-year-olds. Whole fat yogurt may be authorized per medical documentation by a healthcare provider. **Authorized milk – see a full listing of authorized milks in the DC WIC Authorized Foods List *** CVB amounts may be adjusted annually.

Whole milk issuance to 2 to 4-year-olds Whole milk may be issued to 2 to 4-year-olds in place of low-fat and nonfat milk only when determined appropriate by a healthcare provider per medical documentation and must be assigned as part of Food Package III (see DC WIC policy 9.008 Qualifying Medical Conditions). Reduced-fat milk (2%) issuance to 2 to 4-year-olds Reduced-fat milk (2%) may be issued to 2 to 4-year-olds in place of low-fat and nonfat milk only as determined, at minimum, by a CPA based on an individual nutritional assessment and its justification documented in the participant’s record. A DC WIC Medical Prescription form is not needed to issue reduced-fat milk as part of Food Package IV, Part B. Additional food package tailoring options for 2 to 4-year olds Additional food tailoring options may be considered as part of Food Package III issuance including infant fruits and vegetables, infant cereal, whole milk yogurt, and special formula as determined appropriate by a healthcare provider per medical documentation. See DC WIC policy 9.008 Qualifying Medical Conditions for more information. REFERENCES 7 CFR 246.10 DC WIC policies 2.003 Nutrition and Breastfeeding Assessment, 9.004 Federal Food Packages, 9.008 Qualifying Medical Conditions ATTACHMENTS & FORMS DC WIC Medical Prescription Form DC WIC Authorized Foods List

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.007 1 | P a g e Title: Women Food Packages Category: Food Delivery CFR Reference: 7 CFR 246.10€ Policy Number: 9.007 Effective Date: 3/2022 Revised Date: 03/01/2026

POLICY STATEMENT: The State Agency will make available in the MIS food packages based on the woman’s categorical status (e.g. pregnancy, postpartum and breastfeeding statuses) that allow up to the Maximum Monthly Allowance (MMA)* of authorized supplemental foods in accordance with 7 CFR 246.10(e)(4). Each woman will receive a tailored food package based on a nutrition assessment conducted in accordance with DC WIC policy 2.003 Nutrition and Breastfeeding Assessment that meets the cultural, medical, and dietary needs of the DC WIC participant. Mother-infant dyads* must have corresponding categories that best characterize the infant’s feeding status. *See DC WIC policy 9.004 Federal Food Packages for definition of MMA and DC WIC policy 9.005 Infant Food Packages for definition of mother-infant dyads. PROCEDURE The CPA or CPPA must provide each woman with a tailored food package based on the MMAs established for each woman’s categorical status as defined in DC WIC policy 8.004 Categorical Eligibility: Pregnant (Singleton Fetus) The table below lists the MMAs of authorized supplement foods for the following DC WIC categories: PG1, PG2, PG1 & PN+, and PG2 & PN+ Authorized Supplemental Food Food Package V, Part A Juice 64 fl oz full substitution: - $3CVB Low-fat and nonfat milk 5.5 gallons (i.e. 22 quarts) partial substitutions: - 1 lb of cheese (in place of 3 quarts of milk) - Up to 64 oz of yogurt (32 oz per 1 quart of milk) - Up to 4 quarts of kefir (1 quart of kefir per 1 quart of milk) full substitutions: - 1 lb of tofu for each quart of milk - Any additional authorized milk (e.g. dry powdered milk, lactose-free, soy, goat’s milk, UHT milk, etc) for each quart of milk* Breakfast cereal 36 oz Eggs 1 dozen full substitution: - 1 lb of tofu or - 1 CTR of dry or canned beans, peas, lentils, or 16 to 18 of peanut butter or nut or seed butter Fruits and vegetables $47** CVB

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.007 2 | P a g e Whole wheat bread or other whole grain option 48 oz Canned fish 10 oz Mature legumes 1 lb dry beans or 64 oz canned beans and*** 1 CTR of 16 to 18 oz peanut butter or nut and seed butter WIC formula (see DC WIC policy 9.008) Up to 455 fl oz of liquid concentrate (powdered and RTF may be substituted at equivalent rates). *Authorized milk - see a full listing of authorized milks in the DC WIC Authorized Foods List ** CVB amounts may be adjusted annually ***Mature legumes – Participants may choose from any of the three options for each of their legume selections (dry beans, canned beans, peanut butter and/or nut and seed butters)

Partially (Mostly) Nursing and Pregnant with Multiples The table below lists the MMAs of authorized supplement foods for the following DC WIC categories: PN, PG1 (Multiples) and PG2 (Multiples). Authorized Supplemental Food Food Package V, Part B Juice 64 fl oz full substitution: - $3CVB Low-fat and nonfat milk 5.5 gallons (i.e. 22 quarts) partial substitutions: - 1 lb of cheese (in place of 3 quarts of milk) - Up to 64 oz of yogurt (32 oz per 1 quart of milk) - Up to 4 quarts of kefir (1 quart of kefir per 1 quart of milk) full substitutions: - 1 lb of tofu for each quart of milk - Any additional authorized milk (e.g. dry powdered milk, lactose-free, soy, goat’s milk, UHT milk, etc) for each quart of milk* Breakfast cereal 36 oz Eggs 1 dozen full substitution: - 1 lb of tofu or - 1 CTR of dry or canned beans, peas, lentils, or 16 to 18 of peanut butter or nut or seed butter Fruits and vegetables $52** CVB Whole wheat bread or other whole grain option 48 oz Canned fish 15 oz Mature legumes 1 lb dry beans or 64 oz canned beans and*** 1 CTR of 16 to 18 oz peanut butter or nut and seed butter WIC formula (see DC WIC policy 9.008) Up to 455 fl oz of liquid concentrate (powdered and RTF may be substituted at equivalent rates). *Authorized milk - see a full listing of authorized milks in the DC WIC Authorized Foods List ** CVB amounts may be adjusted annually

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.007 3 | P a g e ***Mature legumes – Participants may choose from any of the three options for each of their legume selections (dry beans, canned beans, peanut butter and/or nut and seed butters)

Postpartum, Partially (Some) Nursing, Pregnancy Loss within Last 6 Months The table below lists the MMAs of authorized supplement foods for the following DC WIC categories: PN+, P, PN+ (Multiples), and P (Multiples). Authorized Supplemental Food Food Package VI Juice 64 fl oz full substitution: - $3CVB Low-fat and nonfat milk 4 gallons (i.e. 16 quarts) partial substitutions: - 1 lb of cheese (in place of 3 quarts of milk) - Up to 64 oz of yogurt (32 oz per 1 quart of milk) - Up to 4 quarts of kefir (1 quart of kefir per 1 quart of milk) full substitutions: - 1 lb of tofu for each quart of milk - Any additional authorized milk (e.g. dry powdered milk, lactose-free, soy or other plant-based milks, goat’s milk, UHT milk, etc) for each quart of milk* Breakfast cereal 36 oz Eggs 1 dozen full substitution: - 1 lb of tofu or - 1 CTR of dry or canned beans, peas, lentils, or 16 to 18 of peanut butter or nut or seed butter Fruits and vegetables $47** CVB Whole wheat bread or other whole grain option 48 oz Canned fish 10 oz Mature legumes 1 lb dry beans or 64 oz canned beans or 1 CTR of 16 to 18 oz peanut butter or nut and seed butter WIC formula (see DC WIC policy 9.008) Up to 455 fl oz of liquid concentrate (powdered and RTF may be substituted at equivalent rates). *Authorized milk – see a full listing of authorized milks in the DC WIC Authorized Foods List ** CVB amounts may be adjusted annually

Fully Breastfeeding, Partially (Mostly) Nursing Multiples, Pregnant and Partially (Mostly) Nursing The table below lists the MMAs of authorized supplement foods for the following DC WIC categories: EN, PN (Multiples), PG1 and EN, PG1 and PN, PG2 and EN, PG2 and PN

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.007 4 | P a g e Authorized Supplemental Food Food Package VII Juice 64 fl oz full substitution: - $3CVB Low-fat and nonfat milk 6 gallons (i.e. 24 quarts) partial substitutions: - 1 lb of cheese (in place of 3 quarts of milk) - Up to 64 oz of yogurt (32 oz per 1 quart of milk) - Up to 4 quarts of kefir (1 quart of kefir per 1 quart of milk) full substitutions: - 1 lb of tofu for each quart of milk - Any additional authorized milk (e.g. dry powdered milk, lactose-free, soy or other plant-based milks, goat’s milk, UHT milk, etc) for each quart of milk* Breakfast cereal 36 oz Eggs 2 dozen full substitution**: - 1 lb of tofu or - 1 CTR of dry or canned beans, peas, lentils, or 16 to 18 of peanut butter or nut or seed butter Fruits and vegetables $52*** CVB Whole wheat bread or other whole grain option 48 oz Canned fish 20 oz Mature legumes 1 lb dry beans or 64 oz canned beans and**** 1 CTR of 16 to 18 oz peanut butter or nut and seed butter WIC formula (see DC WIC policy 9.008) Up to 455 fl oz of liquid concentrate (powdered and RTF may be substituted at equivalent rates). *Authorized milk – see a full listing of authorized milks in the DC WIC Authorized Foods List **Eggs- Participants may choose from any of the three options for each of their egg benefit allotments (1 dozen eggs, 1 lb of tofu, or 1 CTR of dry or canned beans, peas, lentils, or 16 to 18 oz of peanut butter or nut or seed butter) *** CVB amounts may be adjusted annually ****Mature legumes - Participants may choose from any of the three options for each of their legume selections (dry beans, canned beans, peanut butter and/or nut and seed butters)

Fully Breastfeeding Multiples The table below lists the MMAs of authorized supplement foods for the following DC WIC categories: EN (Multiples) Authorized Supplemental Food Food Package VII (1.5 MMA) Juice 96 fl oz full substitution: - $4.5 CVB Low-fat and nonfat milk 9 gallons (i.e. 36 quarts) partial substitutions:

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.007 5 | P a g e - Up to 2 lb of cheese (1 lb per 3 quarts of milk) - Up to 64 oz of low-fat/nonfat yogurt (32 oz per 1 qt of milk) - Up to 4 quarts of kefir (1 qt of kefir per 1 qt of milk) full substitutions: - 1 lb of tofu for each quart of milk - Any additional authorized milk (e.g. dry powdered milk, lactose-free, soy, goat’s milk, UHT milk, etc) for each quart of milk* Breakfast cereal 54 oz Eggs 3 dozen full substitution**: - 1 lb of tofu or - 1 CTR of dry or canned beans, peas, lentils, or 16 to 18 of peanut butter or nut or seed butter Fruits and vegetables $78*** CVB Whole wheat bread or other whole grain option 72 oz Canned fish 30 oz Mature legumes 1 lb dry beans and 64 oz canned beans and**** 1 CTR of 16 to 18 oz peanut butter or nut and seed butter WIC formula (see DC WIC policy 9.008) Up to 455 fl oz of liquid concentrate (powdered and RTF may be substituted at equivalent rates). *Authorized milk – see a full listing of authorized milks in the DC WIC Authorized Foods List **Eggs- Participants may choose from any of the three options for each of their egg benefit allotments (1 dozen eggs, 1 lb of tofu, or 1 CTR of dry or canned beans, peas, lentils, or 16 to 18 oz of peanut butter or nut or seed butter) *** CVB amounts may be adjusted annually ****Mature legumes - Participants may choose from any of the three options for each of their legume selections (dry beans, canned beans, peanut butter and/or nut and seed butters)

Whole milk issuance to women Whole milk may be issued to women in place of low-fat and nonfat milk only when determined appropriate by a healthcare provider per medical documentation and must be assigned as part of Food Package III (see DC WIC policy 9.008 Qualifying Medical Conditions). Reduced-fat milk (2%) issuance to women Reduced-fat milk (2%) may be issued to women in place of low-fat and nonfat milk only as determined, at minimum, by a CPA based on an individual nutritional assessment and its justification documented in the participant’s record. Additional food package tailoring options for women Additional food item tailoring options may be considered as part of Food Package III issuance including issuance of jarred infant fruits and vegetables, infant cereal, and whole milk yogurt as determined appropriate by a healthcare provider per medical documentation. See DC WIC policy 9.008 Qualifying Medical Conditions for more information.

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.007 6 | P a g e REFERENCES DC WIC policies 2.003 Nutrition and Breastfeeding Assessment, 9.004 Federal Food Packages, 9.005 Infant Food Packages, 9.008 Qualifying Medical Conditions ATTACHMENTS & FORMS DC WIC Medical Prescription Form DC WIC Authorized Foods List

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.008 1 | P a g e Title: Qualifying Medical Conditions Category: Food Delivery CFR Reference 7 CFR 246.10(e)(3) Policy Number 9.008 Effective Date 3/2022 Revised Date: 11/17/2025

POLICY STATEMENT: The State Agency will make available in the MIS specialized food packages designed to meet the cultural, medical, and dietary needs of participants with qualifying medical conditions that allow up to the Monthly Maximum Allowance (MMA)* of authorized supplemental foods* as part of Food Package III in accordance with 7 CFR 246.10(b)(2)(ii). Food package III may not be issued solely for the purpose of enhancing nutrient intake or managing body weight or 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 (7 CFR 246.10(e)(3)(ii)). *See DC WIC policy 9.004 Federal Food Packages for definition of MMA and supplemental foods. DEFINITIONS Qualifying medical condition – any diagnosed medical condition which requires the issuance of a WIC formula, exempt infant formula, or WIC-eligible nutritional as deemed appropriate by a healthcare provider per medical documentation. Examples include preterm birth, low birth weight, failure to thrive, inborn errors of metabolism and metabolic disorders, gastrointestinal disorders, and severe food allergies. Reconstituted Fluid Ounces (RFO) – the amount of formula prepared from one can or container of formula product when prepared with water according to standard mixing instructions. PROCEDURE Only a CPA may issue a WIC infant formula, noncontract infant formula*, or WIC-eligible nutritional as part of Food Package III with appropriate medical documentation in accordance with 7 CFR 246.10(d) as described below. Required Medical Documentation Any issuance of a WIC infant formula, noncontract infant formula, or WIC-eligible nutritional as part of Food Package III requires a completed DC WIC Medical Prescription Form or other medical documentation form from a licensed healthcare provider with prescriptive authority in the District of Columbia. The following information is required and may be obtained in writing or received verbally (see further guidance on this below): A. The name of the formula or WIC-eligible nutritional being requested, including the amount needed per day (this can be determined by the CPA if indicated as so). B. The authorized supplemental food(s)* appropriate for the qualifying condition(s) and their prescribed amounts. C. Length of time the prescribed WIC formula and/or supplemental food is required by the participant. D. The qualifying condition(s) for issuance of the authorized supplemental food(s).

