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GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Clinic Breastfeeding Environment BF-1220.01 Effective Date: October 1, 2016
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Policy The State and Local Agencies shall establish and maintain a positive clinic environment that clearly endorses and supports breastfeeding and human milk as the normative standard for infant feeding and nutrition. Printed, audiovisual materials, and office supplies that display formula product names and/or advertising, such as: cups, pens, badge holders, pins, posters and note-pads, are not permitted. Purpose To provide breastfeeding education, promotion and help to inform women participants and, as appropriate, their families (e.g., partner/spouse, grandmother) to not only understand the many health, nutritional, economical and emotional benefits of breastfeeding, but to be prepared and empowered to meet their breastfeeding goals. Procedures I. Encourage breastfeeding anywhere in the clinic, including the waiting room. II. Use clinic area to promote breastfeeding as the optimal method of infant feeding; displaying posters, clear signage (including indicators of locations for private breastfeeding space), information pamphlets, etc III. For those wishing to breastfeed in private, provide space for participants/staff to breastfeed or express breastmilk via pump use or hand expression.. IV. Store infant formula supplies, baby bottles, and nipples out of participants’ view.
Authority 7 CFR § 246.11
Definitions/Supporting Information Breastfeeding –the practice of feeding a mother’s breast milk to her infant(s) on the average of at least once a day Clinic - A facility where WIC business is conducted (e.g., certification and voucher issuance).
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Referral to Breastfeeding Resources BF-1240.01 Effective Date: October 1, 2016
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Policy Local agencies shall identify or develop a list of breastfeeding resources for use in the local agencies. Purpose
To provide guided support and help each lactating woman meet her breastfeeding goal. Procedure I. Include hospital staff, physicians, local support groups, public health staff with expertise in handling breastfeeding questions, sources for breast pumps, peer counselors, and other relevant resources.
II. Document in the prenatal and breastfeeding participant’s record all referrals provided; including enrollment in the peer counselor program.
III. Establish written procedures for referring women to peer counselors; CLC; IBCLC, or the equivalent, and other appropriate breastfeeding support.
IV. Provide appropriate training.
Authority 7 CFR § 246.11 Nutrition Services Standards 8. Breastfeeding Education, Promotion and Support – B.7; C.4.e
Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Ordering and Receiving Breast Pumps, Pump Kits and Breast Pump Supplies BF-1260.01 Effective Date: October 1, 2016 No. of Pages: 1
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Policy All breast pumps and supplies must be ordered through the state WIC office. Local Agency must maintain a six-month inventory of pumps and supplies. Purpose To enable participants with special circumstances to initiate breastfeeding and increase the duration of breastfeeding creating a positive breastfeeding culture throughout the state of Georgia. Procedures I. Submit the completed Georgia WIC Program Breast Pump and Accessory Order Form: Medela, with justification and current inventory for each item requested, to the state breastfeeding unit at: GAWIC.Breastfeeding@dph.ga.gov by January 1, April 1, July 1 and October 1. If pumps and supplies are not needed, then a submission is not needed for that quarter. II. When the order is received, the local agency must verify the order within three business days. Check the order requisition against the packing slip to ensure that all supplies requisitioned were received.
A. If the order is correct and complete, write the word “received” on the packing slip; sign and date the packing slip; scan and email the packing slip to: GAWIC.Breastfeeding@dph.ga.gov or fax to the SWO attention: Breastfeeding Unit.
B. If the order is not correct or incomplete, write the word “incomplete” on the packing slip; sign and date the packing slip; scan and email, or fax, to GAWIC.Breastfeeding@dph.ga.gov informing them of the incorrect shipment.
Authority 7 CFR § 246.14 Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Breast Pump Issuance Policy No. BF-1260.06 Effective Date: October 1, 2016 No. of Pages: 3
Revised October 2018
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Policy WIC Competent Professional Authorities (CPAs), WIC Breastfeeding Peer Counselors (PCs), WIC Certified Lactation Counselors (CLCs), WIC Certified Lactation Educators (CLEs) and WIC International Board Certified Lactation Consultants (IBCLCs) that have been trained on breast pump competency may issue breast pumps to breastfeeding certified mothers on the WIC Program based on established need. Staff must complete an initial follow-up by contacting participants within one to five business days from issuance of manual pumps, personal double breast pumps, and multi-user breast pumps, to ensure pump usage is going well. When breast pump usage is not going well, refer participants to a Designated Breastfeeding Expert (DBE), WIC CPA, WIC IBCLC, for additional support and guidance.
Purpose To support a subset of lactating mothers and breastfeeding infants with demonstrated or potential lactation difficulties or special circumstances, such as returning to work or school, or medically fragile.
Procedures I. Local agency staff shall determine which pump best fits the participants’ need (manual, personal, or multi-user). See Quick Reference to Issuing Breast Pumps
II. WIC staff should issue a manual breast pump (or two pumps for double pumping) when the participant:
A. Has a short-term separation from their baby such as:
1. Looking for work
2. Working or going to school less than ten (10) hours per week
B. Has limited access to electricity when pumping
C. Requests a pump due to engorgement and has been assessed by the DBE(s)
III. WIC staff should issue a personal double breast pump when the participant:
Plans to breastfeed exclusively for four (4) to six (6) months without receiving formula from WIC and (one of the following):
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Breast Pump Issuance Policy No. BF-1260.06 Effective Date: October 1, 2016 No. of Pages: 3
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A. Works and/or goes to school more than 10 hours per week.
B. Plans to return to work within the next two (2) weeks.
C. Has exclusively breastfed an infant for at least four (4) weeks.
IV. WIC staff should issue multi-user breast pump when the postpartum woman:
A. Has a premature or medically fragile infant unable to feed at the breast
B. Is unable to feed at the breast due to their own medical issues
C. Is breastfeeding multiples and needs to increase milk production
D. Is having problems breastfeeding and must use pump to provide breast milk
E. Is unsure of her long-term commitment to breastfeeding and will be separated from her infant a significant portion of the day.
V. At the time of issuance of a breast pump WIC staff must:
A. Demonstrate 1. Hand expression 2. Breast Pump Assembly 3. Breast Pump cleaning guidance
B. Allow the participant repeat and demonstrate what they understand
C. Discuss United States Department of Agriculture’s Human Milk Storage Guidelines
D. Complete appropriate form or loan agreement and tracking guidance (See table below)
Pump Type Form to Use How to Track What To Do Manual Issuance Form Georgia WIC Inventory Log File Issuance Forms (in clinic or district designated areas) PDP Issuance Form Georgia WIC Inventory Log File Issuance Forms (in clinic or district designated areas) Multi-user Loan Agreement Breast Pump Inventory Tracking System • Complete all required issuance fields within the tracking system • Scan and Upload the Multi-user loan agreement • Follow-up on the participants’ need of the pump and document within the tracking system.
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Breast Pump Issuance Policy No. BF-1260.06 Effective Date: October 1, 2016 No. of Pages: 3
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E. Provide participant with a copy of the signed Issuance Form or Loan Agreement.
Authority 7 CFR § 246.14 Definitions/Supporting Information Certified Lactation Counselor (CLC) – is an individual that has demonstrated knowledge to construct and maintain conditions that predispose mothers and babies to an uncomplicated breastfeeding experience through counseling, education, and support. (Taken from Healthy Children’s Project, Inc) Certified Lactation Educator (CLE) – is an individual that educates, counsels, and supports families and the community by providing evidence based information about lactation and breastfeeding. (Adopted from http://www.cappa.net/lactation-educator) Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials. International Board-Certified Lactation Consultant (IBCLC) – an individual who specializes in the clinical management of breastfeeding. They are certified under the direction of the US National commission for Certifying Agencies. (Adopted from http://www.ilca.org/main/why- ibclc/ibclc) Designated Breastfeeding Expert (DBE) – Is an individual who is an expert with special experience or training in helping breastfeeding mothers and who provides breastfeeding expertise and care for more complex breastfeeding problems when WIC staff face situations outside their scope of practice. Individuals with this designation can be WIC staff including Breastfeeding Coordinators, Peer Counselor Coordinators, IBCLCs, CLCs, or CLEs, nutritionist, and nurses or community health care providers. The IBCLC is the preferred WIC DBE (2013 WIC NSS). (Taken from United States Department of Agriculture’s Breastfeeding policy and Guidance) Peer Counselor (PC) – A woman of the community with similar characteristics as the participants WIC serves; has successfully breastfed for six months; a current or past WIC participant. PCs offer para-professional level mother to mother support. Peers are encouraged to be available outside of normal clinic hours, and within various community settings.
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Breast Pump Storage and Inventory BF-1260.07 Effective Date: October 1, 2016
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Policy The local agency shall manage a supplies and materials inventory that maintains ongoing accuracy of all breast pumps using the breast pump inventory system; as well as required state inventory forms. Pumps and accessories must be stored in a secure location. Purpose To ensure adequate supply; to track/account for assets and liabilities of breastfeeding supplies. Procedure
I. The local agency must maintain Symphony multi-user pump inventory in the Breast Pump Inventory Tracking System.
A. Request Breast Pump Inventory Tracking System access for all trained issuers via email to Gawic.breastfeeding@dph.ga.gov submit:
1. Staff’s name
2. District
3. Work phone number
4. Email address
B. Enter Symphony pumps into the database within five (5) days of receipt of quarterly order.
C. Verify transferred pumps in the database within forty-eight (48) hours of receipt of the pumps.
D. Enter pump issuance details into the database when loaned to the participant; no later than one business day.
II. Maintain an inventory of Personal Double Pumps (PDPs), Harmony breast pumps, and all other supplies and accessories manually via the Georgia WIC Program Inventory Log.
A. Use the Georgia WIC Program Inventory Log to document receipt, issuance, transfer, or verification of:
1. Personal Double Pump (PDP)
2. Harmony Breast Pumps
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Breast Pump Storage and Inventory BF-1260.07 Effective Date: October 1, 2016
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3. Multi-User Pump Kits
4. Breast Pads
5. Milk Storage Bags
6. Multi-User Car Adapters
7. Personal Double Pump (PDP) Car Adapters
8. Valves/Membranes, PDP Replacement Tubing, Breast Shields/Flanges
III. Maintain a perpetual inventory of all breast pumps and supplies at a district level using the Georgia WIC Program Inventory Log.
IV. Conduct a physical inventory to reconcile items: A. Monthly: 1. PDPs 2. Harmony Breast Pumps 3. Multi-User Pump Kits 4. Multi-User & PDP Car Adapters B. Quarterly 1. Breast Pads 2. Milk Storage Bags 3. Valves/Membranes 4. PDP Replacement Tubing 5. Breast Shields/Flanges
Authority 7 CFR § 246.14
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Breast Pump Storage and Inventory BF-1260.07 Effective Date: October 1, 2016
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Definitions/Supporting Information Breast Pump Inventory Tracking System: an online inventory database for multi-user breast pumps used to track multi-user pumps’ activity such as: issued, transferred, repair, needs clean, return, or surplus.
Inventory Log: A form to track the issuance, receipt, transfer, and verification of all breastfeeding supplies and accessories.
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Multi-User Electric Breast Pump Retrieval Policy No. BF-1260.08 Effective Date: October 1, 2016 No. of Pages: 2
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Policy WIC staff must provide at least monthly follow-up on multi-user electric breast pumps after the initial issuance follow-up to ensure the pump is still needed. Allowed methods of contact are: at WIC appointments/voucher pick up, phone (including leaving a message), text (with an approved state or local policy), or email.
Purpose To provide breast pumps judiciously and support liability; as well as cost accountability.
Procedures I. Complete initial issuance follow-up as detailed within Policy 1260.06 Breast Pump Issuance. II. Contact participant at least monthly to determine if the multi-user breast pump is still needed. III. If three consecutive follow-up contacts are unsuccessful: A. Make one attempt to contact any alternate designated on the participant’s Loan Agreement. B. Place an alert in the participant’s and infant’s medical record in the front-end WIC system indicating that the participant has an outstanding breast pump. C. Mail the state approved Multi-User Breast Pump Follow-Up Letter to both the participant and alternate contact; notate a ten to fourteen-day deadline for the participant to contact the local agency. IV. Refer to Policy 1260.11 Multi-User Electric Pump Recovery if there is no response from the participant by the deadline indicated within the Multi-User Breast Pump Follow-Up Letter.
Authority USDA Breastfeeding Policy and Guidance Georgia WIC Program Policy
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Multi-User Electric Breast Pump Retrieval Policy No. BF-1260.08 Effective Date: October 1, 2016 No. of Pages: 2
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Definitions/Supporting Information Certified Lactation Counselor (CLC): is an individual that has demonstrated knowledge to construct and maintain conditions that predispose mothers and babies to an uncomplicated breastfeeding experience through counseling, education, and support. (Taken from Healthy Children’s Project, Inc) Certified Lactation Educator (CLE): is an individual that educates, counsels, and supports families and the community by providing evidence based information about lactation and breastfeeding. (Adopted from http://www.cappa.net/lactation-educator) Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials. Designated Breastfeeding Expert (DBE): Is an individual who is an expert with special experience or training in helping breastfeeding mothers and who provides breastfeeding expertise and care for more complex breastfeeding problems when WIC staff face situations outside their scope of practice. Individuals with this designation can be WIC staff including Breastfeeding Coordinators, Peer Counselor Coordinators, IBCLCs, CLCs, or CLEs, nutritionist, and nurses or community health care providers. The IBCLC is the preferred WIC DBE (2013 WIC NSS). (Taken from United States Department of Agriculture’s Breastfeeding policy and Guidance) International Board-Certified Lactation Consultant (IBCLC): an individual who specializes in the clinical management of breastfeeding. They are certified under the direction of the US National commission for Certifying Agencies. (Adopted from http://www.ilca.org/main/why- ibclc/ibclc) Peer Counselor (PC): A woman of the community with similar characteristics as the participants WIC serves; has successfully breastfed for six months; a current or past WIC participant. PCs offer para-professional level mother to mother support. Peers are encouraged to be available outside of normal clinic hours, and within various community settings.
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Cleaning, Maintaining, and Repairing Breast Pumps No. BF-1260.09 Effective date: October 1, 2016
No. of Pages: 2 Revised: October 2018 Page 1 of 2
Policy Multi-User Breast Pumps that have been loaned, must be cleaned when returned, prior to re- issuing. Local agencies must send damaged pumps to the manufacturer for repair after receiving authorization from the SWO Breastfeeding Unit. Purpose
To ensure that breast pumps are operable, in working condition and meet health standards prior to reissuing to another participant. Procedures At the time of returning the multi-user breast pump, the local agency will: I. Place returned multi-user pumps in clear bag and leave sealed for at least three days.
II. Update multi-user pump’s status within Breast Pump Inventory Tracking System as “Returned”; system will remain in “Needs Clean” status until the pump has been cleaned.
III. Check the sealed bag after the three-day period.
IV. If pest or smoke infested, keep the pump in the secure sealed bag and complete the “Breast Pump Repair/Cleaning Request” and return it to gawic.breastfeeding@dph.ga.gov for return authorization from the manufacturer and further instructions from the SWO. V. If free of pests and smoke, check the pump for damaged parts, clean the pump and assess the pump’s pressure level. (Normal testing pressure ranges are from 50-250 mmHg). See Cleaning, Maintaining, and Repairing Breast Pumps p7.
VI. If the pump is damaged, complete the “Breast Pump Repair/Cleaning Request” form and return it to Gawic.breastfeeding@dph.ga.gov for return authorization from the manufacturer and further instructions from the SWO.
A. Clean all visible parts with Cavicide on a clean cloth. (See Cleaning, Maintaining, and Repairing Breast Pumps pp30 & 31)
B. Breast pump pressure gauges are fragile; it is best practice is to keep the gauge attached to the testing flange.
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Cleaning, Maintaining, and Repairing Breast Pumps No. BF-1260.09 Effective date: October 1, 2016
No. of Pages: 2 Revised: October 2018 Page 2 of 2
VII. After the local agency has cleaned the pump and determined that it is in working order, they will seal pump in a clean, clear bag, dated and labeled as “clean” and Update SENDSS status to “Cleaned.”
VIII. To repair Personal Double Pumps (PDPs), participant must call Medela at (800)435- 8316.
IX. Discard all used pump kits, Personal Double Pumps (PDPs), and Harmony manual pumps.
Authority Georgia WIC Program Policy
Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Multi-User Electric Pump Recovery
Policy No. BF-1260.11 Effective date: October 1, 2017
No. of Pages: 2 Revised March 2019
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Policy Local Agency Staff, excluding Breastfeeding Peer Counselors, must attempt to recover and track multi-user breast pumps no longer being used, or without successful monthly follow-up contact with the participant. Purpose To minimize costs associated with replacing unreturned pumps. Procedures Local agency staff must:
I. Complete all issuance follow up steps as detailed within Policy 1260.06 Pump Issuance.
II. Mail the Final Request for Return of Medela Symphony® Breast Pump letter to the participant and the alternate contact five to ten calendar days after the deadline outlined in the Multi-User Breast Pump Follow Up letter.
III. Complete the following steps to report retrieval efforts after mailing the Final Request for Return of Medela Symphony Breast Pump letter:
A. Update WIC Breast Pump Inventory Tracking System as “Lost.” B. Complete the Lost or Stolen Multi-User Electric Breast Pump Report. C. Submit copies of the following to the State WIC Office Breastfeeding Unit at Gawic.breastfeeding@dph.ga.gov : 1. Lost or Stolen Multi-User Electric Breast Pump Report 2. Multi-User Electric Breast Pump Loan Agreement 3. Multi-User Breast Pump Follow Up letters to both the participant and alternate 4. Final Request for Return of Medela Symphony® Breast Pump letters to both the participant and alternate 5. Most recently signed copy of the participant’s Rights and Responsibilities 6. Pertinent medical record information that supports local recovery efforts
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Multi-User Electric Pump Recovery
Policy No. BF-1260.11 Effective date: October 1, 2017
No. of Pages: 2 Revised March 2019
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IV. If a pump is reported to have been stolen: A. Request a copy of the police report B. Update WIC Breast Pump Inventory Tracking System as “Lost” C. Complete the Lost or Stolen Multi-User Electric Breast Pump Report D. Submit copies of the following to the State WIC Office Breastfeeding Unit at: Gawic.breastfeeding@dph.ga.gov : 1. Lost or Stolen Multi-User Electric Breast Pump Report 2. Multi-User Electric Breast Pump Loan Agreement 3. Police report 4. Pertinent medical record information that support local recovery efforts.
Authority USDA Breastfeeding Policy and Guidance Georgia WIC Program Policy
Definition/Supporting Information (None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Breastfeeding Peer Counselor Contacts BF-1290.01 Effective Date: October 1, 2016
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Policy Peer Counselors (PC) must maintain regular contact throughout the prenatal and postpartum period with women enrolled in the Loving Support Breastfeeding Peer Counseling Program. Purpose To prepare women to breastfeed successfully. To support women enrolled in the Loving Support Breastfeeding PC Program and help them to reach their breastfeeding goals. Procedures I. Peer Counselors should use “Talking Points” as a guide for their conversations with WIC participants.
II. Peer counselors must contact prenatal women on the following schedule:
A. Every six (6) to eight (8) weeks from enrollment in the PC Program to nineteen (19) weeks gestation
B. Monthly: 20 to 27 weeks gestation
C. Biweekly: 28 to 35 weeks gestation
D. Weekly: 36 weeks to Delivery III. Peer counselors must contact postpartum women on the following schedule: A. Week One: Every 2 to 3 days
B. Weeks Two through Four: once weekly
C. At Six weeks Postpartum
D. At Two months Postpartum
E. Monthly thereafter
IV. Peer counselors must contact their case-managed postpartum mothers reporting breastfeeding problems every 24 to 48 hours; until the reported problem is resolved.
V. Peer counselors must contact their case-managed postpartum mothers returning to work/school:
A. A week before she is scheduled to return, if return date is known
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Breastfeeding Peer Counselor Contacts BF-1290.01 Effective Date: October 1, 2016
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B. Twice the first week after she returns to work/school C. Resume regular schedule of contacts, thereafter
VI. Peer Counselors must document contacts in the Peer Counselor Database (PCDB) daily. Documentation must include the following:
A. A reference to the participant’s breastfeeding goal
B. Required Follow up
C. Participant’s concerns and how the participant was educated
D. Referral to Skilled lactation/medical care (i.e. DBE, IBCLC, CLC, CLE, physician etc) if applicable
VII. Utilize the below hard copies of the PCDB screens when internet access is not available. The collected data must be entered within the database within forty-eight (48) hours.
A. Peer Counselor Contact
B. New Participant Enrollment
C. Adding a Baby/New Baby
VIII. Document unsuccessful attempts to contact participants as “Comments.”
Authority
Georgia WIC Program Policy
Definitions/Supporting Information Peer Counselor (PC): A woman of the community with similar characteristics as the participants WIC serves; has successfully breastfed for six months; and current or past WIC participant. Peers are enthusiastic about breastfeeding. They offer para-professional level mother to mother support. Peers are encouraged to be available outside of normal clinic hours, and within various community settings.
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Breastfeeding Peer Counselor Contacts BF-1290.01 Effective Date: October 1, 2016
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Contacts: Two way communication such as telephone, in person (home visit, hospital, clinic, lactation support center), or electronically. WIC Designated Breastfeeding Expert (DBE): is an individual who is an expert with special experience or training in helping breastfeeding mothers and who provides breastfeeding expertise and care for more complex breastfeeding problems when WIC staff face situations outside of their scope of practice. (From Nutrition Services Standards, August 2013) International Board Certified Lactation Consultant (IBCLC): an individual who specializes in the clinical management of breastfeeding. They are certified under the direction of the US National commission for Certifying Agencies. (Adopted from http://www.ilca.org/main/why- ibclc/ibclc ) Certified Lactation Counselor (CLC): is an individual that has demonstrated knowledge to construct and maintain conditions that predispose mothers and babies to an uncomplicated breastfeeding experience through counseling, education, and support. (Taken from Healthy Children’s Project, Inc) Certified Lactation Educator (CLE): is an individual that educates, counsels, and supports families and the community by providing evidence based information about lactation and breastfeeding. (Adopted from http://www.cappa.net/lactation-educator )
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Peer Counseling Monitoring Policy No. BF-1290.02 Effective Date: October 1, 2016
No. of Pages: 2
Revised: October 2018 Page 1 of 2
Policy The Breastfeeding Coordinator, Peer Counselor (PC) Supervisor, Lead Peer Counselor, or other designee is responsible for monitoring Peer Counselors’ caseloads and documentation; observing their face to face and telephone contacts; and completing quality assurance surveys. Purpose To standardize consistency with peer counseling management of their roles and responsibilities. Procedures I. Breastfeeding Coordinators, Peer Counselor Supervisors or Leads shall ensure that Peer Counselors’:
A. Carry a caseload size that is 2 to 3 times their scheduled hours worked.
B. Have appropriate caseload ratio (i.e. prenatal versus postpartum) (See Peer Counselor Caseload Management Policy).
C. Contact participants within appropriate timeframes (See Breastfeeding Peer Counselor Policy)
D. Document in the Peer Counselor Database (PCDB) record
1. Participants’ concerns 2. How they were educated 3. Participants’ breastfeeding goal 4. Use of “Talking Points” for conversation guidance.
E. Addresses any follow up from the previous contact F. Yield to Designated Breastfeeding Expert or skilled care (if applicable)
II. Breastfeeding Coordinators, Peer Counselor Supervisors or Leads shall ensure that each Peer Counselor have one face to face and one telephone observation per quarter. (See Peer Counselor Observation Checklist).
A. Maintain documentation that Peer Counselor staff received required quarterly observations. (See Continuing Education Documentation Log) III. Breastfeeding Coordinators, Peer Counselor Supervisors, or Leads shall ensure that random quality assurance participant surveys are completed quarterly as detailed below. (See Peer Counselor Participant Survey).
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Peer Counseling Monitoring Policy No. BF-1290.02 Effective Date: October 1, 2016
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A. Five (5) percent of participants on the Peer Counselor Database’s ”Recently Off Program” list from the previous quarter.
B. Five (5) percent of participants on the “Peer Counselor Database’s “Estimated Due Date (EDD)” list.
Authority Georgia WIC Program Policy
Definitions/Supporting Information Peer Counselor Database (PCDB): a web-based application that provides mobile access to Peer Counselors’ (PCs) caseloads. This allows PCs to input time sensitive data from any location that has a secure internet network.
GEORGIA WIC PROGRAM PROCEDURES MANUAL BF Peer Counselor Caseload Management BF-1290.03 Effective Date: October 1, 2016
No. of Pages: 1
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Policy Peer counselors must maintain a full caseload based on hours worked. Peer Counselors will regularly add prenatal women and remove postpartum women to/from their caseload to maintain the required ratio. Purpose To increase the number of women who successfully initiate breastfeeding and meet their breastfeeding goal. Procedures I. Peer Counselors shall maintain a caseload of three (3) times their weekly scheduled hours.
II. Peer Counselors shall maintain a caseload with the following ratio:
A. At least fifty (50) percent prenatal participants
B. No more than thirty (30) percent postpartum zero (0) to five (5) months
C. No more than twenty (20) percent postpartum six (6) months plus.
III. Peer counselors shall remove the following from their caseloads:
A. Participants with three documented unsuccessful attempts to contact within forty- five (45) days of the last documented contact.
B. Participants no longer breastfeeding.
C. Participants who no longer wish to participate in the program.
D. Dyads as they approach twelve (12) months postpartum.
Authority Georgia WIC Program Policy Definition/Supporting Information (None)
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CM Monitoring No-Show Rates Policy No. CM- 700.03 Effective date: October 1, 2016
No. of pages: 2
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Policy
Local Agencies (LAs) must monitor the number of eligible applicants and participants who fail to attend scheduled certification appointments, including nutrition education contacts, and to pick up vouchers, otherwise known as a “no-show”.
LAs are required to maintain a monthly no-show rate for all clinics of 10% or less of actual caseload. Each LA that exceeds this standard will be notified by the State WIC Office, and will be required to submit a corrective plan of action to reduce the number of missed appointments within 45 days of date of the notification. The corrective plan should address staffing patterns, operating policies, and customer satisfaction issues that could be causing a barrier to participation.
Purpose To ensure the timely delivery of benefits to eligible participants and reduce the number of applicants or participants who miss their appointments by reducing barriers to clinic access.
Procedures
I. Local agencies must track the number of no-show applicants/participants monthly.
II. To decrease no-show rates, LA staff must: A. Complete reminder calls, emails, or text to participants 1-3 days prior to their scheduled appointments and document the calls in the computer or on the appointment sheet.
B. Use client surveys quarterly to determine reasons for missed appointments.
C. Allow participants to select appointment dates and times that best serve their needs.
D. Call, email, or text participants who were no-shows to reschedule their missed appointments.
III. Pregnant Applicants/Participants. The clinic must make three attempts by telephone to contact a pregnant woman who has missed her initial certification appointment to reschedule the appointment.
A. If she cannot be reached by phone, the local agency will send a postcard or letter requesting that she contact the clinic for a second appointment.
B. The contact must be documented clearly on the clinic’s appointment list next to her original appointment with the type of contact made (text, phone, email) and the date of each contact.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CM Monitoring No-Show Rates Policy No. CM- 700.03 Effective date: October 1, 2016
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IV. The LAs must submit the monthly no show reports to the SA quarterly for monitoring and compliance.
Authority
7 CFR § 246.7(b)(5)
7 CFR § 246.11(e)(4)
Definitions/Supporting Information
(None)
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CM Caseload Allocation Policy No. CM- 710.01
Effective date: October 1, 2016
No. of pages: 1
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Policy For each federal fiscal year (FFY) beginning October 1, Georgia WIC shall assign Local Agency WIC programs their set participation caseload levels. Caseload assignments and funding will be allocated based on current year participation caseloads as of March of the current fiscal year by one of two options described in the procedures section of this policy.
Purpose To inform local agencies of the methodology used to assign participation caseloads and FFY allocations Procedures
I. The State WIC Office (SWO) uses two (2) methodologies for assigning FFY participation caseloads and allocations. A. Both methodologies use the current FFY four-month closeout, one month (30) day and one month (issue) their new assigned target. B. Option A – local agencies meeting or exceeding their current caseload targets using the current FFY four month closeout, one month (30) day and one month issued participation caseloads will be assigned a new target using their highest one-month participation during this period. C. Option B – local agencies failing to meet their current caseload targets will be assigned a new target equaling a six-month average of the current FFY four month closeout, one month (30) day and one month issued participation caseloads. D. These caseloads will be used to determine each local agency’s pro rata share of the statewide caseload established by the SWO after projecting for a reasonable statewide target for the next FFY.
II. Upon analysis of projected next FFY Nutrition Services and Administration (NSA) funding and projected needs, remaining NSA available for allocation to local agencies will be determined. The amount will be the initial funding to be allocated to the local agencies.
III. The local agency allocation will be calculated as follows: A. Initial funding ÷ statewide caseload ÷ 12 months = Rate B. Local agency caseload × Rate × 12 months = local agency allocation
IV. SWO may make additional NSA funds available for local agency allocation as requested or necessary. These allocations will not result in an increase in the current assigned caseloads.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CM Caseload Allocation Policy No. CM- 710.01
Effective date: October 1, 2016
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V. Participant Cost Adjustment – SWO may assess local agencies a participant cost adjustment for agencies failing to meet their assigned caseload in the current fiscal year. The assessment (decrease) will be calculated as follows:
A. Calculate current 6 month average participation caseload by averaging the current FFY four-month closeout, one month-30 day and one month (issue). B. Calculate the difference between the assigned caseload and the 6 month average caseload. C. Multiply the difference calculated in B. by the initial rate calculated in step III. and multiply this amount by 12 months. D. This calculation is stated as: (Assigned Caseload – Current 6 month) x Rate x 12 months. E. For local agencies exceeding their Assigned Caseload, a Participant Cost Adjustment (increase) will be allocated in the next FFY after closeout calculated as follows: (Final Caseload – Assigned Caseload) x Prior Year Rate x 12 months. These Adjustments will be made based upon the availability of NSA funds and at SWO discretion.
Authority 7 CFR § 246.4(a)(13); 7 CFR § 246.16(c)(2)(i)
Definitions/Supporting Information
(None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL CM Special Populations
Policy No. CM-730.01 Effective Date: October 1, 2016
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Policy The local agency must accommodate all special population groups such as migrants, loggers, individuals residing in institutions, homeless people, Limited English Proficiency people, refugees, Native Americans, and persons with disabilities. Purpose
To provide equal access to WIC benefits and WIC-related services and minimize hardships for segments of the population that require non-traditional services. The process for certifying special populations must comply with standard certification procedures. Procedures I. Migrants, Loggers, and Seasonal Farm Workers A. The local agency must issue an Electronic Verification of Certification (EVOC) or Verification of Certification (VOC) card to every migrant at the time of certification.
B. Vouchers must be issued on the same day the migrant participant is certified.
C. In lieu of a VOC and or EVOC card, the receiving clinic must verify the current certification information. Vouchers must only be issued for thirty (30) days if WIC clinic staff cannot verify certification information with the certifying clinic.
D. When a migrant presents WIC vouchers from another state, the certifying clinic must void the vouchers and issue Georgia WIC Program vouchers as a replacement. The certifying clinic must send the voided vouchers back to the appropriate State Agency where vouchers originated.
II. Non-Traditional Housing A. Non-traditional housing representatives who provide accommodations for WIC participants must sign an Assurance Statement. The signed copy must stay on file at the local agency before participants may be served.
B. Employees of non-traditional housing facilities may not serve as proxies for the residents.
C. Do not include other residents of the institution or the temporary housing facility in determining income eligibility and family size. The applicant’s income is also separate from the general revenue of the institution of facility.
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Policy No. CM-730.01 Effective Date: October 1, 2016
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D. If a participant no longer resides in the WIC clinic service area where vouchers were last received, the vouchers should be issued and the participant transferred to the nearest WIC clinic. III. Limited English Proficiency (LEP) A. WIC applicants or participants will not be denied WIC services or benefits because they did not bring an interpreter to their appointment. It is the responsibility of the Georgia WIC Program to provide interpreters by hiring multilingual employees, or accessing interpreter services through the Georgia Department of Public Health State-wide contract for Translation Interpretive Services, or through the Department of Public Health’s State Refugee Health Program. The cost associated with the provision of interpretive services and translation services for outreach and educational materials is an allowable nutrition services and administration (NSA) cost for local agencies. Local agencies may contract with translators or interpreters not listed in the State-wide contract, as needed.
B. The local agency staff must inform a WIC applicant or participant of the availability of a qualified or certified interpreter at no cost, so that he or she may make an informed decision to access interpretative services. If an applicant or participant decides not to access the free interpretive services, opting to use another service provider (the expense for which is the participant’s responsibility), or decides to use a family member or friend in lieu of an interpreter, the applicant or participant and the interpreter who accompanies them must sign a Waiver of Rights to Free Interpreter Services. A copy of the signed Waiver must be placed in the participant’s file.
C. The local agency must post the Notice of Free Interpretation Services in the waiting room, front office, or voucher issuance area for WIC applicants and participants. The purpose of the sign is to indicate that WIC services are available in other languages at no charge upon request. The display of the Notice of Free Interpretation Services sign will be monitored during Program Review and self-reviews.
D. Nutrition education materials, breastfeeding materials, and other outreach materials and resources that are needed must be approved by the Nutrition Operations/Education Manager for the populations served. When determining what languages, other than English, materials need to be translated into, the State Agency and local agencies must consider the “significant number or proportion of the [WIC-eligible] population that needs the information in a language other than English, considering the size and concentration of such population and, where possible, the reading level of participants.” The Refugee Health Program has access to a library of translated health education materials as well, and these materials can be distributed to organizations and individuals upon request.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CM Special Populations
Policy No. CM-730.01 Effective Date: October 1, 2016
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IV. Refugees
A. The Department of Public Health’s Refugee Health Program assists refugees with accessing health care by making appointments, arranging transportation, and providing interpretive services at appointments.
B. The Refugee Health Program can provide interpretative and translation services in the following languages: Arabic, Maay-Maay, Somali, Swahili, Bhutanese, and Nepali. For more information on the Department’s Refugee Health Program, you can visit the website for details and updates at https://dph.georgia.gov/refugee-health-program.
V. Native Americans Every effort should be made to locate and enroll all eligible Native Americans residing within a local agency service area, including the provision of on-site WIC services at Indian Health Services facilities.
VI. Persons with Disabilities
Local agencies are responsible for ensuring that services will be made accessible to individuals covered by the Americans with Disabilities Act. This also applies to vision and hearing impaired participants and applicants. Interpreters for the hearing impaired are available through the State Rehabilitation Program Translation Interpretative Services.
Authority 7 CFR § 246.7 (m) 7 CFR § 246.8(c) 7 CFR § 246.11(c)(3) 7 CFR § 246.14(c)(5) FNS Instruction 113-1, Section VII
Definitions/Supporting Information Limited English Proficient (LEP) Population- Individuals whose primary language is not English, and/or who do not read or speak English well enough to have access to WIC services and benefits provided in local clinics, may be considered members of the Limited English Proficient (LEP) population. Loggers: Individuals whose principal employment has been seasonal harvesting of trees within the last twenty-four (24) months and for which temporary residence was established.
Migrant Farm Workers: Individuals (and family members) employed seasonally in agriculture occupations within the last twenty-four (24) months, who establish temporary residence for the
GEORGIA WIC PROGRAM PROCEDURES MANUAL CM Special Populations
Policy No. CM-730.01 Effective Date: October 1, 2016
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purpose of such employment. Seasonal farm workers who do not establish temporary residence for the purpose of work are NOT migrant farm workers as defined by the Georgia WIC Program.
