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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