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.008 2 | P a g e E. Signature, date, and contact information (or name, date, and contact information) if the initial medical documentation was received verbally and the signed document is forthcoming. All medical documentation requesting a formula or WIC-eligible nutritional must be uploaded into the participant’s record. All requests are subject to approval by a CPA. If a medical provider has prescribed a formula or feeding plan that, based upon the nutritional assessment of the CPA is not appropriate or indicated, the CPA should contact the medical provider to discuss alternative options. *See DC WIC policy 9.005 Infant Food Packages for definitions of noncontract infant formula. In accordance with 7 CFR 246.10(d)(4)(iii)(B), medical documentation may be provided by telephone to a CPA who must promptly document the information. The collection of the required information by telephone for medical documentation purposes may only be used until written confirmation is received from a licensed healthcare provider with prescriptive authority and used only when absolutely necessary on an individual participant basis. Written medical documentation must be received no later than 2 weeks after accepting the initial medical documentation by phone. Licensed healthcare providers with prescriptive authority In accordance with District of Columbia Code § 3–1201.02 the following healthcare providers are authorized to complete a DC WIC Medical Prescription Form or other written medical documentation to prescribe WIC authorized foods: • Doctor of Medicine (MD) • Doctor of Osteopathy (DO) • Physician Assistant (PA) • Certified Registered Nurse Anesthetist (CRNA) • Certified Nurse-Midwife (CNM) • Certified Nurse-Practitioner (CNP, CRNP, NP, DNP) • Clinical Nurse Specialist (CNS) Hospital discharge forms Hospital discharge forms may be used to prescribe and issue a special formula or WIC-eligible nutritional for up to two months of food benefits. The DC WIC Medical Prescription Form or other completed written medical documentation must then be obtained and uploaded into the participant’s record. Recommended prescription duration length DC WIC recommends that all approved requests for special formula for infants be reassessed at a duration of no greater than three months from issuance. The recommended maximum duration of a prescription for women and children is six months. CPAs may approve special formula and WIC-eligible nutritional requests beyond these ranges as they deem appropriate. Food Package III issuance in HANDS The following food packages descriptions are used to indicate Food Package III issuance in HANDS (i.e. contain special formula or WIC-eligible nutritionals to tailor and issue): Infants (IFF, IPN+, IPN) • Special Formula

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.008 3 | P a g e • No Solid Foods Children and Women (C1, C2, C3, C4, PG1, PG2, P, PN+, PN) • Special with Formula • Formula Only No Solid Foods Packages In lieu of infant foods (cereal, fruit, and vegetables), infants older than 6 months of age in Food Package III may receive WIC formula (infant formula, exempt infant formula, or WIC-eligible nutritionals) at the same MMA as infants ages 4 through 5 months of age of the same feeding option (i.e. fully formula feeding or partially (some) breastfeeding, and partially (mostly) breastfeeding). Children and Women Special with Formula – Additional Tailoring Options For a participant receiving Food Package III, the healthcare provider must indicate which WIC-authorized supplemental foods and their forms (e.g. pureed fruits and vegetables or whole fruits and vegetables) to issue to the participant or indicate that the WIC CPA may determine the supplemental foods, forms, and amounts to issue to the participant on the written medical prescription form. Standard tailoring options for each participant category and accompanying food package can be found in DC WIC policies 9.005 Infant Food Packages, 9.006 Children Food Packages, and 9.007 Women Food Packages. In addition to the standard tailoring options available to each participant category, the following additional tailoring options are available in the “Special with Formula” food packages: Category(s) Additional Food Item Substitution Food Category to Substitute From Children 1-year-old Nonfat yogurt Whole milk Infant cereal Breakfast cereal Infant fruit and vegetable CVB for fruits and vegetable Juice Children 2 to-4-years Pregnant women Postpartum women (all feeding statuses) Whole milk Low-fat or nonfat milk Whole milk yogurt Infant cereal Breakfast cereal Infant fruit and vegetable CVB for fruits and vegetable Juice

DC WIC NONCONTRACT FORMULA TAILORING GUIDE The following tables can assist the CPA in tailoring the amount of powdered formula for participants issued food package III. Ready-to-feed (RTF) formulas should be issued in quantities that match the total amount needed for one month up to the MMA. A full listing of formulas offered in DC WIC can be found in the DC WIC Formula Guide. Formula Reconstituted Fluid Ounces (RFO) Range # of daily ounces of formula # of cans to issue Exempt Infant formula Reconstituted Fluid Ounces (RFO) Range # of daily ounces of formula # of cans to issue Neocate Infant 14.1 oz 97 to 112 ounces < 3 oz 1 can

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.008 4 | P a g e Pepticate 14.1 oz Pregistimil 16 oz PurAmino 14.1 oz Similac PM 60/40 14.1 oz 4 to 6 oz 2 cans 7 to 9 oz 3 cans 10 to 12 oz 4 cans or up to MMA 13 to 15 oz 5 cans or up to MMA 16 to 18 oz 6 cans or up to MMA 19 to 21 oz 7 cans or up to MMA 22 to 24 oz 8 cans or up to MMA 25 or more 9 cans or up to MMA Alfamino Infant 14.1 oz Elecare Infant 14.1 oz Enfamil AR 12.9 oz Enfamil NeuroPro Enfacare 13.6 oz Gerber Extensive HA 14.1 oz Nutramigen 12.6 oz Nutramigen Jr Similac Alimentum 12.1 oz Similac Neosure 13.1 oz 86 to 96 ounces < 3 oz 1 can 4 to 6 oz 1 to 2 cans 7 to 9 oz 2 to 3 cans 10 to 12 oz 3 to 4 cans or up to MMA 13 to 15 oz 4 to 5 cans or up to MMA 16 to 18 oz 5 to 6 cans or up to MMA 19 to 21 oz 6 to 7 cans or up to MMA 22 to 24 oz 7 to 8 cans or up to MMA 25 to 27 oz 8 to 9 cans or up to MMA >28 oz 10 cans or up to MMA

Elecare Jr 14.1 oz PurAmino Jr 14.1 oz Neocate Jr 14.1 oz Alfamino Jr 14.1 oz

64 to 66 ounces < 3 oz 1 can 4 to 6 oz 2 cans 7 to 9 oz 3 to 4 cans 10 to 12 oz 4 to 5 cans 13 to 15 oz 6 to 7 cans 16 to 18 oz 7 to 8 cans 19 to 21 oz 9 to 10 cans 22 to 24 oz 10 to 11 cans 25 to 27 oz 11 to 13 cans >28 oz 14 cans

Exempt Formula and WIC-Eligible Nutritionals - Liquid concentrate and RTF amounts See DC WIC policy 9.005 Infant Food Packages for tailoring guidance on liquid concentrate and RTF formula. Customized Food Package Creation and Issuance Additional formulas and WIC-eligible nutritionals may be available for issuance in DC WIC beyond those listed in this policy and the DC WIC Formula Guide. The CPA should contact the State Agency to assist with food package issuance for any of the following:

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.008 5 | P a g e 1. A request for a formula or product not currently available as a tailoring option for the participant’s age and category. 2. A request to issue two or more formulas within the same benefit cycle. Example – a healthcare provider requests that both Similac Advance and Similac Neosure be issued in the same month to help the infant transition to a standard formula. 3. A change in benefits mid-cycle if the participant has already redeemed partial benefits for the month (see DC WIC policy 9.002 Replacement of Food Benefits). REFERENCES 7 CFR 246.10(b)(2)(ii) District of Columbia Code § 3–1201. DC WIC policies 9.002 Replacement of Food Benefits, 9.004 Federal Food Packages, 9.005 Infant Food Packages, 9.006 Children Food Packages, 9.007 Women Food Packages ATTACHMENTS & FORMS DC WIC Medical Prescription Form DC WIC Formula Guide

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.009 1 | P a g e Title: Food Packages for Homeless Participants Category: Food Delivery CFR Reference 7 CFR 246.10(b)(1)(ii) Policy Number 9.009 Effective Date: 1/2022 Revised Date: 11/17/2025

POLICY STATEMENT: The State Agency will ensure that authorized supplemental foods* and food tailoring options are available to address any food storage and preparation constraints of homeless participants in DC WIC. The Local Agency will ensure that a CPA/CPPA performs a comprehensive nutrition assessment in accordance with 2.003 Nutrition and Breastfeeding Assessment that identifies the cultural, medical, and dietary needs of the participant. For a participant identified as homeless and residing in a homeless facility, the CPA/CPPA must provide food benefit education that supplemental foods issued are for their personal use only and not to be used in a communal setting or belonging to the homeless facility or institution, in accordance with 7 CFR 246.10(b)(2)(ii)(D). *See DC WIC policy 9.004 Federal Food Packages for definition of supplemental foods. PROCEDURE The following food tailoring options can be used to assist the CPA/CPPA in providing food benefit education to homeless participants: Food Item Food tailoring considerations Infant formula - Powdered formulas are shelf-stable and can be prepared as needed. - Powdered formula is preferred for mothers that are partially nursing. - The CPA can determine the need for RTU/RTF formulas if a lack of access to clean water and/or refrigeration is a concern (see DC WIC policy 9.005 for more information). Milk - For storage concerns, the CPA/CPPA can issue milk in smaller package sizes like quarts and half gallons. - If there is a lack of access to refrigeration, DC WIC authorizes UHT milk, powdered milk, and evaporated milk as shelf-stable options. Cheese and yogurt - DC WIC has expanded its allowable package sizes to allow for purchasing of smaller quantities at once. Cheese can be purchased in 8 oz packaging, yogurt can be purchased in 16 oz packaging. Juice - 64 ounce juices authorized in DC WIC are shelf-stable. Eggs - Eggs can be substituted for canned beans or peanut butter or nut or seed butters. Breakfast cereals - DC WIC has expanded its allowable package sizes to allow for purchasing of smaller quantities at once. Breakfast cereals can be purchased in minimum package sizes of 9 ounces up to 36 ounces. Fruits and Vegetables - DC WIC authorizes several forms of fruits and vegetables that allow for flexibility in purchasing including fresh, frozen, canned, and dried.

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.009 2 | P a g e Whole wheat bread and whole grains - DC WIC has expanded its allowable whole wheat bread options to include English muffins, bagels, and naan, and has additionally authorized more whole grain options that are shelf-stable (e.g. quinoa, oats, brown rice, etc) Fish - Allowable package sizes range from 2 ounces to 15 ounces, allowing for flexibility in purchasing. Dry beans, canned beans, peanut butter or nut or seed butters - The participant may choose from any of the three options. Each form is shelf stable. Infant foods (cereal, fruit and vegetable, meats) - All approved infant foods are in shelf-stable forms (e.g. jars, pouches, containers, etc).

REFERENCES DC WIC policies 2.003 Nutrition and Breastfeeding Assessment, 9.004 Federal Food Packages, 9.005 Infant Food Packages ATTACHMENTS & FORMS

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.010 1 | P a g e Title: Authorized Foods List Category: Supplemental Foods CFR Reference: 246.10 Policy Number: 9.010 Effective Date: 01/2021 Revised Date: 6/15/2026

POLICY STATEMENT: The State Agency will develop and maintain a list of authorized foods – the DC WIC Food List – which specifies the types, sizes, and nutrient standards of authorized foods in the DC WIC program. The Food List will be revised and reissued when there is: a. A change in federal program regulations b. Information on new products developed since the issuance of the last Food List c. A product recall, discontinuation, or reformulation resulting in a change of eligibility status The DC WIC Food List can be found online at www.dcwic.org/foods-formulas.