Non-Traditional Housing: Accommodations that include, but are not limited to, private and public institutions which provide meals and sleeping accommodations to a special group of people (other than private residences and homeless facilities), homeless shelters which provide temporary living accommodations and meal services for individuals who lack a fixed and regular night time residence, temporary housing (including the residence of another person), and special drug rehabilitation homes for pregnant women in a group home. Refugee – refers to someone who flees his or her country to another country to seek protection or relief from persecution because of race, religion, nationality, their political opinion, or membership in a social group.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CM Outreach Method Policy No. CM- 740.01 Effective date: October 1, 2016
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Policy
Outreach activities are those promotional efforts designed to encourage and/or increase participation in the Georgia WIC Program. To administer outreach activities, the State agency issues a standard set of outreach materials for use and distribution by local agencies. At a minimum, local agencies must distribute outreach materials about the Georgia WIC Program to organizations, agencies, and other public assistance programs that serve potentially WIC- eligible individuals and families in their service areas.
Purpose The purpose of outreach is to:
1. Increase program caseload. 2. Increase public awareness of the benefits of the Georgia WIC Program 3. Inform potentially eligible persons in order to encourage and promote their participation in WIC. 4. Inform health and social agencies about WIC eligibility criteria for participation and to encourage referrals. 5. Ensure cooperation and coordination between WIC and other health-related and public assistance programs to benefit WIC applicants and participants 6. Promote a positive image of the Georgia WIC Program.
Procedures I. Outreach Materials A. Only State created or approved outreach materials may be used by the local agency. Outreach materials will be provided in English and Spanish. The local agencies will be responsible for translating materials into additional languages that reflect the cultural composition of their respective service areas (See Section IV, Program Costs of Outreach Activities). B. Outreach materials developed by a local agency must be reviewed and approved by the State Agency.
C. All outreach materials must include the following information: 1. USDA non-discrimination statement (see Non-Discrimination Statement Policy); 2. The toll-free phone number for the Georgia WIC Program, which is 1-800-228- 9173; and, 3. The website address for the Georgia WIC Program, which is http://dph.georgia.gov/WIC. These resources are available on printed materials and are provided during radio and television interviews about WIC.
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II. Methods of Outreach: Outreach Activities for Local Agencies
A. Outreach efforts must be consistent with the goals of the WIC program.
B. Outreach activities should be aimed directly at potentially eligible individuals, and includes the development of a referral network consisting of programs housed in the local health department, religious organizations, and other organizations and agencies/programs that work with and provide assistance to the WIC-eligible population in a local agency’s service area.
C. Special Populations. Local agencies must coordinate their outreach efforts with other agencies and community organizations that serve WIC-eligible individuals and those WIC-eligible individuals who can be classified into a special population (see Policy CM-730.01, Special Populations). This includes making service referrals to WIC applicants and participants for other health-related and public assistance programs when appropriate. Service coordination efforts by local agencies should include:
1. The development of a network of local organizations and persons serving and providing resources to special population groups and coordinate services with those other agencies/organizations/programs; 2. The implementation of outreach activities in the appropriate language(s) where a substantial number of individuals are non-English speaking through obtaining services through Translation Interpretive Services, the Department’s Refugee Health Program, and/or its own local service provider. 3. The provision of accommodations for those who are hearing impaired through the State Rehabilitation Program Translation Interpretive Services, or its own local service provider. 4. Coordinate referrals with local health and human service agencies, that serve individuals and families who reside in non-traditional housing, temporary housing, and institutions, including but not limited to Temporary Assistance for Needy Families (TANF) and client assistance services, food pantries and meal programs, local shelters, Supplemental Nutrition Assistance Program (SNAP), and, Legal services.
D. Native Americans. Every effort should be made to locate and enroll all eligible Native Americans residing within a local agency service area, including the provision of on-site WIC services at Indian Health Services facilities.
E. Local agencies must ensure that nutrition education and breastfeeding materials are available in Spanish as well as in other languages based upon the size and concentration of those populations in the local agencies’ respective service areas. III. Outreach Activities When Operating at Maximum Caseload
Local agencies operating at maximum caseload are not exempt from conducting outreach activities.
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IV. Agencies to Contact for Outreach
Examples of agencies, private and not-for-profit organizations, and citizen participation groups that should be contacted regarding referrals and coordination of services include:
A. Alcohol/Drug Abuse Counseling and Treatment Centers B. Family Planning Programs C. Child Abuse Counseling Centers D. Physicians, Obstetricians, Pediatricians, Family Practitioners, Nurses and Nurse Practitioners E. Health and Medical Organizations, Hospitals, Community Centers and Clinics F. Pharmacies G. Public Assistance Offices H. Unemployment Offices I. Social Service Agencies J. Religious and Community Organizations K. Agencies offering services for Homeless Families and Individuals L. Housing Authorities M. School-Based Health Clinics N. Migrant Health Centers, Migrant Offices, Logging, and Agricultural Communities O. Military Bases P. Department of Family and Children Services Q. Day Care Centers R. Charitable Organizations (Goodwill, Salvation Army, etc.) S. Head Start Programs T. Department of Labor V. Program Costs for Outreach Activities
Outreach costs are allowable if costs are considered reasonable and necessary to promote the specific program purposes of outreach. The cost of developing outreach materials, including the translation of outreach materials to the appropriate language(s) reflective of a local agency’s service area population, are reimbursable to the local agencies.
Authority
7 CFR 246.4(a)(6), (7), and (20) 7 CFR § 246.7(b) 7 CFR 246.8(c) 7 CFR 246.11(c)(3)
Subpart A-State Plan-Outreach
Agreements with Local Agency
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CM Outreach Method Policy No. CM- 740.01 Effective date: October 1, 2016
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Definitions/Supplemental Information
Outreach - Promotional efforts designed to encourage and/or increase participation in the Georgia WIC Program. Outreach materials may include, but are not limited to, informational posters, brochures, displays in public places, and public service advertisements through local newspapers, radio, or television.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Promotion/Incentive Items Policy No. CM- 74.02 Effective Date: October 1, 2019
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Policy Outreach incentive items must provide the program a benefit commensurate with the cost incurred, have a proven positive impact, be reasonable and necessary, align with the purposes of increasing the number of participants at a local agency, and reach a group of potential participants who are unaware of the WIC program or unsure how to access it. Purpose To provide guidance on the purchase of outreach incentive items for usage by the WIC Program. Procedures I. Before purchasing, submit outreach incentive items purchase plans to the Department of Health Promotions Office of Fiscal Operations for approval, using the “District Request to Purchase Form”.
II. Submit a detailed plan for using the item with the request to purchase including the following information: a. how the item will be used b. who will use the item c. who will receive the item d. when will the item be distributed including dates(s) of any specific events
III. Submit a detailed evaluation plan for determining how the incentive items will provide the program a benefit commensurate with the cost incurred.
IV. Ensure program incentive items for outreach meet the following guidelines: a. contain a WIC-specific message that targets the potentially eligible population b. would normally be seen in public (i.e. pen, cup, mug) c. Where practicable include the appropriate Georgia WIC nondiscrimination statement (Non-Discrimination Policy) a. have value as outreach device that equals or outweighs other uses (for example, a promotion and support message would outweigh the value of a pen) d. Include Georgia WIC contact information for state or local agency name, address, phone number (as appropriate)
V. Ensure program incentive items for nutrition education: a. are targeted to participants b. Where practicable include the appropriate Georgia WIC nondiscrimination statement (Non-Discrimination Policy) have a clear and useful connection to specific WIC nutrition education message and either convey enough in to be
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Promotion/Incentive Items Policy No. CM- 74.02 Effective Date: October 1, 2019
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considered educational or be utilized by participants to reinforce nutrition education contacts c. have value as nutrition education aids that equal or outweigh other uses d. be distributed to the audience for which the items were designed
VI. Ensure program incentive items for breastfeeding promotion and support: b. Where practicable include the appropriate Georgia WIC nondiscrimination statement (Non-Discrimination Policy) c. have a clear and useful connection to promoting and supporting breastfeeding in general d. have value as breastfeeding promotion and support items that equal or outweigh other uses (for example, a promotion and support message would outweigh the value of a pen) e. be distributed to the audience for which the items were designed
Authority 7 CFR 246.14(c)(1) 7 CFR 246.11 2 CFR 200.403 Policy Memo 95-5 WIC BF Policy & Guidance 7 CFR 246.14(a)(1)
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CM Public Comment Period Policy No. CM- 740.03 Effective date: October 1, 2017 No. of pages: 1
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Policy
The State agency shall establish a procedure under which the general public are provided an opportunity to comment on the development of the State agency plan
Purpose
The WIC Program is a valuable program serving women, infants and children in need in Georgia. Public comments and suggestions are important and useful ways to evaluate the program and ensure that it is effectively serving families.
Procedures
I. On an annual basis, the State Agency will notify participants, vendors, advocates, and the general public about the Public Comment Period.
II. The Public Comment Period will be for 30 days and will solicit responses via Survey Monkey
III. Public Comments questions will be accessed via Survey Monkey through the Georgia WIC Program website (dph.georgia.gov/WIC) and Georgia WIC Online Nutrition Education website (georgiawiconline.org)
IV. The WIC Communication and Outreach Liaison will prepare news release or other communication tool as deemed appropriate by the Georgia Department of Public Health (DPH) to notify the public of the Georgia WIC Program Public Comment period. The DPH Office of Communications will disseminate the news release or other tool to statewide media outlets (newspapers, radio and television stations) listed in the agency’s database and also on the Georgia WIC Program website.
V. The news release will include the full USDA non-discrimination statement.
Authority
7 CFR 246.4(b) Subpart A-State Plan-Outreach Agreements with Local Agency
Definitions/Supporting Information
(None)
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CR Civil Rights Training Policy No. CR-1100.01 Effective date: October 1, 2019
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Policy Georgia WIC approved Civil Rights Training must be completed annually by all staff funded through Georgia WIC Grant in Aid or providing Georgia WIC Services. All new employees must have the most current year’s version of Annual Civil Rights training prior to providing any WIC services or interacting with the public as a WIC provider. Purpose To ensure people involved in all levels of administration of the Georgia WIC program understand civil rights related laws, regulations, procedures, and directives. Procedures I. Staff must complete an approved annual Civil Rights Training between the time the state hosts the current year’s annual training and by the end of the fiscal year.
II. Local Agencies may provide Civil Rights Training upon approval of the Georgia WIC Civil Rights Coordinator. The annual Civil Rights Training will include, but not be limited to, the following topic areas: A. Assurances B. Collection and use of ethnicity and race data C. Effective public notification systems D. Complaint procedures E. Compliance review techniques F. Resolution of noncompliance G. Training H. Requirements for reasonable modification for persons with disabilities I. Requirements for language assistance J. Conflict resolution K. Customer service
III. Local agency will maintain records of completion of annual Civil Rights Training on the Continuing Education Log.
Authority 7 CFR § 246.8 FNS Instruction 113-1
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CR Civil Rights Training Policy No. CR-1100.01 Effective date: October 1, 2019
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Definitions/Supporting Information Assurances – Nondiscrimination provisions in federal law, regulation and guidance must be agreed to by subrecipients of federal funding and is met through Local Agency signed and dated Master Agreement and WIC Annexes.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CR Nondiscrimination Statement Policy No. CR- 1110.02 Effective date: August 1, 2017
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Policy All information materials and sources used by the state and local agencies to inform the public about the WIC Program must contain the nondiscrimination statement when it contains information vital to program participation. The nondiscrimination statement must not be altered in terms of content or format. All web sites used to inform the public about the WIC Program must include the full nondiscrimination statement, or a link to it must be included on the website’s home page. The nondiscrimination statement must be used on applicant or participant facing materials when the WIC logo is used. Purpose To ensure that WIC program requirements and benefits are consistently applied to all applicants and participants regardless of race, color, national origin, sex, age or disability.
Procedures I. Use the following nondiscrimination statements: A. English full statement B. English short statement C. Spanish full statement D. Spanish short statement
II. Contact the Georgia WIC Civil Rights Coordinator for questions regarding the use of the nondiscrimination statement.
III. A nondiscrimination statement is not required:
A. To be imprinted on items such as cups, buttons, magnets, and pens that identify the WIC program, when the size or configuration makes it impractical.
B. For nutrition education and breastfeeding promotion and support materials “that strictly provide a nutrition message with no mention of the WIC Program.”
IV. The short statement can be used:
A. When materials are too small to permit the full nondiscrimination statement. The short statement print size must be no smaller than the text.
B. Radio and television public service announcements.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CR Nondiscrimination Statement Policy No. CR- 1110.02 Effective date: August 1, 2017
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C. On non-vital program materials. The short statement print size must be no smaller than the text.
V. All outreach provided to a specific Limited English Proficiency population must include the full nondiscrimination statement in the language of the targeted population. Please consult with the Georgia WIC Civil Rights Coordinator for assistance.
Authority 7 CFR § 246.8(a)(1) FNS Instruction 113-1 USDA-FNS, WIC Policy Memorandum #2016-2
Definitions/Supporting Information Vital to program participation - any information where not having access to the information may create a barrier to utilization of program benefits, accessibility and/or services.
Vital documents - materials and forms used for certification and eligibility, program outreach, program promotion and participant rights that are distributed, posted or aired for public viewing. Examples: applications, eligibility, notices of disqualification, ineligibility or termination, outreach.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CR Collection of Ethnicity and Race Data Policy No. CR- 1130.01 Effective date: October 1, 2019
No. of Pages: 3
Page 1 of 3 Revised October 2019 Policy At each eligibility determination, the local agency must ask every applicant/participant to self- identify their ethnicity and race designation(s). Ethnicity shall be collected first, and an applicant/participant shall be offered the option of selecting one or more racial designations. Staff must use the WIC Applicant/Participant Education Tool or Interview Script Form when asking an applicant/participant to self-identify their ethnicity/race. Where an applicant/participant does not provide ethnicity, race, or both, staff shall through visual observation or utilizing historical data, secure and record the information where possible.
Medical records, tickler cards, appointments, or any other WIC documents must not openly distinguish applicants/participants by race, color, national origin, sex, age, and/or disability. Any collection of ethnic and race data for local surveys or forms must follow the procedures for data collection and reporting.
Purpose
To determine how effectively the Program is reaching potentially eligible persons and to identify population groups where additional outreach is needed.
Procedures I. Document an applicant’s/participant’s self-declared ethnic category, “Hispanic or Latino” and “Not Hispanic or Latino”.
II. Document an applicant’s/participant’s self-declared racial category(ies): 1) American Indian or Alaska Native, 2) Asian, 3) Black or African American, 4) Native Hawaiian or Other Pacific Islander, and 5) White.
III. Ask participants to self-identify their ethnicity first followed by their race only after the interviewer has explained:
A. The definitions of the ethnicity and race categories. B. The collection of this information is strictly for program evaluation purposes to assure that Georgia WIC is providing services fairly. C. Has no effect on the determination of their eligibility to participate in the program.
IV. Accept an applicant’s/participant’s self-declaration as to their ethnic category or race category(ies), without disputing the selection.
V. Notify the applicant that a visual identification of his or her race and ethnicity will be made and recorded in the data system if they decline to self-identify their ethnicity, race, or both.
VI. Any other collection of the ethnicity and race categories are required to meet the following
GEORGIA WIC PROGRAM PROCEDURES MANUAL CR Collection of Ethnicity and Race Data Policy No. CR- 1130.01 Effective date: October 1, 2019
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Page 2 of 3 Revised October 2019 criteria:
A. Include a statement explaining why the data is collected and that the collection of ethnicity and race data is voluntary. This statement shall precede the ethnicity and race question. (e.g. “The following questions asking about your ethnicity and race are being asked for statistical purposes to make sure that we are giving fair and equal treatment to everyone. Your answers will have no effect on your WIC services.”) B. Display the ethnicity and race questions as separate categories on the form. C. Limit the use of ethnicity and race categories to the ones presented in this policy. D. Collect information about ethnicity before race.
E. List the race categories in the order described in II above.
F. Provide an option to select one or more races (“Mark one or more” or “Select one or more”). G. Keep ethnicity and race information confidential, maintain safeguards that restrict access to records only to authorized personnel, and only use for aggregate analysis. H. Keep information for five (5) years + current year if not otherwise required to be kept for a longer period. Authority 7 CFR § 246.8(a)(3) FNS Instruction 113-1, Section XII
Definitions/Supporting Information Hispanic or Latino. A person of Cuban, Mexican, Puerto Rican, South or Central American, or other Spanish culture or origin, regardless of race. The term “Spanish origin” can be used in addition to “Hispanic or Latino.” Not Hispanic or Latino. Not a Spanish culture or origin. Race 1) American Indian or Alaskan Native. A person having origins in any of the original peoples of North and South America (including Central America), and who maintains tribal affiliation or community attachment.
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2) Asian. A person having origins in any of the original peoples of the Far East, Southeast Asia, or the Indian subcontinent, including, for example, Cambodia, China, India, Japan, Korea, Malaysia, Pakistan, the Philippine Islands, Thailand, and Vietnam.
3) Black or African American. A person having origins in any of the black racial groups of Africa.
4) Native Hawaiian or Other Pacific Islander. A person having origins in any of the original peoples of Hawaii, Guam, Samoa, or other Pacific Islands.
5) White. A person having origins in any of the original peoples of Europe, the Middle East, or North Africa.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CR Discrimination Complaint Handling
Policy No. CR- 1140.01 Effective date: January 31, 2018
No. of Pages: 4 Revised October 2021
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Policy The state agency and all local WIC agencies shall comply with federal law, the regulations of the United States Department of Agriculture (USDA), and USDA policies and instructions in ensuring that no person shall, on the basis of race, color, national origin, age, sex, or disability, be excluded from participation in, be denied benefits of, or otherwise be subject to discrimination, or retaliation for prior civil rights activity, in any program or activity conducted or funded by the USDA.
An individual alleging discrimination based upon federally protected classes has the right to file a complaint within 180 days of the alleged discriminatory action with a local or state agency or with the United States Department of Agriculture (USDA), Office of the Assistant Secretary for Civil Rights. The Secretary of Agriculture or his/her designee may extend this time under special circumstances. Within five (5) calendar days of receipt, all complaints of discrimination based on a federally protected class or complaints of retaliation for engaging in a protected activity, such as making a discrimination complaint, must be forwarded to the Regional Civil Rights Officer (RCRO) within the USDA Food and Nutrition Service (FNS), Southeast Regional Office for processing.
The local agency must send all complaints of discrimination to the state agency without exploration, investigation or resolution. Under no circumstances may any employee of a local agency retaliate against a WIC applicant or participant that has indicated that he or she would like to complete, or has completed, a complaint of discrimination. An applicant’s or participant’s rights or privileges under the WIC Program may not be interfered with because he or she has made a complaint alleging discrimination. All communication about the discrimination complaint must be treated as confidential information. All discrimination complaints must be filed and kept separate from program/customer service incidents/complaints.
The local WIC agency must provide applicants and participants with complaint filing information in a language and/or alternate format that they can understand.
Purpose To ensure that applicants or participants who believe they were discriminated against because of a federally protected class, or who believe they have experienced an adverse action because they engaged in a protected activity, are provided an opportunity to file a complaint without fear of retaliation.
Procedures for Discrimination Complaints
I. At initial certification, provide the applicant or participant with education about complaint filing: A. Their right to file a complaint, including discrimination complaints; B. How to file a complaint; and C. Complaint procedures.
II. At every recertification:
GEORGIA WIC PROGRAM PROCEDURES MANUAL CR Discrimination Complaint Handling
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A. If a participant can state the complaint filing procedures, the local WIC agency may refer the participant to their Georgia WIC ID folder for the complaint contact information. B. If unable to state understanding of complaint filing procedures, reinstruct as necessary per procedure I.
III. WIC clinics must display the following:
A. “How to File a Complaint” poster in all waiting rooms or the “How to File a Complaint” flyer at each point in the service delivery process. B. Displaying the “And Justice for All Poster” in a prominent location. This poster can be obtained from the Georgia WIC Civil Rights Coordinator.
IV. Provide the following information for individuals who wish to directly file a discrimination complaint with the United States Department of Agriculture (USDA) based on race, color, national origin, age, sex, or disability may send the complaint by mail, facsimile, or electronically to:
By Mail: United States Department of Agriculture Attn: Director, Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, DC 20250-9410
By Facsimile Facsimile: (202) 690-7442
By Electronic Submission Email: program.intake@usda.gov or Web-based https://www.usda.gov/oascr/filing-program-discrimination-complaint-usda-customer
V. Document complaints of discrimination on the Incident/Complaint Form. Inform the complainant that discrimination complaints related to WIC federally protected classes will be forwarded to USDA-FNS, RCRO, and age complaints and age complaints involving additional protected bases will be forwarded by USDA-FNS, RCRO to the Federal Mediation and Conciliation Service (FMCS) for attempted resolution.
VI. Obtain the key elements of the complaint and document on the Incident/Complaint Form. The key elements are: A. Complainant’s Name; B. Complainant’s Contact Information: name, address, phone number (and other means of contacting the complainant); C. The location (including county and address) where the alleged discrimination
GEORGIA WIC PROGRAM PROCEDURES MANUAL CR Discrimination Complaint Handling
Policy No. CR- 1140.01 Effective date: January 31, 2018
No. of Pages: 4 Revised October 2021
Page 3 of 4
occurred; D. The nature of the incident or action that led the complainant to feel discrimination was a factor; E. The basis of the alleged discrimination as described by the complainant; F. The name (s) of the individual (s) and organization (s) involved in the alleged discrimination; G. The names, telephone numbers, titles, and business or personal addresses of persons who may have knowledge of the alleged discriminatory action; and H. The date(s) during which the alleged discriminatory actions occurred or, if continuing, the duration of such actions.
VII. For anonymous complaints of discrimination, capture as much information as possible and handle in the same manner as any other discrimination complaint.
VIII. Scan written complaint information from the complainant into the Incident/Complaint Form.
IX. Submit all complaints of discrimination to the State agency within 24 hours of the report being received from the complainant. Electronic Submission: GeorgiaWICCivilRights@dph.ga.gov X. Georgia WIC Civil Rights Coordinator or designee submits electronically all complaints of discrimination to USDA-CRD within five days of the report being received from the complainant.
XI. The local WIC agency may but are not required to retain a copy of the for discrimination complaints; however, the state agency retains responsibility for the official copy with follow-up communication and maintenance of retention schedules. If the local agency chooses to retain a copy of the Incident/Complaint Form: A. Retain in a way to protect the complainant’s confidentiality. B. Treat as protected health information. C. File separately from other complaints. D. Destroy no later than five (5) years after the report.
Authorities 7 CFR § 246.8(a) and (b) FNS Instruction 113-1 State Agency Complaints Processing Memorandum of Understanding between United States Department of Agriculture Food and Nutrition Service and Georgia Department of Public Health 9-9-2016 Definitions/Supporting Information Age - The number of elapsed years from the date of a person's birth.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CR Discrimination Complaint Handling
Policy No. CR- 1140.01 Effective date: January 31, 2018
No. of Pages: 4 Revised October 2021
Page 4 of 4
Color - A person’s skin complexion, pigmentation (lightness or darkness), shade, or tone. Complainant – Any person or groups of persons that allege discrimination in the delivery of program benefits and services. Complaint of Discrimination - A verbal or written allegation of discrimination that indicates a disparity of treatment or services being provided to persons or groups of persons because of federally protected classes. Disability - A person’s physical or mental impairment that constitutes or results in a substantial impediment to one of more major life activities, or a person’s record of having such impairment, or being regarded as having such an impairment. Discrimination - The act of distinguishing one person or group of persons from others, either intentionally, by neglect, or by the effect of actions or lack of actions based on federally protected bases. Investigation - Gathering of facts by the local agency, state agency, or the USDA that will refute or substantiate an allegation of discrimination. National Origin - A person’s place of origin, or his or her ancestor's place of origin; or a person’s physical, cultural or linguistic characteristics that are associated with a national origin group. Protected Classes - The federally protected bases for nondiscrimination in the WIC Program are race, color, national origin, sex, disability, or age. Race - Ancestry, physical characteristics, or cultural characteristics associated with a particular race (such as hair texture, skin color, or certain facial features). Retaliation - The act of intimidating, threatening, coercing, or unlawfully discriminating against any individual for filing a complaint, testifying, assisting, or participating in any manner in an investigation, proceeding or hearing or any other right or privilege secured by the Civil Rights statutes and regulations enforced by FNS. Sex - The biological condition of being male or female.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CR Customer Service Complaint Handling Policy No. CR- 1140.02 Effective date: January 31, 2018 No. of Pages: 2
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Policy It is the policy of Georgia WIC that all complaints will be handled in a timely fashion to a resolution of customer satisfaction and/or understanding. Purpose To ensure that applicant and participants complaints are investigated, resolved, and analyzed to improve the immediate customer service complaint as well as identify potential local or state program improvements. * Please see Policy CR 1140.01 for procedures related to complaints of discrimination based on protected class and participant education about the complaint process.
Procedures I. All applicants and participants must be provided education about their right to file a complaint, how to file a complaint, and how a complaint will be processed at the eligibility determination (see Policy CR 1140.01).
II. Any complaints by participants about Georgia WIC Vendors must be referred to the State WIC Office 1-800-228-9173 for investigation and resolution.
III. Any complaints from Georgia WIC Vendors about Georgia WIC participants must be referred to the State WIC Vendor Office 1-800-228-9173 for investigation and resolution.
IV. An applicant or participant may file a complaint regarding staff, clinic treatment, vendors, or Georgia WIC policy and procedure at the local, state, or federal agency level.
V. The local agency or state agency may file a complaint regarding a Georgia WIC participant who is alleged to have violated the Georgia WIC Rights and Obligations.
VI. Complaints (except for discrimination complaints – see Policy CR 1140.01) should be handled at the closest level to the complaint to obtain the earliest resolution.
VII. Every effort should be made to resolve an applicant or participant complaint within twenty- four hours. If an applicant or participant is making the complaint while still in the clinic for service, every effort should be made to resolve the participant complaint prior to the applicant or participant leaving the clinic.
VIII. All complaints should be closed within 90 days of the initial report with all corrections and resolutions completed including communication with the applicant or participant about the resolution.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CR Customer Service Complaint Handling Policy No. CR- 1140.02 Effective date: January 31, 2018 No. of Pages: 2
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IX. All complaints submitted to the State Agency must be documented on the incident/complaint form.
X. All written complaints must be submitted to the State Agency on the incident/complaint form with the resolution completed unless State Agency assistance with the resolution is required. Please Email the password protected form to GeorgiaWICCivilRights@dph.ga.gov
XI. The local agency is required to document and maintain records of complaints received at the local level to include the resolution of the complaint. It is recommended that the local agency document complaints utilizing the incident/complaint form to assure complete documentation and for follow-up purposes.
XII. The local agency should analyze locally received complaints annually to identify complaint trends and develop a plan to improve or report to the state agency policy and procedure concerns.
XIII. All complaints submitted to the State Agency from or about Georgia WIC applicants and participants will be documented on the incident/complaint form.
XIV. For anonymous complaints capture as much information as possible and handle in the same manner as other complaints.
XV. If a complaint received at the state agency requires the local agency to follow-up with the investigation and/or resolution of the complaint, the local agency must document the information on the incident/complaint form that is sent to the local agency by the state agency.
XVI. All Georgia WIC staff should immediately respond to a complaint and resolve issues.
XVII. All complaints from or about Georgia WIC participants must be kept confidential as WIC participant protected information.
XVIII. The local WIC agency will maintain the documentation of complaints received at the local level for five (5) years plus current. The State agency will maintain the documentation of complaints received at the state level for five (5) years plus current.
Authority
7 CFR § 246.8(b) FNS Instruction 113-1
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CR Civil Rights Compliance and Resolution Policy No. CR-1150.01 Effective date: October 1, 2019 No. of pages: 2 Page 1 of 2 Policy A formal resolution process must be initiated, for all identified Civil Rights Compliance Concerns, (See Civil Rights Compliance Areas) whether identified by formal or informal review processes. When a civil rights compliance concern is identified during local self-review, the local agency must complete a resolution for the compliance concern within 60 days of the self-review. When a civil rights compliance concern is identified by the state agency during any visit, the local agency has 60 days, upon receipt of written notification, to resolve the compliance concern. Any compliance concern not resolved within 60 days of the written notification (or self- identification) must be reported to Georgia WIC Civil Rights Coordinator who will notify the U.S. Department of Agriculture, Food and Nutrition Service, Regional Civil Rights Officer (USDA-FNS- Regional Civil Rights Officer). Purpose To protect the civil rights of eligible Georgia residents to the Georgia WIC program by quickly resolving any civil rights concerns. Procedures I. Develop a plan for resolution of civil rights compliance concerns identified during the self- review. The plan must include the following: A. Date identified B. Specific compliance concern (s) identified C. The action(s) required to resolve the concern or to improve the situation to at least the minimum required standard. D. Timeline for the resolution. The timeline must be less than 60 days. II. If the civil rights concern is identified by the state agency during monitoring reviews, compliance visits or informal visits, address civil rights compliance concerns and resolution in the Quality Improvement Plan (QIP). A. If requesting any extension for the Corrective Action Plan, submit the resolution for the Civil Rights compliance concern (s) with the request for extension. III. Maintain civil rights compliance plans at the LA office. IV. Notify the Georgia WIC Civil Rights Coordinator on day 60 or before of any compliance concerns that cannot be resolved within the required 60-day window. A. Identify barriers and adjusted timeline to resolution. B. Develop a written plan for resolution with the Georgia WIC Civil Rights Coordinator.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CR Civil Rights Compliance and Resolution Policy No. CR-1150.01 Effective date: October 1, 2019
No. of pages: 2
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C. Upon guidance from USDA-FNS Regional Civil Rights, maintain ongoing follow-up per written agreement for resolution with Georgia WIC. D. Maintain copy of Report of Findings of Noncompliance Letter provided by Georgia WIC Civil Rights Coordinator at the LA office.
Authority Food & Nutrition Service Instruction-113-1, Section XIV Master Agreement WIC Annexes Definitions/Supporting Information Civil Rights – within the WIC program, rights that protect individuals’ or groups’ freedom to apply and participate fully in the program without discrimination or repression. Civil Rights Compliance Concerns – non-compliance with any civil rights requirement as interpreted by federal or state statute or regulation, or with policies, procedures and/or practices designed to prevent a violation of an individual’s or group’s civil rights. Report of Findings of Noncompliance Letter – notification letter sent to USDA-FNS Regional Civil Rights Officer that meets the requirements of FNS-113-1, Section XIV for inability to reach voluntary compliance within 60 days. Resolution – an action to resolve noncompliance with any civil rights regulation, instruction, policy, or guidance that meets or exceeds the minimum standard of policy, procedure and/or practice.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Residency Requirements
Policy No. CT- 800.02 Effective Date: October 1, 2016
No. of Pages: 2
Revised June 2018
Page 1 of 2
Policy Local agencies (LAs) must verify each applicant/participant is a Georgia resident at each certification prior to providing WIC services in a way that does not constitute a barrier to any individual, including an individual who is mobile (e.g. homeless individual, applicants living at a campsite or in a car, military personnel or migrant). LA staff must ask the participant to state their address at each recertification to ensure residency has not changed. LAs must obtain a verification of residency anytime a change of residency or custody occurs. Residency must be verified at the receiving clinic at the time of a transfer. Vacations may not be considered for residency.
LA cannot require length of residency, fixed residence, or a mailing address for an applicant to receive services.
Proof must be in the applicant’s or spouse’s name. Children are considered residents of the state in which their parent/caretaker resides. Proof of residency for children can be in their parent/caretaker’s name.
Applicants may apply for and receive WIC benefits in the county in which he/she resides or at any clinic of their choice within the state of Georgia.
Purpose To provide program integrity, ensuring that those applying for WIC benefits from the Georgia WIC Program reside within the State of Georgia. Procedures
I. Local Agency will verify proof of residency by reviewing one of the following:
A. The physical copy presented on site by the applicant/participant.
B. A document uploaded by the applicant or another program in Georgia Gateway.
II. Complete the Proof of Residency Form for Applicants for applicant/participant(s) who has a PO box.
III. File the completed Proof of Residency Form for Applicants in the participants record
IV. Continue to use the current Proof of Residency Form for Applicants if there is no change in the PO Box and the physical address is still the same.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Residency Requirements
Policy No. CT- 800.02 Effective Date: October 1, 2016
No. of Pages: 2
Revised June 2018
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V. Request new proof of residency when informed of a residency change during the categorically eligibility period.
VI. Refer to Identification, Residency and Income Reporting Codes for a list of Gateway Codes
VII. Ensure billing statements provided by applicant/participant (including utility bill, etc.) are within the past 30 days for proof of residency.
VIII. Require applicant/participant who is unable to provide proof of residency to complete the Client Statement Form. File the completed form in the participant’s record or scan it into Georgia Gateway.
IX. Allow military personnel to use their temporary duty station where the WIC participant lives as their residence for WIC purposes, even though they vote and pay taxes in another state.
X. Accept a copy of a bill with the parent, guardian, or other person’s name for a minor prenatal, breastfeeding, or postpartum applicant who resides with his/her parent(s), guardian(s), other relative(s), or with someone that is not related to them as proof of residency. Require applicant/participant to complete a Verification of Residency and/or Income Form and file or scan the form into the participant’s WIC record.
Authority 7 CFR § 246.2 (definitions) 7 CFR § 246.7 (c)(1)(i) and (c)(2)(i)
Definition/Supporting Information Migrant Farmworkers – Individuals and their family members whose principal employment (over 50 percent) is in agriculture on a seasonal basis, who have been employed within the last 24 months, and who have established a temporary residence for the purpose of such employment. Examples of employment in agriculture include: field worker, cannery worker, packing shed worker, farm equipment operator, harvester, logger, timber worker, log hauler (e.g., timber, crops). Residency-The location or address where an applicant routinely lives or spends the night.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT
Income Eligibility Requirement Policy No. CT- 800.03 Effective Date: October 1, 2016
No. of Pages: 2 Revised June 2018
Page 1 of 2
Policy When determining program eligibility, the local agencies (LA) must verify and document an applicant’s income at each certification. An applicant’s income must be documented at or below 185% of the current federal poverty level for their family size using current WIC Income Guidelines to receive WIC services/benefits. The income verification must reflect a full thirty days of income. All household members’ income must be included when determining a participant’s income eligibility.
Purpose To ensure applicants are income eligible for Georgia WIC Program prior to receiving benefits. Procedures I. Verify the applicant’s enrollment in Medicaid, Food Stamps and/or Temporary Assistance for Needy Families (TANF), using the Adjunctive Eligibility Policy, prior to requesting other types of proof of income.
Calculate income in Georgia Gateway if participant is not adjunctively eligible.
A. Determine the family size and Applicant Group. See Family, Household, and Economic Unit Policy;
B. Calculate the earned income for the family using the income submitted by the applicant/participant.
Weekly = 4 paystubs Bi-weekly = 2 - 3 paystubs Bi-monthly = 2 paystubs Monthly = 1 paystub
C. Complete the unearned income questions if the participant receives any payments other than wages (child support, pension, social security income, contributions, etc.) on the gatepost page in Gateway.
D. Complete the self-employment questions if the applicant group has income from a business owned by anyone in the group on the gatepost page in Gateway.
