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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