DC WIC FOOD ITEM SPECIFICATIONS The following chart provides food item selection criteria for inclusion on the DC WIC Food List. Food Item Allowed on the DC WIC Food List Cow’s Milk USDA requirements: ▪ Must be pasteurized ▪ Must contain at least: - 400 IU vitamin D per quart (100 IU per cup) - 2000 IU vitamin A per quart (500 IU per cup)

Not Allowed: o Flavored milk o Added protein (ultra skim)

o Any brand o Organic store brands Regular Milk Nonfat, low-fat, reduced-fat, whole o Quarts, half gallons, gallons Lactose-reduced Milk Nonfat, low-fat, reduced-fat, whole o Quarts, half gallons Buttermilk Low-fat or reduced-fat o Quarts, half gallons Evaporated or Powdered Nonfat, low-fat, reduced-fat, whole o 5 oz to 64 oz packages UHT Milk Nonfat, low-fat, reduced-fat, whole o Quarts Kefir milk o Quarts Goat’s Milk

USDA Requirements: ▪ Must be pasteurized ▪ Must contain at least: - 400 IU vitamin D per quart o Fluid goat’s milk, pasteurized, unflavored o Quarts, half gallons o Approved brands only

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.010 2 | P a g e (100 IU per cup) - 2000 IU vitamin A per quart (500 IU per cup) Cheese

USDA requirements: Made from 100% pasteurized milk Not Allowed: o Cheese from in-store deli o Imported cheese (made outside USA)

o Any brand o Organic store brands o 8 oz, 16 oz, 24 oz, 32 oz packages o Monterey Jack, Colby, Cheddar, Swiss, Muenster, Provolone, part-skim or whole Mozzarella, pasteurized processed American, or blends of these o Block, sliced, cubed, shredded, individually wrapped slices, or string cheese

Soy Milk

USDA requirements (per cup): ▪ Must contain ≤10g added sugar ▪ 276 mg calcium ▪ 8 g protein ▪ 500 IU vitamin A ▪ 100 IU vitamin D ▪ 24 mg magnesium ▪ 222 mg phosphorus ▪ 349 mg potassium ▪ 0.44 mg riboflavin ▪ 1.1 mcg vitamin B12

o Approved brands and flavors o Quarts, half gallons

Tofu

USDA requirements: o 100 mg of calcium per 100 g of tofu o No added fats, sugars, oils, or sodium o Any texture (soft or silken, regular, firm, medium firm, extra firm, super firm) o 8 oz, 14 to 16 oz packages Yogurt

USDA Requirements: o Must be pasteurized o ≤16g sugar per cup o No added granola, candy, nuts, honey, etc o No artificial sweeteners o Pasteurized cow’s milk (nonfat, low-fat, whole) o Organic store brands only o Approved Greek, flavored, and multipack yogurt brands o Single containers - 16 oz, 32 oz o Multipacks - 21.2 oz or 48 oz

Eggs

Not allowed: o Brown or white fresh chicken eggs o Organic store brands only o Cage-free or free-range

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.010 3 | P a g e o Liquid, powdered, or hard-boiled eggs o Pasture-raised o Specialty eggs (i.e., Omega-3) o One dozen (12 count) 100% Juice

USDA Requirements: o Must be pasteurized o Must be 100% juice (Fruit and/or Vegetable juice) o Must contain at least: - 30 mg Vitamin C per 100 mL o Any 100% fruit and/or vegetable juice or juice blends o Any pulp content o Added calcium or fiber o Approved organic brands o Any brand of 100% orange, pineapple, or grapefruit juice Breakfast Cereal

USDA Requirements o Must contain at least: - 28mg iron per 100g dry cereal - < 21.2g added sugar per 100g dry cereal

o Hot cereals - ready-to-eat, instant, and regular o Cold cereals - bagged or boxed o 9 oz to 36 oz

Dried or Canned Beans, Peas, Lentils

Not allowed: o Added sugar, fat, oil, meat, fruit or vegetable o Baked beans or bean soups o Green beans or peas – these can be purchased with the Fruit and Vegetable CVB o Any brand o Organics allowed o Regular, low-, or no-sodium allowed o Refried beans allowed with no added fat o Spices or seasonings are allowed o Dried beans, peas, and lentils – 16 oz, 32 oz, 48 oz packages o Canned beans, peas, and lentils – 15 oz to 16 oz packages Peanut Butter

Not allowed: o Add-ins such as jam, jelly, marshmallow, chocolate, honey or other similar ingredients are not allowed

o Any brand o Organic store brands o Creamy, crunchy, chunky, plain or reduced fat/sodium, unsalted forms allowed o 16 oz to 18 oz packages o Low-fat, reduced-fat, or reduced sodium o “Natural” Nut and Seed Butters

Not allowed: o Add-ins such as jam, jelly, marshmallow, chocolate, honey or o Approved brands only – almond butter o Creamy or chunky, regular, or reduced-fat, salted or unsalted forms allowed o Limited brand options for tahini, sunflower seed butter o 16 oz packages

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.010 4 | P a g e other similar ingredients are not allowed

Canned Fish

“Canned’ refers to processed food items in cans or other shelf-stable containers – cans, jars, or pouches are allowed o Any brand o Packed in water or oil o With bones or skin o Added spices, sauces, and flavorings o Regular or low sodium o 2.5 oz to 40 oz packages

Bread and Bread Products

USDA requirements: o Whole wheat must be the primary ingredient by weight o No added sugars, fats, or oils o 100% whole wheat bread, buns, and rolls o Whole grain breads – whole grain must be the primary ingredient by weight o Whole grain bread products – naan, English muffins, pita, bagels o 12 oz to 48 oz packages Whole Grains – Oats

Not allowed: o Added sugars, fats, or oils o Dry, plain whole oats o May be old-fashioned, quick, or instant o 12 oz to 48 oz packages Whole Wheat Pasta

USDA requirement o Whole wheat must be the primary ingredient by weight o No added sugars, fats, or oils o 100% Whole wheat pasta o Dry, plain, any shape o Organic allowed o 12 oz to 48 oz packages Whole Grains - Rice, Barley and Quinoa

Not allowed: Added sugars, fats, oils, or salts

o Any brand o 100% whole grain brown rice or barley o Organics allowed o 12 oz to 48 oz packages Whole Grains – Tortillas

Not allowed: o Added sugars, fats, or oils

o 100% whole wheat tortillas or corn tortillas o Soft tortillas only o 12 oz to 48 oz packages Infant Cereal

USDA requirement: o Must contain at least: - 45 mg iron per 100g dry cereal Not allowed: o Any brand o Organics allowed o Rice, Oatmeal, or Multigrain cereal o 8 oz or 16 oz packages

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.010 5 | P a g e o Added DHA o Added sugar, milk, fruit, or other non-cereal ingredients Infant Food Fruits and Vegetables

Not allowed: o Added sugars, starches, fats, oils, or sodium o Added DHA

o Any brand o Organics and Naturals allowed o Single fruits, single vegetables, or fruit + vegetable combinations o Texture may range from pureed through diced o Single serving- 2 oz to 4 oz packages o Multipacks- up to 128 oz packages

Infant Meats

Not allowed: o Added sugars, starches, fats, oils, or sodium o Added DHA

o Any brand o Organics and Naturals allowed o Any variety of infant food with a single major ingredient of chicken, turkey, beef, veal, lamb, or ham o May contain broth or gravy o Texture may range from pureed through diced o Single serving - 2.5 oz packages o Multipacks up to 77.5 oz packages

Fresh Fruits and Vegetables

Not Allowed: o Added sugars, fats, or oils o Artificial sugars o Frozen fruit cannot have added salt o Edible blossoms and flowers o Ketchup or other condiments o Vegetable-grain mixtures, fruit-nut mixtures, breaded vegetables, salad bar items, peanuts o Ornamental and decorative fruits and vegetables o Fruit baskets and party trays o Fruit muffins or other baked goods o Mature legumes (beans, lentils, etc.) o Plain fruits and vegetables o Organics allowed o Whole, cut, loose, bagged or plastic o Any immature beans (i.e. green beans, lima beans, succotash) o Fresh herbs

Canned Fruits and Vegetables

Not allowed: o Pickled vegetables, olives, soups o Creamed or sauced vegetables o Fruits packed in syrups or with artificial sugars o Organics allowed o Canned or jarred o May be seasoned with herbs and spices o Fruit or vegetable must be listed as the first ingredient o Canned fruits packed in 100% juice allowed o Canned immature beans, peas, or lentils (e.g. edamame, green beans, yellow wax beans)

DC WIC POLICY & PROCEDURE MANUAL

Policy 9.010 6 | P a g e

Frozen Fruits and Vegetables

Not allowed: o Added sugars or oils o Frozen fruits cannot have added salt

o Organics allowed o May be seasoned with herbs and spices o Frozen vegetables may have added salt o Frozen beans (immature or mature) are allowed. Beans purchased with CVV may contain added vegetables and fruits, but may not contain added sugars, fats, oils, or meat as purchased. Canned beans, peas, or lentils may be regular or lower in sodium content. Dried Fruits and Vegetables

Not allowed: o No added sugars, oils, or salt

o Organics allowed

AUTHORIZED PRODUCT LIST The State Agency will additionally maintain an Approved Products List (APL), which lists the Universal Product Codes (UPCs) for each unique food item that meets the above specifications and is authorized in DC WIC. The APL file is disseminated daily to DC WIC authorized vendors to ensure their Point of Sales (POS) systems stay current on allowable food item redemption and ensure eWIC purchase of eligible WIC food items. Participants can check whether a specific food item is authorized and eligible for their purchase by scanning the UPC via the EzWIC mobile app prior to scanning the item at the POS system.

SUBMISSION OF NEW ELIGIBLE FOOD PRODUCTS New food items found to meet the above food item specifications may be considered for inclusion on the DC WIC Authorized Foods list if all required components below are submitted to info.vendor@dc.gov :

• Full UPC or PLU Code • Brand name and full name of product • Full product description, including container size • Picture: Front label • Picture: UPC barcode • Picture: Nutrition information • Picture: Ingredients

The State Agency will review each submission. If approved, the item will be added to the APL within three (3) business days.

REFERENCES 7 CFR 246.10

DC WIC POLICY & PROCEDURE MANUAL

Policy 10.001 1 | P a g e Title: Local Agency Reporting Procedures Category: Monitoring and Audits CFR Reference: 7 CFR § 246.25 Policy Number: 10.001 Effective Date: 9/30/2014 Revised Date: 8/15/23

POLICY STATEMENT The State and Local Agency must maintain full and complete records concerning program operations. In addition to the current fiscal year, all records must be retained for a minimum of three years following the date of submission of the final expenditure report for the period to which the report pertains, in accordance with DC WIC policy 12.001A Local Agency Scope of Work. PROCEDURE The Local Agency must complete reports as indicated by the State Agency. See attachments 10.001A Local Agency Reporting Deliverables and 10.001B Local Agency Workplan & Narrative for a list of reports, submission dates, format, and instructions.

REFERENCES 7 CFR § 246.25 DC WIC policy 12.001A Scope of Work ATTACHMENTS & FORMS 10.001A Local Agency Reporting Deliverables 10.001B Local Agency Workplan & Narrative

10.002 - 1 Monitoring and Audits

Revised August 2019 X. Monitoring and Audits - Audits

PROCEDURE 10.002 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 08/11/2015

I. Authority USDA

II. Reason for the Policy CFR § 246.20 Audits (b)(3) III. Applicability DC WIC Local Agency

IV. Policy Statement 1. Local agency sponsored audit reports of Program operations shall be made available for State Agency and the U.S. Department of Agricultural (USDA) review upon requests.

2. The local agency shall submit the current A-133 audit to the State Agency along with the Local Agency Annual Plan of Operations. The A-133 audit must provide a line item audit review of the Special Supplemental Nutrition Program for Women, Infants and Children (WIC) with the CFDA No. 10.557. The A-133 audit must cover at least the second year prior to the current fiscal year (for example in Fiscal Year 2010—October 1, 2009– September 30, 2010, the A-133 Audit that is submitted will cover FY 2009, not FY 2010).

3. The State Agency will monitor submission of the most current A-133 Audit during site visits (10.003) and the management evaluation process (10.004).

V. Procedures The following concerns auditing procedures: 1. Submit current A-133 Audit to the State Agency along with the Local Agency Workplan and Quarterly Narrative Report (see appendix 10.001B). 2. Provide other audits reports upon request from State Agency or USDA.

VI. Appendix

N/A VII. Reference 10.001B Local Agency Workplan and Quarterly Narrative Report 10.003 State Monitoring, Technical Assistance, and Site Visits 10.004 State Management Evaluations

10.003 - 1 Monitoring and Evaluation

Revised January 2020 X. Monitoring and Audits - State Monitoring of Local Agencies

PROCEDURE 10.003 Implementing Office: Community Health Administration (CHA) Revised 01/2020 Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective 10/1/2019

I. Authority USDA

II. Reason for the Policy The State Agency may visit Local Agencies on a rolling basis to monitor the delivery of Program Services, competency of staff, and to provide technical assistance.

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement State Agency visits to WIC Local Agency sites may be announced for the purpose of technical assistance or corrective action plan reviews, or unannounced for candid Program monitoring.