II. Refer to Identification, Residency and Income Code Reporting Chart for a list of allowed documents and codes for verifying income.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT
Income Eligibility Requirement Policy No. CT- 800.03 Effective Date: October 1, 2016
No. of Pages: 2 Revised June 2018
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III. Use the Client Statement Form, if an applicant is unable to provide proof of income at the certification visit. The form must be copied/scanned into the participant’s record.
IV. Count a foster child as a family of one and use Medicaid for adjunctive eligibility.
V. When calculating income for military participants:
A. Review the Leave and Earning Statement (LES) and find the amount received.
B. Subtract all applicable income exclusions including combat pay (See Military Inclusions/Exclusions Chart)
Authority 7 CFR § 246.7(c)(1)(ii)
7 CFR § 246.7(d)(2)(i) – (ii) 7 CFR § 246.7(d)(2)(v) 7 CFR § 246.7(d)(2)(vii) – (ix) WIC Final Policy Memorandum #2016-3, Publication of the 2016-17 WIC Income Eligibility Guidelines WIC Policy Memorandum #2013-3, Income Eligibility Guidance
Definitions/Supporting Information Combat zone: Any area that the President of the United States designates by Executive Order as area in which the U.S. Armed Forces are engaging or have engaged in combat. Combat pay received by the service members is normally reflected in the entitlements column of the military LES. Combat pay is excluded. Income: Income is calculated as gross cash income before deductions for income taxes, employee’s social security taxes, insurance premiums, child support, bonds, and similar payments.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT
Adjunctive Eligibility Policy No. CT- 800.04 Effective Date: October 1, 2016
No. of Pages: 3
Revised: June 2018 Page 1 of 2 Policy Individuals eligible for public assistance programs are income eligible for WIC, regardless of their reported income. They are “adjunctive” or automatic income eligibility for WIC with proof of the following:
• Recipient of Temporary Assistance for Needy Families (TANF) or a member of a family that is certified eligible to receive assistance under TANF; • Recipient of benefits from the Supplemental Nutrition Assistance Program (SNAP). • Recipient of Medicaid, which includes presumptive eligibility for Medicaid or a member of family in which a pregnant woman or infant receives Medicaid
If a pregnant mother qualifies for Medicaid, her infant and children will adjunctively qualify for WIC.
If an infant qualifies for Medicaid, his/her pregnant, breastfeeding, or postpartum/non- breastfeeding mother will adjunctively qualify for the Georgia WIC Program using the infant’s Medicaid number.
A child on Medicaid cannot qualify his/her mother or a sibling.
Purpose To streamline income eligibility process for applicants who are determined to be participants in Medicaid, SNAP, or TANF.
Procedures I. Enter a declared income amount in the Gross Monthly Income field for a participant adjunctively eligible for WIC.
II. Process an applicant/participant who is adjunctively eligible even if their declared gross income exceeds WIC's income guidelines and do not require any other documentation of income.
a. Verify adjunctive eligibility in the Georgia Gateway worker portal.
b. Verify each participant/applicant’s eligibility period, ensuring that it is in “Active Status”, indicating current Medicaid eligibility.
c. SNAP and TANF eligibility is for the entire family listed under the primary individual.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT
Adjunctive Eligibility Policy No. CT- 800.04 Effective Date: October 1, 2016
No. of Pages: 3
Revised: June 2018 Page 2 of 2
Authority 7 CFR § 246.7 (d)(2)(v) and (vi) WIC Policy Memorandum #2013-3, Income Eligibility Guidance
Definitions/Supporting Information Medicaid (MA)- A federally and State funded portion of the Medical Assistance Program that pays for health care to low income households, and is administered by the Georgia Department of Community Health. SNAP (FS)- Supplemental Nutrition Assistance Program (formerly known as Food Stamps) is a program administered by the Georgia Department of Human Services (DHS) in which eligible households receive benefits that can be used to purchase food items from authorized retail stores and farmers' markets. Families are issued an electronic benefits card. TANF (TF)- Temporary Assistance for Needy Families: A program administered by the Georgia Department of Human Services (DHS) that provides financial assistance to needy children and/or their families.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Identity Requirements
Policy No. CT- 800.05 Effective Date: October 1, 2016
No. of Pages: 2 Revised June 2018 Page 1 of 2
Policy
Local agencies (LA) shall require each applicant/participant and each parent/caretaker/alternate-proxy for infants/children to provide proof of identity at the initial certification. If a person other than the original documented person presents at a subsequent appointment (recertification, voucher pickup, food package change, or nutrition education), identification (ID) must be requested and documented. LA may accept the WIC Identification Card as proof of identity (ID) for participants/ parents/guardians and alternate-proxy at recertification and all other WIC related appointments, if the same individual is present and they have signed the WIC ID folder. For an infant’s initial certification, the LA may accept a birth document, crib card, or hospital bracelet (mom and baby). Identity must be verified by the receiving clinic at the time of a transfer a thirty-day can be used if identification is not available during the appointment. Identification verification is required when a different parent/caretaker brings a child to any subsequent appointment whose identity has not previously been documented.
Purpose
To ensure that program benefits are issued to approved individuals.
Procedures
I. Upload a copy of the identification verified into Georgia Gateway. II. Request a photo ID at initial certification as the optimal form of ID. III. Verify a foster child’s identity using their recent information in Georgia Gateway IV. Reference Identification, Residency, and Income Code Reporting Chart for allowed types of ID. V. Label documents as hospital records VI. Only accept a birth document, crib card, or hospital bracelet up to three (3) months of age. VII. Request of Infants over three (3) months old, a non-birth document for certification or transfer. For example, a birth certificate, Social Security Card, etc.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Identity Requirements
Policy No. CT- 800.05 Effective Date: October 1, 2016
No. of Pages: 2 Revised June 2018 Page 2 of 2
Authority 7 CFR § 246.7(c)(2)(i)
Definitions/Supporting Information
Identification: A valid ID, such as a Driver’s License, Birth Certificate, and Immunization record used to establish a person’s identity.
Proofs: Reasonable documentation of personal identity, income and current residency as approved by the state WIC program.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Family, Household, and Economic Unit Policy No. CT- 800.08 Effective Date: October 1, 2016
No. of Pages: 3
Revised June 2018
Page 1 of 3
Policy WIC income eligibility is based on the income and size of the economic unit. Applicant(s) shall be interviewed to determine their family’s size.
An individual, or group of individuals, who has a source of income that is separate from that of other persons who reside in the household shall be considered a separate family unit if the local agency determines that their independent source of income is adequate to provide for their living expenses in their particular environment.
Purpose To establish a consistent method for determining the economic unit size of applicants whose income will be assessed to determine WIC eligibility.
Procedures I. Local agencies (LA) shall exercise discretion when determining the size of a family, or economic unit within the following general framework and examples provided. LA must:
A. Count a child in the family of the parent, guardian, alternate-proxy, or other caregiver with whom the child lives, with the exception of a foster child. For example, a child who resides with and is being cared for by a grandparent would be counted in the household of the grandparent.
B. Consider a foster child living with a family, the legal responsibility of the welfare agency or placement agency and count the child as a family of one (1).
1. The payments made by the welfare agency, or another agency for the care of that child is not considered to be the income of that foster child.
2. All foster care children are adjunctively eligible due to becoming a ward of the state, they received Medicaid.
C. Count a child who lives as a member of the family with whom he/she resides, when the family has accepted permanent legal responsibility for him/her.
D. Count a child who resides in more than one home as a result of a joint custody situation as a member of the household of the parent who first applies on behalf of the child.
II. The LA may reassess the family economic unit for a pregnant woman based on a family size increased by one or the number of expected infant(s), when she is determined to not be income eligible based on the current size of her family economic unit.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Family, Household, and Economic Unit Policy No. CT- 800.08 Effective Date: October 1, 2016
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III. LA can consider a household where the spouse is away and maintains a separate residence due to job related assignments as a separate economic unit without the inclusion of the spouse’s income. If the absent spouse is contributing to the household, then their contribution is included as income.
IV. LA must count college students who:
A. Maintain a separate residence at school but are supported by parents/guardians as a member of their parent/guardian’s household.
B. Maintain a separate residence and are self-supported as a separate household. Any regular cash supplements received from parents or guardians must be included in the student's total income.
V. LA will count an emancipated minor who is supporting herself without economic support from other persons as a separate family economic unit for purposes of determining income eligibility for WIC services. Therefore, a minor who lives at home but supports herself by providing for her own room, board and medical care is considered a separate “family” or economic unit.
VI. LA will count military personnel serving overseas or assigned to a military base as a member of the family economic unit, and their income should be included when determining family income.
VII. LA will count children in the temporary care of others while their parent is on military assignment elsewhere, or if the child(ren) temporarily move in with friends or relatives, choose one of the following options:
1. Count absent parents and their income while excluding current caregivers in their income; or,
2. Count children as members of the caregiver’s household.
VIII. LA will count children of Incarcerated Parent/Guardian in the family size of the caregiver with whom they live. A signed note from the parent giving permission to the caregiver (e.g., grandmother) is acceptable and must be placed in the health record. Services shall not be denied if the caregiver does not have a statement from the parent.
IX. Unemployment - Applicants from families with adult members who are unemployed shall be eligible based on income during the period of unemployment if the loss of income causes the current rate of income to be less than the income guidelines. Persons who are on leave that they requested themselves are not considered unemployed. For example, persons who request maternity leave or a teacher who is not paid during the summer would not be considered unemployed. In these instances, it may be more appropriate to use annual income to determine eligibility. If a woman is on extended
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Family, Household, and Economic Unit Policy No. CT- 800.08 Effective Date: October 1, 2016
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maternity leave [greater than six (6) months], it may be more appropriate to use current income to determine eligibility.
Authority 7 CFR § 246.2 7 CFR § 246.7 WIC Final Policy Memorandum #2016-3, Publication of the 2016-17 WIC Income Eligibility Guidelines WIC Policy Memorandum #2013-3, Income Eligibility Guidance
Definitions/Supporting Information
Current Income: Is defined as gross income received by the household during the month (30 days) prior to the date the application for WIC benefits is made. Family Economic Unit: A group of related or nonrelated individuals who live together as one household/economic unit. These individuals share income and consumption of goods or services. This term may be used interchangeably with “Household”.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Designation of a Proxy Policy No. CT-800.11 Effective Date: June 26, 2018
No. of Pages:2
Page 1 of 2
Policy As deemed necessary and appropriate when neither the participant/parent/caregiver/guardian nor the alternate-proxy is available, local agencies shall allow the WIC participant to designate a person, to pick up and/or redeem WIC food instruments on behalf of the WIC participant. Owners and managers of Georgia WIC Authorized retail vendors, cannot serve as a proxy. Proxy designation may be assigned by submission of a written notice or WIC Proxy Form via e-mail, fax or mail.
Purpose To minimize barriers to receive WIC benefits by allowing participants and parent/guardian/caretakers of a participant an alternative way to obtain and use food instruments (FIs) or cash value vouchers when they are not available to attend a WIC appointment or unable to redeem their benefits themselves.
Procedures I. The local agency’s staff will:
A. Inform WIC participants of their right to designate individuals to serve as their proxy. B. Explain the difference between the terms: alternate-proxy versus proxy. C. Discuss requirements for a proxy. The proxy must be: 1. Able to present a valid ID (See Identity Requirements policy) 2. A responsible person who the WIC participant trusts. 3. Whenever possible, another person in the same household as the participant (grandparent, aunt, older sibling, uncle, other relative, etc.) 4. At least sixteen (16) years old, unless prior approval is obtained from the District Nutrition Services Director or designated Competent Professional Authority (CPA). All approved age exceptions must be documented in the participant’s record. 5. When high-risk nutrition education contact is needed, knowledgeable of the participant medical history and nutritional habits/normal nutritional intake equivalent to the parent’s. D. Instruct the participant that he/she is responsible for properly training their proxy on the use of food benefits. E. Ensure that the participant understands WIC will be unable to replace any food benefits used improperly or not made available to the authorized WIC person by the proxy. F. Ensure that all services are provided for the participant to which they are entitled when a proxy is serving in their role as proxy.
II. When the proxy presents to the clinic for services, local agency staff will:
A. Accept written notification or a WIC Proxy Form from the WIC participant or presented by the proxy, to designate proxy assignment.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Designation of a Proxy Policy No. CT-800.11 Effective Date: June 26, 2018
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B. Request proof of Identification (ID) of the proxy. C. Request the designated proxy to present the participants WIC ID card. However, if proxy does not have the WIC ID card, the staff should still provide services. D. Will document the use of the proxy in the participant’s electronic record in the notes/comments section or participants health record. Authority 7 CFR § 246.12(r)(1)
Definitions/ Supporting Information
Alternate-Proxy: A person who acts on behalf of the participant or parent/guardian/caretaker of a participant to pick-up and/or redeem vouchers, and attend subsequent certifications, mid/half-certifications, or nutrition education visits on behalf of the participant.
Proxy: Any person designated by a woman participant, or by a parent or caretaker of an infant or child participant, parent/guardian/caretaker of a participant to obtain and transact food instruments or cash value vouchers or to obtain supplemental foods on behalf of a participant.
Food Instruments: Commonly referred to as “vouchers” or “checks”, it is a negotiable financial instrument by which WIC benefits are provided to participants. Food instruments can provide either specific amounts of WIC authorized foods or formulas (vouchers), or a fixed-dollar amount for participants to obtain WIC-approved fruits and vegetables (referred to as a “Cash Value Voucher” or “CVV”).
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Designation of Alternate-Proxy Policy No. CT- 800.12 Effective Date: October 1, 2016
No. of Pages: 3
Revised May 2018
Page 1 of 3
Policy A WIC participant, or a parent/guardian/caretaker of a participant applying for WIC benefits on behalf of an infant or child, may designate an individual to act as their alternate-proxy at the time of enrollment or at subsequent visits. In the event that the participant or parent/guardian/caretaker of a participant is unable to attend WIC appointments; including nutrition education, sub-certification, or mid-year assessment; the alternate-proxy may conduct WIC business on their behalf. The alternate-proxy may also obtain and transact food instruments or cash-value vouchers or obtain supplemental foods on behalf of a participant.
A pregnant, breastfeeding, or postpartum woman participant can only have an alternate- proxy when she, the participant, has a disability that requires an exception to physical presence (See Physical Presence Policy).
Local agency staff may disallow an individual who has misused WIC benefits to serve as an alternate-proxy.
Georgia owners and managers of WIC Authorized retail vendors, are not allowed to serve as an alternate-proxy.
Purpose To minimize barriers for participants to receive WIC benefits by allowing participants and parent/guardian/caretaker of a participant an alternative way to obtain and use food instruments (FIs) or cash value vouchers when they are not available to attend a WIC appointment or unable to redeem their benefits themselves.
Procedures
I. To designate an alternate, local agency staff will:
A. Inform WIC participants of their right to designate individuals to serve as their alternate-proxy for subsequent WIC appointments.
B. Assess the need for an alternate-proxy change at each participant visit.
C. Explain the difference between an alternate-proxy versus proxy.
D. Explain physical presence requirements for a woman to designate an alternate- proxy.
E. Discuss requirements for an alternate-proxy. The alternate-proxy must be:
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Designation of Alternate-Proxy Policy No. CT- 800.12 Effective Date: October 1, 2016
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1. Able to present a valid ID (See Identity Requirements Policy)
2. A responsible person who the WIC participant trusts.
3. Another person in the same household as the participant; ie, grandparent, aunt, older sibling, uncle, other relative, etc.; whenever possible.
4. At least sixteen (16) years old, unless prior approval is obtained from the District Nutrition Services Director or designated Competent Professional Authority (CPA). (All approved age exceptions must be documented in the participant’s record.)
F. Explain that the alternate-proxy must bring/have the following information to represent the parent, guardian or caretaker at recertification:
1. A statement of family size and documentation of participant’s income (Paystub, Medicaid, TANF, SNAP, etc.), residency, and ID for parent and child
2. Signed WIC ID card or written acknowledgement of being an alternate-proxy, or designation within the participant’s record.
3. Knowledge of the participant’s medical history and nutritional habits/normal nutritional intake equivalent to the parent’s
G. Instruct the participant that he/she is responsible for properly training their alternate- proxy on the use of food benefits.
H. Ensure that the participant understands that WIC will be unable to replace any food benefits used improperly or not made available to the authorized WIC person by the alternate-proxy.
I. Ensure that all services are provided for the participant to which they are entitled when an alternate-proxy is serving in their role as alternate-proxy.
J. Inform participant of the ability to utilize online education for upcoming low risk nutrition education contacts.
K. Inform the WIC participant that he/she will be liable for any resulting programmatic violations committed by their appointed alternate-proxy(s)
II. Upon designation of an alternate-proxy local agency staff will:
A. Issue an Alternate-Proxy Letter which explain the alternate-proxy’s responsibilities, to the participant, to give to the alternate-proxy.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Designation of Alternate-Proxy Policy No. CT- 800.12 Effective Date: October 1, 2016
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B. Document designated alternate-proxy(s) name in the participants record.
C. Have the participant ensure the alternate-proxy(s) signs his/her name, in the designated space, on the WIC ID card in participant presence.
III. When the alternate-proxy presents to the clinic for services, local agency staff will
A. Request alternate-proxy present the required documents necessary to obtain vouchers.
B. Ensure the alternate-proxy attends appropriate appointment; ie, certification, sub- certification, or nutrition education (high and low risk) contact for the participant.
Authority 7 CFR § 246.12(r)(1)
Definitions/ Supporting Information
Alternate-Proxy: A person who acts on behalf of the participant or parent/guardian/caretaker of a participant to pick-up and/or redeem vouchers, and attend subsequent certifications, mid/half-certifications, or nutrition education visits on behalf of the participant.
Food Instruments: Commonly referred to as “vouchers” or “checks”, it is a negotiable financial instrument by which WIC benefits are provided to participants. Food instruments can provide either specific amounts of WIC authorized foods or formula (vouchers), or a fixed-dollar amount for participants to obtain WIC-approved fruits and vegetables (referred to as a “Cash Value Voucher” or “CVV”).
Participant: Pregnant women, breastfeeding women, postpartum women, infants and children who are receiving supplemental foods or food instruments or cash-value vouchers under the Program, and the breastfed infants of participant breastfeeding women.
Proxy: Any person designated by a woman participant, or by a parent or caretaker of an infant or child participant, parent/guardian/caretaker of a participant to obtain and transact food instruments or cash value vouchers or to obtain supplemental foods on behalf of a participant.
GEORGIA WIC PROGRAM POLICY AND PROCEDURE MANUAL CT
Documentation and Error Correction Procedures Policy No. CT-800-14
Effective date: October 1, 2016 No. of pages: 1 Revised Date: June 2018 Page 1 of 1
Policy
Official WIC documents must be typed or completed in blue or black non-erasable ink. All corrections and updates must be initialed and dated. Never use pencil, red ink, or correction fluid (white out), nor scratch out or writing over errors. Late entry additions may be added to official WIC documents.
Purpose
To ensure official WIC documents are properly completed, and to standardize how corrections and insertions of additional information on official WIC documents are made.
Procedures
I. To make corrections on an official WIC document the local agencies must: A. Make a single line through the error. B. Initial C. Date D. Make the correction near the line
II. Add missing documentation according to the following procedure: A. Write the words “LATE ENTRY” in caps in the space where the correction needs to be made. B. Make the necessary “LATE ENTRY” documentation. C. Sign your initials and date the change.
Authority
Georgia WIC Program Policy
Definition/Supporting Information
Official WIC Documents - include, but are not limited to: WIC Assessment/Certification forms, ID cards, VOC cards, voucher registers, inventory logs, vouchers, voucher receipts and health records.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Guardianship Policy No. CT- 800.15 Effective date: October 1, 2016
No. of pages: 2
Revised February 2019
Page 1 of 2 Policy
When an infant/child participant has a new primary caregiver, the local agency must document the change in infant’s/child’s WIC record. No WIC services or vouchers can be provided to the original caregiver once the local agency (LA) has been notified of the caregiver change. The LA cannot provide WIC services to the new caregiver until Caregiver’s Statement of Change Form has been completed.
Official documents are not required, however local agency staff may accept a written note from the previous caregiver regarding the change if there is no official documentation. EXAMPLE: Parent leaves the child with a relative/friend for a specified period of time. Local agency staff may accept a signed note from the parent stating the change of caregiver. If a statement is not available (parent incarcerated or cannot be located) use the Caregiver’s Statement of Change Form as documentation.
Purpose To ensure there are no barriers to the issuance of vouchers for infant and children participants who change caregivers during a certification period.
Procedures
I. Have the new caregiver sign a Caregiver’s Statement of Change Form and a Rights and Responsibilities Statement
II. Place the signed documentation in the participant’s WIC record or scan into the front- end system or Georgia Gateway system.
III. Replace an infant/child’s vouchers, as necessary, when the previously issued vouchers were not given to the new caregiver. LA must:
A. Search Georgia WIC Information System (GWIS) for last voucher issuance and voucher redemption.
B. Report the unused vouchers issued to the first caregiver on Lost, Stolen, and Destroyed voucher report.
C. Submit a copy of the report to DXC Technology and the assigned Operations Specialist for the district.
D. Document on the new voucher receipt “Change in Custody” when issuing a replacement set of vouchers to the new caregiver.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Guardianship Policy No. CT- 800.15 Effective date: October 1, 2016
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Page 2 of 2 E. Provide the new caregiver a new WIC ID card.
F. Explain how to use the vouchers and the use of authorized vendors.
Authority 7 CFR §246.12 ¶(r)(1)—Food Delivery Systems O.C.G.A. § 29-2-22 (a)(2)
Definitions/Supporting Information
Caregiver: The parent or legal guardian of an infant or child. A caregiver may also be an individual who is neither a biological or step parent, nor a legal guardian, who provides financial support and care of an infant or child that resides in his/her/their home.
Foster Parent: Volunteers who provide temporary care to children who have been placed in the temporary, legal custody of the local Department of Family and Children Services. Foster parents work as a part of a team to assure that a child’s physical, emotional, medical and psychological needs are met while they are in foster care.
Guardian: An individual who has been granted legal responsibility for a child.
Parent: The biological, adoptive, or stepparent of an infant or child.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Notice of Disclosure Policy No. CT-800.16 Effective date: October 1, 2016
No. of pages: 2
Page 1 of 2
Revised June 2018 Policy Local agencies (LA) must inform applicants/participants and the caregivers of minor WIC applicants/participants of the potential that their information may be shared with other public organizations that administer programs for the purpose of determining eligibility for the other services. LA must explain the Notice of Disclosure (located on the certification form) to participant/alternate-proxy/caregivers and ask them to indicate whether he/she consents or declines to the release of their information at each certification. Participant/alternate- proxy/caregivers must be informed that their decision to share or not to share their information shall not affect their ability to receive WIC services.
Purpose
To ensure compliance with the federal regulations that govern the disclosure of confidential applicant and participant information that is collected by the local agencies that administer the Georgia WIC Program in partnership with the State Agency.
Procedures
I. At each certification the local agency staff must:
1. Allow the applicant/participant to read (or have read to them) the Notice of Disclosure statement.
2. Inform applicants/participants that a decision to not allow their information to be shared with other public organizations will not impact their eligibility to receive WIC benefits and services.
3. Request the applicant/participant or parent/caregiver/guardian/spouse or alternate- proxy parent to initial either the “I Agree” or the “I Do Not Agree” statement on the WIC Assessment Certification Form below the Notice of Disclosure statement or in Georgia Gateway.
II. Document the applicant/participant decision within the Georgia Gateway System or the WIC record by completing the Yes/No answer.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Notice of Disclosure Policy No. CT-800.16 Effective date: October 1, 2016
No. of pages: 2
Page 2 of 2
Revised June 2018
Authority 7 CFR § 246.7(b) 7 CFR § 246.7(d)(2) and (4) 7 CFR § 246.7(h)(3)(i) Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Nutritional Risk Priority System Policy No. CT- 810.01 Effective Date: October 1, 2016
No. of Pages: 3
Page 1 of 3
Policy At each certification, sub-certification, and mid-year assessment the participant will be assigned a priority based on WIC type and risk criteria assigned. Purpose To describe the nutrition risk priority system. Procedures I. At the time of certification, the CPA must assign a priority based on the identified nutrition risk criteria. (Risk Criteria Handbook).
II. Participants are assigned a priority based on their highest priority risk.
III. Reciprocal Risk - A breastfeeding mother and her infant shall both be assigned to the highest priority for which either is qualified.
IV. A participants’ priority cannot be downgraded during the certification period (with the exception of a breastfeeding woman changing status to a post-partum non- breastfeeding woman). For example, an infant that is priority I at the initial certification will remain priority I until their next certification.
V. Priority status can be upgraded at the mid-certification, mid-assessment or half- certification visit if new risk(s) apply that are a higher priority.
VI. NUTRITIONAL RISK PRIORITY SYSTEM Priorities I -VI
A. Each nutrition risk criterion is assigned a priority based on WIC category. Priorities are set in accordance with the following federal guidelines:
1. Priority I: The following applicants with nutrition-related medical conditions. a. Pregnant women
b. Breastfeeding women
c. Infants
2. Priority II: Breastfeeding women who do not qualify under Priority I, but are breastfeeding Priority II infants. a. Infants up to six (6) months of age who do not qualify under Priority I whose mothers were WIC participants during their pregnancy.
b. Infants up to six (6) months of age who do not qualify under Priority I whose mothers were not WIC participants during pregnancy, but had a documented nutritional need.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Nutritional Risk Priority System Policy No. CT- 810.01 Effective Date: October 1, 2016
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3. Priority III: Children under the age of five (5) years with a nutrition-related medical condition. a. Postpartum teenagers who are not breastfeeding.
4. Priority IV: The following applicants with a dietary problem (for example, poor diet).
a. Pregnant women
b. Breastfeeding women
c. Infants
5. Priority V: Children with a dietary problem (for example, poor diet).
6. Priority VI: Postpartum, non-breastfeeding women with nutrition-related condition or dietary problem.
Authority 7 CFR § 246.7(e)(4)
Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Reciprocal Risk- A breastfeeding mother and her infant are assessed as a dyad. Reciprocal risk is a process where a breastfeeding infant’s risk factors are documented on the mother’s certification form and the breastfeeding mother’s risk factors are documented on the infant’s certification form. Priority System – Used to ensure that WIC services and benefits are provided first to participants with the most serious health conditions when funding is inadequate to provide
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Nutritional Risk Priority System Policy No. CT- 810.01 Effective Date: October 1, 2016
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services and benefits to all applicants. When the priority system is implemented, services are provided in number order from one to six based on the roman numeral system I – VI (equivalent number). Priority “I” is the highest priority.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Nutrition Risk Assessment Policy No. CT- 810.02 Effective Date: October 1, 2016
No. of Pages: 2
Page 1 of 2
Policy
All applicants must undergo a nutrition risk assessment by local agency staff who qualify as a Competent Professional Authority (CPA) to be eligible for WIC benefits. CPAs are required to select all nutrition risks that apply to the applicant. The local agency cannot require an applicant to obtain prescribed tests at their own expense. Purpose
To ensure an accurate and thorough determination of WIC eligibility and identification of all nutrition risk.
Procedures I. Competent Professional Authority (CPA) will assess and assign nutrition risks at certification and mid-certification/mid-assessment/ half-certification visits. Nutrition risks identified after the certification is completed will be assessed at the next certification.
II. CPAs must evaluate the applicant’s nutrition status to identify their indicators of nutrition need based on the following approved criteria: A. Anthropometric (height, length, and weight measurements); B. Biochemical (laboratory blood test results); C. Clinical (health, medical conditions, nutrition status, and social factors); and, D. Dietary (food intake).
III. If no nutrition risks are evident, women and children 2-5 years who are otherwise eligible based on income, residency, identification, and category may be presumed to be at nutritional risk and assigned Risk Code 401 (Failure To Meet Dietary Guidelines).
IV. If no nutrition risks are evident, infants 4-12 months and children 12-24 months who are otherwise eligible based on income, residency, identification, and category may be presumed to be at nutritional risk and assigned Risk Code 428 (Dietary Risk Associated with Complementary Feeding Practices).
V. The CPA must document reciprocal risks for the breastfeeding dyad on the breastfeeding mother and her infant at certification and mid-assessment or mid- certification visits. VI. Refer to the current Risk Criteria Handbook for a listing of all risks and their definitions. The risks are listed by WIC type.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Nutrition Risk Assessment Policy No. CT- 810.02 Effective Date: October 1, 2016
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Authority
7 CFR § 246.7 (e)
Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Nutrition Risk – Health problems or habits which put the applicant’s health at risk and which may be improved by the applicant participating in the WIC Program. They may be categorized as anthropometric, biochemical, clinical and/or dietary. Reciprocal Risk – A breastfeeding mother and her infant are assessed as a dyad. Reciprocal risk is a process where a breastfeeding infant’s risk factors are documented on the mother’s certification form and the breastfeeding mother’s risk factors are documented on the infant’s certification form.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Referral Data
Policy No. CT- 810.04 Effective Date: October 1, 2016
No. of Pages: 1
Revised: June 2018 Page 1 of 1
Policy Nutritional risk determination may be based on referral data for anthropometric and hematologic measurements furnished by a health care provider in lieu of measurements obtained at the clinic site. Referral data from the health care provider may be received in written or verbal format. If verbal data is used, the referral source and date the information was obtained must be documented in the medical record.
Purpose To increase clinic efficiency and customer access to WIC services.
Procedures
I. Local agencies must accept the referral data on the Georgia WIC Referral Form or on official letterhead/prescription pad from a private provider, provided that the entire minimum required referral data/information is included. II. Ensure all private provider referral forms contain, at a minimum, the following information: A. Applicant’s first and last name
B. Referral Agency/Medical Provider name
C. Medical Provider contact information
D. Medical/Hematological Data Date(s) when the information is included as part of the referral
III. Local agencies should make the authorized referral form available to area health care providers to facilitate entry into the Georgia WIC Program. Local agencies may not develop their own referral form.
Authority 7 CFR § 246.7 (e)
Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Required Medical Data
Policy No. CT- 810.05 Effective Date: October 1, 2016
No. of Pages: 2
Page 1 of 2
Policy Anthropometric (length/height and weight) measurements are required for all participants at each certification, recertification, and mid-year assessment.
Hematological (hemoglobin/hematocrit) measurements are required for women and children at each certification and recertification, and at the mid-year assessment for children under two years. If a child’s hemoglobin is low at certification, it must be taken again at half-certification. Infants whose initial certification is at or greater than nine months of age are required to have a hematological test. Most infants will have their first blood test around twelve months as part of the first child certification.
Anthropometric and hematological data used to determine the eligibility of pregnant women must be taken during the current pregnancy. Anthropometric and hematological data for postpartum and breastfeeding women must be obtained after delivery.
Purpose To ensure an accurate and complete identification of all nutritional risk conditions used to determine eligibility for WIC benefits.
Procedures I. Anthropometric Data
A. Anthropometric data may be obtained by referral, measurements taken at the clinic site, or from the medical/clinical record.
B. The Medical Data Date required for certification (length/height and weight) may precede the date of certification by up to, or equal to, sixty (60) days. Anthropometric data greater than sixty (60) days old cannot be used to assess WIC eligibility.
C. Verbally reported birth weight and birth length may be used.
II. Hematological Data
A. Hematological results may be obtained by the local agency by referral (See Referral Data Policy), bloodwork screening at the clinic site, or medical/clinical record.
B. Postpartum breastfeeding women who have breastfed for six (6) months are not required to have blood work performed at their mid-Assessment visit.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Required Medical Data
Policy No. CT- 810.05 Effective Date: October 1, 2016
No. of Pages: 2
Page 2 of 2
C. If an infant greater than six months has referral bloodwork, if can be documented in the medical record.
D. The Hematological Data Date required for certification (hemoglobin/ hematocrit) may precede the date of certification by up to, or equal to, ninety (90) days. Hematological data greater than ninety (90) days old cannot be used to assess WIC eligibility.
E. When a participant refuses bloodwork due to medical/religious reasons, attempt to use referral data or non-invasive means to obtain a measurement. If still unable to obtain a measurement, document in the WIC medical record why the bloodwork is missing.
III. Blood work may not be routinely performed on women prior to discharge from the hospital. A non-invasive hemoglobin can be obtained by WIC staff when allowed by the hospital. (See Hospital Certification Policy).
IV. Local agencies should refer participants with low hemoglobin or abnormal screening values to their medical provider per the district local agency protocol for hematological follow-up and diagnosis.
Authority
7 CFR § 246.7(e)
Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Hematological Data Date - The date the hematological data was taken. The Medical Data Date - The date that the anthropometric data was taken.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Health Care Agreements
Policy No. CT- 820.01 Effective Date: October 1, 2016
No. of Pages: 2
Page 1 of 2
Policy The local agency shall enter into a written agreement with other public organizations and health programs that provide services to WIC eligible individuals and families. Purpose To improve access to publicly administered health care programs for WIC applicants and participants in need of such services. Procedures I. If the local agency wishes to disclose confidential applicant and participant information to other public organizations that serve similar populations, the following shall apply:
A. The local agency disclosing the information must enter into a written agreement or memorandum of understanding (MOU) with the other public organization.
B. The MOU must specify that the receiving organization may use the confidential applicant and participant information only for:
1. Establishing the eligibility of WIC applicants or participants for the programs that the receiving organization administers;
2. Conducting outreach to WIC applicants and participants for such programs;
3. Enhancing the health, education, or well-being of WIC applicants or participants who are currently enrolled in such programs, including the reporting of known or suspected child abuse or neglect;
4. Streamlining administrative procedures in order to minimize burdens on staff, applicants, or participants in either the receiving program or the WIC Program; and,
5. Assessing and evaluating the receiving program’s responsiveness to participants’ health care needs and health care outcomes.
C. The MOU must contain the receiving organization’s assurance that it will not use the information for any other purpose or disclose the information to a third party.
II. The local agency must notify the State WIC Office of all agreements and MOUs entered into with other local public organizations and programs.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Health Care Agreements
Policy No. CT- 820.01 Effective Date: October 1, 2016
No. of Pages: 2
Page 2 of 2
Authority 7 C.F.R. § 246.4(a)(16) and (26) 7 C.F.R. § 246.6(b)(3) and (5) 7 C.F.R. § 246.7(b) 7 C.F.R .§ 246.26(d)(2)(ii) 7 C.F.R § 246.26 (h)(3)
Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT National Voter Registration Act (NVRA) Policy No. CT-820.04 Effective Date: October 1, 2016
No. of Pages: 2
Revised: October 2018 Page 1 of 3 Policy Georgia WIC Program local agencies shall distribute a Voter Registration application and a Voter Registration Declaration Statement to all applicants/participants at each WIC certification, recertification, or change of address related to the provision of WIC benefits. This must be done whether in person, electronically, or by phone, facsimile, or mail. An applicant’s/participant’s decision to register to vote, or declination to do so, must be documented. The Voter Registration Declaration Statement shall remain confidential and not be subject to public inspection. If an applicant/participant fails to complete the Statement, then he/she will be deemed to have declined to apply to register to vote.
While an applicant/participant is not required to be a United States citizen to be eligible to receive WIC services, an applicant/participant must be a United States citizen to register to vote. However, NEVER assume a person is or is not a citizen.
Completed voter registration applications received within fifteen (15) days of a voter registration deadline must be transmitted to the Secretary of State by the close of each business day. Failure to comply with the NVRA requirements could result in monetary penalties against an out-of-compliance local agency and the State of Georgia. Failure to comply could also result in enforcement action by the United States Department of Justice.
