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