V. Procedures 1. The State Agency shall monitor 20% of all Local Agencies on an annual basis to ensure adequate delivery of Program services by competent staff. 2. When monitoring the process of Certifications, State Agency staff shall refer to 10.003A (or 10.003B) to record observations of Local Agency staff performing the certification and the environment of the clinic. 3. When monitoring general Program procedures and customer service, the State Agency staff shall refer to appendix 10.003B to record observations and recommendations for corrective action. 4. When monitoring Local Agency sites for compliance with participant’s files, the staff performing the monitoring visit shall use a participant’s Household ID number to assess the presence of the Voter Registration Agency Certification form, as this form is meant to be stored in the youngest participant’s file (see policy 12.007 Voter Registration) and for that reason may not be found in a woman participant’s file. 5. The Local Agency staff shall return reports in conjunction with State Agency monitoring visits according to policy 10.001 - Reporting Procedures. VI. Appendix

10.003A Certification Monitoring Workbook 10.003B Certification Monitoring PDF 10.003C Local Agency Program Monitoring Form VII. Reference 10.001 Reporting Procedures 12.007 Voter Registration

10.004 - 1 Monitoring and Audits Revised September 2019 X. Monitoring and Audits – State Management Evaluations PROCEDURE 10.004 Implementing Office: Community Health Administration (CHA) Revised September 2019 Approved by: _______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel: ____________________ Phillip Husband, Esq.; General Counsel Effective Date: September 2019 I. Authority USDA II. Reason for the Policy FED § 246.19 State Agency Responsibilities b (2), (3), (4) and (6). III. Applicability DC WIC State Agency and Local Agency Staff IV. Policy Statement 1. Management Evaluations of Local Agencies shall encompass, but not be limited to, certification, nutrition education, breastfeeding support, civil rights compliance, accountability, financial management systems, and food delivery systems. 2. The State Agency shall conduct management evaluations of each Local Agency at least once every two years, but reserves the right to conduct the management evaluation every year. Such reviews shall include on-site reviews of a minimum of 20 percent of the clinics in each Local Agency or one clinic, whichever is greater. 3. The State Agency shall develop a corrective action process which includes: prompt notification of deficiencies to the Local Agency, timely development of corrective action plans, and monitoring of Local Agency implementation of such plans. 4. The State Agency shall require Local Agencies to establish management evaluation systems to review their operations and those of associated clinics or contractors. 5. The Local Agency must submit a corrective action plan, including implementation time-frames, within 30 days of receipt of a Management Evaluation report. V. Procedures 1. Sixty days before a management evaluation, the Local Agency shall receive written notification from the State Agency that a management evaluation will be conducted. See appendix 10.003A for an example of the pre-management evaluation questionnaire. 2. The Local Agency shall provide documentation and/or access to files as indicated in the written notification.

10.004 - 2 Monitoring and Audits

Revised September 2019 3. The Local Agency shall set aside an appropriate workspace for State Agency staff. 4. The Local Agency Director, or a designated representative, shall participate in an entrance interview with State Agency staff. 5. The Local Agency shall ensure availability of staff for observation of actual service delivery, gathering data, and interviews. 6. The Local Agency Director, or a designated representative, shall participate in the exit interview with WIC State Agency staff. 7. The Local Agency shall receive the management evaluation report from State Agency within 30 days of exit interview. 8. The Local Agency shall submit a corrective action plan within 60 days of receipt of the management evaluation report. 9. Once the Local Agency has submitted their Corrective Action Plan, the State Agency shall review within 30 days.

VI. Appendix

10.004A Pre-Management Evaluation Questionnaire 10.004B Management Evaluation Workbook 10.004C Management Evaluation Report Template with Corrective Action Plan

VII. Reference N/A

10.005 - 1 Monitoring and Evaluation

Created September 2019 X. Monitoring and Audits - Internal Monitory (Local Agencies)

PROCEDURE 10.005 Implementing Office: Community Health Administration (CHA)

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Created September 2019

I. Authority DC WIC State Agency

II. Reason for the Policy DC WIC Local Agencies shall monitor staff, Program operations, and clinic environments on a rolling basis to ensure efficient delivery of services and participant satisfaction.

III. Applicability DC WIC Local Agency Staff

IV. Policy Statement Local Agency Directors, or appropriate designated staff, are expected to monitor staff performance, delivery of Program services, and clinic environments on a rolling basis to ensure competency of staff, satisfaction of Program participants, and compliance to State and Federal Regulations.

V. Procedures 1. The Local Agency shall monitor 20% of it’s clinic sites and staff on an annual basis 2. When monitoring the process of Certifications, the Local Agency staff performing the monitoring visit shall refer to 10.003A (or 10.003B) to record observations of the staff performing the certification and the environment of the clinic. 3. When monitoring general Program procedures and customer service, the Local Agency staff shall refer to appendix 10.003C to record observations and recommendations for corrective action. 4. The Local Agency staff shall submit monitoring reports as outlined in policy 10.001 - Reporting Procedures, or as requested by the State Agency.

VI. Appendix N/A VII. Reference 10.001 Reporting Requirements 10.003A Certification Monitoring Workbook 10.003B Certification Monitoring PDF 10.003C Local Agency Program Monitoring Form

10.006 - 1 Monitoring and Audits

Revised September 2019 X. Monitoring and Audits – Internal Evaluation

PROCEDURE 10.006 Implementing Office: Community Health Administration (CHA) Revised September 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: September 30, 2019

I. Authority USDA

II. Reason for the Policy 7 CFR 246.19 (b)(6)

III. Applicability DC WIC Local Agency Staff

IV. Policy Statement The Local Agency shall conduct a thorough evaluation of its operations at least once, every other year and at any time as deemed appropriate. The management evaluation tool entails chart reviews, staff’s competency observations, and Management Information System (MIS) documentation review.

V. Purpose The purpose of Local Agency internal-evaluation is to identify strengths and areas for improvement. This also allows the Local Agency to realize its achievements, identify competent staff and those who need coaching or re-training. The following staff shall be evaluated during internal evaluations:

1. Competent Professional Authorities (CPAs). The Local Agency Director or designate staff shall monitor CPAs for competency in the following areas:

a. Nutritional risk screening using ABCDE guidance b. Care plan (TGIF) notes and SMART goal setting c. Special formula prescriptions and approvals d. Group or class nutrition education e. High nutritional risk management and follow ups f. Design of lesson plans

2. Competent Para-Professional Authorities (CPPAs) and Clerks. Depending on their job description, the Local Agency Director or CPA shall evaluate their competency as it relates to:

a. Participants’ intake (proof of address, income, adjunctive eligibility, pregnancy, etc.)

10.006 - 2 Monitoring and Audits

Revised September 2019 b. Laboratory works (anthropometric measurement and hematological assessment) c. Rights and responsibilities (R&R) d. Voter registration and immunization record e. Participant’s appointment scheduling f. Food package tailoring g. Check issuance and registers h. TGIF note and SMART goal setting i. Missed appointment contact and rescheduling j. Referrals

3. Breastfeeding Peer Counselors (BPCs). The Local Agency Director, Local Agency Breastfeeding Coordinator, designated CPA, or IBCLC shall assess peer counselors regarding:

a. Breastfeeding promotion and support b. Pregnant women and breastfeeding mothers’ follow-up contact (text messaging, phone calls, emails, etc.) c. Effective counseling and understanding of participant’s needs d. Breast pump issuance and log keeping e. Processing and management of breastfeeding referrals

4. New WIC Employees. The Local Agency Director, CPA or designated staff shall evaluate the competency of all new staff members during the first six (6) months of employment or until they are deemed competent to operate independently. This entails consistently monitoring their work, including direct observation and files reviews.

V. Procedures 1. Local Agencies shall perform internal evaluations every other year, as directed by the State Agency.

2. Local agencies shall use the following tools to prepare for and document staff and program evaluations:

a. 10.004A – Pre-Management Evaluation Questionnaire i. LAs shall use this document as a guide to prepare them for performing the ME, allowing appropriate staff members at the given site/s being evaluated to answer relevant questions, while the LAD will answer other questions (such as those pertaining to Local Agency policies, and financial management).

b. 10.004B – Management Evaluation Workbook This excel workbook has tabs for the following: i. Certification Observations ii. File Reviews

10.006 - 3 Monitoring and Audits

Revised September 2019 iii. Clinic Environment Reviews iv. Breastfeeding Peer Counselor Reviews v. Secondary Nutrition Education Reviews 3. Local agencies shall submit pre-Management Evaluation questionnaires, Management Evaluation workbooks, and internal evaluation reports with corrective action plans (see 10.004C) by April 15 of the years when no State agency Management Evaluation is occurring or as directed by the State agency. VI. Appendix

N/A

VII. Reference 10.001 Reports and Reporting Procedures 10.004A Pre-Management Evaluation Questionnaire 10.004B Management Evaluation Workbook 10.004C Management Evaluation Report and Corrective Action Plan Template

DC WIC POLICY & PROCEDURE MANUAL

Policy 11.001 1 | P a g e Title: Civil Rights Overview Category: Civil Rights CFR Reference: 7 CFR 246.8

Policy Number: 11.001 Effective Date: 01/01/2019 Revised Date: 01/31/2024

POLICY STATEMENT: The DC WIC program is a federally assisted program and therefore must comply with • Title VI of the Civil Rights Act of 1964 (42 U.S.C. 2000d et seq.) • Title IX of the Education Amendment of 1972 • Section 504 of the Rehabilitation Act of 1973 • The Age Discrimination Act of 1975 • Department of Agriculture regulations on nondiscrimination • FNS instructions and the requirements of 7 CFR 246.8 to ensure that no person shall on the grounds of race, color, national origin, age, sex (including gender identity and sexual orientation), or handicap, be excluded from participation in, be denied benefits of, or be otherwise subjected to discrimination under the Program. The State and Local Agency are responsible for the following: 1. Informing DC WIC program applicants and participants on how to file a civil rights complaint with the USDA. Civil rights complaints must be referred to FNS within 5 calendar days. 2. Maintaining a record of civil rights complaints. 3. Make WIC program information available to the public upon request. 4. Providing service assistance for persons with disabilities and language services for applicants and participants with Limited English Proficiency (LEP). 5. Including the most current FNS non-discrimination statement (available at https://www.fns.usda.gov/cr/fns-nondiscrimination-statement) on all essential Program materials and prominently displaying the “And Justice for All” poster in all offices where there is a USDA presence and where it may be read by customers. All “And Justice for All” posters must be displayed in a specific size” 11” width x 17” height. The Local Agency must contact the State Agency to order posters. 6. Collecting and reporting racial and ethnic participation data as required by title VI of the Civil Rights Act of 1964. 7. Provide ongoing civil rights training to staff on an annual basis, at minimum. 8. Regularly review and monitor activity to ensure Program compliance with the nondiscrimination laws and regulations. DEFINTIONS 1. Limited English Proficiency – individuals who do not speak English as their primary language and who have a limited ability to read, speak, write, or understand English because of their national origin.

DC WIC POLICY & PROCEDURE MANUAL

Policy 11.001 2 | P a g e 2. Disability – a person who has a physical or mental impairment which substantially limits one or more major life activity, has a record of such an impairment, or is regarded as having such an impairment. PROCEDURE The State and Local Agency must perform at minimum the following actions related to their civil rights responsibilities: Inform DC WIC program applicants and participants on ways to file a civil rights complaint with the USDA Applicants or participants may file a civil rights complaint via the following methods: 1. Any of the contact methods listed on the most recent nondiscrimination statement. The most recent nondiscrimination statement can be found at https://www.fns.usda.gov/cr/fns- nondiscrimination-statement .

2. The State or Local Agency staff may use attachment 11.001B WIC Complaint Form to collect the complaint information and refer this information to program.intake@usda.gov within 5 calendar days. The Local Agency must notify the State Agency when referring a complaint. The State or Local Agency staff must inform the applicant or participant that complaints may be written, verbal, or anonymous. All complaints must be filed within 180 days of the alleged act of discrimination. Maintain a record of civil rights complaints If a civil rights complaint is completed by the State or Local Agency using the 11.001B WIC Complaint Form, the complaint must be logged using attachment 11.001C Civil Rights Complaint Log Sheet. This log sheet, along with any correspondence regarding the complaint, must be kept on file for three years from the date the State Agency is notified that the complaint is closed. Make WIC program information available to the public upon request The State and Local Agency must ensure DC WIC program applicants and participants are made aware of Program availability in accordance with DC WIC policy 7.007 Wait List Overview, program rights and obligations in accordance with DC WIC policy 8.016 Rights and Obligations, and procedures for filing a civil rights complaint (see above). Program assistance for persons with disabilities The State and Local Agency must make reasonable accommodations to provide Program services in a manner appropriate to persons with disabilities. Examples of reasonable accommodations include architectural accommodations (e.g., wheelchair accessible entrances, elevator access, etc.), remote WIC services in accordance with 8.003 Physical Presence and Identification, and access to communication aids to persons that have hearing, vision, or speech disabilities. Serving persons with LEP State and Local Agency staff must notify LEP persons of their right to free language assistance services. This can include a bilingual staff member or interpretation services through the Language Line.

DC WIC POLICY & PROCEDURE MANUAL

Policy 11.001 3 | P a g e The LEP person may opt to provide their own interpreter. The State Agency highly discourages reliance on children as interpreters. Likewise, the LEP person should be permitted to use family and friends as interpreters only after the State or Local Agency has offered free language assistance. If the LEP person opts to use their own interpreter or chooses to decline interpretation services, they must sign the Language Service Waiver in the participant’s record in the MIS. If requested, a physical form of the Language Service Waiver may be used (see attachment 11.00D Language Service Waiver). The physical form must be signed and scanned into the participant’s record in the MIS. The Language Service Waiver must be completed each time an LEP person declines the use of free language assistance services. The Local Agency must ensure that all rights and responsibilities are read to the AR/AAR or participant in the appropriate language and in accordance with DC WIC policy 8.016 Rights and Obligations. In accordance with DC code § 2–1933 (a)The State and Local Agency must ensure that all vital Program documents are available in each language spoken by a limited or no-English proficient population that constitutes 3% or 500 individuals, whichever is less, of the population served. Vital documents include at minimum: • Rights and Obligations form • Ineligibility Notice • Waiver forms (i.e. Language Service Waiver, Zero Income, Breast Pump Release of Liability, etc) • Notice of Program Violations Nondiscrimination Statement and “And Justice for All” poster At minimum, the State Agency must ensure that the nondiscrimination statement must be included on: • Rights and Obligations form • Ineligibility Notice • Notice of Program Violations • Public information promoting the DC WIC program (e.g., program brochures, marketing materials, webpages, etc). The Local Agency must display the “And Justice for All” poster in a prominent location for all to view. The State and Local Agency must convey the message of equal opportunity in all photos and other graphics that are used to provide program or program-related information, including the use of the nondiscrimination statement when and where applicable. Regular review/monitoring of Program activities The State and Local Agency must annually review their activities for civil rights requirements compliance. The Local Agency may use 11.001A Monitoring Civil Rights Compliance as a checklist for monitoring civil rights compliance. The State Agency will monitor the Local Agency civil rights activities and compliance in accordance with 10.004 State Agency Management Evaluations. Collection/reporting of racial and ethnic participation data In accordance with 7 CFR 246.8(a)(3), the State Agency must collect and report racial and ethnic participation data. This data is collected in the MIS and must be maintained for three years.