At no time may a WIC staff person, assisting an applicant/participant with completing a voter registration application, engage in the following behaviors: A. Influence an individual’s political preference or party registration; B. Display any political preference or party allegiance; C. Take any action or making any statement to an individual to discourage interest in registering to vote; D. Take any action or make any statement(s) that may lead the individual to believe that a decision to register or not to register has any bearing on the availability of or eligibility for WIC services
Purpose
To comply with the Congress enacted National Voter Registration Act of 1993 (“NVRA”), requiring states to establish procedures for public assistance applicants and participants to register to vote as designated under Section 7 of the NVRA.
To provide every citizen the opportunity to vote and ensure every citizen is informed of their right to vote.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT National Voter Registration Act (NVRA) Policy No. CT-820.04 Effective Date: October 1, 2016
No. of Pages: 2
Revised: October 2018 Page 2 of 3 Procedures
I. Provide each applicant/participant, with a Voter Registration Declaration Statement and the voter registration application form at each certification, recertification, or change of address related to the provision of WIC benefits.
II. Advise all applicants/participants, regardless of citizenship, that completion of the Voter Registration Declaration Statement is mandatory.
III. Advise all applicants/participants that the voter registration application form may be completed and returned to a member of the local agency staff.
IV. Offer the voter registration application form to all applicants/participants.
V. Inform the applicant/participant the application can be mailed per the instructions on the application if an applicant/participant refuses to complete the voter registration application form in the clinic.
VI. Offer an applicant/participant the same degree of assistance in completing a voter registration application as would be provided when completing WIC-related forms, if an applicant/participant elects to apply to register to vote on-site.
VII. Accept completed voter registration applications and forward them to the Secretary of State at least once per week.
VIII. Maintain Voter Registration Declaration Statements for a period of five years plus current.
IX. Maintain statistical records on the number of voter registrations and declinations for submission to the Secretary of State upon request.
X. Order voter registration supplies by contacting your local County Board of Registrar’s Office. To find your County Board of Registrar’s Office, visit http://sos.ga.gov/cgi- bin/countyregistrarsindex.asp, and select your county. Voter registration applications can be found on the Secretary of State website, at http://sos.ga.gov/index.php/Elections/election_connection.
Authority The National Voter Registration Act of 1993 (NVRA) (52 U.S.C. § 20501 - 52 U.S.C. § 20511) O.C.G.A. § 21-2-222(b)(1).
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT National Voter Registration Act (NVRA) Policy No. CT-820.04 Effective Date: October 1, 2016
No. of Pages: 2
Revised: October 2018 Page 3 of 3 Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Processing Standards Policy No. CT- 830.01 Effective Date: October 1, 2016
No. of Pages: 2
Revised June 2018
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Policy When the local agency is not serving its maximum caseload, the local agency shall accept applications, make eligibility determinations, notify the applicants of the decisions made and, if the applicants are to be enrolled, issue food, cash-value vouchers or food instruments. Special nutritional risk applicants; to include, pregnant or breastfeeding women, infants, migrant farm workers or family members of a migrant farm worker shall be notified of their eligibility or ineligibility within ten (10) calendar days of the date of application. All other eligible applicants must be certified within twenty (20) calendar days. Individuals requesting a transfer into the LA must be given an appointment within twenty (20) calendar days or earlier so program benefits are not interrupted.
The processing timeframes shall begin when the applicant visits the clinic during clinic office hours to make an oral or written request for program benefits. The initial contact date and the processing time frame restarts based on the date the applicant reapplies (appointment is rescheduled). To ensure that accurate records are kept of the date of such requests, the local agency shall, at the time of each request, record the applicant's name, address and the date. Local agencies (LA) must make special provisions when scheduling employed, rural and migrant participants. Appointments for applicants/participants must be provided even when processing standards cannot be met due to a lack of available appointments. Each local agency shall attempt at least three total contacts for a pregnant woman who misses her first appointment to apply for WIC services (CFR 246.7 C.(a) (5). The contact must be made after each missed appointment.
If LA is open less than five days a week and a request for services is received while the clinic is closed, the LA must contact the applicant on the first day the clinic is open after the initial request was made (e.g. MWF clinics: If a participant requested services Monday, due to Tuesday’s closing, the LA first attempt to reach the participant should occur on Wednesday).
Purpose To ensure eligible participants receive WIC benefits in a timely manner. Procedures I. During an applicant’s initial contact: A. Determine the applicant’s category: e.g. pregnant, postpartum, or breastfeeding woman, infant, or child.
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B. Offer an appointment for eligibility determination within the required time frame. C. Record the applicant’s name, address, telephone number, date of request and date of appointment on the Request for WIC Services Log or an approved Initial Contact log. D. Document requests and appointments that are outside of the standard time frame. E. Document the requested appointment date as the initial contact date (ICD) for appointments made over the telephone and walk-in services at the clinic F. Document the date the application was registered by the Clearinghouse as the ICD.
II. Document the following on the Request for WIC Services Log when an appointment is rescheduled: A. Appointment date B. Reason for the change C. Type of contact (phone or mail) D. Initials of the person making the appointment E. New ICD
III. Maintain a Request for WIC Services Log or a state approved method for tracking initial contact dates, appointments scheduled, and missed appointments.
Authority 7 CFR § 246.7 (f) 7 CFR 246.7 C.(a) (5) Definitions/Supporting Information Initial Contact Date (ICD) - is defined as the date the individual first requests WIC benefits face-to-face, through online registration, or by telephone. Break in Service - the period or lapse of time between a valid certification period and the subsequent certification. Date of Application - The date when an applicant visits a local program during clinic office hours to request program benefits. For applicants requesting an eligibility appointment by phone, the date of the first contact, regardless of its method, is the start of the 10/20-day processing time frame. Processing Standards - The time frame during which an applicant is required to be scheduled for an appointment and receive WIC benefits to determine eligibility.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Pre-Registration - Gateway Applications Policy No. CT- 830.02 Effective date: October 1, 2018
No. of pages: 2
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Page 1 of 2 Policy The local agency must monitor their WIC front-end system daily for Georgia Gateway applications that have been pre-processed by the state clearinghouse. The applicant must be contacted within 24 hours of the date and time the notification was received. Local agencies shall receive alerts, from DXC Technology through Vouchers Management and Reporting System (VMARS) IES_ Poll, to process incoming applications. Purpose To provide access to multiple programs (including WIC) on one site and during one application session. Procedures
I. Upon receipt of notification from VMARS, clinic staff must:
A. Review the information in Gateway for missing verifications. B. Contact the applicant/participant by close of business based on the date and time the notification was received and submitted to DXC Technology through Vouchers Management and Reporting System (VMARS).” C. Provide an appointment within processing standard timeframes. (See Processing Standard Policy). 1. Inform applicant of missing verifications (if applicable), to bring with them to their appointment. 2. Make three attempts to reach applicant to schedule appointment, contacts can be made on same day at different times or three different days. 3. Document in the computer or on the copy of the electronic mail all three attempts to contact the applicant to schedule the appointment.
D. Maintain the online email in a physical file or an electronic file at the clinic for the required retention period. E. During applicant/participant’s visit: 1. Ensure all demographic information is correct (name, address, phone, etc.) 2. Verify all required proofs are complete in the system or upload missing proofs 3. Advise participant of rights and responsibilities 4. Advise participant of next steps in eligibility process (anthropometric and hemoglobin/hematocrit measurement, discussion with nutritionist, voucher issuance) 5. Advise participant of area vendors, how to use vouchers, next appointment, how to file complaint, and how to request verification of certification (VOC), if moving
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Authority 7 C.F.R. §§ 246.7(f) (ii) and (iii) Definitions/Supporting Information None
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Processing Standards Reporting Policy No. CT- 830.03 Effective Date: June 2018
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Policy
Local Agencies (LA) must ensure processing standards are met for all applicants/participants. Accurate and timely quarterly Processing Standard Reports (PSR) shall be submitted to the State Agengy (SA). LA must submit a Processing Standards Improvement Plan Form when processing standards are below 90%.
District staff must randomly make covert telephone calls to various local agencies quarterly to assess processing standards. Each district will randomly call clinics in another district, assigned by the Operations unit, to assess processing standards by inquiring of the next available appointment date for each WIC type. The districts will be required to perform these calls twice a month. The results of those calls must be sent to the State WIC Operations office quarterly on the Covert Call Log.
LA shall retain a copy of all information sent to the State for their records. Purpose To provide procedures for LAs to report and monitor processing standards according to Federal Regulations. Procedures I. Submit Processing Standard Reports (PSR) and covert call reports to the State WIC Office (SWO) of Operations assigned Program Specialist quarterly, by the 15th of January, April, July, and October for the previous quarter.
II. Include the following in the PSR:
1. List each clinic name and number 2. If the clinic met processing standards 3. The percentage of appointments that met 4. An explanation if processing standards were less than 90%
III. Calculate processing standards using the number of appointments scheduled minus the number of appointments not meeting processing standard, then divide this total by the total number of appointments.
Example: 2706 – 36 = 2670, 2670/2706 = 98.6%. Explantion of calculation: 2706 (total number of appointments scheduled) - 36 (total number of apppointments not meeting processing standards) = 2670 (total number
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appointments met processing standard), 2670/2706 = 98.6 processing standards percentage.
IV. Submit the quality improvement plan when processing standards are below 90%, including the following: 1. An explanation for not meeting processing standards 2. Strategies developed to resolve the deficiency 3. A targeted timeline the task/strategies will be completed 4. The position responsible for each task 5. Next steps to ensure compliance with meeting processing standards
V. Request technical assistance with planning, as deemed necessary.
Authority 7 CFR § 246.7 (f) Definitions/Supporting Information Initial Contact Date: is defined as the date the individual first requests WIC benefits face-to- face, through online registration, or by telephone. Processing Standards- The time frame during which an applicant is required to be scheduled for an appointment and receive WIC benefits to determine eligibility.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Processing Standards Extension Request Policy No. CT- 830.04 Effective Date: June 2018
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Policy
Local agencies may request, in writing to the state office, a temporary extension of processing standards from the ten (10) day standard to a maximum of fifteen (15) days when processing cannot be met due to staff shortages, clinic closure due to declared weather emergencies, other special circumstances approved by the State Agency (SA).
Upon approval of an extension, the State WIC Office may request the Local Agency (LA) to submit a processing standards improvement plan (see Processing Standards Improvement Plan Form).
Purpose To provide a method for local agencies to request an extension to processing standards when certain circumstances prevent meeting the guidelines.
Procedures I. Submit a written request to extend processing standards including the following information: 1. An explanation of the need for an extension 2. An estimated length of time for the extension, up to 15 days
II. When requested, submit a Processing Standards Improvement Plan (see Processing Standards Improvement Plan Form) to include: 1. Reason- What caused the deficiency? How Frequent is it occurring? 2. Strategies/Activites Expected Outcomes- Describe the tasks and/or steps developed to resolve the deficiency, (ex: extended hours when clinic re- opens, added more appointment slots, re-train staff, etc). Describe the districts expected outcomes at each interval. 3. Position Responsible- The position responsible for the activity (ex: Clinic, District, NSD, Supervisor, etc) 4. Targeted Timeline- The targeted task completion date for each strategy. 5. Task Accomplished- Yes/No 6. Next Steps- How does the district plan to monitor the tasks/steps taken have resolved the deficiency
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Authority 7 CFR § 246.7 (f) Definitions/Supporting Information Initial Contact Date: is defined as the date the individual first requests WIC benefits face-to- face, through online registration, or by telephone. Processing Standards- The time frame during which an applicant is required to be scheduled for an appointment and receive WIC benefits to determine eligibility.
CT GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL Certification Period Effective Date: October 1, 2016 Policy No. CT- 840.01 No. of Pages: 3 Revised October 2018 Updated March 2020 Page 1 of 3
Policy
The duration of a certification period is based on the participant’s category. The local agency (LA) must notify the participant either verbally or in writing of the length of their certification period and provide notification to each participant not less than 15 days before the expiration of each certification period (30 days for a homeless participant) that their eligibility to receive program benefits is about to expire. The certification period always begins with the date of certification and ends on the termination date for the participant category (see Certification Period Guidelines). WIC benefits will be provided to participants in accordance with the timeframes defined by federal regulations for each category.
The certification period may be shortened or extended by a period not to exceed thirty days for infants and children. A breastfeeding woman’s certification period may be shortened only if breastfeeding ceases, at which time the participant must be transitioned to a postpartum non- breastfeeding certification if less than six-months postpartum or terminated from the program if more than six-months postpartum.
Purpose To identify the length of time program participants are eligible for WIC benefits. To define WIC certification periods based on participant category and require client notification prior to expiration of the participant’s certification period.
Procedures
I. Begin certification periods on the date the applicant is determined eligible for benefits. Designate certification periods for eligible participants for the full allowable period.
II. Shorten the certification period if a participant is later disqualified from the program (e.g., increased income) prior to expiration of the certification period.
III. Ensure that participants are placed in the correct WIC type and receive recertification/renewal at the correct interval.
IV. Certify a pregnant woman for the duration of her pregnancy and/or up to six weeks postpartum. EXAMPLE: Expected delivery date: 11/22/18 Date infant is six weeks old: 01/03/19 Certification expiration date: 01/03/19 The benefits issued between delivery and six weeks postpartum may be issued before OR at the time of the postpartum screening.
CT GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL Certification Period Effective Date: October 1, 2016 Policy No. CT- 840.01 No. of Pages: 3 Revised October 2018 Updated March 2020 Page 2 of 3
V. Certify postpartum woman who is not breastfeeding through six months postpartum. Certification shall expire on the day her infant is six months old. EXAMPLE: Delivery date: 11/22/18 Certification action date: 12/01/19 Certification expiration date: 05/22/19
VI. Certify a breastfeeding woman (exclusively, mostly or some breastfeeding) for a 12- month period or until breastfeeding is discontinued. The woman’s certification shall expire the day before the infant's first birthday, or the day the woman stops breastfeeding. EXAMPLE: Delivery date: 11/22/18 Certification action date: 01/05/19 Certification expiration date: 11/21/19
A. If a woman discontinues breastfeeding before six months postpartum, for continuation of certification, her category, risk conditions (if applicable) and food package code need to be changed in the front end system so she may participate as a postpartum woman. If her eligibility was based solely on breastfeeding risk conditions, staff shall assign risk code 401, Failure to Meet Dietary Guidelines for Americans, and the woman shall be issued postpartum benefits. B. If a woman discontinues breastfeeding after six months postpartum, she is no longer categorically eligible. Staff shall void any remaining benefits for which she is not eligible to receive, and she shall be terminated in the frontend system.
VII. Certify a child, up to age five, for a 12-month period ending on the last day of the twelfth month. EXAMPLE: Certification action date: 12/14/18 Certification expiration date: 12/31/19 For a child turning five years of age, their eligibility will expire at the end of the month in which the child reaches his/her fifth birthday. EXAMPLE: Child’s fifth birthday Certification action date: 01/25/19 Child’s fifth birthday: 03/19/19 Certification expiration date: 03/31/19 If a child is certified in the month of his/her fifth birthday, the certification must occur before the birth date in order for the child to be eligible for benefits. This includes initial and subsequent certifications. EXAMPLE: Child certification in fifth birthday month Child’s fifth birthday: 03/19/19 Certification action date: 03/18/19 Certification expiration date: 03/31/19
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VIII. Certify an infant, younger than six months at the time of initial enrollment, up to his/ her first birthday. Certification shall expire on the day prior to the infant's first birthday. EXAMPLE: Date of birth: 11/22/18 Certification action date: 04/10/19 Certification expiration date: 11/21/19
IX. Certify an infant, six months or older at the time of initial enrollment, for a six-month period ending on the last day of the sixth month. EXAMPLE: Date of birth: 11/22/18 Certification action date: 07/11/19 Certification expiration date: 12/31/19
X. Revise the participant’s priority ranking when the participant’s category changes at mid- certification.
Authority
7 C.F.R. § 246.7(g) and (j)(8)
Definitions/Supporting Information Certification - The use of criteria and procedures to assess and document each applicant’s eligibility for the program. Certification Date - Date that client was certified or recertified into the WIC Program and eligible to receive checks and nutrition education. Certification Expiration Date - The last day of the certification period and the last day the participant shall receive benefits. Certification Period - The period of time during which a participant is eligible to receive program benefits.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Thirty Day Policy Policy No. CT- 840.02 Effective Date: October 1, 2016
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Policy A thirty (30) day temporary certification period exists when a participant or existing client/caregiver does not provide proof of client identity, residency, or income (or cannot be verified by staff as adjunctively eligible) but a WIC staff member has determined that the participant meets all other eligibility criteria. One month of benefits may be issued. If the participant provides all proofs within the thirty-day period and is determined to be eligible, the participant is certified for the full certification period, beginning with the date that the WIC benefits were initially provided. If the participant fails to provide the proof within the thirty-day time limit or provides proof and is found to not meet eligibility criteria, the individual shall be determined ineligible. Under no circumstances can a second, subsequent thirty-day certification period be used if the participant fails to provide the required proof. If that same person returns after the thirty-day period, the certification expires, and a new eligibility determination must be conducted. A new initial contact date must be documented for all terminated thirty-day participants. Purpose To minimize barriers and allow time for participants to obtain documentation for program eligibility. To increase participation and provide good customer service.
Procedures I. If a participant ’s eligibility is pending due to an inability to provide proof of identity, residency, or income at the time of the certification appointment, the local agency (LA) must: A. Complete and issue a Thirty (30)-Day Temporary Certification Form
B. Issue one month of vouchers
C. Issue a WIC ID card
D. Provide WIC services as needed during the thirty (30) day grace period
E. Schedule the participant for voucher pick up for the following month and ask them to bring in the missing proofs at that time or at an earlier time as determined by the local clinic.
F. Explain to the individual that they have thirty (30) days to bring in the missing proof(s) and/or risk being removed from the program for failure to bring in the acceptable proof by the given date.
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G. Explain to participant, they may be terminated, if the information provided indicates that they are ineligible for the program. II. When the participant provides the required proofs within the thirty-day timeframe and is determined eligible: A. Enter the participant’s updated proof code and date in the “UP” field on the printed certification form and send an update transaction Turnaround Document (TAD) to DXC Technologies.
B. Update the in information by changing the “verified on” date in Georgia Gateway for the missing verification and updating the verification field (see Verification Checklist job aid in Gateway).
C. Rerun Eligibility Determination Benefit Calculator (EDBC) and authorize case.
D. Change interval code (if applicable), to issue three months of benefits. III. When the participant provides the proof within the thirty-day period and is found to not meet the eligibility criteria, the LA shall terminate the individual from the program. IV. When the participant returns the information after the initial thirty-day period, the LA must A. Start the certification process over and request current residency and income information due to the certification expired and a new eligibility determination must be conducted. B. Ensure the income documentation presented is within the current thirty-day period. For example, the participant may not have provided income verification at certification but did not return with the proofs until ninety days later. C. Enter the new income in Georgia Gateway and re-run the Eligibility Determination Benefit Calculator (EDBC) to update the income. Authorize case. D. Document new initial contact date for all terminated thirty-day participants. E. Complete certification process and issue vouchers.
Authority 7 C.F.R. § 246.7(c)(2)(i), 246.7(d)(1)(v), and 246.7(i). Reference: Federal WIC Policy Memorandum #2013-3
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Definitions/Supporting Information Proofs: Reasonable documentation of personal identity, income and current residency as approved by the state WIC program or local coordinators. Thirty (30)-day Temporary Certification - exists when an applicant or existing client/caregiver does not provide proof of client identity, residency, or income (or cannot be verified by staff as adjunctively eligible) but a WIC staff member has determined that the applicant meets eligibility criteria based on reported information.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT WIC Certification Form Policy No. CT- 840.03 Effective date: October 1, 2018
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Policy State WIC certification data for each applicant/participant will be recorded on the certification form provided by the State agency or entered in the District’s computer system. Paper certification forms may be used to certify applicants only when the computer system is inoperable, for a hospital, or home certification. Information gathered on a paper certification form must be entered in the electronic record within twenty-four hours of certification or of the system being operable. All eligibility data for each person certified for WIC shall be recorded on the appropriate forms. The forms shall be maintained on file in each participant's or family’s health record.
Purpose To document the eligibility of each participant. To increase participant access to services when the approved computer system is inoperable or inaccessible.
Procedures I. Print a copy of the certification form for each certification or mid-year assessment completed in the district’s computer system.
A. Collect required signatures and initials.
B. File the form in the participants record or scan the form into the participant’s record.
II. Reference Prenatal Certification Form, Breastfeeding Certification Form, Non- Breastfeeding Certification Form, Infant Certification Form, and Child Certification Form.
III. The Local Agency (LA) shall determine where the forms shall be maintained in the record which should include, but not limited to: 1. Certification Form; 2. Signed copy of Rights and Responsibilities 3. Income Questionnaire Form; and 4. Required proof documentation 5. Diet History Questionnaire 6. Appropriate Growth Charts 7. Physical presence waiver form, if applicable
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IV. A supply of paper certification forms must be kept on hand for each WIC category for emergency purposes.
Authority 7 C.F.R. § 246.7(i) Georgia WIC Program Policy Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Hospital Certifications
Policy No. CT- 840.04 Effective Date: October 1, 2016
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Policy
Hospital clinics are responsible for certifying newborn infants delivered on site and their mothers. Women and infants who are certified in a hospital must be transferred to a receiving clinic for follow-up WIC appointments and services. Any food package changes made after a participant’s discharge will be made at the receiving clinic. It is the responsibly of the receiving clinic to provide breastfeeding follow-up according to state and district standards. Purpose
To facilitate the certification of newborn infants, non-breastfeeding postpartum women, and breastfeeding mothers at the earliest possible date and to ensure the mother/baby breastfeeding dyad is processed as a unit. Procedures
I. WIC staff may use the hospital medical record to obtain the identification (ID), residency, weight, heights and hemoglobin. If WIC staff do not have approval to access the hospital medical record, then WIC staff can receive a list (daily) of patients which contains the information needed to certify each patient (e.g., name, age, lab data, etc.).
A. Record Medical Record (MR) on the certification form for proofs obtained from the hospital medical records.
B. If access to an individual’s hospital medical record is not permitted; identification, residency and income information may be brought to the hospital by an applicant/participant. Proofs received from the applicant/participant must be copied and date stamped.
C. If a paper Certification Form is used for certification, file it in the WIC record. Once the certification information is entered into the computer, do not print an additional computer Certification Form.
D. When the participant’s hemoglobin/hematocrit was unavailable at the hospital, the receiving clinic must complete bloodwork at the next voucher pick-up. The hospital clinic must inform the participant of this requirement and note it on their WIC ID card.
II. WIC participant ID numbers for hospital certification are assigned using the hospital clinic number, unless the participant is a transferring participant. The clinic staff must
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search for each new or transferring participant on GWISnet.com before issuing a new WIC ID number. When adding an additional family member to an existing WIC family, the hospital clinic number must be used for tracking purposes and to ensure a duplicate WIC ID number is not given.
III. If the mother is currently receiving WIC services:
A. The hospital clinic will transfer her into their clinic and complete the certification.
B. The hospital clinic will verify voucher issuance in GWIS.
C. If the participant has received vouchers for the current issuance period, the hospital clinic can void all issued food packages and issue the new food package. New vouchers should not be issued if the original vouchers are not available to be voided.
D. If the vouchers are not available to be voided, the new food package can begin with the next month’s vouchers.
E. The hospital clinic must instruct the participant to return the previously issued vouchers for a current food package or allow the participant to retain the vouchers and schedule the next voucher pickup for the new food package. This must be noted on the WIC ID for the receiving clinic.
F. Both the hospital clinic and the receiving clinic verify that all previously issued vouchers are voided prior to re-issuance
IV. Only one (1) month of vouchers may be issued to those certified at a hospital clinic.
V. Vouchers to be issued in the participant’s hospital room must be stored in a locked container until issued.
VI. When transferring the participant to a clinic within the state, an EVOC or a copy of the certification form can be given to the participant. A termination notice is not given unless the participant is transferring out of state.
VII. Receiving clinics should have procedures for transferring mothers and babies into their clinics and providing appropriate follow-up. The procedures must include checking GWIS for voucher issuance, dual participation, and correct WIC numbers.
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VIII. The participant is given a follow-up appointment at the clinic of their choice. They should be provided with the name and phone number of the WIC clinic they wish to enroll in. To accommodate mothers delivering outside their home district, the hospital clinic should work with the receiving clinic when scheduling the next visit. This could be a standard time (i.e. Mondays 9-11).
IX. Evaluation of Inappropriate Nutrition Practices and completion of Growth Chart are both optional for newborns certified at hospital clinics.
Authority 7 C.F.R. § 246.6(f)
Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Foster Care Policy No. CT- 840.05 Effective date: June 26, 2018
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Policy
Foster children shall be certified eligible for WIC Program benefits according to age, residency, income, nutritional risk requirements and physical presence. Children left in the care of a family member or friend are not considered foster children unless DFACS is involved.
The LA must process all foster care referrals provided to them by the Clearinghouse staff from Gateway foster care referrals. Infants and children placed by DFACS with a relative, close family friend or others who have a long-standing relationship with the infant/child may be screened utilizing thirty-day procedures if the DFACS placement letter is not available.
A foster child shall be considered a one-person household. Money received from any outside source for the care of the child, such as Social Security payments shall be considered as income. If a relative does not receive any money for the care of the child, the child’s income will be zero. Verification is not required at subsequent certifications if the child remains in the same foster home.
Purpose To ensure there are no barriers to the issuance of vouchers for infant and children participants who are placed in foster care. To ensure individuals at nutritional risk receive program benefits.
Procedures
I. Obtain verification of placement by the clearinghouse staff at initial certification. II. Accept written or verbal verification. III. Document the DFACS contact name and phone number in the foster child’s file. IV. Place the signed documentation in the participant’s WIC record or scan into the front-end system or Georgia Gateway system. V. Issue the foster child a WIC ID Card, which is separate from the foster family. VI. Issue a separate WIC ID Card for multiple foster children, including siblings, residing in the same foster home. VII. Replace an infant/child’s vouchers, as necessary, when the previously issued vouchers are not given/transferred over to the new caregiver, using the guidelines below:
A. Report the unused vouchers issued to the first caregiver on the Lost, Stolen, and Destroyed voucher report.
B. Submit a copy of the report to DXC Technology and the state WIC office.
C. Document on the new voucher receipt “Change in Custody” when issuing a replacement set of vouchers to the new caregiver.
D. Provide the new caregiver a new WIC ID card.
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VIII. Issue vouchers in one month increments to the foster parent if placement is changed and the new foster parent does not have the placement letter.
Change in Foster Homes
I. Follow the below procedures when a participant is removed from a foster home and is reunited with his/her parent(s): A. Request the parent present the child at the WIC appointment or provide written documentation from DFACS or former guardian. B. Obtain and document the contact information of the staff providing the verbal verification, when applicable. C. Always Check Georgia WIC Information System (GWIS) before issuing vouchers. D. Complete the Caregivers Statement of Change form. E. If the child was issued benefits for the current month while in foster care: 1. Schedule an appointment for the following month. 2. Reassess income, unless there is 90 days or less before the expiration of the certification period. 3. Require the caregiver to provide acceptable written documentation of the household income or eligibility in a Gateway program at the next appointment, and issued one month of benefits. F. If the child’s certification has expired, determine if the individual is income eligible according to the Income Policy.
II. Follow the below procedures if the foster child is later adopted: A. Accept current Medicaid verification as income even if it continues to list the foster child's name rather than the adoptive name. B. Use Medicaid eligibility as income for the other household members per the Adjunctive Eligibility policy if the adopted individual is an infant or pregnant woman. C. Do not reassess income if the child has an active certification period. D. Process the certification as an in-state transfer and issue benefits. E. Schedule an appointment for the following month. F. Add the child to the adoptive family’s record and issue benefits, if the family is currently participating in the WIC program. G Create a record and issue a WIC ID Card for the adoptive family, if the family is not participating in the WIC Program. H. Allow the adoptive family to redeem the remaining benefits, if the child was previously issued benefits for the current month.
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Authority 7 CFR §246.12 (r)(1)—Food Delivery Systems O.C.G.A. § 29-2-22 (a)(2)
Definitions/Supporting Information
Caregiver: The parent or legal guardian of an infant or child. A caregiver may also be an individual who is neither a biological or step parent, nor a legal guardian, who provides financial support and care of an infant or child that resides in his/her/their home.
Foster Parent: Volunteers who provide temporary care to children who have been placed in the temporary, legal custody of the local Department of Family and Children Services. Foster parents work as a part of a team to assure that a child’s physical, emotional, medical and psychological needs are met while they are in foster care.
Parent: The biological, adoptive, or stepparent of an infant or child.
Foster Child: – any child placed through the Georgia Department of Family and Children Services (DFACS). A child returning to his/her parent shall not be considered a foster child.
DFACS placements include: a. Foster family home or group home that has been either trained and verified by DFACS. b. Residential group care facility that has been licensed by DFACS; or a facility under the authority of another state agency. c. Infant or child placed with a relative, close family friend or others who have a long-standing relationship with the infant/child.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Separation of Duties Policy No. CT- 840.06 Effective Date: October 1, 2016
No. of Pages: 2
Revised: June 2018 Page 1 of 2 Policy
Local Agency (LA) staff members cannot complete any portion of the certification process or issue food benefits to themselves, relatives, or friends. One employee cannot be solely responsible for determining the eligibility of an applicant for all the certification requirements (income and risk criteria). Food benefits can be issued by either of the individuals responsible for determining eligibility or a third individual.
LA that operationally needs to be staffed by only one employee must be approved by the State Agency (SA). In the event that one person must complete the certification process alone due to an emergency situation (absence or sickness of staff) state approval is not required but must be informed.
Local Agencies are required to report questionable certifications and benefit issuance to the participant and/or staff fraud to the State Agency within the same work week the issue is identified.
Purpose To ensure program integrity and prevent program abuse.
Procedures
I. The Nutrition Services Director or his/her designee may grant prior approval for an individual to certify a relative or friend in special situations.
II. Monitor participant records when one staff person completes the certification alone or certifies a relative, compromising integrity, requiring an individual other than the certifier (e.g. the Nutrition Service Director) to using the following process:
A. Conduct a post review of all non-breastfeeding infant certification records.
B. Review at least 20 percent of the remaining certification records within two (2) weeks of the certification.
C. Complete the Separation of Duties Form (see Separation of Duties Form) within three (3) days of certification and submit to Operations Unit Specialist.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Separation of Duties Policy No. CT- 840.06 Effective Date: October 1, 2016
No. of Pages: 2
Revised: June 2018 Page 2 of 2 D. Maintain on file documentation of the completed Separation of Duties Form and district review at the district office.
III. Develop and maintain on file procedures to reduce the number of certifications completed without Separation of Duties and reduce the risk of fraud when someone must certify a relative or complete the entire certification process themselves. Procedural options may include, but are not limited to the following:
A. Rotate staff
B. Use video conference for a portion of the certification
IV. Promptly remove any Local Agency employee suspected to be abusing the Georgia WIC Program from WIC certification or benefit issuance until the investigation is completed.
Authority 7 C.F.R. § 246.4(a)(27) WIC Policy Memorandum #2016-5 Definitions/Supporting Information Food Instrument- “Food instrument” or “FI” means a negotiable financial instrument by which WIC benefits are provided to participants. Food instruments can provide either specific amounts of WIC authorized foods or formulas or a fixed-dollar amount for participants to obtain WIC authorized fruits and vegetables (referred to as a “Cash Value Voucher” or “CVV”). Food instruments are also referred to as “checks” or “vouchers.” Cash Value Vouchers are also referred to as “Fruit and Vegetable Vouchers.” Separation of Duties- A standard accountability/security practice to separate eligibility assessment (intake) and risk assessment from food instrument issuance responsibilities between more than one person.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT WIC Overseas Program
Policy No. CT- 840.07 Effective Date: October 1, 2016
No. of Pages: 2
Revised October 2018 Page 1 of 2
Policy
WIC participants affiliated with the military who are transferred overseas and meet eligibility requirements are eligible to participate in the WIC Overseas Program until the end of their certification period.
WIC participants issued a Verification of Certification (VOC) must be instructed that:(1) there is no guarantee that the WIC Overseas Program will be operational at the overseas site where they will be transferred, (2) by law only certain individuals are eligible for the WIC Overseas Program, and (3) issuance of a WIC VOC does not guarantee continued eligibility and participation in the WIC Overseas Program. WIC clinics must issue a Verification of Certification to WIC participants affiliated with the military who will be transferred overseas.
Clinics should ensure that all VOC’s issued are thoroughly completed.
Purpose To provide guidelines for accepting a valid WIC Overseas Program VOC card and to describe the process of providing WIC benefits to eligible applicants living abroad through the Department of Defense.
Procedures
I. Provide services to WIC Overseas Program participant who returns to the U.S. with a valid WIC Overseas Program Verification of Certification (VOC) card.
II. Follow the same procedures outlined in Transfer of Certification Policy when completing the EVOC or VOC card for a transfer overseas.
III. Place special emphasis on completing the EVOC cards with the necessary data to prevent long distance overseas communications.
IV. Accept a valid WIC Overseas Program VOC card presented at a WIC clinic by WIC Overseas Program participants returning to the U.S. from an overseas assignment.
A. Follow the current procedures outlined in Transfer of Certification Policy.
B. Use list of WIC Overseas Program Contacts (see WIC Overseas Program Contacts) if questions arise about the VOC card presented.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT WIC Overseas Program
Policy No. CT- 840.07 Effective Date: October 1, 2016
No. of Pages: 2
Revised October 2018 Page 2 of 2
C. Request proof of residency and identification in accordance with WIC regulations and policies.
V. Visit the TRICARE Website at: http://www.tricare.mil/wic/ for locations and additional information about DOD’s WIC Overseas Programs.
VI. Inform participants to contact their base to determine continued eligibility.
Authority
United States Department of Agriculture (USDA) – Food and Nutrition Services (FNS) WIC Policy Memo 2016-4, Verification of Certification
Definitions/Supporting Information
Dependent - includes a spouse and “U.S. national” who are U.S. citizens or individuals who are not U.S. citizens but owe permanent allegiance to the U.S. as determined in accordance with the Immigration and Nationality Act.
Participant Profile Report/VOC Card-The Department of Defense (DOD) WIC Overseas Program Verification of Certification (VOC) card, which also serves as a participant profile report (see DOD WIC Overseas Program VOC Card).
WIC Overseas Program- An overseas program like WIC implemented by the Department of Defense using DoD funds for active duty military personnel, civilian employees and contractors of the DoD living overseas, or their family members, who are eligible for WIC.
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Video Certification Policy Policy No. CT- 840.08 Effective Date: October 1, 2016
No. of Pages: 3
Revised October 2020
Page 1 of 2
Policy Districts/clinics must use the WIC Telehealth Network to provide Video Certification services. Local agency must ensure clinics coordinate efforts between Participant site(s) and the CPA site(s) to schedule and complete video certifications. The participant can be located at the CPA site or the Clerical site to receive video certification services. Local agency must ensure Separation of Duties policy is followed for video certifications. Purpose
The purpose of Video Certification is to allow an applicant/participant visiting the local county health department to receive WIC certification services through the WIC Telehealth Network.