DC WIC POLICY & PROCEDURE MANUAL

Policy 11.001 4 | P a g e The Local Agency must: 1. Ask for race and ethnicity data of each applicant to the DC WIC program. 2. Inform the applicant (or AR/AAR for children and infants) that reporting this data is voluntary and is requested solely for the purpose of determining the State’s compliance with Civil Rights laws and has no effect on their eligibility. 3. Inform the applicant (or AR/AAR for children and infants) that another data collection method will be used if they decline to self-identify (i.e. the Local Agency staff will observe and report based on their judgement). 4. Collect ethnicity before race. 5. Provide an option to select one or more races. Civil rights training requirements The State Agency will provide civil rights training to the Local Agency on an annual basis. The Local Agency must provide civil rights training: • On an annual basis to all staff who interact with DC WIC program applicants or participants • To all new employees prior to participating in the delivery of DC WIC program services The State and Local Agency civil rights training must cover: • the collection and use of Program data • effective public notification system (i.e. program information available to the public upon request and notice of nondiscrimination) • complaint procedures • compliance review techniques • resolution of noncompliance • requirements for reasonable modifications and auxiliary aids and services for persons with disabilities, requirements for LEP persons • confliction resolution and customer service REFERENCES DC WIC policies 7.007 Wait List Overview, 8.016 Rights and Obligations, 10.004 State Agency Management Evaluations Code of the District of Columbia; Subchapter II. Language Access; DC code § 2–1933 (a) Americans with Disabilities Act - www.ada.gov/resources/disability-rights-guide/ ATTACHMENTS & FORMS 11.001A Monitoring Civil Rights Compliance 11.001B WIC Complaint Form 11.001C Civil Rights Complaint Log 11.001D Language Service Waiver

DC WIC POLICY & PROCEDURE MANUAL

Policy # 11.002 1 | P a g e Title: Mandatory Non-Smoking in WIC Clinics Category: Civil Rights CFR Reference: CFR § 246.6 Policy Number 11.002 Effective Date: 01/01/2016 Revised Date: 01/31/2024

POLICY STATEMENT: In accordance with CFR 246.6(b)(4), smoking is prohibited in the space used to carry out the WIC Program during the time any aspect of WIC services are performed. In accordance with DC code § 7-1704, the Local Agency must display a “no smoking” sign, using the internationally recognized symbol, in all WIC clinics where WIC services are provided. The State Agency must issue a written citation to the Local Agency and withhold administration funds if found out of compliance with this policy. This penalty will be lifted once the Local Agency complies with the policy. PROCEDURE The State Agency will monitor the Local Agency’s compliance in displaying the “no smoking” signs in each WIC clinic in accordance with DC WIC policy 10.003 State Monitoring of Local Agencies. The Local Agency must ask persons entering the WIC clinic with a lit smoking device (e.g. cigarettes, e- cigarettes, pipes, e-pipes, vapes, vaporizers, vape pens, hookah pens, etc.,) to extinguish the device before entering the clinic. Failure of the person to extinguish the smoking device may result in a delay in receiving WIC services.

REFERENCES CFR 246.6(b)(4) DC code § 7-1704 DC WIC policy 10.003 State Monitoring of Local Agencies ATTACHMENTS & FORMS DC WIC Style Guide

12.001 - 1 Administrative Procedures

Revised August 2019 XII. Administrative Procedures – Local Agency Grant Award

PROCEDURE 12.001 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2016

I. Authority USDA

II. Reason for the Policy CFR 246.6 Agreements with Local Agencies III. Applicability DC WIC Local Agency Staff

IV. Policy Statement The DC WIC State Agency will review applications from Local Agencies for compliance prior to the awarding of funds. This pre-award compliance review will include the following criteria: 1. The Local Agency has had no recent history of non-compliance with Title VI 2. The local entity will operate within the procedures established by the State Agency 3. The clinic site location(s) does not deny access to any person on the basis of race, color, national origin, sex, religious creed, disability, age, political beliefs, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA. See Non-Discrimination Agreement (appendix 12.001B) 4. Bilingual staff and materials are or will be made available in areas that have a significant proportion of non-English or limited English proficient persons 5. There are no discrimination complaints pending against the applicant agency

V. Procedure for Grant Submission 1. See Suggestion Form in Appendix 12.001A for Local Agency Grant Application. Follow policy as stated above.

2. Resources to assist the application process:

DC WIC State Agency DC Health

12.001 - 2 Administrative Procedures

Revised August 2019 Community Health Administration Nutrition and Physical Fitness Bureau WIC State Agency Office 899 North Capital Street NE, 3rd Floor Washington, DC 20002 202-442-9397

CSA Office of Federal Management Policy • Federal Management Circular No. A-87 Cost Principles Applicable to Grants and Contracts With State and Local Governments. 34 CFR 255 • Office of Management and Budget Circular No. A-102 Revised Uniform Administrative Requirements for Grants-in –Aid to State and Local Governments. Federal Register; Vol. 42, No. 176, September 12, 1977.

VI. Appendix

12.001A WIC Scope of Work 12.001B Non-Discrimination Agreement

VII. Reference N/A

12.002 - 1 Administrative Procedures

Revised September 2019 XII. Administrative Procedures – Ordering Supplies

PROCEDURE 12.002 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2016

I. Authority DC WIC State Agency

II. Reason for the Policy To ensure an accurate process for maintenance of inventory and reordering of forms and materials.

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement To ensure an accurate process for maintenance of inventory and reordering of forms and materials, the WIC State Agency utilizes an ordering control system for use by Local Agencies. All Local Agency supplies are ordered on an as-needed basis using the WIC Program Ordering Control Form (see Appendix 12.002A), which can be downloaded from dcwic.org. The supply request should be e-mailed to the State Agency at info.wic@dc.gov. Supply requests are not accepted by phone or face-to- face. The State Agency asks that Local Agency inventories be monitored carefully in order to avoid last minute request.

The ordering of pre-printed checks is monitored and initiated by the WIC State Agency on a bi-monthly basis. The State Agency schedules the automatic delivery of all manual checks.

V. Procedures Local and State agency staff must follow the procedure below when ordering supplies from the State agency:

1. The Local Agency must complete the DC WIC Program Ordering Control Form (Appendix 12.002A) and email the form(s) to the State agency at info.wic@dc.gov. Each Local Agency is responsible for ordering and/or purchasing its own nutrition, breastfeeding, and outreach materials.

2. Should the Local Agency be ordering supplies from the State agency, the State agency will arrange the delivery of the supplies to the site(s).

3. The requested supplies will be sent by courier to the Local Agency’s address listed on the request form.

12.002 - 2 Administrative Procedures

Revised September 2019

4. The DC WIC Program Ordering Control Form can be used to order a variety of administrative forms, as well as education/outreach materials and other supplies that are available at the State Agency. A minimum of five (5) business days for processing is needed to fill orders generated by the Ordering Control Form.

a. WIC Clinic Forms (individual forms can be accessed online at www.dcwic.org) b. WIC ID Folder Bags c. WIC ID Folder Spanish d. WIC ID Folder English e. Nutrition Education Handouts (appendix 12.002B))

5. Outreach Supply Material

Local Agencies are responsible for ordering their own outreach materials,, paraphernalia and general education materials for outreach events for the WIC Program. Updated brochures, posters and flyers can be found at https://www.dcwic.org/wic-marketing- materials. Approved paraphernalia and general education materials can be found in the DC WIC Resource Guide (12.002B), which can also be found on dcwic.org.

Delivery for supplies ordered using the WIC Program Ordering Control may be provided by a courier or a messenger from the State Agency.

VI. Appendix

12.002A DC WIC Program Ordering Control Form 12.002B DC WIC Resource Guide

VII. Reference N/A

12.003 - 1 Administrative Procedures

Revised August 2019 XII. Administrative Procedures – Customer Service, Vision and Guidelines

PROCEDURE 12.003 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2016

I. Authority DC WIC State Agency

II. Reason for the Policy Vision – We, the WIC Staff, are proud to consistently deliver world-class customer service in all aspects of our work. We readily provide supplemental foods, nutrition education, breastfeeding promotion and support, and referrals to health and social services to meet the diverse needs of all customers. Our customers are impressed with the efficiency and timeliness and professionalism of the services.

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement 1. Each local agency shall implement the gold standard of customer service delivery, exemplified by the following four key components:

a. Reliable points of entry b. Prompt response to customer calls, written correspondence, and requests for services c. Front-line customer contacts handled with the highest level of professionalism and customer service d. Service delivery within the established, easily understood, and widely known performance standards 2. Each local agency shall ensure that they meet the following objectives of high quality customer service:

12.003 - 2 Administrative Procedures

Revised August 2019 a. Treat all customers with enthusiasm, courtesy and respect b. Promptly answer all customers’ questions with accurate, objective information c. Resolve all customers' needs with the fewest number of calls possible d. Provide educational information to all customers e. Use language that all customers can easily understand f. Ask for and consider all customers' ideas about program services g. Promptly respond to all customers' suggestions, concerns, and complaints 3. Each local agency is directly responsible for delivery of all customer service commitments. To better support the WIC staff, local agency management shall: a. Give staff the decision-making parameters that will enable them to go "the extra mile" to satisfy customers b. Involve staff in customer service improvement initiatives c. Establish a customer-focused culture and infrastructure at all levels of management and internal support V. Procedures The following steps must be implemented by all staff to ensure exceptional customer service: 1. Incorporate vision and guidelines in the Local Agency Workplan (see appendix 10.001B) 2. Report progress quarterly via the Quarterly Narrative Report (see appendix 10.001B) VI. Appendix

N/A VII. Reference 10.001B Local Agency Workplan and Quarterly Narrative Report

12.004 - 1 Administrative Procedures

Revised August 2019 XII. Administrative Procedures – Customer Service Master Competencies

PROCEDURE 12.004 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by: _____________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel: ____________________ Phillip Husband, Esq.; General Counsel Effective Date:01/01/2016

I. Authority DC WIC State Agency

II. Reason for the Policy WIC Local Agency staff are expected to show respect and courtesy towards Program participants when providing WIC services. III. Applicability DC WIC State Agency and Local Agency Staff IV. Policy Statement 1. All WIC staff shall demonstrate master (core and contributory) competencies to provide the gold standard of customer service delivery; See Appendix 12.004A for a list of the master competencies, and their corresponding practices and behaviors/evidences 2. Master competencies are the areas of knowledge, skills and attitudes that characterize exemplary service employees. 3. The Local Agency WIC Director is responsible for ensuring development of master competencies for local agency staff

V. Procedures Local agency staff must follow the procedure below when completing competencies: 1. Provide and/or participate in training to develop competencies in customer service skills 2. Monitor employee customer service competency skills 3. Provide corrective actions to address deficiencies in customer service skills VI. Appendix 12.004A Master Competencies for Service Providers

12.005 - 1 Administrative Procedures

Revised August 2019 XII. Administrative Procedures – Customer Service, Telephone Standards

PROCEDURE 12.005 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2016

I. Authority DC WIC State Agency II. Reason for the Policy DC WIC Local Agency staff shall treat all persons with respect during customer service, including those calling WIC clinics via telephone. III. Applicability DC WIC Local Agency Staff IV. Policy Statement The following must be implemented concerning customer service: 1. Develop objectives to ensure compliance with telephone standards 2. Submit objectives with the Local Agency Work Plan 3. Provide training to develop competencies in customer service skills 4. Monitor employee customer service skills 5. Provide corrective actions to address deficiencies in customer service skills V. Definitions a. Main Service Number - are the entry points into the Local Agency’s WIC clinics. This service number shall be staffed at all times during business hours, or may provide an automated system whereby customers can receive information, leave a message, or speak with a person. b. Desk Numbers - are telephone numbers for local agency employees. All employees shall answer calls professionally and courteously. Desk voicemail shall

12.005 - 2 Administrative Procedures

Revised August 2019 also reflect the same professionalism that would be provided during a direct conversation with a customer. VI. Procedures 1. Customer Service Voicemail Standard (CSVS) All voice mailboxes shall be set-up with the customer service voicemail standard and ready to accept voice messages. Each voice mailbox shall never be full and unable to accept new messages. The automated greeting option available through the standard voice messaging system does not comply with the standard. a. Main Service Greetings - This greeting shall convey the following information: I. Name of WIC clinic II. Hours of operation III. What number to dial for immediate assistance IV. Options for caller (e.g., website address, fax number) V. When calls will be returned b. Desk Telephone Standard Greetings - Every telephone equipped with voice mail shall have a standard outgoing greeting that is professional, concise, and conveys relevant and useful information to the caller. Each desk phone shall have the following information included within the greeting: I. Name of employee II. Title of employee III. Clinic name IV. What number to dial for immediate assistance V. When calls will be returned c. Extended Absence Greeting - Every employee who will be out of the office for more than two business days (annual/sick leave, training, and jury duty) shall record an extended absence greeting. In addition to the standards, this greeting shall outline the expected date of return, or that all calls shall be forwarded to an employee in the office. d. Closed Greeting – When the WIC clinic is closed, a greeting must be recorded on the main service telephone. The greeting shall convey the following information: I. Name of WIC clinic II. Reason for closure III. Date(s) of closure IV. Date and time when clinic will be re-opened

12.005 - 3 Administrative Procedures

Revised August 2019 V. When calls will be returned 2. Receiving and Returning Telephone Calls a. Salutation - Staff name and agency, and solicit information (e.g., "Thank you for calling agency X. This is Mary Ann. How may I help you?"). At the end of the conversation, thank the person for calling. b. Receiving Telephone Calls – WIC staff shall receive all incoming calls during business hours. Each call shall be handled at the first point of contact or prioritized based on the greatest need during busy periods. c. Returning Telephone Calls - Calls made to all numbers at every level (main service or desk number) shall be returned within one (1) business day of receipt. 3. Receiving a Transferred or Three-Way Conference Calls a. All WIC local agency staff shall take transferred and three-way conference calls from the State Agency to resolve participant concerns or complaints. Local agencies shall also accept all transferred calls from other organizations. b. WIC staff shall minimize the number of times a caller is transferred to resolve an issue by taking the message and distributing it to the appropriate staff person for resolution. The goal is one transfer per customer and the transfer shall be to another person, not voicemail. 4. Basic Knowledge All WIC staff shall be knowledgeable of WIC benefits and services. 5. Telephone Etiquette In addition to the requirements for salutation, call transfer and basic knowledge, each telephone call shall be handled with the highest level of customer service by all WIC staff:

I. Answer calls within 3 rings II. Direct the conversation to obtain the essential information quickly III. Give customers options (i.e., hold, call back, leave a message, try another number) IV. Ask to put the caller on hold and wait for the response V. Check back with customer frequently when placed on hold VI. Use judgment by handling callers as you would want your call to be handled VII. Provide options for resolution VIII. Facilitate IX. Speak as you would like to be spoken to

12.005 - 4 Administrative Procedures

Revised August 2019 6. Courtesy Local Agency staff shall be treat all callers with the highest level of customer service:

I. No speakerphones unless the customer agrees II. No food or gum while talking with customer III. No secondary conversations while caller is on the phone IV. No loud music in the background V. Convey empathy, professional courtesy, and a pleasant attitude VI. Provide reference information when transferring calls VII. Treat callers as you would want to be treated VIII. No rudeness IX. Do not become confrontational

VII. Appendix N/A VIII. Reference N/A

12.006 - 1 Administrative Services

Revised August 2019 XII. Administrative Procedures – Customer Service: Comments, Complains and Compliments

PROCEDURE 12.006 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 02/01/2003

I. Authority DC WIC State Agency

II. Reason for the Policy Procedures must be set in place to ensure timely correspondence between WIC Local Agencies and current or potential Program participants, the State Agency, and the public.

III. Applicability DC WIC Local Agency Staff

IV. Policy Statement 1. The local agency is responsible for receiving and responding to all customer comments, complaints and compliments within 48 hours (two days) of receipt. The WIC Local Agency Director shall determine whether an oral or written response is necessary based on the situation.

2. Each WIC clinic shall have customer feedback forms/surveys readily available (See Appendix 12.006A and 12.006B for examples) and in a conspicuous place for customers to provide anonymous comments.

3. The local agency is responsible for resolving customer complaints, except those relating to civil rights (discrimination). The State Agency will become involved only after the chain of command has been followed and there is no mutual resolution, or as referred to by the WIC Local Agency Director.

4. The Local Agency Director shall ensure that all clinic staff has the authority to resolve customer complaints at the initial point of contact.

V. Procedures Local agency staff must follow the procedure below concerning customer service:

1. The local agency staff person receiving the complaint shall facilitate resolution.

2. If at the initial point of contact, the staff person is unable to resolve the complaint, refer it to the clinic supervisor, then to the Local Agency Director,

12.006 - 2 Administrative Services

Revised August 2019 in that order.

3. The Local Agency Director shall refer the customer to the State Agency only if a mutual resolution cannot be achieved on the local agency level.

4. If referred to the State Agency, the State Agency staff will follow up with the Local Agency Director with the final resolution within 3 business days.

5. For civil rights (discrimination) complaints, refer to Policy 11.001.

VI. Appendix

12.006A WIC Client Survey (English) 12.006B WIC Client Survey (Spanish) VII. Reference 11.001 Civil Rights

12.008 - 1 Administrative Procedures

Revised August 2019 XII. Administrative Procedures – Participant Suggestions

PROCEDURE 12.008 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2016

I. Authority DC WIC State Agency

II. Reason for the Policy Participants are entitled to provide feedback about the WIC Program at their own will.

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement The most effective way to solicit written suggestions is with a suggestion box located in an obvious, easily accessible area. Suggestion forms and pencils/pens should be readily available near the box.

V. Procedures See Suggestion Form in Appendix 12.008A that can be used to solicit comments/complaints.

VI. Appendix

12.008A Suggestion/Complaint Form for DC WIC

VII. Reference N/A

12.009 - 1 Administrative Procedures

Revised August 2019 XII. Administrative Procedures – Facility Re-Organizing and Re-Location Planning

PROCEDURE 12.009 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.6 Agreements with Local Agencies

III. Applicability DC WIC Local Agency Staff

IV. Policy Statement As a part of the State and Local Agency Agreement the Local Agency must notify the State Agency of any re-organization plans for the facility at least 3 months prior to relocating or reducing the designated space for these services.

V. Procedures The following process should be implemented pertaining to the opening, expansion, closing, or moving of a clinic:

1. The Local Agency must notify the State Agency in writing using their Local Agency letterhead of the relocation or reduction plans for the clinic with the signature of the administrator of the Local Agency- see template for example of letter- in appendix 12.009A.

2. Submit the Site Closing/Moving/Opening Information Sheet to the State Agency three (3) months prior to the closing and include:

(1) The reason for closing/moving/opening (2) Detailed plans for providing benefits to affected participants (3) A Civil Rights Impact Analysis (see appendix 12.009D)

3. Post announcements notices throughout the WIC clinic indicating the date for closing as well as the address of the new WIC site, or

4. Post announcements notices throughout the WIC clinic indicating the date for closing as well as alternative WIC sites to refer participants

5. Mail the announcement notices which indicate closing/new address of the new WIC sites

12.009 - 2 Administrative Procedures

Revised August 2019

6. Mail the announcement notices which indicate the closing and reference to alternative WIC sites where participants can voluntarily make a transfer

7. Arrange a visit with the State Agency liaison, IT Contractor, and the administrator’s building management of the new location

8. Provide the State agency with the actual moving date and notification of when the clinic will be operable to serve clients; this decision can be made in tangent with the State Agency liaison for the Local Agency

VI. Appendix

12.009A Template letter for clinic closing/moving/opening 12.009B Site closing/moving/opening information sheet/data equipment transfer request form 12.009C Completing the Site Closing/Moving/Opening Information Sheet/Data Equipment Transfer Request Form 12.009D Civil Rights Impact Analysis

VII. Reference N/A

12.010 - 1 Administrative Procedures

Revised August 2019 XII. Administrative Procedures – Termination and Installation of Network Connections at Closing and New Sites

PROCEDURE 12.010 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2016

I. Authority USDA

II. Reason for the Policy CFR § 246.14(c) Program costs – Specified allowable nutrition services and administration costs III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement This policy outlines responsibilities and procedures for State Agency information technology (IT) support personnel when assisting in the termination of network connections at closing sites, and the installation of network connections at new WIC sites.

This policy also outlines the responsibilities of the network provider and WIC Local Agency staff in assisting State agency IT personnel in preparation for closing, opening, or relocation of a WIC site.

V. Procedure for Local Agency Staff The following steps must be completed by local agency staff in preparation for network installation/de-installation at WIC sites:

1. Notify the State agency 90 days in advance in writing of the opening, closing or relocation of a site. The written notification must be documented on the agency’s letter head (Appendix 12.009A), and emailed to info.wic@dc.gov.

2. A Civil Rights Impact Analysis (CRIA) Form (Appendix 12.016C) is required to be submitted to the State Agency 90 days prior to closing or relocating a local agency and must be submitted at info.wic@dc.gov.

3. Depending on the opening or closing of a site, the local agency must determine where WIC computer data outlets will need to be connected/disconnected.

4. Have the necessary network cabling (drops) in their newly designated spaces, including network panels in walls, going in ceilings and making appropriate connections to the existing patch panel.

12.010 - 2 Administrative Procedures

Revised August 2019

5. Distribute marketing materials to WIC enrollees including the specific move date as well as the new location at the local agency clinic site that is to be moved or closed. 6. Pack WIC equipment at the current WIC clinic site for transport to the new location.

VI. Procedure for DC WIC IT Support Staff The following steps must be completed by the Department of Health (DC Health) WIC IT support staff once notification of WIC new site opening or site closing:

1. Determine the number of network printers, PC (computers), network lines to be moved.

2. Unplug monitors, mice, keyboards, printers, switch and router.

3. Label all WIC equipment.

4. Plug monitors, mice keyboards, printers, switch and router at the new location.

5. Coordinate installation of new network with LA management, LA IT and contractors as well as the WIC State Agency LA liaison.

6. Coordinate installation/de-installation of circuit and router with network provider in time to ensure seamless continuation of WIC services.

7. Print labels of enrollees and send a letter of the clinic site that is be relocated / closed (See Policy 12.009).

8. Coordinate the addition of new service site number in CARES (through DC System Administration module) and set up the print queue for the new service site number.

VII. Procedure for State Agency Representative

The following step must be completed by the State agency representative:

1. Use the printing labels that DC Health IT provided to send notices or letters of clinic relocation / opening to WIC enrollees at affected clinic site

VIII. Procedure for Network Provider The following steps are performed by the network provider concerning installation of network connections at WIC clinics:

1. The order is placed by DC Health IT with OCTO/DCNet.

2. OCTO/DNCET acknowledges that the order was placed

12.010 - 3 Administrative Procedures

Revised August 2019 3. OCTO/DCNET performs their portion of the installation. (Note that the installation/de-installation process may take up to 30 days and must be factored into total relocation and/or closing of WIC sites).

4. OCTO/DCNET or DC Health IT, establishes the CARES connection in the cloud.

IX. Appendix N/A

X. Reference 12.009 Facility Re-organization/Relocation Planning 12.009A Site Closing/Moving Agency Announcement Letter 12.016C Civil Rights Impact Analysis

DC WIC POLICY & PROCEDURE MANUAL

Policy 12.011 1 | P a g e Title: State Plan Category: Nutrition Services Plan and Evaluation CFR Reference: 7 CFR § 246.4 7 CFR § 246.11 Policy Number: 12.011 Effective Date: 01/01/2016 Revised Date: 8/15/2023

POLICY STATEMENT By August 15 of each year, the State Agency must submit to FNS for approval a State Plan for the following fiscal year as a prerequisite to receiving funds under 7 CFR § 246.4. The State agency may submit the State Plan in the format provided by FNS guidance. Alternatively, the State agency may submit the Plan in combination with other federally required planning documents or develop its own format, provided that the information required below is included. The State Plan must be signed by the State designated official responsible for ensuring that the Program is operated in accordance with the State Plan. After receiving approval of the State Plan, the State Agency must only submit to FNS for approval substantive changes in the State Plan. The State agency must establish a procedure under which members of the general public are provided an opportunity to comment on the development of the State agency plan. PROCEDURE 1. A complete State Plan must include everything requested by FNS under Subpart B – State and Local Agency Eligibility, State Plan: 246.4(a), Requirements. 2. The State Agency must conduct an annual evaluation of its State Plan that includes participant feedback on nutrition education and breastfeeding promotion activities. (7 CFR § 246.11) The DC WIC State Plan will be open for public comment per DC Health standard procedures. REFERENCES 7 CFR § 246.4

12.012 - 1 Administrative Procedures

Revised August 2019 XII. Administrative Procedures – Program Integrity, WIC Services for Employees and Relatives

PROCEDURE 12.012 Implementing Office: Community Health Administration (CHA) Revised August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 07/28/216

I. Authority USDA

II. Reason for the Policy CFR § 246.3(e) Administration – State staffing standards

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement The local agency employee is prohibited from participating in any component of the certification process and issuing checks to themselves, their relatives or close friends to ensure that no conflict of interest exists, and to prevent and detect staff fraud abuse.

V. Procedures The following procedure must be followed to ensure program integrity concerning WIC services for employees and relatives:

1. For any local agency employee, their relatives or close friends applying for or participating in WIC, only the local agency program manager, site supervisor or designee, appointed in the absence of the program manager and site supervisor, is authorized to:

a. Determine their eligibility to receive WIC benefits, and

b. Process the certification and provide appropriate nutrition education contacts including the prescribing of WIC checks.

2. The local agency program manager, site supervisor or designee must:

a. Restrict access to the participant’s information in CARES by rendering it “confidential”

b. Secure and file the applicant’s or participant’s paper records separately from the general paper files

12.012 - 2 Administrative Procedures

Revised August 2019 c. Maintain separation of duties between prescribing, printing and removing checks from the printer, and distributing Cash Value (CVC) and WIC checks

3. The local agency will develop and implement procedures to ensure WIC program integrity is maintained when services are provided by the designee. The written procedures will be made available to program reviewers upon request.