Video Certification is intended to: • Increase participant access to certification services • Increase productivity by allowing CPAs and clerical staff to support more than one clinic site at a time • Expand available service hours for certification services • Improve access to WIC staff • Increase the number of participants that can be certified and provided nutrition education • Reduce the number of hours and cost of employees traveling from one location to another
Procedures I. The CPA site will: A. Review or complete the nutrition questionnaire. B. Review applicant/participant data (i.e., anthropometric data, medical record / history, medical documentation forms, etc.). C. Complete the WIC certification while following state policies (including risk assessment, provision of nutrition education, documentation of goals, and assign food package, etc.). D. Check the “certification completed by videoconference box” as “yes” and enter their full name and credentials in the box provided in order for “certification completed by videoconference” to be printed on the certification form.
II. The Clerical Site will: A. Complete the WIC Certification while following state policies (including income eligibility, rights and obligations, etc.). B. Schedule follow-up appointment(s).
GEORGIA WIC PROGRAM PROCEDURES MANUAL CT Video Certification Policy Policy No. CT- 840.08 Effective Date: October 1, 2016
No. of Pages: 3
Revised October 2020
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III. The Participant Site (site where the participant is located) will: A. Assist in the coordination of clinic flow (i.e. moving participant from the waiting room to the Video Certification room to voucher issuance/scheduling). B. Complete anthropometric measurements or enter referral data into the WIC system. C. Print completed certification form and have the participant review and sign all required forms. D. Issue benefits based on assigned food package.
Authority Georgia WIC Program Policy
Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials. Clerical Site – Site where clerical staff are located. CPA Site – Site where CPA staff are located. Participant Site – Site where the participant is located. This can be the “Clerical Site” or the “CPA Site”. Full Name – First name and last name or first initial and last name. Video Certification - is the method in which a participant is certified and becomes eligible for the WIC program via the Georgia WIC Telehealth Network services.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Transfer of Certification
Policy No. CT- 850.01 Effective Date: October 1, 2016
No. of Pages: 5 Revised: March 2019
Page 1 of 5
Policy
Electronic Verification of Certification (EVOC) cards are the official documents for validating WIC certification nationwide (see Electronic Verification of Certification (EVOC) Card). Local agencies (LA) must provide an Electronic Verification of Certification (EVOC) card to every participant who is a member of a migrant family, and any other participant who is likely to relocate during a certification period (7 CFR § 246.7(k)(1).
The participant must be allowed to continue to receive services throughout their original certification period even if the participant does not meet the receiving agency’s nutritional risk, priority, or income criteria. If the receiving agency is at maximum caseload, the transferring participant must be placed at the top of any waiting list and enrolled as soon as possible.
Under no circumstances should a WIC participant transferring into a clinic with a valid Verification of Certification (VOC) card be denied WIC benefits or reassessed for eligibility. When an applicant transfers in with a VOC card, the parent, guardian, or caregiver is not required to bring the infant or child. An alternate-proxy can present VOC or transfer information for the participant. Participants are not required to sign a release of information to request or share VOC information with other state or local agencies. WIC information retrieved from other WIC programs is considered confidential information and may only be used for WIC purposes. Child Nutrition Act requires that an eligibility certification remain valid for the period for which an individual was originally certified, specifically if that participant moves from one area of WIC operations to another. The LA may conduct a recertification for the convenience of the participant if a VOC is presented to a clinic and the certification will expire soon (within the next 30 days). The LA is not required to do a mid-certification income reassessment, and the participant may receive the remainder of the benefits for that certification period (7CFR 246.7 (h)(1)(i)) if the transferring participant reports a change in income within the last ninety (90) days of the certification period. The participant must not be denied service if they do not have this information. 1. Local agencies are not allowed to establish minimum length of residency requirements or waiting periods. 2. The local agency may accept a written statement from the participant using the No Proof form if a participant is unable to provide documentation.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Transfer of Certification
Policy No. CT- 850.01 Effective Date: October 1, 2016
No. of Pages: 5 Revised: March 2019
Page 2 of 5
Purpose To ensure seamless and continued participation of certified participants for the period for which an individual was originally certified through the entirety of their certification period. Protecting WIC program integrity is also important for the implementation of the VOC policy.
Procedures Districts shall establish procedures to ensure other WIC clinics obtain the information needed to complete an in-state/out-of-state transfer. I. Provide an EVOC to every participant who is likely to relocate during a certification period and every member who is a participant of a migrant family.
II. Print two copies of the EVOC Card on regular white 8 ½ x 11 paper 1. Give the first signed copy to the participant. 2. Place the second signed copy in the medical record or EVOC card file. 3. Stamping the EVOC card is no longer required.
III. Ensure participants know and understand the availability, process and purpose of an EVOC by:
1. Describing the EVOC process during the explanation of Rights and Responsibilities.
2. Posting signs for participants to request an EVOC if they are planning to move before their next certification appointment and providing a flier for the participant to take as a reminder. (See EVOC Poster)
3. Routinely asking the participant if they plan to move during their certification period (during voucher pickup).
IV. Issue A Notice of Termination Form on site when an EVOC card is issued to a participant, with the exception of a migrant participant and participants transferring from Grady Hospital District (see Notice of Termination Form in English or Spanish). If the participant is issued a termination notice and has vouchers that can be used before the participant is scheduled to relocate, do not submit the termination to DXC Technologies until after the scheduled move date.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Transfer of Certification
Policy No. CT- 850.01 Effective Date: October 1, 2016
No. of Pages: 5 Revised: March 2019
Page 3 of 5
V. Document “Thirty Day”, the Thirty Day return date and the missing proof information on the EVOC card to alert the next clinic of the incomplete certification due to missing information. VI. Provide a copy of the current Medical Documentation Form (MDF) to the participant, when applicable. VII. Include the below information as VOC/EVOC content:
a. Name of participant b. Date certification was performed c. Date income was determined d. Nutritional risk of participant e. Date certification expires f. Signature and printed name of local agency official g. Name, address, and phone number of local agencies h. WIC ID number i. Last date Food Instruments/benefits were issued (not required but encouraged)
VIII. Accept an incomplete VOC/EVOC card as long as the certification period has not expired, and the card contains:
1. Participant’s name 2. Date of certification 3. Date certification expires 4. Name and address of the certifying agency
IX. Verify any questionable information and retrieve any missing information by contacting the sending agency. X. Assign risk 502 can be used to complete the transfer, if the VOC card does not contain a nutritional risk condition, XI. Follow the below steps when transferring participants without a VOC/EVOC Card
1. The receiving clinic will call the original clinic and obtain all necessary information required to complete the transfer process in the absence of a VOC Card. 2. The original clinic must send a signed copy of the current Certification form to the receiving clinic within twenty-four (24) business hours in the absence of a VOC Card. 3. For an in-state transfer, the clinic staff must perform a search on Georgia WIC Information System (GWIS.net) to obtain current participant information to transfer the participant into the clinic in the absence of the VOC card. 4. If WIC clinic staff is unable to obtain the necessary information by phone or by accessing GWIS.net for a Georgia participant, a valid Georgia WIC Program ID card may be accepted in lieu of a VOC card, with proper ID.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Transfer of Certification
Policy No. CT- 850.01 Effective Date: October 1, 2016
No. of Pages: 5 Revised: March 2019
Page 4 of 5
5. A participant who is transferred using a Georgia WIC Program ID card will be issued vouchers for one (1) month. a. Prior to the next issuance, clinic staff must contact the certifying clinic for certification information. b. All transfer certification information must be in the participant record within two (2) weeks of the transfer. If VOC information is obtained via phone call, all information must be documented in the participant’s health record and followed with the written documentation within two weeks.
XII. The LA must not require a participant who is transferring to a different clinic within the district to present residency, income, or identification if the participant brings in a valid EVOC card or WIC ID card. Staff must update the new address in the frontend system and send an update Turnaround Document (TAD) to DXC Technologies.
XIII. The LA must ensure the below procedures are completed when an out of state participant transfers into their clinic:
1. Request participant surrenders any unused food instruments (FIs) or Electronic Benefit Transfer (EBT) cards from the previous agency in their possession, however do not be deny benefits if the FIs are not in the participants possession. 2. Give an explanation to the participant for any differences in authorized supplemental foods, e.g. a different contract formula. 3. Securely destroy all food instruments or EBT cards retrieved from the transferring participant. 4. Provide a food package that ensures the participant receives the maximum monthly allowance for that month, unless individually tailored in accordance with 7 CFR 246.10. 5. Prorate the food benefits to correspond with the unused benefits retrieved from the participant. XIV. Integrate transferring participants into the clinic’s regular appointment scheduling process for the remainder of the certification period. XV. Utilize the list of Point of Contacts (POC) for each state found at http://www.fns.usda.gov/wic/wic-contacts, if you wish to contact the state POC directly. XVI. Submit the following information to the Program Operations Unit should a clinic refuse to send information and require a completed Release of Information form:
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Transfer of Certification
Policy No. CT- 850.01 Effective Date: October 1, 2016
No. of Pages: 5 Revised: March 2019
Page 5 of 5
1. The name of the employee who refused to provide the information, clinic name and number for both in-state and out of state agencies 2. Date the information was requested XVII. Request proof of Identity and Residency--While the VOC card satisfies the income and nutritional condition requirements, the participant must provide proof of residency and identification if transferring from out of state or another LA. If the information is not available, a thirty-day certification may be used for missing proof information. FNS 2016-4 states that if proof of identity or residency are not immediately available, the local agency may wait to process the transfer until the information is provided. If a participant is unable to provide this documentation, the local agency may accept a written statement from the participant in accordance with 7 CFR246.7(c)(2)(i). XVIII. Document the Transfer
1. Retain the original WIC Assessment/Certification Form in the district/clinic where the participant was originally certified. 2. The local agency must document the transfer with the date, source of transfer information, and scan or place actual copy of the VOC card in the medical record.
XIX. LAs and clinics must maintain an inventory of EVOC cards issued. XX. LAs must conduct EVOC inventory quarterly on the last working day of December, March, June, and September of each year.
Authority 7 CFR § 246.7(k) Food and Nutrition Services (FNS) WIC Policy Memo 2016-4, Verification of Certification Definitions/Supporting Information
Electronic Verification of Certification (EVOC)/ Verification of Certification (VOC cards) Paper or electronic negotiable instruments used to validate a WIC certification. These cards allow WIC participants to transfer certification from one clinic, city or state to another. Local agencies must maintain accurate records of issuance, security and receipt from participants.
Migrant-An individual whose principal employment is in seasonal agriculture, who has been so employed in the last 24 months, and who establishes, because of that employment, a temporary abode.
Participant Profile Report /VOC Card- The Department of Defense (DOD) WIC Overseas Program verification of certification (VOC) card which also serves as a participant profile report.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Dual Participation
Policy No. CT- 860.02 Effective Date: October 1, 2016
No. of Pages: 3
Page 1 of 3 Revised June 2018 Policy Participants shall not receive benefits in more than one WIC program or under more than one identity. Such dual participation is illegal and is a form of program abuse and as such is subject to sanctions. Dual participation is considered fraudulent when the State Agency (SA) determines a client has intentionally enrolled and simultaneously redeemed benefits from two programs. Program benefits obtained or disbursed improperly may result in a reimbursement claim (repayment of value of vouchers) against the participant for the full value of such benefits. In conjunction with LA, the SA is responsible for preventing and identifying dual participation within each LA. The SA will refer to any LA, the name of any participant who appears on a list of possible dual participants generated as per the written agreement the SA has with a bordering state. The LA shall follow the same review and investigative requirements as set forth in this policy. Purpose The WIC program is required to establish procedures designed to control participant violations, establish sanctions, prevent dual participation, and take follow up action. The WIC program must document the disposition of all participant abuse and claims. Procedures I. Preventing Dual Participation-The Local Agency must A. Notify participants that enrolling in and receiving benefits from more than one WIC clinic, within or outside of Georgia, at the same time is considered program abuse at each certification.
B. Allow each participant, parent, or caretaker read, or have read to them, and sign the WIC Rights and Responsibilities.
C. Inform participants that have Commodity Supplemental Food Program (CSFP) in the same county that they can only participate in one of the programs at a time (either CSFP or WIC). Dual participation may result in a claim for reimbursement and disqualification from one or both programs.
II. Detecting Dual Participation- Local Agency must:
A. Review and investigate participant records identified by Voucher Management and reporting System (VMARS) as suspected instances of dual participation for all new and transferring participants.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Dual Participation
Policy No. CT- 860.02 Effective Date: October 1, 2016
No. of Pages: 3
Page 2 of 3 Revised June 2018 B. Complete and submit the Composite Dual Participation Report monthly to the Program Operations Unit of the SA regarding each incident that involves improperly issued benefits. The local agencies must submit the report by the 15th day of the following month.
C. Investigate and reconcile each instance of possible dual enrollment identified in the Composite Dual Participation Report. If other local agencies are involved, they are responsible for cooperating during the course of the investigation.
D. Complete and submit the Dual Participation Report Investigation Form.Submit a copy of the signed certification form, and voucher receipts of all questionable issuance to the SA when dual participation is detected.
E. Sign and date the Dual Participation Report by the staff person who completed the report.
F. Waive the termination from one program after consulting with the SA, if is it determined suspension from both programs will result in a serious health risk to the participant, or agrees to an alternate caregiver or proxy for the participant.
III. State Agency Action Based on Substantiated Cases of Dual Participation
A. When dual participation has been substantiated, the following action must be taken within 120 days of initial identification:
a. The SA will determine appropriate sanctions and refer the participant to Federal, State, or local authorities for possible prosecution under applicable statutes. b. If the dual participation is determined to be unintentional, the local program must assist the participant in determining which clinic they wish to continue services and ensure that they are terminated from the other clinic.
c. The SA will issue a warning or termination letter to participants for any substantiated cases of dual participation.
B. The SA will forward all documents to the LA to be placed in the participant’s health records.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Dual Participation
Policy No. CT- 860.02 Effective Date: October 1, 2016
No. of Pages: 3
Page 3 of 3 Revised June 2018 Authority 7 CFR § 246.2; 7 CFR §§ 246.7(l)(1) – (l)(4)
Definitions/Supporting Information CSFP- Commodity Supplemental Food Program that is administered by the United States Department of Agriculture, authorized by section 5 of the Agriculture and Consumer Protection Act of 1973, as amended, and governed by Part 247 of Title 7. Dual participation- Simultaneous participation in more than one WIC program (more than one state or more than one local clinic) or participation in any WIC program and CSFP at the same time. Dual participation occurs when benefits have been received in both programs. Participant Violation- any action by a participant, parent/caretaker, or alternate-proxy that violates Federal or State statutes, regulations, policies or procedures that govern the Georgia WIC Program. See 7 CFR § 246.2
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Rights and Responsibilities of Applicants and Participant Policy No. CT- 860.03 Effective Date: October 1, 2016
No. of Pages: 4
Revised June 2018
Page 1 of 3
Policy At every certification and recertification each participant, guardian, parent, or caretaker must sign that they have read, or have had read to him or her, and understand the WIC Rights and Responsibilities to: 1. acknowledge an understanding of his/her rights and responsibilities, 2. authorize release of information; and 3. consent to anthropometric measurements and blood work. The Rights and Responsibilities form must have a parent/WIC Caregiver/Alternate Caregiver signature and date before staff complete a certification or issue WIC checks. If multiple family members are being certified on the same day, staff members are to indicate all the names on the Rights and Responsibilities Form so the parent/WIC Caregiver/Alternate Caregiver is only required to sign once. Purpose To ensure that WIC applicants and participants or their parents or caretakers are fully informed of and understand their program rights and responsibilities and eligibility status in the program. Procedures The Local Agency Must: I. Provide the participant, parent, or caretaker with a WIC Identification Folder and explain the Rights and Responsibilities statement is contained on the inside of the WIC Identification Folder at initial certification.
II. Allow time for the participant, parent, or caretaker to read, or have read to them, the Rights and Responsibilities Statement. Ensure that the Rights and Responsibilities are explained to the applicant or participant if the individual cannot read or does not understand English
III. Allow a new caregiver to read, or have read, and sign a Caregiver Statement of Change form when the caregiver changes.
IV. Issue the Rights and Responsibilities form using the following guidelines:
A. Enter the current date on the Rights and Responsibilities form.
B. Obtain the participant’s, parents, or caretaker’s signature on the Rights and Responsibilities form to document that they received and understand their rights and responsibilities.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Rights and Responsibilities of Applicants and Participant Policy No. CT- 860.03 Effective Date: October 1, 2016
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Revised June 2018
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C. Provide the participant, parent, or caretaker with a copy of the signed Rights and Responsibilities form.
D. File the signed and dated Rights and Responsibilities form in the participant’s health record.
E. Retain the signed and dated Rights and Responsibilities form for five years, or until all issues related to any litigation, claim, negotiation, audit, or other action involving the participant, parent or caretaker is resolved, whichever is later.
V. The LA must emphasize the following items in conjunction with the Rights and Responsibilities Statement:
A. The illegality of dual participation: All participants must have dual participation explained, including the consequences of being identified as a dual participant.
B. Food Delivery System in the Local Area: The local food delivery system must be explained to the adult applicant/participant or the parent/caregiver/guardian/spouse or alternate-proxy of an infant or child applicant/participant, including an overview of the Approved Food List and the local WIC authorized vendors in the area. To access a listing of WIC authorized vendors by District and County, visit http://dph.georgia.gov/clinic-listing, and select the link, “Clinics in Georgia”.
C. How to File a Complaint: Applicants/Participants are to be informed of their right to file a complaint, how to file a discrimination complaint, and the complaint process (See Policy, Complaint Handling). Applicants/Participants must also have explained to them that reports of discrimination alleged in a complaint will be investigated by the Office of Program Integrity and Strategy and/or the Office of Vendor Management at the State WIC Office.
D. Explain the reason for the participant’s visit to the program and the purpose of the program, example: “The goal of the WIC program is to improve the health and nutrition of families. Today we are going to talk about your child’s health and diet to see if s/he is eligible for WIC and how WIC can help.”
a. If eligible, inform the participant of their eligibility and the length of the certification period.
b. Inform the participant that they will need to be recertified at the end of their certification period to determine if WIC benefits may continue past that period.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Rights and Responsibilities of Applicants and Participant Policy No. CT- 860.03 Effective Date: October 1, 2016
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Revised June 2018
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c. Explain the reason the participant is being enrolled on the program by stating a connection between their eligibility and the desired health outcome. This does not mean every risk must be reviewed, but rather is intended to summarize the reasons the participant is being enrolled. EXAMPLE: “Your child is being enrolled in WIC so we can help with his good nutrition and watch his growth and weight gain over the next six months.”
E. Explain that the food provided by the WIC Program is supplemental; it is not intended to provide all of the participant’s daily food requirements.
F. Instruct participants on the identification requirements for WIC and who may be issued food benefits, attend nutrition education, and bring a child to certification appointments.
G. Explain that giving away, selling or attempting to sell WIC foods, WIC-issued breast pump, formula, or vouchers online or by any other means will be considered a participant violation.
VI. Ensure that Limited English Proficiency (LEP) or visually and/or hearing-impaired applicants or participant understand their rights and responsibilities.
Authority 7 CFR § 246.7(j) 7 CFR § 246.8(c) Definitions/Supporting Information Applicant- An individual who comes to the WIC clinic requesting WIC services. Participant - An individual who receives WIC benefits or services (i.e. supplemental foods, breastfeeding services, nutrition education, referrals).
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Sanction System
Policy No. CT-860.05 Effective Date: October 1, 2016
No. of Pages: 4
Revised July 30, 2020 Page 1 of 4 Policy The local agency must process Category I violations and report Category II-V violations. All correspondence must be maintained according to the Retention of Records Policy. When processing violations within Category I, the Nutrition Services Director (NSD) or designee must complete an investigation within three days of the alleged actions. Upon completion of the investigation, when warranted, the local agency must provide a verbal warning notification and education to participants regarding the violation. All actions related to the violation must be reported to the state agency via email after the participant has been educated and the investigation has concluded. When reporting violations within Category II – V, the NSD or designee must notify the Operations Program Specialist in writing, of any occurrence of alleged or intentional abuse committed by a participant, parent or caretaker of an infant/child, alternate proxy, or proxy, using the Request for Investigation form. All Notice of Assessment of Claims, Notice of Participant Violations, Request for Appointment and Dual Participation must be filed in the participant’s record and at the district office. The Categories of Participant Violations with Resulting Sanctions describes the five (5) categories, violations and prescribed sanctions. Purpose To establish a system of sanctions for participant violations based upon the nature and severity of the violation, in accordance with the federal regulations. To provide an equitable control for identifying, reporting, and investigating alleged WIC Program violations by a participant, parent or caretaker of an infant/child, alternate proxy, or proxy. Procedures I. Notify the Operations Program Specialist via email of actions taken for Category I violations after the participant has been educated and the investigation has concluded.
Include in the email the following supporting documentation: • Participants Name • Description of the Alleged Violation(s) • WIC ID Number • Date(s) warning and education was completed
II. Notify the Operations Program Specialist in writing, using the Request for Investigation form of any occurrence of alleged or intentional abuse committed by a participant, parent or caretaker of an infant/child, alternate proxy, or proxy of Categories II-V violations.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Sanction System
Policy No. CT-860.05 Effective Date: October 1, 2016
No. of Pages: 4
Revised July 30, 2020 Page 2 of 4 Include in the request the following supporting documentation: • Certification forms • Proof Verifications • Rights and Responsibilities • Description of the Alleged Violation(s) • Voucher Issuance • Change in Guardianship
III. Respond, within the requested timeframe, to the Office of Inspector General and the State WIC Office during the investigation.
IV. Distribute all Notice of Participant Violations to all clinics within the district.
State Agency Actions Categories of Participant Violations with Resulting Sanctions
II. Exceptions to Disqualification. A. The State WIC Office may decide not to impose a disqualification under one of the following circumstances:
1. A participant makes full restitution of an assessed claim within thirty (30) days of receipt of the demand letter from the State WIC Office;
2. A repayment schedule agreed upon by the State WIC Office and participant; or
3. In the case of an infant, child, or a participant who is under the age of eighteen (18) years, the State WIC Office may waive disqualification if an alternate-proxy or proxy is appointed to receive nutrition education and transact vouchers and for an infant, child, or participant under 18 years of age. The State WIC Office may permit a disqualified participant to reapply for the program before the end of a disqualification period if full restitution is made or a repayment schedule is agreed upon, or in the case of an infant, child, or a participant who is under the age of eighteen (18) years, the State WIC Office or local agency approves the designation of an alternate-proxy or proxy.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Sanction System
Policy No. CT-860.05 Effective Date: October 1, 2016
No. of Pages: 4
Revised July 30, 2020 Page 3 of 4
B. The State WIC Office will notify the local agency of any participant terminated in error. The participant will be reinstated immediately. Retroactive benefits will not be issued. III. Notice of Assessment of Claim for Participant Violation. The State WIC Office will assess a claim when it is determined that a participant violation has resulted in the improper issuance or disposal of benefits. A. When alleged participant violations are determined by the State WIC Office to be substantiated, the State WIC Office will issue a notification letter to the participant demanding repayment of the full value of the program benefits.
B. The claim letter must include the right to a fair hearing (see Fair Hearing Procedures policy, Policy No. CT-860.04) and must advise the participant that failure to pay the claim may result in disqualification.
C. A copy of the claim letter demanding repayment will be sent to the local agency for monitoring purposes and a copy must also be kept in the participant records.
D. If full restitution is not made to the State WIC Office, or a repayment schedule is not agreed upon with the State WIC Office within thirty (30) days of receipt of the claim letter, the State WIC Office may take additional collection actions until restitution is made or a repayment schedule is agreed on, unless the State WIC Office determines that further collection actions would not be cost-effective.
IV. Notice of Assessment of Sanction. A. The State WIC Office will assess the sanction committed by a participant, parent, guardian, or caretaker of an infant or child participant or proxy and notify in writing. B. The notification must include: 1. the reason for the sanction; and 2. the right to a fair hearing (see Fair Hearing Procedures policy, Policy No. CT- 860.04). C. In the cases of suspension or disqualification, this notice must be provided at least fifteen (15) days before the suspension or disqualification occurs. D. A copy of the notification will be sent to the local agency for monitoring purposes and a
copy must also be kept in the participant records.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL CT Sanction System
Policy No. CT-860.05 Effective Date: October 1, 2016
No. of Pages: 4
Revised July 30, 2020 Page 4 of 4
Authority 7 CFR § 246.7(j)(7) 7 CFR § 246.12(u) 7 CFR § 246.23(c)
Definitions/Supporting Information Abuse - 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. Disqualification - The act of ending a participant’s participation in the program as a punitive sanction for violations committed for a period of time or for administrative reasons. Dual Participation - Simultaneous participation in more than one WIC program (more than one state or more than one local clinic) or participation in any WIC program and CSFP at the same time. Dual participation occurs when benefits have been received in both programs. Participant - A pregnant, breastfeeding and postpartum woman, infants and children under five years of age who are receiving supplemental foods, food instruments (FIs) under the Program. Participant Violation - Any intentional action of a participant, parent or caretaker of an infant/child participant, alternate-proxy, or proxy that violates Federal or State statutes, regulations, policies or procedures governing the Program. A violation may include but is not limited to making false or misleading statements or withholding facts to obtain benefits; selling or attempting to sell vouchers for cash; exchanging or attempting to exchange WIC benefits for cash, non-food items, services or unauthorized food items; threatening to harm or physically harming clinic farmer, or vendor staff; and dual participation.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Security of Issuance Materials
Policy No. FD- 900.02 Effective Date: October 1, 2016
No. of Pages: 2
Revised March 2019
Page 1 of 2
Policy The Local agencies (LA) are fiscally responsible for proper issuance and accountability of check stock paper from receipt from the printing contractor until printed food instruments (FIs) are issued to eligible participants or are voided.
LA must maintain an inventory of check stock paper and a record of FIs printed and the status of the FI as either issued or voided. Store Voucher Management and Reporting System (VMARS) stock paper in a locked cabinet, desk, or closet. Keys to this storage area must be stored on site in a secure location. The LA shall limit access to WIC vouchers, VMARS printers, and/or VMARS stock paper to authorized personnel. LA shall ensure the safe and secure transportation, receiving, handling and storage of all issuance material. WIC Program Stamp is no longer required on new WIC ID card or the Electronic Verification of Certification (EVOC). WIC Manual Verification of Certification Cards are no longer required to be maintained in the clinics.
Purpose To decrease the risk of fraud and increase security. To prevent fraudulent usage and ensure accurate inventory of all issuance material including check stock, FIs, laptops, VMARS printers, and portable printers at all times. Procedures
I. Prevent fraudulent issuance by unauthorized personnel by using the following guidelines:
A. The LA authorized WIC representatives must log out before leaving the workstation.
B. When more than one person is using the same terminal, each person must log out upon completion of their printing job.
C. WIC staff must change passwords to their workstation every ninety (90) days at a minimum.
D. When a WIC representative resigns or is no longer authorized to issue vouchers, the LA must:
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Security of Issuance Materials
Policy No. FD- 900.02 Effective Date: October 1, 2016
No. of Pages: 2
Revised March 2019
Page 2 of 2
1. Immediately delete employees from the system. 2. Change key to voucher security door (when applicable). 3. Change location of all security keys.
Authority 7 C.F.R. § 246.4(a)(14) (xiii) 7 C.F.R. § 246.12 (p)
Definitions/Supporting Information Food Instrument- means a voucher, check, electronic benefits transfer card (EBT), coupon or other document which is used by a participant to obtain supplemental foods.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Guidelines for Investigating Employee Abuse Policy No. FD- 900.04 Effective Date: October 1, 2016
No. of Pages: 3
Page 1 of 3
Policy All WIC program employees shall be informed of their responsibilities regarding program rules and regulations, including confidentiality, conflict of interest, and employee fraud and abuse. Georgia WIC Program employees who also receive benefits from the Georgia WIC Program are required to adhere to the Program’s rules and regulations for WIC participation and to successfully perform his or her job responsibilities. They have the same rights and obligations, as any other participant, if sanctioned for commission of participant violations.
Purpose To provide specific references and guidelines for use when informing employees of their responsibilities regarding program rules and regulations and documentation requirements to demonstrate WIC program employee receipt and understanding of the information provided. Procedures I. Suspected intentional participant abuse by a Georgia WIC Program employee will be investigated by the Office of Inspector General (OIG). When an OIG investigation confirms suspicions of intentional participant abuse by an employee, it may constitute employee misconduct.
II. Any employee, who is certified as a Georgia WIC Program participant, and violates Georgia WIC Program policies and procedures may be terminated from the WIC program and/or employment.
III. Action to be taken as a result of OIG investigation findings shall be based on State Law and DPH policy.
IV. The local agency requesting an order of prosecution, shall notify the Georgia WIC Program and Georgia WIC Program shall notify USDA-FNS. Prosecution shall be processed through the District Attorney's Office.
V. The Georgia WIC Program recommends that any employee found to be abusing Georgia WIC Program should be removed promptly from issuing or processing WIC vouchers, without reappointment rights. VI. The Georgia WIC Program will inform the USDA-FNS of WIC-related employee fraud at the conclusion of the investigation. Employee actions are considered fraudulent and abusive if the act was deliberately and intentionally performed. Such actions include, but are not limited to:
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Guidelines for Investigating Employee Abuse Policy No. FD- 900.04 Effective Date: October 1, 2016
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A. Certifying oneself, co-workers, relatives or friends in the program without supervisory knowledge and/or review; B. Creating fictitious participants or employees; C. Disclosing confidential information regarding WIC participants, vendors or other employees; D. Entering false and/or misleading information in participant records; E. Failing to report conflicts of interest; F. Giving preferential treatment toward specific WIC participants or vendors; G. Issuing WIC benefits to oneself; H. Misappropriating and/or altering food benefits including, but not limited to: 1. Assigning and/or issuing inappropriate benefits 2. Inappropriately re-issuing benefits
I. Misuse and/or theft of materials, supplies or equipment purchased with Georgia WIC program funds; J. Using WIC program funds to purchase goods or services for personal use; and/or K. Verbally or physically abusing WIC participants or other employees
VII. The Georgia WIC Program will maintain all records of employee abuse regardless of dollar amount. Said records will be furnished to OIG during the course of an investigation.
VIII. The District Health Director shall forward a letter requesting an investigation directly to OIG, and a copy of the letter must be forwarded to the Commissioner of the Department of Public Health.
IX. Contract agencies requesting an employee investigation must submit their written request to the Commissioner of the Department of Public Health. The Commissioner's Office will forward the request for investigation along with a cover letter to OIG.
X. Dissemination of Reports – Completed reports, after review and approval by the Deputy of OIG, shall be submitted to the OIG in a timely manner. After approval by the OIG, a copy of the completed report will then be disseminated to the DPH Commissioner, the applicable Executive Leadership Team member who requested the investigation and other DPH Leadership members as deemed applicable by the OIG.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Guidelines for Investigating Employee Abuse Policy No. FD- 900.04 Effective Date: October 1, 2016
No. of Pages: 3
Page 3 of 3
Authority 7 C.F.R. § 246.2 7 C.F.R. § 246.4(a)(27)
Definitions/Supporting Information Conflict of interest- Any relationship, real or apparent which jeopardizes the fair and objective administration of the program, as identified between the WIC program employee and an applicant, participant, staff member, farmer or vendor. Employee Fraud and Abuse- Any act taken by a WIC program employee that intentionally and deliberately violates program regulations, policies or procedures. Suspected intentional abuse by a participant is defined as a deliberate effort to violate Georgia WIC Program policies and procedures (e.g., illegally taking WIC vouchers, giving false/misleading information in order to become certified for WIC, etc.). WIC Program Employee- Any person(s) associated directly or indirectly with a Local WIC Agency to provide services related to the WIC Program. Persons acting under contract, as an intern, or as a volunteer in a Local Agency are included under this definition.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Investigation of Missing Vouchers Policy No. FD- 900.05 Effective Date: October 1, 2016
No. of Pages: 1
Revised: September 2018 Page 1 of 1
Policy When vouchers are discovered missing, WIC clinics are required to immediately notify their supervisor and the District Nutrition Services Director. The Nutrition Services Director or designee must submit the Notification Summary of Missing Vouchers to the Georgia WIC Program Operations district point of contact and the Office of Inspector General within twenty-four hours of the discovery. The Office of Inspector General will investigate reports of any amount of WIC vouchers reported missing. Local agencies who have reported vouchers as missing shall be subject to a compliance visit by OIG or the Program Operations Unit. If an investigation reveals a violation(s) of the Georgia WIC Program’s policies and procedures at the local agency level, a local agency may be subject to corrective action(s) and/or financial penalties. Purpose To ensure vouchers reported as missing are thoroughly investigated by OIG .
Procedures
I. Contact Nutrition Service Director (NSD) and State WIC Office immediately upon discovery of missing vouchers.
II. Complete the Notification Summary of Missing Vouchers.
III. Contact local Police to file report.
IV. Cooperate with OIG and State WIC Office during investigation. Authority 7 C.F.R. § 246.12(q) Definitions/Supporting Information Vouchers- “Vouchers” means a negotiable financial instrument by which WIC benefits are provided to participants. Vouchers can provide either specific amounts of WIC authorized foods or formulas or a fixed-dollar amount for participants to obtain WIC authorized fruits and vegetables (referred to as a “Cash Value Voucher” or “CVV”). Vouchers are also referred to as “checks,” “food instruments,” or “FIs.” Cash Value Vouchers are also referred to as “Fruit and Vegetable Vouchers” or “FVV.”
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Voucher Accountability and Monitoring Policy No. FD- 900.06 Effective Date: October 1, 2016
No. of Pages: 2
Revised September 2018
Page 1 of 1
Policy The Nutrition Services Director shall monitor the Closeout Reconciliation Report to ensure all food instruments are accounted for. The local agency shall fully cooperate with the Office of Inspector General (OIG) and Office of Operations during unannounced voucher accountability site visits. Purpose To decrease the possibility of program fraud and ensure all food instruments are accounted for. Procedures I. The local agency will generate the Closeout Reconciliation Report on a monthly basis and review the final disposition of all Voucher Management and Reporting System (VMARS) to ensure all vouchers are accounted for.
II. Based on the findings from the Quality Assurance Self-Review and/or Closeout Reconciliation Report, the District Nutrition Services Director shall determine if an investigation is warranted.
III. Submit a Request for Investigation Form to the Office of Operations and Nutrition Services assigned point of contact and copy Ondray Jennings in OIG at Ondray.jennings@dph.ga.gov.
IV. Attach the Closeout Reconciliation Report to the request for an investigation, as OIG will use the Report to monitor the disposition of any vouchers that have a questionable status (e.g., voids, fail to sign, etc.).
Authority 7 CFR § 246.19 7 CFR § 246.12(q)
Definitions/Supporting Information Closeout Reconciliation Report – A report that is generated at the local agency to provide a final disposition of all food instruments.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Voucher Issuance Policy No. FD-910.01 Effective Date: October 1, 2016
No. of Pages: 4
Page 1 of 4 Revised July 2018 Policy The local agency shall issue the eligible quantity of monthly food benefits, not to exceed three months, to participants within a valid certification period. Every effort should be made to coordinate voucher issuance with regularly scheduled WIC appointments (e.g., nutrition education contacts or recertification) and/or the delivery of other health services whenever possible. Further efforts must be made to provide health services so that the patients/families will not have to return more than once a month. However, vouchers may be issued for one month, if the participant/caregiver is to return for services at that time (this is the exception, not the rule). Under no circumstances are vouchers to be withheld or denied if a participant or a participant’s parent or caregiver fail or refuse to participate in nutrition education activities or any other services provided by the health department.