VI. Appendix

N/A VII. Reference N/A

12.013 - 1 Administrative Procedures

Revised February 2023 XII. Administrative Procedures – Fair Hearings

CFR Reference: 246.9 Policy Number: 12.013 Implementing Office: Community Health Administration (CHA)

Effective date: 04/11/2023 Revised Date: 09/15/2016 03/3/2023 Approved by:

_______________________ Dr Sharon Lewis DHA, RN-BC, CPM, Interim Director of DC Health Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel

I. Authority USDA

II. Reason for the Policy Program participants are entitled to a fair hearing if they are unsatisfied with an adverse action made by the State or Local Agency.

III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement This policy establishes the procedures under which an individual, parent, guardian or other representative may appeal an adverse action made by the State or a local WIC agency. V. Procedure for Availability of Hearings At the time of a claim against an individual for improperly issued benefits or at the time of participation denial or of disqualification from the WIC Program, the local agency shall inform each individual in writing of the right to a fair hearing, of the method by which a hearing may be requested, and that any positions or arguments on behalf of the individual may be presented personally or by a representative such as a relative, friend, legal counsel or other spokesperson.

1. The local agency shall provide written information on how to request a fair hearing to appeal an adverse action made by the local agency, (action which resulted in a claim against the individual at the time of the action. These actions may include request for repayment of the cash value of improperly issued benefits or denial of participation or disqualification from the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC), DC WIC

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Revised February 2023 Policy 8.015 “Violations and Sanctions”). The participant may request notification form for Ineligibility and termination DC WIC Policy 8.006 Income Eligibility and 8.014 Ineligibility. The local agency shall appoint an impartial hearing official or panel to conduct the hearing, who does not have any personal stake or involvement in the decision and who was not directly involved in the initial determination of the action being contested. 2. A participant found ineligible for the Program at any time during the certification period shall be advised in writing of the reason(s) for ineligibility, the termination date, and of the right to a fair hearing. Reasons for ineligibility during a certification period and the termination notice timeframes are: 10 day Notification of Termination: a. No longer categorically eligible; b. Changes to income or family size making them income ineligible; c. No longer have a required nutritional need; or d. Sanctions for Program Abuse. All documentations are saved onto MIS system by the local agency. 3. The participant may request for a conference within 7 days of notification of the adverse action. The local agency shall set up a conference within 10 days of a written or verbal request by an individual. The participant may bring a relative, friend or lawyer to speak for them at the conference. 4. The individual may ask for a fair hearing with the Office of Administrative Hearings within 60 days of notification of an adverse action if no resolution is reached at a conference at the local agency. 5. The State Agency allows for an individual to request a fair hearing within 90 days after the date the agency mails or gives the applicant or participant the notice of adverse action.

Fair hearings are conducted at: WIC State Agency Office Headquarters (Administrative Office) 899 North Capitol Street NE | 3rd Floor | Washington, DC 20002 Telephone: 202-442-9397

Or Participant has an option of Fair Hearing at: District of Columbia – Office of Administrative Hearings 441 Fourth Street, NW Suite 450 North Washington, DC 20001 Telephone: 202-442-9094

In cases where the appointed hearing official is not available, a backup official must be appointed. A panel member could serve in this role. VI. Time Frame and Notification of Fair A written notification of the hearing shall be sent to the applicant/participant (and his/her representative) at least 10 days prior to the hearing date. The notification shall:

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Revised February 2023 Hearing Process 1. Specify the date, time and place of the hearing.

2. State briefly the issues, which are to be subject to the hearing.

3. Explain the manner in which the fair hearing will be conducted.

4. Inform participant of the right to be represented to verify and present documented evidence, produce witnesses, question adverse witnesses and to examine (prior to and during) the documents and records supporting the action under appeal.

VII. Denial of Fair Hearing Request

The Local Agency may deny or dismiss a request for a hearing due to the following reasons:

1. The request is not received within the time frame established by the State Agency 2. The request is withdrawn in writing by the applicant/participant or a representative of the applicant/participant; 3. The applicant/participant or representative fails, to appear at the hearing without good cause; 4. The applicant/participant has been denied participation by a previous hearing and cannot provide evidence that circumstances relevant to Program eligibility have changed in such a way as to justify a hearing; 5. Participants who request a fair hearing to appeal the termination of benefits before the date entered on the Ineligibility Notice shall continue to receive WIC benefits until the Hearing officer reaches a decision or the certification period expires, whichever occurs first. This does not apply to applicants denied benefits at initial certification, participants whose certification period has expired or participants who become categorically ineligible for benefits. VIII. Hearing Decision The applicant/participant shall receive, by mail, a written decision from the DC WIC State Agency or the Office of Administrative Hearings (depending on where the hearing was conducted) within 10 days following the date of determination, but no more than 45 days following the filing date.

When a fair hearing decision is unfavorable to the applicant/participant, OAH or the DC WIC State Agency shall explain the right to pursue judicial review.

If the decision is in favor of the applicant/participant and benefits were denied or discontinued, benefits shall begin immediately. IX. Appendix N/A

X. Reference CFR § 246.9 Fair Hearing Procedures for Participants

12.016 - 1 Administrative Procedures Revised August 2019 XII. Administrative Procedures – Application Process for New Local Agencies and/or New Site Locations PROCEDURE 12.016 Implementing Office: Community Health Administration (CHA) Revised August 2019 Approved by: _______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel: ____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2017 I. Authority USDA II. Reason for the Policy CFR § 246.5 Application for New Local Agency III. Applicability DC WIC State Agency and Local Agency Staff IV. Policy Statement When an organization expresses interest in becoming a WIC Local Agency (LA), the State Agency (SA) will send information regarding the DC WIC program and the responsibilities of being a WIC agency. The SA will instruct the potential new agency to complete the DC Health WIC Program Application for New Local Agencies (see appendix 12.016A), which should be completed and returned to the SA via email at info.wic@dc.gov. Current DC WIC Local Agencies may use the same application when seeking approval to open additional site(s). A copy of the DC Health WIC Program Application for Local Agencies can also be found on the DC WIC Website (dcwic.org). NOTE: Grant agreements start at the beginning of a FFY (October 1st). A new agency to WIC will not start their online training until October 1st and will not provide actual WIC services for clients until a later date to be determined. The SA will acknowledge receipt of an application within 20 days. If any additional information is needed or the application is completed incorrectly, the SA will inform the organization of the deficiencies within 20 days. After receipt of corrections or additional information, the SA will analyze the request and inform the organization of the approval or disapproval of the request within 90 days.

12.016 - 2 Administrative Procedures Revised August 2019 VI. Procedures An organization who would like to be a new WIC Local Agency (or – a current LA wishing to open a new site) must provide the following information to the State Agency: 1. Notify the SA of the desire to be a new WIC LA, or the desire to open new site(s) in conjunction with a currently contracted DC WIC LA 2. Provide a letter stating the reason why the organization would like to become a WIC Local Agency 3. Provide pictures of the exterior and interior of where WIC services would be performed 4. Complete the DC WIC Application for New Local Agency Form (Appendix 12.016A) 5. Review the Proposed WIC site Checklist (Appendix 12.016B) 6. Provide documents requested in bullets 2 thru 6 above via email to the State Agency at info.wic@dc.gov a. Subject Lines: i. New Local Agencies – “Application for new WIC Local Agency” ii. Current LA, new Site – “(LA Name) Application for new WIC Site” VII. Appendix 12.016A DC Health WIC Program Application for New Local Agencies 12.016B Proposed Site Checklist VIII. Reference N/A

12.017 - 1 Administrative Procedures Revised August 2019 XII. Administrative Procedures – Record Retention and Destruction PROCEDURE 12.017 Implementing Office: Community Health Administration (CHA) Created August 2019 Approved by: _______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel: ____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2020 I. Authority USDA II. Reason for the Policy CFR 246.25 (a) III. Applicability DC WIC State Agency and Local Agency Staff IV. Policy Statement This policy is meant to identify recordkeeping retention and destruction requirements for WIC records, which provide documentation of WIC program operations pertaining to fiscal operations, food delivery systems, food instrument issuance and redemption, equipment purchases and inventory, certification, nutrition education including breastfeeding promotion and support, civil rights and fair hearing procedures. Records must be destroyed in a manner that protects the confidentiality of WIC participants and vendors by the following methods: shredding, incineration. or landfill. WIC Local agencies must retain all WIC records for a minimum of three (3) years following the date of submission of the final expenditure report for the period to which the report pertains (usually covering an additional period of 150 days after the completed fiscal year) or until any litigation, claim, negotiation, audit or other action involving the records which was started before the end of the 3-year period has been resolved. V. Guidance Regarding Record Retention WIC RECORD RETENTION 1. Records, whether electronic or hard copy, that contain confidential client information must be stored in a secure manner. All records and reports that contain confidential client information shall be stored or kept in a locked area. Electronic records shall be kept under direct supervision at all times. See also Policy 3.001- DC CARES Management Information System, Appendix 3.001B - MIS CARES Confidentiality Agreement for New User ID Requests, and 12.019 - Confidentiality.

12.017 - 2 Administrative Procedures Revised August 2019 Note: There is no requirement for printing reports or records from the DC WIC data system except where necessary for documentation of compliance investigations. 2. The District of Columbia statutes require maintenance of medical records for a period longer than the WIC three-year guideline (see Record keeping requirements under the health regulations - D.C. MUN. REGS. tit. 22-B § 2030). Local Agencies that are affiliated with hospitals shall consult with the agency legal counsel and governing body for a decision regarding whether or not WIC participant charts are considered medical records. 3. The Local Agency must retain, as applicable, paper copies or electronic versions of the following records in accordance with this policy: a. Computer printouts or electronic reports for the District’s Management Information System (CARES) that serve as payment and/or source documents: • Check registers • Dual Issuance Report b. Other materials and information, which serves as source documents: • Audit documents • Civil rights complaints • Complaint information by and about the participant • Compliance investigation, sanction materials regarding client or employee compliance • Correspondence from State WIC office • Dual Participation materials such as paper reports or investigation materials • Equipment purchases and inventory • Fair hearing requests and documentation • Financial source documentation • Laboratory logs • Local Agency Plans Evaluations of Local Agency Plans • Local Agency Voter Registration Log Sheet • Monitoring reports, corrective action plan (CAP) and CAP approvals • News releases submitted to local media c. Program records: • Agency specific records, • Contracts, budgets and administrative records • Fair Hearing records d. Quality Assurance: • Records from quality assurance activities, • WIC State Agency Management Reviews • Local agency announced and unannounced Site visits e. Returned Formula Logs f. Staff credential verifications

12.017 - 3 Administrative Procedures Revised August 2019 4. During a federal or state management evaluation, participant records/files covering three (3) previous years plus 150 days for situations described above should be furnished upon request for inspection, auditing or copying purposes. If the items are not readily accessible due to being stored off-site based on space limitations, the Local Agency must present these records upon request within five (5) business days. 5. Complete participant files may require longer retention due to state statutes related to medical records. Refer to section 2, above. These include: • All materials used to assess, determine eligibility, or prove service offered, such as Physician documentation & referral, notarized documentation of income support, etc. • Certification Summary (if printed on a regular basis • Notification of Ineligibility and/or Termination • Rights and Responsibilities Participant Signature VI. Procedures for Record Destruction A. Prior to destruction of WIC records the local agency must determine that all agency audits and litigation pertaining to the information are completed for the period of these records. B. All records and printed reports containing client identifiers (e.g; names, addresses, phone numbers, and client IDs) must be destroyed in a manner that protects confidentiality. The approved methods to accomplish this are: a. Shredding (for records that are being recycled) b. Made Unreadable (for records that are being recycled) c. Incineration d. Landfill C. If instructed to do so by the State WIC office or FNS, the WIC Local Agency shall not destroy program records of historical interest, but shall forward such records to the State WIC office VI. Appendix N/A VII. Reference 3.001 – DC CARES Management Information System MIS 3.001B – MIS CARES Confidentiality Agreement for New User ID Requests 12.019 – Confidentiality

12.018 - 1 Organization and Management

Created August 2019 IV. Organization and Management – New Policies at the Local Agency Level

PROCEDURE 4.006 Implementing Office: Community Health Administration (CHA) Created August 2019

Approved by:

_______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel:

____________________ Phillip Husband, Esq.; General Counsel Effective Date: 10/01/2019

I. Authority DC WIC State Agency II. Reason for the Policy The State Agency must be aware of and approve of Local Agency policies which affect the services provided at, or the WIC monies spent by, the Local Agency. III. Applicability DC WIC State Agency and Local Agency Staff.

IV. Policy Statement DC WIC Local Agencies may create policies and procedures specific to their organization. The State Agency must approve any new policies and procedures which the Local Agency may wish to implement, so long as it may impact the delivery of WIC services to Program participants. V. Procedures When creating new policies and procedures, the Local Agency must abide by the following process:

1. Create a draft of the policy/procedure including the following information: a. Functional area in which the policy resides b. Reason for the proposed policy c. Procedures which specify staff duties and processes to be followed, including any resources which should be attached as appendices d. List of appendices indicated in the procedures, if applicable 2. Submit the draft policy for review and approval by the State Agency: a. Save the proposed policy in draft format as a word document b. Email the proposed policy to the State Agency via info.wic@dc.gov c. Use the subject heading “New Policy_(Local Agency Name)” 3. The State Agency will have 30 days to review the policy, suggest amendments to the draft or approve as-is, and return correspondence to the Local Agency 4. The Local Agency will have 30 days to revise the draft if not approved, or to implement the approved policy within their organization 5. Final policies must be saved to the Local Agency’s Procedure Manual

VI. Appendix

N/A

12.018 - 2 Organization and Management

Created August 2019

12.019 - 1 Administrative Procedures

Created September 2019 XII. Administrative Procedures – Confidentiality

PROCEDURE 12.019 Implementing Office: Community Health Administration (CHA) Created September 2019

Approved by: _______________________ LaQuandra S. Nesbitt MD, MPH; Agency Director Review by Legal Counsel: ____________________ Phillip Husband, Esq.; General Counsel Effective Date: 01/01/2020

I. Authority USDA II. Reason for the Policy To ensure compliance with Federal Regulations and to protect the right to privacy of WIC applicants and participants. FNS Instructions 800-1 - WIC Program - General Administration-Confidentiality SPF 90-008 Confidentiality Issues SPF 90-076 Confidentiality Instructions (not able to locate) SPF 93-040 Procedures for Responding to a Subpoena SPF 94-070 Responding to Subpoena and Search Warrants in the WIC Program 6. SFP 93-086, WIC Volunteers and Confidentiality SPF 95-010 Sharing WIC Data and Information with State/Local Immunization Programs Policy Memo 93-2 WIC Volunteers and Confidentiality (not able to locate) SP 42-2014 - Sharing Aggregate Data to Expand Program Access and Services in Child Nutrition Programs CFR § 246.26 Other provisions (d) Confidentiality of applicant and participant information CFR § 246.9 - Fair hearing procedures for participants. III. Applicability DC WIC State Agency and Local Agency Staff

IV. Policy Statement Confidentiality is the protection of information regarding an applicant or participant, whether it is obtained from the applicant or participant, another source, or generated as a result of WIC application, certification, or participation, that individually identifies an applicant or participant and/or family member. Participant information must remain confidential to ensure compliance with Federal Regulations, to protect the right to privacy of WIC applicants/participants, to allow clients access to their own records, and to protect the interests of society by permitting disclosure without client consent in limited situations, such as suspected

12.019 - 2 Administrative Procedures

Created September 2019 child abuse, medical emergencies, communicable disease control, investigation of program violations, and program evaluations. Confidentiality requirements apply to information provided by an applicant/participant that is based on direct observation by WIC personnel.

V. Guidance Regarding Confidentiality DISCLOSING INFORMATION FOR WIC PURPOSES

A. Administration or Enforcement of the WIC Program

The disclosure of WIC applicant/participant information is limited to persons directly connected with the administration or enforcement of WIC. These include:

1. WIC personnel, managers and administrators at the State and local level who are responsible for the ongoing conduct of Program operations. The WIC personnel must sign a Statement of Confidentiality form agreeing to provide WIC services in a manner that maintains client confidentiality (see Appendix 3.001B) 2. Personnel under contract with the State Agency to perform research regarding the WIC program or to conduct ongoing WIC program operations and who are trained and knowledgeable of the restriction on disclosure of information 3. Persons investigating or prosecuting violations in the WIC Program under Federal, State or local authority 4. Interns or volunteers who are responsible for the ongoing conduct of Program operations and who are trained and knowledgeable of the restriction on disclosure of information 5. The comptroller general of the United States for audit and examination authorized by law

B. Release of Information to the WIC Applicant/Participant or Parent/Guardian

1. Each local agency (LA) is responsible for restricting the use and disclosure of information obtained from program applicants/participants. The LA shall provide a copy of the applicant or participant record free of charge to the applicant or participant or the parent or guardian of an applicant or participant. 2. A WIC applicant/participant or the authorized representative of an infant or child applicant/participant may request access to see or copy his/her own record or a copy of a child’s or infant’s record 3. Assuming that any issues regarding custody or guardianship have been settled, such persons have the right of access to the following information:

a. All information provided by the applicant/participant

12.019 - 3 Administrative Procedures Created September 2019 b. The health record (forms completed by WIC personnel or health care providers for medical/nutrition risk assessment for determination of Program eligibility) Note: The Local Agency need not grant the participant/participant or authorized representative access to any other information in the record, such as documentation of income provided by third parties or any information which serves as a staff assessment of the participant’s condition or behavior, unless required by State or local law or policy or unless the information supports a State or local agency decision being appealed pursuant to CFR § 246.9 - Fair hearing procedures for participants. 4. The requested information may be given directly to the applicant/participant or authorized representative, or to their representative (i.e. physician or lawyer) with a signed release 5. A Consent for Release of Participant Information form (see appendix 12.019A) will be completed for the participant’s chart when information is given to the applicant/participant or authorized representative, or their representative. WIC personnel releasing the information and the person receiving the information will sign the form. C. WIC Applicant/Participant Request for Release of Information to a Third Party Third Party data requests can be initiated by the WIC applicant/participant him/herself or by staff to a third party or organization that is not indicated on the Participant Rights & Responsibility Signature form. Consent must be based on a full understanding of what information will be exchanged, with whom it will be shared, and how it will be used. 1. WIC Applicant/Participant Third Party Request An applicant/participant must submit a written consent form (see 2.018 A) to the Local Agency for the release of information to be sent to a specific third party or organization, i.e. doctor. 2. WIC Staff Third Party Request Except in the case of subpoenas or search warrants, the State Agency and its local agencies may disclose confidential applicant and participant information to individuals or entities only if the affected applicant or participant signs a release form authorizing the disclosure and specifying the parties to which the information may be disclosed. 3. Medical Emergency In the event of a medical emergency, local WIC programs may disclose medical/clinical information to medical personnel without participant consent, but only to the extend necessary to meet the medical emergency such as a severe injury, unconsciousness, delirium, diabetic client in insulin shock, etc.

12.019 - 4 Administrative Procedures

Created September 2019 a. The information disclosed should only be that necessary to assess and/or treat the emergency. b. Ensure that the party requesting information (e.g. hospital emergency room) is a legitimate caller by verifying name and phone number.

4. Danger to Society Local program staff may lawfully report participant’s confidential information to law enforcement officials when necessary to protect health or safety in an emergency, for example, if there is reason to believe that an individual may be dangerous to her or himself or to others. In all other circumstances, information should not be released to law enforcement officials without presentation of a subpoena.

DISCLOSING INFORMATION FOR NON-WIC PURPOSES

A. Release of Information to Private Physicians or other Healthcare Providers Release forms authorizing disclosure to private physicians or other healthcare providers is included as part of the WIC application or certification process. All other requests for applicant and participants to sign voluntary release forms shall occur after the application and certification process is completed. In accordance with § 246.26(d)(4), the State or local agency must permit applicants and participants to refuse to sign the release form and must notify the applicants and participants that signing the form is not a condition of eligibility and refusing to sign the form will not affect the applicant’s or participant’s application or participation in the WIC Program.

B. WIC Program Written Agreement with a Health or Welfare Program The State agency and its local agencies may disclose confidential applicant and participant information for use in its programs or to other public organizations for use in the administration of their programs that serve persons eligible for the WIC Program. The purpose of the release of information is to facilitate a WIC client’s entry into other healthcare and social services programs that would assist and benefit the individual. If this sharing of data with programs within the Local Agency or with health or welfare program is routinely requested, the State Agency must enter into a written agreement. 1. The agreement specifies that the receiving program use WIC Program information only for the purpose of a. Establishing the eligibility of WIC applicants/participants for the program which it administers b. Conducting outreach to WIC applicants/participants for the other program(s) c. Enhancing the health, education, or well-being of WIC applicants/participants who are currently enrolled in such

12.019 - 5 Administrative Procedures

Created September 2019 programs, including the reporting of known or suspected child abuse that is not otherwise required by State law; d. Streamlining administrative procedures in order to minimize burdens on staff, applicants, or participants in either the receiving program or the IWC program; and, or e. Assessing and evaluating the responsiveness of a State’s health care needs and health care outcomes. 2. The agreement contains the receiving program’s assurance that it will not disclose the information to a third party.

C. Requested Data in Aggregate or Summary Form Requested data in aggregate or summary form that excludes any items which would identify WIC Program applicants/participants may be granted upon approval by the State Agency. Aggregate data may be disclosed to persons engaged in scientific research, program evaluation, peer review, quality assurance, disease prevention, abuse fatality review, fiscal audits, etc. Before releasing information for research, etc. local agencies must contact the State agency to discuss the nature of data to be disclosed and the validity of the request for disclosure.

D. Release of Information to other State WIC Agencies The State Agency and/or Local Agency may release information to WIC agencies in other states for certification verification for the transfer of participants without a written authorization from the participant and/or to prevent and detect dual participation. The communication method(s) should permit the expedient release of information.

1. Local Agency staff may give information via telephone, fax, or mail as requested by the other State without a release signed by the WIC participant after eliminating any doubt that it is not a WIC agency representative that is calling by documenting the name and phone/fax number of the person requesting the information and returning a call to the requesting agency prior to releasing the information if there is any doubt that it is not a WIC agency. Information provided will be limited and must be pertinent (i.e., information contained on the VOC card). 2. Local Agency staff will terminate the WIC participant in CARES when such information is received from the requesting State WIC agency. 3. Upon detection of dual participation, the WIC participant will be terminated from one (1) WIC clinic.

12.019 - 6 Administrative Procedures

Created September 2019 E. Release of Information to Child Protective Services The District of Columbia encourages a person who knows about, or has reason to suspect, child abuse or neglect report such information to the Child and Family Services Agency (CFSA) at (202) 671-SAFE or (202) 671-7233, whether the information is reported by a WIC applicant/participant or is observed by WIC personnel who may remain anonymous. The reporting of such information does not necessitate the consent of the participant or applicant to the extend necessary to comply with such law.

1. Requests for information from Child and Family Services Agency (CFSA) pertaining to an investigation of suspected abuse or neglect which was reported by WIC personnel to Child Protective Services may be provided by WIC personnel. 2. Release of participant information to Child and Family Services Agency (CFSA) must be evaluated on a case by case basis. Contact the State Agency immediately upon receipt of a request, for guidance.

F. Release of Data During Program Evaluations State and local WIC agencies and contractors must cooperate in studies and evaluations conducted by or on behalf of the Department, 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).

G. Request for Information Requiring Legal Counsel Assistance In the following circumstances, the Local Agency shall contact the State WIC Agency immediately upon receipt of a request for information by sending an e- mail to info.wic@dc.gov. If a local agency does not have access to a legal counsel, the local agency may need to seek legal advice on such issues from the WIC State's Agency legal counsel.

a. Requests for information made by a third party, such as Child and Family Services Agency (CFSA), which might substantiate allegations of child abuse

b. Receipt of a court ordered subpoena for information: A subpoena is merely a request for information issued by the clerk of a court in response to a request by an attorney representing a party. A Subpoena does NOT represent a court's ruling that a WIC State or local agency MUST release the information requested. However, a subpoena could potentially result in the State or local agency being found in contempt of court which could result in the incarceration of or fines against WIC employees.

In responding to a subpoena, the Local Agency shall follow the following guidelines:

12.019 - 7 Administrative Procedures

Created September 2019

(i) Consult with legal counsel at its own agency to determine whether the information requested is in fact confidential and prohibited from release as stated in the subpoena under 7 CFR 246.26 (d) of the WIC Program regulations, any pertinent State laws, FNS Instruction 800-1, and Policy Memorandum 94-3. (ii) LA must make a determination based on the content of the subpoena and the requested information whether or not to comply with the subpoena. If replying, LAs will inform the requestor of the WIC confidentiality provisions and request a signed client release from the requestor (iii) Inform the court or the receiving party that the provided information is confidential under federal regulations and limit (1) the provision of information to the specific information requested in the subpoena and (2) public access to the disclosed information to the greatest extend possible. (iv) Comply with LA policies governing subpoenas, unless the local policies conflict with State agency policies.

c. Receipt of a court ordered search warrant for information. Search warrants are used by police investigators to obtain WIC applicant and participant information. State and Local agencies MUST comply with search warrants providing ONLY the specific information requested (no other information) involving the legal counsel of the respective agency. A copy of the search warrant must be kept on file. Failure to fully comply with a search warrant at the time it is served could result in the immediate incarceration of WIC State or local agency staff. The individual(s) producing a search warrant should be apprised of the confidential nature of WIC information.

In responding to a search warrant, the Local Agency shall follow the following guidelines: (i) Immediately notify legal counsel for the LA and comply with any LA protocol concerning search warrants. (ii) Comply with the search warrant. (iii) Inform the individuals serving the warrant that the information being sought is confidential and limit (1) the provision of information to the specific information requested in the subpoena and (2) public access to the disclosed information to the greatest extend possible.

d. Freedom of Information Act Request (FOIA) It is the public policy of the District of Columbia that all persons are entitled to full and complete information regarding the affairs of the government and the official acts of those who represent them as public officials and

12.019 - 8 Administrative Procedures

Created September 2019 employees. At all other times, applicant/participant information and their whereabouts shall be kept confidential.

(ii) WIC staff may discuss applicant/participant information with other WIC staff as appropriate. Discussion shall take place in private areas where the information cannot be overheard by other participants, staff from other programs, or the general public. (iii) WIC staff shall ensure that a professional attitude is maintained at all times about applicant/participant information. This includes respecting the applicant/participant’s privacy and maintaining respect for the dignity of the applicant/participant at all times. VI. Appendix

12.019A Consent for Release of Participant Information VII. Reference N/A