Purpose To provide a uniform procedure for local agencies to follow when issuing WIC benefits to participants that will ensure adequate nutrition education opportunities and coordination with other health services. Procedures I. Local agency staff shall routinely issue and print vouchers for WIC participants at:
A. Initial program enrollment for new WIC participants B. Nutrition Education Contact appointments C. Recertification of WIC participants
II. Identification of Persons Picking Up Vouchers. Local agency staff must verify the identity of the person picking up the vouchers as follows:
A. Participants/Alternate-Proxy: Check the WIC ID card for signatures of either the participants or his/her designated alternate. Participant/Alternate-Proxy must sign the VMARS receipt before vouchers are issued.
B. Proxy: Check the WIC Proxy Form, WIC ID card, and proof of identification.
C. Foster Parent: Check the WIC ID card and proof of identification, and DFACS paperwork.
D. Local agency staff must document the types of identification presented by the person picking up the vouchers by entering the proof code on the voucher receipt under the user’s identification.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Voucher Issuance Policy No. FD-910.01 Effective Date: October 1, 2016
No. of Pages: 4
Page 2 of 4 Revised July 2018
III. How to Issue Vouchers
A. Vouchers must only be issued to participants who are in a valid certification period. (See Certification Periods Policy).
B. Local agency staff must verify that the serial numbers on the VMARS vouchers match the serial numbers on the VMARS receipt.
C. Local agencies may issue vouchers to participants at a one, two, or three-month intervals. With the two or three - month issuance, WIC clinic staff must explain to participants not to use vouchers prior to the "First Day to Use" date on the vouchers.
D. Local agencies are strongly encouraged to issue one month of benefits to:
1. Pregnant women enrolled in their third trimester 2. Foster children who are not in a stable foster situation 3. Infants or children receiving formula for medical conditions 4. Participants who receive the homeless package 5. Participants who plan to relocate 6. Participants for whom there are custody disputes 7. Participants for whom the Thirty Day Eligibility proof is pending; and, 8. Newborns who are exclusively, mostly, or partially breastfeeding in the first 30 days 9. If nutrition education is not completed by parent/guardian/caretaker. Alternate-proxy, or proxy
E. Local agency staff may issue a full month of vouchers for participants who are in their final month of eligibility. Participants receive a full food package if the “First Day to Use” date on the voucher is prior to their last date of eligibility (i.e., categorical termination date), or their recertification due date.
F. Categorically Ineligible. Local agency staff must not issue vouchers if the “First Day to Use” or printed date is after the last date of eligibility (i.e., categorical termination date), or the recertification due date.
IV. All infants who are eleven months old must be issued an infant’s food package. They shall not be issued a child’ package until their first birthday (12 months, 0 days).
A. Infants certified after six months of age will be transitioned to a child’s food package for
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Voucher Issuance Policy No. FD-910.01 Effective Date: October 1, 2016
No. of Pages: 4
Page 3 of 4 Revised July 2018 the first month’s vouchers with a first day to use on or after their first birthday.
B. Participants may be certified as a “child” at 11 months 1 day. But will receive an infant package for any vouchers with a first day to use prior to their first birthday. They will be transitioned to a child’s food package for the following month’s vouchers with a first day to use after their first birthday.
V. Prenatal women must not receive vouchers dated greater than 45 days after their EDC date.
VI. A recertification is required to change the prenatal woman to either a breastfeeding woman or a non-breastfeeding woman before new food instruments can be issued.
A. When prenatal participants are recertified as a postpartum woman, they must not be issued food instruments without first checking the last voucher issuance date.
B. If the postpartum package is different than previously assigned prenatal package, void the prenatal unused vouchers with a First Day to Use Date after her delivery date and replace them with the new food package.
Authority 7 C.F.R. § 246.12(r)(4) and (5) 7C.F.R. § 246.11(a)(2) 7 C.F.R. § 246.7(j)(2)(iii)
Definitions/Supporting Information Alternate-Proxy: A person who acts on behalf of the participant or parent/guardian/caretaker of a participant to pick-up and/or redeem vouchers, and attend subsequent certifications, mid/half-certifications, or nutrition education visits on behalf of the participant.
Categorically Ineligible - The period of time a WIC client is no longer in a valid certification period and, therefore, not eligible to receive WIC benefits. Participants who are categorically ineligible are postpartum women at six months postpartum, children who have reached their fifth (5th) birthday, and breastfeeding women who stop breastfeeding and are greater than or equal to six (≥ 6) months postpartum or up to 12 months postpartum.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Voucher Issuance Policy No. FD-910.01 Effective Date: October 1, 2016
No. of Pages: 4
Page 4 of 4 Revised July 2018 Food Instrument – Commonly referred to as "vouchers" or "checks", it is negotiable financial instrument by which WIC benefits are provided to participants. Food instruments can provide either specific amounts of WIC authorized foods or formula (vouchers), or a fixed-dollar amount for participant to obtain WIC-approved fruits and vegetables (referred to as a "Cash Value Voucher” or "CVV") Pending Eligibility-Status of a WIC participant who has not brought in all required proofs (proof of identity, residency and verification of income) at the time of new enrollment or recertification. Proxy – Any person designated by a woman participant, or by a parent or caretaker of an infant or child participant, parent/guardian/caretaker of a participant to obtain and transact food instruments or cash value vouchers or to obtain supplemental foods on behalf of a participant. Receipt –The detachable bottom portion of the FI paper stock. When FIs are printed, FI issuance data is printed on this stub. There is also a signature line where the participant, alternate-proxy, or parent or caretaker must sign when receiving FIs.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Voucher Overrides
Policy No. FD-910.03 Effective Date: October 1, 2016
No. of Pages: 2
Page 1 of 2
Policy Voucher override requests must be approved by an authorized manager. Permission must be granted for a Voucher Management and Reporting System (VMARS) override to print vouchers for a participant who has already received benefits for the requested month. Acceptable reasons for conducting a voucher override include: change in guardianship; food package change in which all vouchers are not voided; participant name similarity that has been identified as non-dual participation; stolen or destroyed vouchers; and, domestic violence situations.
Purpose To prevent over-issuance of benefits to a participant and provide guidance on re-issuing vouchers for foster children and domestic abuse victims. Procedures I. The Nutrition Service Director (NSD) must submit the name(s) of staff that need permission for override vouchers to the state WIC Technology Manager. The State WIC Office will respond to the NSD within 5 days of receipt of the request.
II. When staff are no longer authorized to override vouchers, the local agencies (LA) must notify the State Technology Manager within three (3) days of the change. The notification must include the name of the staff person and a formal request to have that individual’s rights to override vouchers terminated.
III. To override and replace vouchers when the original vouchers were not returned for voiding, due to one of the acceptable reasons listed above:
A. List the previously issued vouchers on the Lost/Stolen/ Destroyed Voided Voucher Report
B. Submit the Lost/Stolen/Destroyed Voided Voucher Report to the State WIC Office and its ADP contractor, Computer Science Corporation (CSC), to be flagged.
C. Flag the vouchers in the frontend system for monitoring to ensure vouchers that were reported as stolen or replaced were not cashed by the participant.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Voucher Overrides
Policy No. FD-910.03 Effective Date: October 1, 2016
No. of Pages: 2
Page 2 of 2
D. Issue new vouchers and document on the receipt the reason for re-issuance.
Note: Do not void the previously issued vouchers in the front end system and submit to CSC. IV. Monthly, the clinic supervisor or Nutrition Service Director (NSD) must sign, date, and review the Monthly Override Report to monitor why the overrides are being used in the clinic. If a pattern of inappropriate use of overrides is noted, the supervisor or NSD must train staff.
Authority 7 C.F.R. § 246.12(r)(5)
Definitions/Supporting Information Override Report- Report that list all vouchers that were reissued to any participant that has previously received vouchers and were not voided or returned due to circumstances such as change in guardianship or reported as stolen.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD VMARS Stock Paper
Policy No. FD-910.04 Effective Date: October 1, 2016
No. of Pages: 3
Page 1 of 3
Policy
Local agencies (LA) shall be responsible for all stock paper received from the ADP contractor and VMARS stock paper issued to authorized staff until the food instruments (FI) are issued to eligible participants. LAs shall be responsible for all VMARS stock paper received from the contracted printer, including maintaining the inventory and security of VMARS stock paper, until issued to a WIC participant.
Purpose
To ensure that local agencies consistently monitor VMARS stock paper inventory received from the State WIC Office’s ADP contractor and the distribution of the same to LA staff to prevent any fraudulent use of the FI check stock.
Procedures
I. VMARS stock paper orders must be made using the electronic Form and Manual Voucher Supply Order Form. Orders received by the ADP contractor by the 10th or 25th day of each month will be filled within (10) ten days.
II. Upon receipt of VMARS stock paper, inspect the shipment for damaged or missing paper. The clinic should notify the OIG-Deputy Inspector General immediately of any discrepancies.
III. VMARS Stock Paper must be logged on the VMARS Stock Paper Inventory Tracking Log when received as follows:
A. Record the date VMARS stock paper was received in the "Date" column. B. Enter the box number, which is the number listed on the Packing Label. C. Record the beginning and ending serial numbers exactly as listed on the inventory ream. D. Enter the balance, which accounts for total number of reams remaining in stock inventory. E. This documentation must be completed within three (3) days from the date the VMARS stock paper is received by the responsible WIC staff person and verified again by another responsible WIC staff person.
IV. The distribution of VMARS stock paper must be recorded on the VMARS Stock Paper Issuance Tracking Log and the VMARS Stock Paper Inventory Tracking Log as follows:
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD VMARS Stock Paper
Policy No. FD-910.04 Effective Date: October 1, 2016
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A. VMARS Stock Paper Issuance Tracking Log. When stock paper is issued: 1. Enter the date of issuance in the “Date” column. 2. Record the beginning and ending serial numbers exactly as listed on the inventory ream in the columns so indicated. 3. Print the clinic staff member’s name in the “Ream Issued To” column. 4. The staff person issuing the stock must record his/her initials in the first “Staff Initials” column. 5. The staff person receiving stock from inventory must record his/her initials in the second “Staff Initials” column to verify.. 6. The VMARS Stock Paper Issuance Tracking Log must be completed immediately from the date the VMARS stock paper is issued to WIC clinic staff.
B. VMARS Stock Paper Inventory Tracking Log. When stock paper is issued to staff and following entry into the VMARS Stock Paper Issuance Tracking Log:
1. Enter the date of issuance in the “Date” column. 2. Record the beginning and ending serial numbers exactly as listed on the inventory ream in the columns so indicated. 3. Record the number of reams issued to staff in the “Reams Issued” column. 4. Record the balance to account for total number of reams remaining in stock inventory in the “Balance” column.
C. LA staff must document receipt and issuance of stock paper within three (3) days. V. A monthly physical inventory of all VMARS Stock Paper must be conducted and recorded on the VMARS Stock Paper Inventory Tracking Log. A. Physical inventory documentation must include the date inventory was conducted and the balance of reams on hand. B. The physical inventory must be labeled “Physical Inventory Conducted and Verified by.” Two staff persons must initial and date the physical inventory.
VI. FI stock, pre-printed FIs and MICR toner cartridges must be locked in a secure location.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD VMARS Stock Paper
Policy No. FD-910.04 Effective Date: October 1, 2016
No. of Pages: 3
Page 3 of 3
Authority
7 CFR § 246.12(p)
Definitions/Supporting Information
“Food instrument” or “FI” – A negotiable financial instrument by which WIC benefits are provided to participants. Food instruments can provide either specific amounts of WIC authorized foods or formulas or a fixed-dollar amount for participants to obtain WIC authorized fruits and vegetables (referred to as a “Cash Value Voucher” or “CVV” or “Fruit and Veggie Voucher” or “FVV”). Food Instruments are also referred to as “checks” or “vouchers”.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Provision of WIC Services for Employees and Relatives Policy No. FD- 910.05 Effective date: October 1, 2016
No. of pages: 2
Revised June 2018
Page 1 of 2
Policy
Local agency staff are prohibited from performing income eligibility and certification duties and issuing food instruments for themselves, their relatives, friends, and for any person who resides in the same household. Hence, the employee must list all relatives or individuals (friends) residing in the employee’s home that is receiving WIC benefits on the Disclosure Statement. The Disclosure Statement must be completed annually or when changes occur by all clinic employees who perform WIC services.
In clinics where there are no other trained staff to determine WIC eligibility, the certification determination will be reviewed by a clinic supervisor or manager. The WIC Nutrition Services Director must conduct a post review of all family members record within two (2) weeks of the certification. Documentation of review must be kept on file at the Local agency for review during program review/management evaluations.
Purpose
To prevent conflict of interest at the local agency and clinic level.
Procedures
I. Local Agency staff will:
A. Complete and submit a Disclosure Statement to the Nutrition Services Director by September 30th of each year or anytime changes occur. B. Maintain the staff Disclosure Statements at the county health department / WIC clinic site.
II. Contact the Nutrition Service Director if there is no other clinic supervisor or manager to review the certification. The WIC Nutrition Service Director will review the certification and will document approval in the record.
III. District staff will: A. Review all disclosure statements during self-reviews. B. Review the certification and ensure that the applicant meets the applicant category (pregnant, breastfeeding, infant, etc.), income, residency, and nutritional risk criteria requirements for certification during self-reviews. C. Ensure that the appropriate food package has been assigned. D. Schedule all employee WIC appointments outside of the employees scheduled work hours.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Provision of WIC Services for Employees and Relatives Policy No. FD- 910.05 Effective date: October 1, 2016
No. of pages: 2
Revised June 2018
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E. Assign a non-related staff person to print and issue vouchers to WIC staff currently enrolled in the WIC program.
Authority 7 C.F.R. § 246.4(a)(27)
Definitions
Relatives - Persons who are related by marriage or blood to include spouse, parent, children, grandchildren, grandparents, brother, sister, aunt, uncle, niece, nephew, first cousin, stepparent, stepchildren, and stepsister.
GEORGIA WIC PROGRAM PROCEDURES MANUAL FD Lost, Stolen, Destroyed, Voided Vouchers Policy No. FD- 920.01 Effective Date: October 1, 2016
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Policy Food instruments (FI) that are lost, stolen, damaged, voided or securely destroyed prior to or following issuance must be documented. Any suspected instances of fraud associated with the lost, stolen, or damaged vouchers must be reported to the Office of Inspector General’s WIC Investigations Unit. Stolen or damaged food instruments may be replaced. Local agencies are prohibited from replacing lost food instruments, unless proof of casualty loss is presented (i.e., insurance claim forms) or a state of emergency has been declared for the area where the reporting participant resides or under limited circumstances including, vouchers lost during mailing, car repossession or home displacement. Replacement vouchers must only be issued for food instruments that have not been redeemed. Complete and submit the Lost, Stolen, Destroyed, Voided Voucher Report to Gainwell Technologies and State Office within three days. Retrievable vouchers must be voided in the front-end system prior to re-issuance.
Purpose To track vouchers that are stolen, damaged or under limited circumstances reported as lost.
Procedures
I. Complete the following when replacing issued vouchers that are reported as damaged or stolen:
A. Replace damaged FIs, if the participant returns FIs that are identifiable. 1. Void the FIs as “Damaged” in the computer and replace FIs. 2. Shred and discard of damaged FIs.
B. Replace damaged FIs due to property fire upon receipt of a copy of the fire report.
1. Verify in GWIS.net that the damaged FIs have not been redeemed. 2. Document the date of the fire and the fire report number in the “WIC Notes” field on the “Intake” screen and the voucher receipt.
C. Replace stolen vouchers upon receipt of a police report from the participant, or if stolen as a result of domestic violence, a police report or letter of placement from a family violence shelter.
1. Verify in GWIS.net that the stolen FIs have not been redeemed. 2. If any of the FIs have been redeemed and the participant states she/he did not redeem them, call the State Office to obtain an image of the FI. 3. Check if the signature on the FI matches the signature on the WIC ID card. If it does not match, then replace the FIs. If it does match, do not replace the FIs and review the “Rights and Responsibilities” form with the participant/ parent/guardian, – caretaker of an infant/child, alternate-proxy.
GEORGIA WIC PROGRAM PROCEDURES MANUAL FD Lost, Stolen, Destroyed, Voided Vouchers Policy No. FD- 920.01 Effective Date: October 1, 2016
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4. Document the date of the theft and the police report number in the “WIC Notes” field on the “Intake” screen. 5. Replace vouchers after a (7) day waiting period to ensure vouchers have not been redeemed. 6. Notify the Office of Inspector General’s WIC Investigations Unit.
Gainwell Technologies II. Complete and submit the Lost, Stolen, Destroyed, Voided Voucher Report to Gainwell Technologies, State Office and local agency district office.
1. Submit the report within three days of completion to Elizabeth Vaughn at evaughn4@dxc.com or by fax to (913) 469-5804 and Operations Program Specialist. 2. Submit the report to the local agency’s district office within three days of clinic completion. 3. Maintain reports according to the retention policy.
Authority 7 CFR § 246.12 (q) Definitions/Supporting Information “Food instrument” or “FI”- means a negotiable financial instrument by which WIC benefits are provided to participants. Food instruments can provide either specific amounts of WIC authorized foods or formulas or a fixed-dollar amount for participants to obtain WIC authorized fruits and vegetables (referred to as a “Cash Value Voucher” or “CVV”). Food instruments are also referred to as “checks” or “vouchers.” Cash Value Vouchers are also referred to as “Fruit and Vegetable Vouchers.”
Original Food Instruments - The first set of food instruments issued to a participant.
Replacement Food Instruments- Food instruments that are used to replace original food instruments.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL Proration of Vouchers
Policy No. FD-920.02 Effective Date: October 1, 2016
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Page 1 of 1 Revised June 2019 Policy Local Agencies (LA) will issue full food packages to participants who pickup vouchers after their scheduled pickup date, but before the Last Day to Use date for the vouchers.
Proration is required when: • pick-up codes are changed during a valid certification period • when a new participant is being added to the family pick-up schedule • when a change in circumstance, such as a change in job or working hours, results in a hardship on the participant
Cash value vouchers can never be prorated and must always be issued for their full value, if a participant is allowed to receive any vouchers for the issuance month.
Purpose To ensure delivery of full nutritional benefit for participants who are late picking up vouchers and to increase food redemption. Procedures I. Issue full nutritional benefits to all participants, even those who missed their voucher pickup appointment. II. Instruct the participant of the last day to use vouchers to ensure redemption within the allotted time frame.
Authority 7 C.F.R. § 246,4(a)(11)(iii) Definitions/Supporting Information Prorate - The issuance of partial food packages by eliminating one or more vouchers from the designated food package to prevent over issuance.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FD Borrowed VMARS Stock Paper Policy No. FD-920.04 Effective Date: October 1, 2016
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Policy Local agencies (LA) may borrow or transfer voucher stock paper only from another clinic within their district.
Purpose To minimize unmatched redemption of voucher stock paper when LA clinics reassign reams from one clinic to another.
Procedures I. Complete the Borrowed VMARS Voucher Stock Paper Report.
II. The clinic must seek approval from the SA to borrow and/or transfer voucher stock paper.
III. Upon approval from the SA, designated clinic staff will submit the Borrowed VMARS Voucher Stock Paper Report to DXC Technology and copy the assigned Operations Program Specialist on the submission.
IV. DXC Technology will accept the Borrowed VMARS Voucher Stock Paper Report form, edit the required fields for validity, and reassign the voucher stock paper serial numbers to the transferring and/or borrowing clinic.
V. The clinic must record the borrowed serial numbers on the Voucher Management and Reporting System (VMARS) Stock Paper Inventory Tracking logs to ensure accountability.
Authority 7 C.F.R. § 246.12(q)
Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL FFM Financial Management and Participation Report (FNS-798) Policy No. FFM-600.02 Effective Date: October 1, 2016
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Policy
The Georgia WIC Program must submit financial and program performance data on a monthly basis as specified by USDA’s Food and Nutrition Services (USDA/FNS). USDA/FNS requires the completion and monthly submission of the FNS-798, WIC Financial Management and Participation Report, and its addendum, FNS-798A, for this purpose. Purpose
The purpose of this form is to outline the standardized process by which the Georgia WIC Program provides monthly financial and participation data to support program management and funding information. Procedure
I. The Georgia WIC Program’s State Office of Program Administration (“Program Administration”) develops an annual food obligation estimate each year, and updates this estimate monthly based on actual redemptions (See Procedures for Estimating Food Obligations). The monthly estimate is provided to DPH/Finance to prepare the FNS-798 each month.
II. Infant formula rebates are collected from the PeopleSoft Teamworks general ledger module. This amount is recognized the month it is received. DPH/Finance and Program Administration develop invoices from reports generated by Georgia WIC’s banking and data contractor, CSC, based on monthly product redemptions. Rebate rates are reconciled to the appropriate Infant Formula Rebate (IFR) contract rates. Rebates collected from the rebate contractor are reconciled to rebates invoiced.
III. Amounts in items I and II are used to complete lines 1 through 14 of the FNS-798.
IV. Program Administration updates federal participation data items on lines 15, 16, and 17 using the monthly reporting in the Revised Participation Summary by Clinic (Georgia WIC Information System (GWIS) Report – R169) as referenced in Procedures for Estimating Food Obligations.
V. DPH/Finance and Program Administration will update Nutrition Services & Administration costs monthly.
VI. District administrative costs are reported by Districts through the Uniform Accounting System and posted in the PeopleSoft Teamworks general ledger module. Staff uses the monthly reporting of these costs to complete the FNS-798.
VII. State administrative costs are recorded in the PeopleSoft Teamworks general ledger, payroll, accounts payable and purchasing modules. Staff uses the monthly reporting of these costs to complete the FNS-798.
VIII. All NSA expenditures are reported in the month paid.
IX. Breastfeeding and nutrition education costs are tracked through the Personnel Activity
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Reporting System (PARS). State level breastfeeding and nutrition education costs are compiled in spreadsheet analyses each year. For the year-end FNS-798A Addendum to WIC Financial Management and Participation Report, these two sets of costs are used to complete this report.
Georgia WIC does not use in-kind expenditures to meet breastfeeding or nutrition education requirements.
X. Program income is reflected on the report the month it is credited to the general ledger accounts in Teamworks.
XI. Post-payment vendor collections received due to recovery of grant funds improperly paid to vendors are reported on line 9 of the FNS-798. This type of income is used to offset food outlays.
XII. Participant collections received due to recovery of food benefits improperly received by participants are reported on line 10 of the FNS-798. This type of income is used to offset food outlays.
XIII. Income other than vendor and participant claims collections and rebates that are received and are used to offset food outlays are reported on line 11 of the FNS-798.
XIV. Program income received that is a recovery of NSA funds are reported on line 25 of the FNS-798 the month in which they become available.
XV. Universal Service Funds (USF) that support Visual Collaboration network offset the costs of the network and will be noted on FNS-798. (See Reporting Program Income Procedures)
XVI. DPH/Finance will submit the FNS-798 report monthly through USDA’s Food Program Reporting System (FPRS) and a final FNS-798 and final FNS-798A annually.
Authority 7 CFR § 246.14(e)(4)
7 CFR § 246.14(f) 7 CFR § 246.25(b)(1)(i) WIC Policy Memorandum #2005-3, Price Adjustments, Collections, Fines, and Program Income
Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL IS Computer System Issues, Problems, and Data Reports IS-300.01 Effective Date: October 1, 2016
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Policy All reports of Computer Services Corporation (CSC) and front-end data collection systems problems and discrepancies and requests for financial and/or statistical data must be submitted in writing to the Program Technology Unit of Georgia WIC.
Purpose
To ensure a standardized method by which local WIC agencies report front-end data collection systems errors and submit requests for financial and/or statistical data from the Georgia Department of Public Health’s State WIC Office.
Procedures
I. REPORTING SYSTEMS PROBLEMS 1. Local WIC agencies must immediately report any CSC and/or front-end systems discrepancies to the Program Technology Unit of the Georgia WIC Program. Systems discrepancies may include, but are not limited to, the following: system shutdown, unprinted vouchers, or any action which causes the clinic system to become unusable.
2. Local WIC agencies must complete a Computer Systems Issues and Problem Report Form and submit it either electronically to the Georgia WIC Program’s Program Technology Unit, or fax it to the Georgia WIC Program at (404) 657-2910, to the attention of the Program Technology Unit.
3. The clinic experiencing the systems issues must also notify the District Nutrition Services Director and Management Information System’s staff at the district office.
II. REQUESTS FOR FINANCIAL AND/OR STATISTICAL DATA
Local WIC agencies or Public Health Districts must complete the Data Request Form, and submit it electronically to the Georgia WIC Program’s Program Technology Unit, or, fax it to the Georgia WIC Program at (404) 657-2910, to the attention of the Program Technology Unit.
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Authority
Georgia WIC Program Policy
Definitions/Supporting Information
Front-End Systems. Georgia WIC currently has four front-end data collection systems:
1. AEGIS – A Custom-Built Legacy DPH investment in Clinic Automation developed in 1999 by Kean Consulting. AEGIS is used by 2 public health districts and 1 contract agency.
2. Mitchell and McCormick Visual HealthNet – A vendor-built and maintained Commercial Off-The-Shelf (COTS) EHR/PM built for the Public Health market on IBM Informix and J2EE technologies. It is used by 14 public health districts (typically 1 instance per County).
3. Netsmart Insight – A vendor-built and maintained COTS EHR/PM built on Microsoft .NET technologies (of early 2000s) for the acute care setting and expanded to address other Program automation needs. Netsmart Insight is used by the DeKalb Public Health District.
4. HealthNet2 – An in-house, custom-built Electronic Health Record (EHR) / Practice Management (PM) application developed on a primarily open source infrastructure and application technologies. HealthNet2 is used by the Northeast (Athens) District.
Back-End System. Georgia WIC has a contract with Computer Services Corporation (CSC) for all back end data processing, banking, and reports.
Voucher Management and Reconciliation System (VMARS). Implemented State-wide in FFY 2014, VMARS eliminates the need for daily batching and provides the ability to check for dual participation in real time. VMARS also reduces the number of Bank Exceptions, Cumulative Unmatched Redemptions (CUR), and Unmatched Redemptions because it validates all WIC client transactions and information in real time before WIC vouchers are printed for issuance. In the event there are unresolved critical errors, the system will notify the clinic user for resolution.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL IS Cumulative Unmatched Redemption (CUR) Report Policy No. IS-320.01 Effective Date: October 1, 2016
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Policy Each month the local WIC agencies must reconcile all redeemed VMARS-issued and manually issued vouchers identified on the Cumulative Unmatched Redemption (CUR) Report that were not matched with a valid client or issuance record. Purpose To ensure that local WIC agencies timely reconcile the Cumulative Unmatched Redemption (CUR) Report to match vouchers with a valid client or issuance record. Procedures I. To view the Unmatched Redemption Report:
A. Log on to the CUR-to-Web website at
https://vmars.statewic.net/CUR/ B. Select a district/unit (D/U) to filter down to a clinic, or select “ALL” to see all clinic numbers C. Select a clinic D. Select the month and year, then click FIND E. The grid will list the information from the Unmatched Redemption Report, including a listing of CUR1 and CUR 2 vouchers to be reconciled. II. Reconciliations must be submitted through the CUR reconciliation website by the seventh working day of the month following the report month.
A. To reconcile vouchers with a problem:
1. Click SELECT on the voucher you want to reconcile 2. Fill in the appropriate fields 3. Enter a comment, if needed 4. Click the MANUALLY RECONCILE checkbox, then click SAVE
B. The “Recon Type” column will show the type of reconciliation.
1. “V” will show if the record/voucher was reconciled through VMARS. 2. “M” will show if the record has/was been manually reconciled.
C. The “Recon By” column will show who reconciled the voucher.
1. “V” for VMARS reconciled 2. ”O” for CSC reconciled 3. “S” for State reconciled
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4. “D” for District reconciled 5. “C” for Clinic Reconciled.
D. Reconciled records will move to the bottom of the grid. Unreconciled vouchers will remain at the top of the grid.
Authority 7 CFR § 246.12(q)
Definitions/Supporting Information CUR- The Cumulative Unmatched Redemption (CUR) report is a listing of redeemed VMARS- issued and manual vouchers that do not match a valid client or issuance record. CUR 1 Vouchers- CUR 1 includes vouchers which have been cashed but no issue record was received. Manual vouchers that were not submitted through VMARS are listed in this report CUR 2 Vouchers- CUR 2 are vouchers which have not been matched a valid WIC ID, or the client was terminated and/or there is no certification record on file. These could include but are not limited to TADS that were not promptly processed through VMARS.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL IS Reconciliation of WIC Reports and Daily Program Operations Policy No. IS-320.02 Effective Date: October 1, 2016
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Policy The local WIC agencies must reconcile WIC reports daily, and immediately report discrepancies to the Georgia WIC Program Operations and Systems Information Units. Purpose To provide an audit trail for the issuance and proper validation of vouchers by ensuring that vouchers are printed correctly, issued to the correct participant, and that any voided vouchers are property accounted for. Procedures I. Daily Verifications. Local WIC agencies must perform the daily verifications and reconciliations, including but not limited to the following:
A. Verify Vouchers Issued: The Daily Activity Report. Voucher receipts must be reconciled with the Daily Activity Report to ensure all receipts and vouchers are accounted for. The Daily Activity Report must be printed, signed, and dated to verify reconciliation. At the end of each day, the WIC clinic staff must print a Daily Activity Report that includes:
1. Voucher Numbers 2. Participant’s Name 3. Issue Date 4. Initials of issuing clerk 5. Status of voucher(Issued or Void)
B. Match numbers on the computer with vouchers issued. C. Ensure all vouchers contain required voucher numbers. D. Ensure that manual voucher numbers received are properly entered into the system. E. Ensure that vouchers do not skip numbers. If a number(s) is skipped, document the number on activity log and in the VOIDED section of the inventory log. F. Verify that duplicate numbers have not been issued. G. Voided vouchers must be stamped “VOID” and stapled to the corresponding receipt.
II. Monthly Verifications. A. Ensure that all vouchers are appropriately issued and/or voided. “Did not print” is not an acceptable voucher status. B. Review Unmatched and CUR Reports and reasons indicated. C. Ensure voucher redemption reports are verified and resubmitted in the required time frame. D. Review the override reports at each clinic location.
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL IS Reconciliation of WIC Reports and Daily Program Operations Policy No. IS-320.02 Effective Date: October 1, 2016
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Authority 7 CFR § 246.12(q)
Definitions/Supporting Information Voucher Override- Reconciliation of vouchers that were reissued due to change in guardianship, lost or stolen, and replaced for formula exchange. Cumulative Unmatched Redemption Report (CUR) - The Cumulative Unmatched Redemption (CUR) report is a listing of redeemed VMARS-issued and manual vouchers that do not match a valid client or issuance record.
GEORGIA WIC PROGRAM PROCEDURES MANUAL MO Quality Assurance Self Reviews Policy No. MO- 1000.02 Effective Date: October 1, 2016
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Policy The Local Agencies (LAs) shall monitor WIC Program operations for all WIC clinics located in its service area annually with half (½) of the LA’s WIC clinics reviewed one year and the other half (½) of those clinics reviewed the following year to ensure Program compliance. Self-monitoring should address the following areas: 1. Clinic management and services 2. Nutrition, breastfeeding and health education 3. Food Delivery 4. Vendor management 5. Administrative operations 6. Other contractual services
Purpose To improve the quality of local agency program operations and to ensure consistent and effective service delivery to participants. Procedures I. Annually, the LA must:
A. Review its response to the most recent SA Management Evaluation Report;
B. Review the LA Monitoring File for the most recent self-review; and,
C. Perform self-reviews of clinics, giving special attention to findings from the last SA review and the previous LA review.
II. The LA must utilize the SA Monitoring Tool in its entirety to perform self-reviews of each clinic. The LA must use the Operations Spreadsheet and/or the Nutrition Spreadsheet.
III. Nutrition Service Directors must document observations of counseling sessions to review staff skills and competency in nutrition assessment and implementation of participant centered services in the Local Agency Monitoring Tool.
IV. Each LA shall prepare a quality improvement plan for each finding identified during the course of the self-review. A copy of the quality improvement plan, including documentation of trainings conducted for clinic staff, and a report evaluating its progress with resolving identified deficiencies must be submitted to the SA. See Quality Improvement Plan for sample template.
V. The Local Agency will maintain all of its self-review documentation for five (5) years.
GEORGIA WIC PROGRAM PROCEDURES MANUAL MO Quality Assurance Self Reviews Policy No. MO- 1000.02 Effective Date: October 1, 2016
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Authority 7 C.F.R. § 246.19(b)(6) 7 C.F.R. § 246.25(a)
Definitions/Supporting Information Monitoring Tool Operations Spreadsheet Nutrition Spreadsheet Plan for Correction Form
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Staff Eligible to Provide Nutrition Education Policy No. NS-200.01 Effective Date: October 1, 2016
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Policy Nutrition education contacts shall be provided by a Competent Professional Authority (CPA), Nutrition Assistants (NA), or an International Board Certified Lactation Consultant (IBCLC).
Purpose To provide accurate and appropriate nutrition education and assessment to WIC participants. Procedures I. Local Agencies: A. Shall ensure CPAs provide nutrition education as allowed within their professional scope of practice. B. May allow Nutrition Assistants (NAs) to provide low-risk secondary nutrition education contacts for topics they have been trained on. C. May allow International Board Certified Lactation Consultants (IBCLC) to provide low-risk secondary breastfeeding nutrition education contacts. D. Shall encourage IBCLC CPA’s as the preferred provider, to provide high risk education when the only risk leading to high-risk status is a breastfeeding risk (risk codes 602 and 603). E. Must ensure that all non-credentialed (not licensed as a dietitian) CPAs have oversight and on-going monitoring by a Licensed Dietitian at the local or district level. F. Shall deem Registered Dietitian Nutritionists (RDN) Licensed Dietitian (LD) and Nutritionists as the preferred provider for high risk secondary nutrition education.
Authority
7 CFR § 246.11(c)(2) Official Code of Georgia, Title 43, Chapter 11A., Dietetics Practice Act. http://iblce.org/ http://www.eatrightpro.org/resources/about-us/what-is-an-rdn-and-dtr/what-is-a-registered- dietitian-nutritionist
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Staff Eligible to Provide Nutrition Education Policy No. NS-200.01 Effective Date: October 1, 2016
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Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Nutrition Assistant (NA) – An individual on the local agency staff who has been authorized to provide low risk secondary nutrition education within a limited scope of practice. NA must only provide education that they have specifically been trained to provide. Lesson plans or evidence of training related to the content must be available for review by the State Agency for all low-risk nutrition education an NA provides. Registered Dietitian Nutritionist (RDN, LD) – Completed a minimum of a bachelor’s degree at a US regionally accredited university or college and course work accredited or approved by the Accreditation Council for Education in Nutrition and Dietetics (ACEND) of the Academy of Nutrition and Dietetics, completed an ACEND-accredited supervised practice program at a health-care facility, community agency, or a foodservice corporation or combined with undergraduate or graduate studies, passed a national examination administered by the Commission on Dietetic Registration (CDR), and completed continuing professional educational requirements to maintain registration. In Georgia, the RDN must also be licensed to practice. Licensed Dietitian (LD) – Meets the standards and requirements set forth in the Georgia Dietetics Practice Act. Maintenance of the license requires bi-annual application. International Board Certified Lactation Consultants (IBCLC) – An IBCLC is a health care professional who specializes in the clinical management of breastfeeding. IBCLCs are certified by the International Board of Lactation Consultant Examiners under the direction of the US National Commission for Certifying Agencies. Certification is awarded upon completion of extensive clinical experience with breastfeeding mothers, educational credits in lactation, and a passing score on the lactation consultants' examination. IBCLCs must re-certify by acquiring continuing education recognition points over five years and must retake the certification examination after 10 years.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Georgia WIC Online Nutrition Education Policy No. NS-200.04 Effective date: October 1, 2016
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Policy Local agencies shall offer participants the option of completing a secondary low-risk nutrition education contact online at www.gawiconline.org. Local agencies must ensure all online contacts are documented in the medical record. If participants elects to complete secondary nutrition education contacts online, the local agency must provide the appropriate resources (i.e. gawiconline business cards) or training for participants on how to access and use the website.
Purpose To provide Georgia WIC participants with a self-directed alternative method of receiving low risk secondary nutrition education that may be completed prior to coming into the WIC clinic. Procedures
I. The local agency may allow the participant to complete the online nutrition education in the clinic.
II. If participants elects to complete secondary nutrition education contacts online, the local agency must:
A. Review the procedures and requirements for completing online nutrition education.
B. Offer participants an opportunity to speak with a CPA to answer any questions that they may have at the first clinic visit following an online secondary education contact.
C. Verify an online nutrition education contact was completed during the current certification period prior to issuing vouchers. See Participant Nutrition Education Policy.
Note: In most cases education completed using Georgia WIC Online will be automatically documented in your WIC system.
D. Document online nutrition education contacts for all family members participating in WIC at the time the activity was completed.
E. Upload or enter the online nutrition education contact into the front-end system.
1. If the local agency WIC system does not reflect an online contact, staff must utilize the processes described in the GaWICOnline User Manual to screen for completion of a secondary nutrition education lesson.
2. Once completion of the online nutrition education is verified, local agency
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staff person can enter the data manually as follows:
a. Enter the Secondary Nutrition Education Provider Code, P7 “Self-Study (Used with Online Education or Kiosk)”
b. Enter the Secondary Nutrition Education Service Code, O (Online).
c. Assist the participant with correcting incorrect WIC Identification (ID) numbers or correcting other family members’ WIC ID numbers, as needed.
F. Offer participants a group or individual contact if unable to verify online education.
G. Inform participants that while high-risk participants are eligible to visit the website, high-risk participants must still receive a high risk nutrition education contact.
Authority 7 C.F.R. §§ 246.11 WIC Nutrition Services Standards – Standard 7
Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Secondary Nutrition Education – Participant-centered nutrition education that is provided at any WIC follow-up visit between certifications including half-certification, mid-certification and mid-Assessment. Low Risk Nutrition Education – General nutrition education provided to WIC participants not defined as high risk (as defined in the Risk Criteria Handbook).
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Nutrition Services Plan Policy No. NS- 200.05 Effective date: October 1, 2016
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Policy
Each District shall develop, implement, and maintain an approved Nutrition Services Plan (NSP) consistent with Georgia WIC Program’s State Plan and in accordance with federal guidelines. Purpose To provide each participant with quality nutrition education at required intervals. Procedures
I. Districts shall submit a NSP work plan every three years and annual updates according to instructions from the State Agency (SA) by the designated dates as identified in the instructions. A copy of the completed NSP shall be kept on file at the local agency and be submitted to the SA.
II. The SA communication and review process of the NSP work plan and annual updates consists of:
A. Written or oral requests for revisions or additions B. Electronic notification of approval to the LA. The LA shall keep the e- notification on file with their NSP.
III. NSP may include: A. The provision of secondary nutrition education to participants and nutrition education for high risk participants. B. Breastfeeding promotion. C. Communication and program outreach. D. Staff development skills related to Value Enhanced Nutrition Assessments (See VENA) and Participant Centered Education (See PCE). E. Special targeted nutrition, breastfeeding, physical activity and other related health behaviors that foster the integration of services within public health for the benefit of WIC Participants. This may include partnerships and collaborations. When these integrated plans are included in the Nutrition Services Plan, they must show evidence how the primary focus areas of WIC related to nutrition, physical activity and breastfeeding education are met.
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Authority 7 CFR § 246.11(b), (d), (e) WIC Nutrition Services Standards: Standards 1, 3, 4, 5, 6, 7, 8, 10 Value Enhanced Nutrition Assessment https://wicworks.fns.usda.gov/wicworks//Learning_Center/VENA/VENA_Guidance.pdf
Definitions/Supporting Information PCE - is a systems approach designed to focus on education that is relevant to the participant. This approach puts the participant’s needs and the goal of healthy behaviors at the core of WIC Service delivery, and focuses on a person’s capacities, strengths and developmental needs, not solely on the problems, risk or negative behaviors. VENA - is an initiative, developed jointly by the Food and Nutrition Service (FNS) and the National WIC Association (NWA), to improve nutrition services in the WIC Program by establishing standards for the assessment process used to determine WIC eligibility and to personalize nutrition education, referrals, and food package tailoring. VENA is part of the larger process known as Revitalizing Quality Nutrition Services (RQNS) in WIC.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Participant Referral To Other Agencies Policy No. NS- 200.06 Effective date: October 1, 2016
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Policy WIC participants must be referred to other health-related services and public assistance programs for which they are eligible. All WIC participants not already enrolled in the Supplemental Nutrition Assistance Program (SNAP), Medicaid, and Temporary Assistance for Needy Families (TANF) must be referred at least one time. Participants shall be informed of these programs and, if needed, be provided with the addresses and telephone numbers of local/state offices.
Purpose To ensure WIC participants are provided access to health care and services to maintain and enhance their overall health. Procedures I. Local agencies are encouraged to coordinate with and refer participants to the Cooperative Extension Service, Expanded Food and Nutrition Education Program (EFNEP), Head Start, Pre-K, and other programs.
II. Staff should refer participants to other health services offered within the health department system and other agencies and services. These include, but are not limited to:
MATERNAL HEALTH PROGRAMS CHILD HEALTH PROGRAMS High Risk Pregnancy Program Children 1st Family Planning Program Children Medical Services Sexually Transmitted Disease Immunization Program
Lead Screening Program ASSISTANCE PROGRAMS Health Check SNAP Dental Health Program Medicaid Vision Screening Program Right from the Start COMMUNITY RESOURCES TANF AIDS Program Head Start Private Physician
Mental Health and Substance Abuse Program
III. CPAs are required to refer participants with the following nutrition risks to the District Children 1st coordinator:
Risk 134: Failure to Thrive Risk 211: Elevated Blood Lead Level
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Participant Referral To Other Agencies Policy No. NS- 200.06 Effective date: October 1, 2016
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Risk 348: Central Nervous System Disorders Risk 349: Genetic and Congenital Disorders Risk 351: Inborn Errors of Metabolism Risk 362: Developmental, Sensory or Motor Delays Interfering with Ability to Eat Risk 382: Fetal Alcohol Syndrome Risk 703: Infant Born to Mother with Mental Retardation, or Alcohol or Drug Abuse during Most Recent Pregnancy Risk 801: Homeless Risk 901: Recipient of Abuse
To initiate the referral process, CPAs must complete the Children 1st Screening and Referral Form, or follow the District Children 1st referral procedures. IV. CPAs shall provide additional prenatal information, assistance, or support to participants in need, and refer participants to the appropriate person(s) designated through the local agency breastfeeding program for additional breastfeeding information.
Authority 7 C.F.R. § 246.7(b) Value Enhanced Nutrition Assessment (VENA) WIC Nutrition Services Standards
Definitions/Supporting Information Children 1st – Administered by the Georgia Department of Public Health, it serves as a single point of entry for children, birth to age five. Children 1st facilitates early identification of at-risk children and links them with early interventions services, as well as other public health services and community based resources.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Education Materials
Policy No. NS- 200.07 Effective date: October 1, 2020
No. of Pages: 2
Revised October 2020
Page 1 of 1
Policy All education materials used by the local agency must be listed on the State Approved Education Materials List. Local agency created materials must be approved by the State WIC Office (SWO) prior to use.
Purpose To ensure consistency in nutrition messaging with resources offered and tools used. Procedures I. Maintain a list of district materials approved for use from the State Approved Education Materials list.
II. Establish a process for replenishing approved materials at the clinic level.
III. Submit local agency created materials to the State Nutrition Unit for review and approval.
Authority 7 CFR §§ 246.11(c)(3) and (d)(1) WIC Nutrition Services Standards
Definitions/Supporting Information Education Materials - Materials that are used to reinforce education provided to Georgia WIC participants related to nutrition, physical activity, program utilization, materials that are used to provide program outreach, and materials that are used to promote and support breastfeeding.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Group Nutrition Education
Policy No. NS - 200.08 Effective date: October 1, 2016
No. of pages: 2
Page 1 of 2
Policy Group nutrition education may be used to provide low risk secondary nutrition education. Group nutrition education shall take into account cultural differences and must include an interpreter or translation services when information is not provided in a participant’s language. Group education must be interactive and offer participants the opportunity to ask questions and receive feedback. The Local agency shall ensure that lessons presented to WIC participants contain accurate, current, culturally appropriate, and professionally recognized nutrition information. All prenatal women should be offered the opportunity to attend a breastfeeding class.
Purpose To provide a counseling method that allows for education to be provided to more than one participant at a time.
Procedures
I. Local Agencies must develop a class outline for each group-facilitated class (topic). The class outline must:
A. Include learning objective(s)
B. Be kept on file at the District WIC Office and at the clinic site for use by clinic staff.
C. Be provided to the Office of Program Operations and Nutrition Services at the time of program reviews.
II. Local Agencies:
A. May provide group education face-to-face or through the state video conferencing system.
B. May utilize Competent Professional Authority’s (CPA’s) or Nutrition Assistants to provide group education. In the case of a breastfeeding class, the Internationally Board Certified Lactation Consultant can also provide the group nutrition education.
III. Staff shall incorporate facilitated discussion as a best practice for providing group nutrition education.
IV. In cases where a breastfeeding class is not available, the breastfeeding information must be covered on an individual basis.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Group Nutrition Education
Policy No. NS - 200.08 Effective date: October 1, 2016
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Page 2 of 2
Authority
7 CFR §§ 246.11(a), (b), (d)(1), and (e)(1) and (4)
Nutrition Services Standards
Definitions/Supporting Information
Group Nutrition Education – Low risk secondary education for Georgia WIC participants that is provided in a group setting with multiple Georgia WIC participants at the same time.
Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Nutrition Assistant (NA) – An individual on the local agency staff who has been authorized to provide low risk secondary nutrition education within a limited scope of practice. NA must only provide education that they have specifically been trained to provide. Lesson plans or evidence of training related to the content must be available for review by the State Agency for all low-risk nutrition education an NA provides. International Board Certified Lactation Consultants (IBCLC) – An IBCLC is a health care professional who specializes in the clinical management of breastfeeding. IBCLCs are certified by the International Board of Lactation Consultant Examiners under the direction of the US National Commission for Certifying Agencies. Certification is awarded upon completion of extensive clinical experience with breastfeeding mothers, educational credits in lactation, and a passing score on the lactation consultants' examination. IBCLCs must re-certify by acquiring continuing education recognition points over five years and must retake the certification examination after 10 years. Facilitated discussion – A method of nutrition education where a facilitator will guide a group through a discussion keeping in mind the values and experiences of the group as well as the knowledge, attitude or skills that is the goal for the session.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS High Risk Secondary Nutrition Education Contact Policy No. NS - 200.09 Effective date: October 1, 2016
No. of pages: 2
Revised: October 2018 Page 1 of 2
Policy All high-risk WIC participants (as defined in the Risk Criteria Handbook) must receive an individual high-risk nutrition education contact following each certification / mid-year assessment at which they were high-risk. This high-risk contact must be done before the next scheduled certification / mid-year assessment. For each high-risk contact a care plan must be documented. Purpose To facilitate positive change in dietary and physical activity habits of high-risk participants. Procedures I. The local agency will provide participant centered high-risk nutrition education through: A. In Person (Individual) B. Video Conference (Individual) C. Phone Contact (Individual) See Phone Contact / Nutrition Education policy.
II. High risk documentation will include all the standards of the Nutrition Care Process from the Academy of Nutrition and Dietetics (AND): Assessment, Diagnosis, Intervention, Monitoring / Evaluation. See Nutrition Care Process.
A. The CPA must address at least one high-risk criteria from that certification period.
B. To remain participant focused at the high-risk nutrition education contact, the CPA shall address the participant centered concern as primary and assure that the participant has no current concerns related to the high-risk criteria(s).
III. CPA must document in the medical record a high-risk visit using SOAP or ADIME format.
A. The CPA care plan must document:
1. Subjective information shared by the participant. 2. The nutrition diagnosis / high-risk condition(s) addressed from the Risk Criteria Handbook. 3. An assessment of the participant’s current nutritional status. 4. The intervention / nutrition education and counseling provided. 5. A follow up plan. The follow up plan can be next steps for the participant or the WIC CPA to complete.
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B. See Documentation of the Nutrition Care Process in WIC Tip Sheet for SOAP and Documentation of the Nutrition Care Process in WIC Tip Sheet for ADIME.
Authority 7 C.F.R. §§ 246.11 (a), (b), (d), and (e) Nutrition Services Standards Nutrition Care Process – http://www.eatrightpro.org/resources/practice/nutrition-care-process
Definitions/Supporting Information
Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Nutrition Care Process – A systematic approach to providing high-quality nutrition care designed to improve the consistency and quality of individualized care for patients/clients or groups and the predictability of the patient/client outcomes
SOAP Note – A SOAP note is a documentation method employed by health care providers to document the events of a health care visit in a clear, concise, and representative manner. The Nutrition Care Process can be documented in the SOAP format. There are four parts of a SOAP note: ‘Subjective, Objective, Assessment, and Plan.
ADIME Note – An ADIME note is a documentation method employed by Registered Dietitian Nutritionists to document the events of a nutrition visit in a clear, concise and representative manner that assures that the nutrition care process is completed in providing patient care. The four parts of the ADIME note: Assessment, Diagnosis, Intervention, and Monitoring/Evaluation.
In Person Nutrition Education – Nutrition education provided directly to the participant. Video Conference Nutrition Education – Nutrition education provided over an approved video conferencing system. Phone Contact – Nutrition education provided over the phone.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Phone Contact / Nutrition Education Policy No. NS- 200.11 Effective date: October 2018
No. of Pages: 3
Page 1 of 4 Revised March 2019
Policy Local agencies may provide nutrition education and breastfeeding support by telephone for the contacts described below. • Primary nutrition education at initial certification when physical presence exemptions apply • Primary nutrition education at recertification including infant mid-certifications, child half- certifications and woman mid-assessments • Low-risk and high-risk secondary nutrition education contacts • Breastfeeding support including Peer Counselor activities
Local agencies must ensure the Participant Nutrition Education Standards, High Risk Secondary Nutrition Education Contact, and Staff Eligible to Provide Nutrition Education policies are maintained when providing nutrition education by telephone. Confirmation of identity must be established before providing nutrition education by telephone. When the participant is unavailable, the designated alternate-proxy or proxy, as identified in the medical record, may receive nutrition education by telephone. See Designation of an Alternate-Proxy and Designation of a Proxy Policies. See Mailing / Delivery of WIC Vouchers Policy for additional guidance on eligible reasons to mail vouchers.
Purpose To improve health status and achieve positive change in dietary and physical activity habits that emphasize the relationship between nutrition, physical activity, and health. To increase participant access to nutrition education. Procedures
I. At the initiation of a telephone contact, have the participant confirm their name.
II. Request the participant to verify at least one additional identifier that can be confirmed from the medical record; such as, A. Current mailing address B. Date of birth C. WIC ID number D. Other verifiable information in the medical record
If the participant’s identity cannot be confirmed, education cannot be provided over the telephone. Schedule an in-person appointment as needed for follow up.
III. Educate alternate-proxy or proxy by the same process used for participants.
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IV. Provide education only after the alternate-proxy or proxy has confirmed the participants current mailing address, date of birth, WIC ID number, or other verifiable information in the medical record
V. Offer the participant(s) the opportunity to ask questions during and after the nutrition education contact.
VI. Document the method used to provide the nutrition education (Nutrition Education Contact Type: P - Phone) in the electronic medical record. See Participant Nutrition Education Standards Policy and High Risk Secondary Nutrition Education Contact Policy for documentation requirements. Also see Staff Eligible to Provide Nutrition Education.
VII. Make appropriate referrals for services as needed to achieve participant goals (Reference Policy NS-200.06 Participant Referrals to Other Agencies). For example:
A. Group education class to learn more about WIC foods and planning healthy meals on a budget, infant feeding, or prenatal classes. B. Refer to a Breastfeeding Peer Counselor or Designated Breastfeeding Expert (DBE) for additional follow-up if needed.
Authority 7 C.F.R. §§ 246.11 (a), (b), (d)(1), and (e) WIC Nutrition Services Standards – Standard 7 WIC Nutrition Services Standards – Standard 8 Value Enhanced Nutrition Assessment (VENA)
Definitions/Supporting Information Breastfeeding Peer Counselor: (BPC) – A WIC Breastfeeding Peer Counselor is a paraprofessional support person who gives basic breastfeeding information and encouragement to WIC pregnant and breastfeeding mothers. Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Phone Contact / Nutrition Education Policy No. NS- 200.11 Effective date: October 2018
No. of Pages: 3
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Assistants or certified by the State medical certifying authority), or State or local medically trained health officials. Designated Breastfeeding Expert (DBE) is an individual who is an expert with special experience or training in helping breastfeeding mothers and who provides breastfeeding expertise and care for more complex breastfeeding problems when WIC staff face situations outside of their scope of practice. (From Nutrition Services Standards, August 2013) International Board Certified Lactation Consultants (IBCLC) – An IBCLC is a health care professional who specializes in the clinical management of breastfeeding. IBCLCs are certified by the International Board of Lactation Consultant Examiners under the direction of the US National Commission for Certifying Agencies. Certification is awarded upon completion of extensive clinical experience with breastfeeding mothers, educational credits in lactation, and a passing score on the lactation consultants' examination. IBCLCs must re-certify by acquiring continuing education recognition points over five years and must retake the certification examination after 10 years. Low Risk Nutrition Education – General nutrition education provided to WIC participants not defined as high risk (as defined in the Risk Criteria Handbook). Nutrition Assistant (NA) – An individual on the local agency staff who has been authorized to provide general nutrition education within a limited scope of practice. NA must only provide education that they have specifically been trained to provide. Lesson plans or evidence of training related to the content must be available for review by the State Agency for all low-risk nutrition education an NA provides. Nutrition Education – A dynamic process delivered through individual or group sessions by which participants gain the understanding, skills, and motivation necessary to promote and protect their nutritional well-being through their food intake, physical activity, and behavioral choices. Nutrition education is focused on the participant’s interests and designed based on ethnic, cultural, and geographic differences with consideration for language, education, environmental factors, and nutritional risks. Breastfeeding education is nutrition education. Nutrition education is a no-cost benefit available to all participants. Primary Nutrition Education – Participant-centered nutrition education that is provided at certification, or a recertification visit. Secondary Nutrition Education – Participant-centered nutrition education that is provided at any WIC follow-up visit between certifications including half-certification, mid-certification and mid-Assessment. Value Enhanced Nutrition Assessment (VENA)/ Participant Centered Education (PCE) – A qualitative dietary assessment that promotes a participant-centered, positive approach to the
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nutrition assessment. The nutrition assessment is based on desired health outcomes rather than deficiency findings. This method allows for individualized counseling sessions.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Goal Setting
Policy No. NS- 200.12 Effective Date: October 1, 2020
No. of Pages: 2 Revised October 1, 2020
Page 1 of 1
Policy Local agencies (LA) must engage the participant / parent / caregiver in setting a participant focused, simple and attainable goal at each certification and mid-year assessment. Competent Professional Authority (CPA) must assist the participant in: • Setting a goal • Identifying barriers and solutions to meet the established goal • Assuring the participant understands their goal
Purpose To assist participants in achieving a positive change in dietary and physical activity habits. Procedures
Document participant goals in a S.M.A.R.T (Specific, Measurable, Attainable, Realistic, and Timely) format. For example, participant will walk three times a week for 20 minutes starting this week.
Authority Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Maximum Monthly Allowance Policy No. NS- 210.01 Effective date: October 1, 2016
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Policy Local agencies must make available to participants the maximum monthly allowances of authorized supplemental foods. A CPA must prescribe the authorized supplemental foods in quantities that do not exceed the maximum monthly allowances. Purpose To ensure each participant receives all of the food benefits to which they are entitled. Procedures I. The local agency will ensure CPAs take into consideration the participant’s nutritional and breastfeeding needs when prescribing authorized supplemental foods. II. The local agency can only provide less than the maximum monthly allowance of supplemental foods to an individual WIC participant when: A. Medically or nutritionally warranted (e.g., eliminate a food due to an allergy); B. A participant refuses or cannot use the maximum monthly allowances. C. The local agency must document in the participant record why the maximum monthly allowance was not provided. D. The Food Section of the Medical Documentation Form can be used for the required documentation. III. The local agency must instruct all participants on how to select WIC approved foods to receive their maximum monthly allowance.
Authority 7 C.F.R. §§ 246.10 (d) and (e) Definitions/Supporting Information Competent Professional Authority (CPA) - An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Contract and Non-Contract Infant Formula Policy No. NS- 210.02 Effective date: October 29, 2018
No. of Pages: 2
Revised: August 2022
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Policy- Infants participating in the Georgia WIC program who require a milk-based or soy-based infant formula shall be provided one of the contract formulas: Enfamil Infant, Enfamil ProSobee, Enfamil Gentlease or Enfamil A.R. Any issuance of an authorized, non-contract infant formula requires appropriate medical documentation. All infant formulas, including contract formula, require medical documentation to be issued to a child participant. Purpose To ensure that participants needing standard milk-based and soy-based formula receive contract formula. Procedures
I. Competent Professional Authorities (CPAs) should issue a food package containing Enfamil Infant, Enfamil ProSobee, Enfamil Gentlease or Enfamil A.R. to any infant requiring a milk-based or soy-based infant formula.
II. Refer to the Medical Documentation Policy for information regarding medical documentation requirements when issuing formula to children.
III. Medical documentation for unapproved, non-contract milk-based, soy-based, or lactose reduced infant formulas should not be accepted. For information on the Georgia WIC Approved contract and non-contract infant formulas, please visit dph.georgia.gov/WIC/wic-formula-resources.
Authority 7 C.F.R. §§ 246.10 (d) and (e) Definitions/Supporting Documentation Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Contract and Non-Contract Infant Formula Policy No. NS- 210.02 Effective date: October 29, 2018
No. of Pages: 2
Revised: August 2022
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Contract Infant Formula – All infant formula (except exempt infant formulas) produced by the manufacturer awarded the infant formula cost containment contract. Exempt Infant Formula – An infant formula that is intended for commercial or charitable distribution that is represented and labeled for use by infants who have inborn errors of metabolism or low birth weight, or who otherwise have unusual medical or dietary problems (21 CFR 107.3).
Infant Formula - Means a food that meets the definition of an infant formula in section 201(z) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321(z)) and that meets the requirements for an infant formula under section 412 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 350a) and the regulations at 21 CFR parts 106 and 107.
Local Agency (LA) – A public or private, nonprofit health or human service agency that provides health services, either directly or through contract.
Non-Contract Brand Infant Formula – All infant formula, including exempt infant formula, that is not covered by an infant formula cost containment contract awarded by the State agency and is not subject to rebates.
WIC Eligible Nutritionals - means certain enteral products that are specifically formulated to provide nutritional support for individuals with a qualifying condition, when the use of conventional foods is precluded, restricted, or inadequate. Such WIC-eligible nutritionals must serve the purpose of a food, meal or diet (may be nutritionally complete or incomplete) and provide a source of calories and one or more nutrients; be designed for enteral digestion via an oral or tube feeding; and may not be a conventional food, drug, flavoring, or enzyme. WIC- eligible nutritionals include many, but not all, products that meet the definition of medical food in Section 5(b)(3) of the Orphan Drug Act (21 U.S.C. 360ee(b)(3)).
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Matching Mother/Baby Breastfeeding Dyad Policy No. NS- 210.07 Effective date: October 1, 2016
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Policy The mother and infant food packages must agree based on the feeding type assignments. For breastfeeding dyads who are not exclusively breastfeeding, Competent Professional Authorities (CPA) are expected to individually tailor the amount of infant formula based on the assessed needs of the breastfeeding infant and provide the minimal amount of formula that meets, but does not exceed the infant’s nutritional needs. The local agency can only issue formula or food benefits to the infant when they have been released from the hospital. Purpose To increase breastfeeding rates in Georgia through assignment and coordination of food packages for the breastfeeding dyad.
Procedures I. The CPA must assign feeding type and food packages to a mother and her infant as a unit or pair rather than as two individuals. The feeding types of both mother and infant must match throughout the certification period. For example, an Exclusively Breastfeeding woman with an Exclusively Breastfed infant.
A. If at any time during the certification period the mother’s or the infant’s feeding type change, the other’s feeding type must be updated to match.
B. If the mother stops breastfeeding after the infant is older than six months, the CPA must change both the mother’s and infant’s feeding type to fully formula fed.
II. To allow a lactating mother to fully establish her maternal milk supply, the CPA should only assign a formula package to a breastfed infant during the first month, when requested.
III. The local agency should assign partially breastfed infants powder formula packages. However, liquid concentrate formula is allowed, when requested.
A. The CPA should refer to Estimating Formula Needs in the Food Package Handbook to assist in determining the approximate amount of formula needed based on the infant’s usual breastfeeding habits.
B. The local agency shall not honor requests for additional formula without an assessment and counseling of the mother/baby breastfeeding dyad. Any problems with breastfeeding should be addressed at this time.
C. When reissuing the infant’s vouchers, the CPA must take into consideration which, if
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any, of the infant’s vouchers have already been redeemed. They must subtract any formula already issued from the total amount of formula required for the month.
IV. When a breastfeeding mother requests formula during a month for which she has already received vouchers, the local agency may issue formula based on the infant’s assessed needs.
A. For a previously exclusively breastfed infant, the CPA must prorate the current month’s package for the number of days/weeks left in the issuance month.
B. For a partially breastfed infant receiving additional formula, the CPA must not issue a combined amount of formula (initial issuance plus additional formula) in excess of the amount allowed for the infant’s new breastfeeding status.
C. The CPA shall not determine the amount of formula the infant can receive based on the food the mother was issued or has already redeemed.
D. The local agency must void and reissue all vouchers previously issued for subsequent months. The new food packages must match the new feeding type for both mom and infant.
E. The CPA must document in the WIC medical record their assessment of the infant’s immediate need of formula.
F. If the assessment does not indicate an immediate need for formula (or additional formula), the local agency must make the food package change effective for the following month.
G. If the mother has not used any of her vouchers for the month, then the local agency may void her current vouchers and re-issue the new food package.
V. The local agency must certify a hospitalized infant receiving human milk and their mother as part of the mother/baby breastfeeding dyad.
A. In most cases, the CPA should certify the breastfeeding mother as “Exclusively Breastfeeding” as no food benefits will be issued to the infant.
B. The CPA should assign the infant, CPA Food Package 290 “Infant in Hospital: Mother/baby breastfeeding dyad”.
Note: Food package 290 contains a tracking voucher with no formula or food benefits. The tracking voucher message encourages the participant to contact their local WIC clinic when the infant is released from the hospital.
C. In cases when the infant is expected to stay in the hospital less than one month and the infant is receiving limited breastmilk in the nursery, the CPA can assign the
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mother’s food package based on the amount of breastmilk she is providing to the hospitalized infant.
1. For example, if mom is only providing breastmilk for one feeding per day, the CPA would certify both mother and infant as Some Breastfeeding.
2. The CPA must assign the infant Food Package 290.
3. The local agency will void Voucher code 190 and replace with the new food package when the infant is discharged.
D. If the mother discontinues breastfeeding prior to the infant being discharged from the hospital, the local agency must continue issuing food package 290 to the infant and update the mother’s food package to reflect her new feeding status.
E. Upon release, the CPA must evaluate the “Mother/baby breastfeeding dyad” feeding status and update the “Mother/baby breastfeeding dyad” food package as needed.
Authority 7 CFR 246.10 USDA Breastfeeding Policy and Guidance - July 2016 Food and Nutrition Service (FNS) - WIC Food Packages State Agency Frequently Asked Questions – 3/1/2016
Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Infant Formula – A food that meets the definition of an infant formula in section 201(z) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321(z)) and that meets the requirements for an infant formula under section 412 of the Federal Drug, Food, and Cosmetic Act (21 U.S.C. 350a) and the regulations at 21 CFR parts 106 and 107.
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Mother / Baby Breastfeeding Dyad – The process of thinking of a mother and her infant as a single unit or pair instead of as two separate individuals for the purposes of assigning food packages and feeding methods. An infant and mothers food package is assigned based on the frequency a mother breastfeeds and the amount of supplemental formula needed for the infant.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Food Packages for Homelessness, Migrancy and Disaster Situations Policy No. NS- 210.11 Effective date: October 1, 2016
No. of Pages: 2
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Policy A Competent Professional Authority (CPA) must tailor food packages for homeless and migrant participants and for those in a disaster situation. Alternative packages must only be issued to participants with a documented need for an alternative package. The CPA must reevaluate and assign appropriate food packages when the participant on an alternative package locates to a permanent residence with adequate refrigeration and/or a safe water supply. Purpose To provide benefits to participants without a refrigerator, stove, clean water supply and/or a place to store food in a form that accommodates their situation. Procedures I. Local agencies have the option to convert participants to an alternative food package under the following circumstances: A. A participant lacks a fixed and regular nighttime residence.
B. A participant's primary nighttime residence is:
1. A publicly or privately operated shelter designed to provide temporary living accommodations.
2. A temporary accommodation in the residence of another individual.
3. A public or private place not designed for or ordinarily used as a regular sleeping accommodation.
C. A participant’s primary residence lacks refrigeration and/or contains a contaminated or limited water supply.
D. Disaster situations such as floods, tornadoes, etc., that temporarily displace participants from their normal residences or that result in an unsafe water supply.
II. CPA can issue Infants ready-to-feed formula or another form as best meets their needs and situation. III. CPA should reference the Food Package Handbook for alternate food package maximum monthly amounts.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Food Packages for Homelessness, Migrancy and Disaster Situations Policy No. NS- 210.11 Effective date: October 1, 2016
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Authority 7 C.F.R. § 246.4(a)(6) 7 C.F.R. § 246.10(b)(1)(ii) 7 C.F.R. §§ 246.10(b)(2)(ii)(C) and (D) Definitions/Supporting Documentation Alternative Food Package: Additional food package options available for homeless participants, migrants, and disaster situations which include smaller package sizes, unrefrigerated options and formula not requiring the addition of water.
Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Homeless Individual: A woman, infant, or child who lacks a fixed and regular night time residence, or whose primary night time residence is: a supervised publicly or privately operated shelter (including a welfare hotel, a congregate shelter, or a shelter for victims of domestic violence) designated to provide temporary living accommodation; an institution that provides a temporary residence for individuals intended to be institutionalized; a temporary accommodation in the residence of another individual; or a public or private place not designed for, or ordinarily used as, a regular sleeping accommodation for human beings.
Migrants: Seasonal farm or agricultural worker or family member who travels from place to place for the purpose of work and such work requires the establishment of temporary residence.
Natural Disaster: An occurrence in nature causing wide spread destruction (e.g., tornado, flood, hurricane, etc.)
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Medical Documentation
Policy No. NS- 210.12 Effective date: October 1, 2016
No. of Pages: 4
Revised January 2021
Page 1 of 5
Policy Medical documentation is required prior to the issuance of any exempt infant formulas or WIC- eligible nutritionals. Participants who transfer from another state within a valid certification period and require a state approved exempt formula or WIC-eligible nutritional may receive one month of the product without written medical documentation. Issuance of an exempt infant formula or WIC-eligible nutritional may be authorized when the medical documentation includes a qualifying medical condition consistent with the manufacturer’s indicated use or nutritional profile of the product prescribed. The local agency must obtain new medical documentation for continued issuance of any exempt infant formulas and WIC-eligible nutritionals at every certification or when the planned length of use documented by the medical provider expires.
New medical documentation is required when the type or amount of exempt formula or WIC-eligible nutritional changes.
Medical documentation is required for the issuance of infant formulas or WIC-eligible nutritionals to participants greater than 12 months of age. This includes the issuance of a nutritional supplement when the consumption of conventional foods is prohibited, restricted, or inadequate.
A current release of information signed by the participant must be in place prior to any conversations and or correspondence regarding the WIC participant with their prescribing medical provider(s). Medical documentation that has been clarified by the medical provider and updated by the WIC Program staff is valid for the full certification period and used in the same manner as medical documentation not requiring clarification. When a current release of information, signed by the participant is in place, verbal medical documentation (verbal order) may be obtained from the prescribing medical provider(s) and used to provide exempt infant formulas and WIC-eligible nutritionals for one month. Purpose To ensure program cost incurred from the issuance of exempt infant formulas and WIC-eligible nutritionals is medically indicated, and necessary to sustain the health and wellbeing of the participant. Procedures I. Accept the Georgia WIC Request for Medical Formulas and WIC Supplemental Foods (RMF) as an original written document, an electronic document, or by facsimile.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Medical Documentation
Policy No. NS- 210.12 Effective date: October 1, 2016
No. of Pages: 4
Revised January 2021
Page 2 of 5
A. Accept a physician’s prescription pad or medical office letterhead in lieu of the Georgia WIC RMF.
II. Do not accept the following forms for medical documentation:
A. Prescription forms or prescription pads which are pre-printed or pre-stamped with a formula requiring a prescription.
B. Forms or prescription pads containing formula advertising.
C. Prescription pads or forms that include a pre-printed list of formulas from which the healthcare provider is expected to choose from a list of formulas. For example, a prescription form that lists ten (10) common special formulas and one (1) blank space to list other formulas is not allowed.
III. Verify that medical documentation received includes all required information. See the Medical Documentation Content Requirements for more details.
IV. Use the Formula Algorithm for Infants on Georgia WIC and the Formula Algorithm for Children on Georgia WIC as a guide for authorizing the issuance of formulas based on the manufacturer’s indicated use and qualifying medical conditions. When issuing nutritional supplements, reference the Issuance Requirements for Nutritional Supplements.
V. Obtain clarification for missing or unclear information provided by medical documentation with either the participant, per the CPA nutrition assessment, or by the medical provider using the procedures described below.
A. Verify that a release of information signed by the participant is available and current prior to contacting their medical provider. (Reference Section VIII of this policy for procedures on obtaining the participant’s release of information.)
B. Contact the medical provider for clarification/verification of any of the information listed below or to request medical documentation if it was not provided.
1. New or undocumented diagnoses
2. Information provided by a source unfamiliar with the information requested
3. Foods that have been selected as contraindicated by the medical provider which parent/caregiver reports as being allowed
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Medical Documentation
Policy No. NS- 210.12 Effective date: October 1, 2016
No. of Pages: 4
Revised January 2021
Page 3 of 5
C. Clarify the following information based on parent/caregiver’s report or per the CPA nutrition assessment:
1. Formula/nutritional history
2. Signs/symptoms that supports the documented diagnosis (i.e. severe allergies/allergic reactions)
3. Product form, flavor, with fiber etc.
4. Historical/previously documented chronic diagnoses available in the medical record or RMF
5. Food restrictions such as nothing by mouth (NPO)
6. Additional foods or formula to be excluded from the food package
VI. Document clarifying information on the current medical documentation form, initial and date each change, and depending on the source of the clarification:
A. Record the name and credentials of the provider or other medical personnel (relaying the information on behalf of the provider) who gave the verbal clarification by each change.
B. Document the applicable nutrition assessment information, the date it was obtained, and the source where it may be referenced (i.e. “Patient was premature, 35 weeks gestation - see RMF dated 7/28/2020).
C. Document the information provided by the parent/caregiver and the name and relationship of the caregiver (i.e. “unflavored verified by mother, Jane Smith, 2/25/19”).
D. When Section 3 – Authorized Supplemental Foods section is left blank, determine foods appropriate based on the CPA’s nutritional assessment and/or parent/caregiver’s report.
1. Document foods not to be issued in the “Comments” section of the RMF or on the alternate form as appropriate.
2. The CPA must sign their full name, title, and date with the authorized supplemental foods documentation.
VII. Request new medical documentation if the authorized signature is not included on the medical documentation, is completed using a signature stamp, or if the form was signed by an unauthorized provider. Provider signatures cannot be documented as clarifying information.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Medical Documentation
Policy No. NS- 210.12 Effective date: October 1, 2016
No. of Pages: 4
Revised January 2021
Page 4 of 5
VIII. Discuss the release of information requirements with the participant prior to them completing a release of information.
A. Assist the participant with completing a Release of Information, Section 5, on the Georgia WIC RMF or the DPH Authorization for Release of Protected Health Information if they wish to authorize a release of information to the provider.
1. If the participant does not wish to authorize release, the CPA shall document “Declined” on the signature line and document the date the release was declined.
2. If the participant refuses to sign a Release of Information, explain to them that they must contact the medical provider themselves to request new medical documentation with required clarity.
B. Reference the Release of Information Frequently Asked Questions (FAQs) for additional details.
IX. Document the details of verbal medical documentation (verbal order) on the Georgia WIC RMF or alternate form and sign/date the information.
A. Record the complete name and credentials of the authorized prescribing medical provider in the place of his/her original signature.
B. Request written medical documentation of the verbal order from the medical provider to be received as soon as possible but no later than two weeks after the initial verbal order.
C. Do not accept consecutive verbal orders for the same medical documentation request.
Authority 7 C.F.R. § 246.10(d) 21 C.F.R. § 107.3 (definition of infant exempt formula) Definitions/Supporting Documentation Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Medical Documentation
Policy No. NS- 210.12 Effective date: October 1, 2016
No. of Pages: 4
Revised January 2021
Page 5 of 5
(certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials. Exempt Infant Formula – An infant formula that is intended for commercial or charitable distribution that is represented and labeled for use by infants who have inborn errors of metabolism or low birth weight, or who otherwise have unusual medical or dietary problems.
Nutritional Supplement – A concentrated source of nutrients for children and adults, often in the form of a beverage, providing supplemental or complete nutrition intended for oral or tube feedings.
WIC-Eligible Nutritionals – means certain enteral products that are specifically formulated to provide nutritional support for individuals with a qualifying condition, when the use of conventional foods is precluded, restricted, or inadequate. Such WIC-eligible nutritionals must serve the purpose of a food, meal or diet (may be nutritionally complete or incomplete) and provide a source of calories and one or more nutrients; be designed for enteral digestion via an oral or tube feeding; and may not be a conventional food, drug, flavoring, or enzyme. WIC-eligible nutritionals include many, but not all, products that meet the definition of medical food in Section 5(b)(3) of the Orphan Drug Act (21 U.S.C. § 360ee(b)(3)).
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Emory Genetics WIC Participants
Policy No. NS- 210.15 Effective date: October 1, 2020
No. of Pages: 2
Revised October 2020
Page 1 of 2 Policy Local agency will issue prescribed contract brand infant formulas and / or supplemental foods for participants based on medical documentation provided by Emory Genetics. The Emory University Department of Human Genetics and Pediatrics (Emory Genetics) is responsible for the coordination and issuance of the prescribed, exempt infant formulas and/or WIC-eligible nutritionals for all WIC participants under their medical care. The combined issuance of contract formula issued from the WIC clinic and the exempt infant formulas and/or WIC-eligible nutritionals provided through Emory Genetics shall not exceed the maximum monthly allowance for the participant’s age and feeding type. Purpose To reduce participant barriers and improve continuity of care for Emory Genetics WIC participants with limited access to ongoing, highly specialized nutritional management. Procedures
I. Issue Food Package Code 099 (Emory Genetics Food Package) to all active WIC participants who present medical documentation from or are being monitored by the Emory Genetics clinic.
II. Print the Emory Genetics 099 food package for each issuance month based on the participant’s pick-up code. The 099 food package contains four (4) tracking vouchers (no formula or supplemental food vouchers) as follows: A. Voucher code 099 – Participant Copy (1 voucher) B. Voucher code 299 – Emory Genetics’ Copies (2 vouchers) C. Voucher code 399 – Chart Copy (1 voucher)
III. Have the WIC participant sign all voucher receipts and give the participant the 099 “Client Copy” voucher for their records.
IV. Fax both Emory Genetics vouchers (voucher codes 299) for each issuance month to the fax number listed on the voucher. Emory genetics will fill in the “Formula Name” and “Cost” lines on the 299 vouchers.
V. File the 299 vouchers (Emory Genetics Copies) and the 399 (Chart Copy) voucher in the participant’s medical record.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Emory Genetics WIC Participants
Policy No. NS- 210.15 Effective date: October 1, 2020
No. of Pages: 2
Revised October 2020
Page 2 of 2 VI. Assign a Second Food Package to issue contract formula and / or supplemental foods authorized by the medical documentation provided by Emory Genetics by entering the appropriate food package code in the “Second Food Package Option” field in the computer system.
VII. Issue contract formula vouchers for the exact amounts requested by Emory Genetics on the Medical Documentation Form (MDF).
VIII. Notify the participant that Emory Genetics will provide the prescribed exempt infant formulas and/or WIC-eligible nutritionals.
IX. Contact the State WIC Office Nutrition Unit at 404-657-2900 or Emory Genetics at 404-778- 8607 for assistance with determining issuance amounts.
X. Enter “000” in the Second Food Package Option field when the participant is not prescribed contract formula or is not approved to receive any supplemental foods.
XI. For additional details on 999 food package requirements, reference Tailoring and 999 Food Package Policy.
Authority 7 CFR 246.10 Definitions/Supporting Documentation Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
WIC-Eligible Nutritionals – means certain enteral products that are specifically formulated to provide nutritional support for individuals with a qualifying condition, when the use of conventional foods is precluded, restricted, or inadequate. Such WIC-eligible nutritionals must serve the purpose of a food, meal or diet (may be nutritionally complete or incomplete) and provide a source of calories and one or more nutrients; be designed for enteral digestion via an oral or tube feeding; and may not be a conventional food, drug, flavoring, or enzyme. WIC-eligible nutritionals include many, but not all, products that meet the definition of medical food in Section 5(b)(3) of the Orphan Drug Act (21 U.S.C. 360ee(b)(3)).
Exempt infant formula - means an infant formula that meets the requirements for an exempt infant formula under section 412(h) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 350a(h)) and the regulations at 21 CFR parts 106 and 107.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Tailoring and 999 Food Packages
Policy No. NS- 210.16 Effective date: October 1, 2016
No. of Pages: 2
Revised February 2019
Page 1 of 3
Policy The local agency shall tailor the participant’s food package to best meet their nutritional and/or medical needs, food preferences, cultural or religious beliefs, food intolerances, and household conditions. The maximum monthly allowance of all supplemental foods must be made available to the participant unless nutritionally or medically warranted (See Maximum Monthly Allowance Policy NS- 210.01).
Purpose To ensure each participant receives the food package that best meets their medical/nutritional needs and preferences. Procedures I. The CPA will assess the participant’s nutritional needs and dietary preferences prior to assigning a food package.
II. Using the Food Package Handbook the CPA will assign the most appropriate state created food package based on their assessment.
III. The CPA shall assign a combination of milk, cheese, yogurt, soy beverage, and tofu based on the participant’s need and preference.
IV. The CPA must document the reason for assigning a soy or tofu package to children ages one to five years, in the medical record.
V. If there is no state created food package that meets the needs of the participant, the local agency will either develop or assign a district created food package using food package code 999 and the active state created voucher codes. A. Regarding creating and managing district created food packages, the local agency will: 1. Designate a person to create and approve all district created food packages 2. Maintain a master list of the district created food packages (999 food packages) for state agency review. 3. Include the following details for each food package on the master list: a. General description of the food package (intended use/rationale, i.e. “No eggs”)
b. WIC type, age group, and feeding type (as applicable)
c. Food package code and/or sub number
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Tailoring and 999 Food Packages
Policy No. NS- 210.16 Effective date: October 1, 2016
No. of Pages: 2
Revised February 2019
Page 2 of 3
d. All voucher codes with current voucher message
4. Update their district created food package list as needed and as the state food package database is updated.
5. Follow the substitution rate and the maximum monthly allotment of supplement foods for each food package category (See Food Package Handbook for maximum monthly allowances and substitution rates).
a. The CPA can substitute beans (1 pound dried or 4 cans) for one jar of peanut butter.
b. The CPA can substitute one jar of peanut butter for 1 pound dried beans or 4 cans of beans.
VI. Tailor food packages for participants receiving a Food Package III, for exempt infant formula or medical nutritionals, according to what has been indicated per medical documentation (See Medical Documentation Policy NS- 210.12).
A. Issue only the quantity of formula prescribed to children and women on Food Package III, up to the maximum allowed.
B. Issue children with a qualifying medical condition on food package III 144 ounces of infant fruits and/or vegetables in lieu of the cash value voucher.
C. Issue women with a qualifying medical condition on food package III infant fruits and/or vegetables in lieu of the cash value voucher.
1. $11 cash value voucher equals 176 ounces
2. $16.50 cash value voucher equals 264 ounces
D. Issue women and children receiving a food package III 32 ounces of infant cereal in lieu of the 36 ounces of breakfast cereal.
E. Issue whole milk to women and children over two receiving a food package III.
F. Reference State Ordered Special Formula Policy for how to order formulas for which no state created vouchers are available.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Tailoring and 999 Food Packages
Policy No. NS- 210.16 Effective date: October 1, 2016
No. of Pages: 2
Revised February 2019
Page 3 of 3
Authority 7 CFR 246.10 Georgia WIC Program Policy
Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Nutrition Tailoring – a process of modifying food packages to better meet the supplemental nutrition needs of individual participants. The term “nutrition tailoring” is reserved solely for making food package accommodations, as authorized by WIC regulations in 7 CFR 246.10©, to accommodate the needs of an individual participant based on the CPA’s assessment of the participant’s nutritional risk condition, breastfeeding assessment, dietary needs, and personal food preferences. Nutrition tailoring entails making changes or substitutions to food types (e.g., dry beans vs. peanut butter) and physical food forms (e.g., dry milk vs. fluid milk). Nutrition tailoring may also involve eliminating foods due to allergy, medical or nutritional condition, or in situations where a participant cannot use or refuses the item.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Issuance of Ready-to-Feed Products
Policy No. NS- 210.18 Effective date: October 1, 2016
No. of Pages: 2
Page 1 of 2
Policy All infant formulas, exempt infant formulas, and WIC-eligible nutritionals must be issued in concentrated liquid or powder physical forms. Ready-to-feed forms may be authorized in special situations. Purpose To provide participants with the most cost-effective form of infant formula and nutritionals while ensuring that the option of the ready-to-feed product is accessible in situations where the powder or concentrated form is unavailable or inappropriate. Procedures I. Issue ready-to-feed WIC-eligible nutritionals when the CPA or medical provider determines and documents any of the following:
A. The participant's household has an unsanitary or restricted water supply or poor refrigeration.
B. The person caring for the participant may have difficulty in correctly diluting concentrated or powder forms.
C. The formula is only available in a ready-to-feed form.
D. The issuance of nursettes is more appropriate than a larger, ready to feed alternative.
II. Issue ready-to-feed formulas to participants with qualifying medical conditions, who are assigned to Food Package III, when the medical provider or CPA determines and documents any of the following:
A. The ready-to-feed form better accommodates the participant’s medical condition.
B. The ready-to-feed form improves the participant’s compliance in consuming the prescribed formula.
Authority 7 C.F.R. §§ 246.10(e)(1)(iv) and (e)(3)(iii).
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Issuance of Ready-to-Feed Products
Policy No. NS- 210.18 Effective date: October 1, 2016
No. of Pages: 2
Page 2 of 2
Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Exempt Infant Formula – An infant formula that is intended for commercial or charitable distribution that is represented and labeled for use by infants who have inborn errors of metabolism or low birth weight, or who otherwise have unusual medical or dietary problems (21 CFR 107.3).
Infant Formula - a food that meets the definition of an infant formula in section 201(z) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321(z)) and that meets the requirements for an infant formula under section 412 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 350a) and the regulations at 21 CFR parts 106 and 107. WIC-Eligible Nutritionals - enteral products that are specifically formulated to provide nutritional support for individuals with a qualifying condition, when the use of conventional foods is precluded, restricted, or inadequate. Such WIC-eligible nutritionals must serve the purpose of a food, meal or diet (may be nutritionally complete or incomplete) and provide a source of calories and one or more nutrients; be designed for enteral digestion via an oral or tube feeding; and may not be a conventional food, drug, flavoring, or enzyme. WIC-eligible nutritionals include many, but not all, products that meet the definition of medical food in Section 5(b)(3) of the Orphan Drug Act (21 U.S.C. 360ee(b)(3)).
Nursette – a small bottle (two to three ounces) of ready-to-feed infant formula typically used in hospitals for newborn infants.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Medical Diagnoses
Policy No. NS- 210.19 Effective date: October 1, 2016
No. of Pages: 2
Page 1 of 2
Policy Medical documentation for exempt formulas and nutritionals must include a specific, qualifying medical condition. The documented diagnosis or medical condition must be consistent with the manufacturers’ labeled and intended use of the formula or nutritional prescribed, or based on the nutrient composition and nutritional features indicated in the management of the specified condition. The medical diagnoses must also be consistent with the participant’s anthropometric data (e.g., length/height, weight, BMI) and WIC nutritional assessment for authorization of issuance. Purpose To ensure that the formula or nutritional prescribed is appropriate and necessary for the medical management of the participant’s health condition. Procedures
I. Verify that the diagnosis provided is a qualifying medical condition.
A. Qualifying medical conditions include, but are not limited to, premature birth, low birth weight, failure to thrive, inborn errors of metabolism and metabolic disorders, gastrointestinal disorders, malabsorption syndromes, immune system disorders, severe food allergies that require an elemental formula, and life threatening disorders, diseases and medical conditions that impair ingestion, digestion, absorption or the utilization of nutrients that could adversely affect the participant’s nutrition status.
B. A “suspected” diagnosis is allowable if it still meets the other diagnostic criteria (e.g., “suspected milk protein allergy”).
II. Contact the medical provider to clarify any non-specific, general medical diagnoses or clinical signs and symptoms documented as the sole diagnosis. These are not sufficient as Georgia WIC medical documentation. Reference the attachment, Diagnoses Requiring Clarification or Additional Documentation for a list of unacceptable diagnoses.
III. If the issuance of the indicated formula or nutritional is not authorized based on the guidance above, inform the provider of the reason GA WIC cannot provide the requested formula or nutritional. The final decision should be based on the information on the Medical Documentation Form and any additional clarification provided by the physician.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Medical Diagnoses
Policy No. NS- 210.19 Effective date: October 1, 2016
No. of Pages: 2
Page 2 of 2
Authority 7 CFR §§ 246.10(d) and (e)
Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Georgia WIC Approved Formulary
Policy No. NS- 210.20 Effective date: October 1, 2016
No. of Pages: 3
Page 1 of 3
Policy The Local Agency may only authorize the issuance of formulas and nutritionals available on the Georgia WIC Approved Formulary . Exempt infant formulas and nutritionals not currently on the Georgia WIC Approved Formulary may be added to the formulary by formal request from the medical provider or other applicable party. Purpose To ensure that GA WIC participants only receive infant formula and nutritionals that meet the minimum federal requirements for WIC-eligibility. Procedures I. Only authorize the issuance of formulas and nutritionals available on the Georgia WIC Approved Formulary.
II. Offer the comparable contract infant formula available on the Georgia WIC Approved Formulary to participants transferring from another state who are using a non-contract, milk or soy based infant formula that Georgia WIC does not approve.
III. When a provider or participant requests an exempt infant formula or nutritional that is not currently listed on the Georgia WIC Approved Formulary, contact the State WIC Office to initiate a formulary addition request. The product will be reviewed with consideration to the following:
A. The medical provider or applicable party must provide written documentation of participant need or a market demand for the formula or nutritional.
B. Documentation of USDA authorization as a WIC-eligible formula or nutritional must be on record. (This may be presented as the USDA WIC Authorization Letter or verified through the WIC Works Formula Database)
C. The State WIC Office Nutrition Unit will review the requested product for appropriateness and accessibility.
D. Following review, the State WIC Office will provide notification to the requesting party of the denial or approval of any formulary additions.
Note: The timeline for requests for approvals can vary from a few days to several weeks. A more specific timeline may be provided at the time of the request.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Georgia WIC Approved Formulary
Policy No. NS- 210.20 Effective date: October 1, 2016
No. of Pages: 3
Page 2 of 3
Authority 7 C.F.R. § 246.10(e)(1)(iii)7 C.F.R. § 246.10(e)(12), Table 4 21 C.F.R. §§ 106 and 107 Federal Food, Drug, and Cosmetic Act (21 U.S.C. § 301 et seq)
Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Contract Infant Formula – All infant formula (except exempt infant formulas) produced by the manufacturer awarded the infant formula cost containment contract.
Exempt Infant Formula – An infant formula that is intended for commercial or charitable distribution that is represented and labeled for use by infants who have inborn errors of metabolism or low birth weight, or who otherwise have unusual medical or dietary problems (21 CFR 107.3).
Infant formula - Means a food that meets the definition of an infant formula in section 201(z) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321(z)) and that meets the requirements for an infant formula under section 412 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 350a) and the regulations at 21 CFR parts 106 and 107.
Local Agency (LA) – A public or private, nonprofit health or human service agency that provides health services, either directly or through contract.
Non-Contract Brand Infant Formula – All infant formula, including exempt infant formula, that is not covered by an infant formula cost containment contract awarded by the State agency and is not subject to rebates.
WIC Eligible Nutritionals – means certain enteral products that are specifically formulated to provide nutritional support for individuals with a qualifying condition, when the use of conventional foods is precluded, restricted, or inadequate. Such WIC-eligible nutritionals must serve the purpose of a food, meal or diet (may be nutritionally complete or incomplete) and provide a source of calories and one or more nutrients; be designed for enteral digestion via an oral or tube feeding; and may not be a conventional food, drug, flavoring, or enzyme. WIC-
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Georgia WIC Approved Formulary
Policy No. NS- 210.20 Effective date: October 1, 2016
No. of Pages: 3
Page 3 of 3
eligible nutritionals include many, but not all, products that meet the definition of medical food in Section 5(b)(3) of the Orphan Drug Act (21 U.S.C. 360ee(b)(3)).
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Returned Formulas and WIC-eligible Nutritionals Policy No. NS- 210.21 Effective date: April 1, 2019
No. of Pages: 2
Page 1 of 2 Revised May 2022 Policy The local agency can only allow infant formulas and WIC-eligible nutritionals to be returned due to food package changes. Only infant formulas and WIC-eligible nutritionals originally purchased with WIC funds can be returned. Infant formulas and WIC-eligible nutritionals that were damaged or expired at the time of purchase, cannot be returned to the WIC clinic and must be returned to the vendor to be exchanged. All returned infant formulas and WIC-eligible nutritionals must be tracked using the Returned Formula Tracking Log. Returned formula must be stored in a secure location that is out of view of WIC participants. Formula must be protected from spoilage, infestation, damage or other conditions that may damage the wholesomeness or degrade the nutritional value or safety of the formula. All returned formulas will be donated to community food programs, such as a local food bank, in the month it was received. The local agency shall not redistribute returned infant formula or WIC-eligible nutritionals for any subsequent participant issuance. All returned formula must be inspected for visible defects and labels checked to ensure that the “use-by-date” has not expired. In accordance with FDA rules, infant formula that is past its “use- by-date” or that is visibly dented or damaged should be discarded and must not be distributed to community food programs. Purpose To safeguard participants against the possibility of receiving infant formulas or WIC-eligible nutritionals that may have been tampered with or improperly stored. Procedures I. Advise participants to redeem small amounts of formula at a time until tolerance is confirmed, to limit the amount of returned formula.
II. Document the details of returned formula on the Returned Formula Tracking Log.
III. Donate returned formula to a local community food program.
A. Record on the Returned Formula Tracking Log the amount of formula donated and to which community food program.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Returned Formulas and WIC-eligible Nutritionals Policy No. NS- 210.21 Effective date: April 1, 2019
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IV. When formula is past the use-by-date, physically damaged, or otherwise not suitable for donation: A. Dispose of returned formula by completely emptying the contents of the formula container prior to throwing it away. B. Containers of powder formula should be opened and emptied into a trash receptacle, sealed, and promptly disposed of. C. Containers of concentrate and ready to use formula should be opened and poured into a sink before the formula container is placed in the trash.
V. Each time formula is donated and/or disposed of, the Returned Formula Tracking Log should be closed out with a signature and date. A new log is required for each donation.
VI. Keep completed signed monthly Returned Formula Tracking Log(s) on file at each local agency WIC clinic.
VII. Start new monthly Returned Formula Tracking Logs as often as needed throughout the month.
Authority USDA Special Supplemental Nutrition Program for Women, Infants and Children (WIC) Food Package Policy and Guidance March 2018. WIC Policy Memorandum #2020-1 Donation of Unused Returned Infant Formula.
Definitions/Supporting Information Infant Formula – means a food that meets the definition of an infant formula in section 201(z) of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 321(z)) and that meets the requirements for an infant formula under section 412 of the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 350a) and the regulations at 21 CFR parts 106 and 107. WIC-eligible Nutritionals – means certain enteral products that are specifically formulated to provide nutritional support for individuals with a qualifying condition, when the use of conventional foods is precluded, restricted, or inadequate. Such WIC-eligible nutritionals must serve the purpose of a food, meal or diet (may be nutritionally complete or incomplete) and provide a source of calories and one or more nutrients; be designed for enteral digestion via an oral or tube feeding; and may not be a conventional food, drug, flavoring, or enzyme. WIC- eligible nutritionals include many, but not all, products that meet the definition of medical food in Section 5(b)(3) of the Orphan Drug Act (21 U.S.C. 360ee(b)(3)).
Community Food Program – community-based or nonprofit food assistance programs that provide individuals with food assistance (ie. local food banks).
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Staff Training
Policy No. NS- 220.01 Effective Date: October 1, 2016
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Policy The local agency shall provide internal or external training opportunities and continuing education for the topics below.
All staff that provide WIC services must have, but not be limited to: - One (1) hour of customer service training annually - Two (2) hours of breastfeeding training annually - State approved civil rights training annually
New staff must have civil rights training prior to interacting with participants. Annual programmatic training is required for all staff that provide the following services: - Anthropometric collection and assessment - Hemoglobin collection and assessment - Mandatory and recommended referrals Annual Value Enhanced Nutrition Assessment (VENA) / Patient Centered Education (PCE) training is required for all staff that provide education and counseling to WIC participants: WIC Competent Professional Authority (CPA), Breastfeeding Peer Counselor (BPC), International Board Certified Lactation Consultant (IBCLC), Nutrition Assistant (NA) and other breastfeeding staff providing WIC services. Purpose To ensure local agency (LA) staff is trained to promote breastfeeding and provide WIC services in a customer friendly, respectful manner. Procedures I. The local agency must maintain documentation that staff received required annual training. See Continuing Education Documentation Log.
A. Staff must be entered in the log on the appropriate tab by position held. Staff holding multiple positions should only be listed once under the position with the highest level of requirements. B. The log must be tracked by Federal Fiscal Year. If changing tracking year, two logs must be kept until the transition to the new tracking year is complete.
II. The local agency must submit training documentation when requested for policy and action memos.
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Authority 7 C.F.R. § 246.11(c)(2) and (c)(7)(iii)
Definitions/Supporting Information Breastfeeding Peer Counselor: (BPC) - A WIC Breastfeeding Peer Counselor is a paraprofessional support person who gives basic breastfeeding information and encouragement to WIC pregnant and breastfeeding mothers. Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials. International Board Certified Lactation Consultants (IBCLC) - An IBCLC is a health care professional who specializes in the clinical management of breastfeeding. IBCLCs are certified by the International Board of Lactation Consultant Examiners under the direction of the US National Commission for Certifying Agencies. Certification is awarded upon completion of extensive clinical experience with breastfeeding mothers, educational credits in lactation, and a passing score on the lactation consultants' examination. IBCLCs must re-certify by acquiring continuing education recognition points over five years and must retake the certification examination after 10 years. Nutrition Assistant (NA) – An individual on the local agency staff who has been authorized to provide general nutrition education within a limited scope of practice. NA must only provide education that they have specifically been trained to provide. Lesson plans or evidence of training related to the content must be available for review by the State Agency for all low-risk nutrition education an NA provides.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Staff Continuing Education Policy No. NS- 220.03 Effective Date: October 1, 2016
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Policy All WIC Competent Professional Authority (CPA), Breastfeeding Peer Counselor (BPC), International Board Certified Lactation Consultant (IBCLC), Nutrition Assistant (NA) and other breastfeeding staff providing WIC services, whether they work full time or part time, must receive at least twelve (12) hours of nutrition specific continuing education each year. Required WIC programmatic in-service trainings do not count towards the required twelve (12) hours, unless approved by the Office of Program Operations and Nutrition. Purpose To ensure local agency (LA) staff is trained to promote accurate health, nutrition and breastfeeding information. Procedures I. Local Agency shall provide or allow access to continuing education through district developed training activities, or via webinars, self-study modules or conferences.
II. Local Agency staff can count the required two (2) hours of Breastfeeding specific continuing education and Value Enhanced Nutrition Assessment/Participant Centered Education (VENA/PCE) skills development training as part of the twelve (12) hours of nutrition specific continuing education. See Staff Training Policy.
III. Local Agencies may prorate continuing education for employees who are employed for a partial year (e.g. new hire or terminated employee) and in special situations (e.g. family and/or medical leave). IV. Local Agencies must document mandatory training and continuing education on the Continuing Education Documentation Log.
A. All CPAs, NAs, IBCLCs, BFPC (and, other staff providing anthropometric and biochemical services) must be listed in the log on the appropriate tab by position held. Staff holding multiple positions should only be listed once under the position with the highest level of requirements.
B. The log must be tracked by Federal Fiscal Year. If changing tracking year, two logs must be kept until the transition to the new tracking year is complete.
C. Certificates of attendance or other documentation evidencing the actual attendance represented in the log must be maintained for five (5) years plus the current year.
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Authority Georgia WIC Program Policy
Definitions/Supporting Information Breastfeeding Peer Counselor: (BPC) - A WIC Breastfeeding Peer Counselor is a paraprofessional support person who gives basic breastfeeding information and encouragement to WIC pregnant and breastfeeding mothers. CEUs - Continuing education units are a system of tracking the amount of time spent in training. One hour is equivalent to one continuing education unit. Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials. FTE – Full time equivalent is the hours worked by one employee working full time (forty hours per week). International Board Certified Lactation Consultants (IBCLC) - An IBCLC is a health care professional who specializes in the clinical management of breastfeeding. IBCLCs are certified by the International Board of Lactation Consultant Examiners under the direction of the US National Commission for Certifying Agencies. Certification is awarded upon completion of extensive clinical experience with breastfeeding mothers, educational credits in lactation, and a passing score on the lactation consultants' examination. IBCLCs must re-certify by acquiring continuing education recognition points over five years and must retake the certification examination after 10 years. Nutrition Assistant (NA) – An individual on the local agency staff who has been authorized to provide general nutrition education within a limited scope of practice. NA must only provide education that they have specifically been trained to provide. Lesson plans or evidence of training related to the content must be available for review by the State Agency for all low-risk nutrition education an NA provides.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Staff Observations
Policy No. NS- 220.04 Effective Date: April 1, 2017
No. of Pages: 2 Page 1 of 2
Policy Employees in the following positions, whether they work full time or part time, must receive an annual skills assessment: • Competent Professional Authority (CPA): One certification observation • Breastfeeding Peer Counselor (BPC): See Peer Counselor Monitoring Policy for monitoring requirements • Nutrition Assistant (NA): Quarterly low risk (individual or group) nutrition education observations
Purpose To ensure local agency (LA) staff are providing participant centered health, nutrition and breastfeeding information. Procedures
I. Local Agency must complete CPA and NA annual skills assessment observations using the Nutrition Monitoring Spreadsheet.
II. Local Agency must document annual skills assessments observations on the Continuing Education Documentation Log.
Authority Georgia WIC Program Policy
Definitions/Supporting Information Breastfeeding Peer Counselor: (BPC) - A WIC Breastfeeding Peer Counselor is a paraprofessional support person who gives basic breastfeeding information and encouragement to WIC pregnant and breastfeeding mothers. Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians
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Assistants or certified by the State medical certifying authority), or State or local medically trained health officials. Nutrition Assistant (NA) – An individual on the local agency staff who has been authorized to provide general nutrition education within a limited scope of practice. NA must only provide education that they have specifically been trained to provide. Lesson plans or evidence of training related to the content must be available for review by the State Agency for all low-risk nutrition education an NA provides.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Strong4Life CPA Staff Observations Policy No. NS- 220.06 Effective Date: March 1, 2019
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Policy Local agencies are required to have at least one designated Strong4Life Champion. Strong4Life champions must be trained prior to beginning observations. Local agency Strong4Life Champion(s) are required to complete state assigned number of Strong4Life Observations monthly. Strong4Life observations are in addition to the yearly CPA annual skills assessment See Staff Observation Policy.
Local agencies with more than one designated Strong4Life Champion must: • Assign a minimum of one observation to each designated local agency Strong4Life Champion per month • Complete at least the minimum number of Strong4Life observations per month as assigned by the State WIC Office
Purpose To improve local agency CPA motivational interviewing counseling skills. Procedures Local agency Strong4Life Champion must:
I. Document monthly Strong4Life CPA observations using the Strong4Life WIC Champion Observation Form.
II. Complete observations of Georgia WIC certification, high-risk or low-risk secondary education visits.
III. Randomly select CPAs, including managers and supervisors providing direct client services.
IV. Enter observations within two (2) working days of the observation into the Redcap Database https://redcap.choa.org/redcap/surveys/?s=KTTHPX8X9R.
V. Request additional Strong4Life Champions to be trained by contacting the Program Operations and Nutrition Services office.
Authority Georgia WIC Program Policy
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Strong4Life CPA Staff Observations Policy No. NS- 220.06 Effective Date: March 1, 2019
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Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials. Strong4Life Champion – A CPA that is designated by the local agency and trained to conduct quality assurance and quality improvement activities relating to motivational interviewing skills. The Strong4Life Champion is primarily responsible for conducting and documenting observations of nutrition education contacts that are provided by CPA staff to WIC participants. The Strong4Life Champion also provides skills development feedback and training for CPAs regarding motivational interviewing skills.
GEORGIA WIC PROGRAM PROCEDURES MANUAL NS Dietetic Internship Program Policy No. NS- 230.01 Effective Date: October 1, 2017
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Policy WIC employees meeting degree, work performance, work experience, and district support requirements may be eligible to apply for admission to the Georgia Department of Public Health’s WIC Dietetic Internship Program in order to complete the core competencies for Registered Dietitians through supervised practice.
Purpose The Dietetic Internship Program’s primary goal is to achieve improved health outcomes of Georgians through the promotion of quality nutrition care practice by assisting qualified employees of the Georgia Department of Public Health’s WIC Program to become Registered Dietitians.
Procedures I. Detailed information regarding the program can be found in The Georgia Department of Public Health WIC Dietetic Internship Handbook and the Master Annex Agreement:
Georgia Department of Public Health WIC Dietetic Internship Handbook: Provides program information, procedures and policies. Master Annex Agreement: Outlines Georgia Department of Public Health WIC Dietetic Internship grant fund restriction, allowances, deliverables, performance measures, and methods of fund allocation.
Authority Accreditation Council for Education in Nutrition and Dietetics Accreditation Standards Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL NSA General Introduction – Financial Management System NSA-500.01 Effective Date: October 1, 2016
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Policy The DPH Division of Finance maintains a financial management system that provides: 1) Accurate, current and complete disclosure of the financial status of the Georgia WIC Program, 2) Effective control and accountability for all program grants and funds, 3) Adequate identification of the source and use of funds expended for all program activities, 4) Prompt and accurate payment of allowable costs and proper allocation of those costs in accordance with 7 C.F.R. § 246.13, 2 C.F.R. Part 200, Subpart E Cost principles, and FNS guidelines and instructions, 5) Accurate identification of obligated program funds and the accurate timing of those obligations, 6) Timely and appropriate resolution of claims and other matters resulting from audit findings and recommendations, 7) Appropriate and accurate adjustment of all program expenditures, 8) Minimal elapsed time between receipt of federal funds and the disbursement of these funds for program costs, and 9) Local agency financial management systems that comply with requirements prescribed by FNS and DPH.
Purpose This procedure identifies and describes the financial management system used by the DPH Division of Finance and the Georgia WIC Program to record financial transactions in a manner that complies with the requirements of 7 C.F.R. § 246.13, Governmental Accounting Standards Board (GASB) and Georgia Legislative standards. State law mandates that the State Auditors perform a financial audit of the financial management system and records of the Department of Public Health each fiscal year. Procedure I. DPH Division of Finance and Georgia WIC utilize Concur and TeamWorks, a PeopleSoft based application for the recording and tracking of all program expenditures through a series of financial system modules including (see TeamWork Financial Modules):
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A. Human Capital Management and Labor Distribution – used for recruitment, employee timekeeping and approval, and personal services (salary, wages and fringe benefit) cost recording and tracking, B. Concur – used for employee travel arrangements, approval and travel cost recording and tracking (see Concur), C. Purchasing – used for initiation of procurement, approval and recording and tracking of non-personal services costs other than travel and other non-procured expenditures D. Accounts Payable – used for payment of vendors E. Accounts Receivable – used for receipt of funds F. General Ledger, and G. Asset Management – used for management of inventories
II. DPH Division of Finance and Georgia WIC utilizes the TeamWork controls, other specific Georgia WIC controls (described later) and the Audit Readiness Toolkit for Districts to insure the proper use and accountability for all funds and financial transactions. Georgia WIC contracts with county Health Departments (local agencies) to certify participants, provide case management, food instrument issuance and nutrition education. By contractual obligations delineated in AD-1 Georgia WIC Program Master Agreement (Contract between the Department of Public Health and County Board of Health for the Distribution of Federal and State Funds for the Administration of Public Health Services), the county Health Departments agree to maintain Financial Management Systems that comply with the standards for financial management systems above and in O.C.G.A. § 31-3-8. WIC financial records for the county Health Departments are subsidiary or supplemental to the state WIC program. To obtain reimbursement for WIC services delivered, county departments must submit monthly reports to the Division of Finance through the Uniform Accounting System (UAS) Monthly Income and Expenditure Report. AUTHORITY 2 CFR Part 200, Subpart E – Cost Principles 7 CFR § 246.13 Financial Management System O.C.G.A. § 31-3-8 County Boards of Health Records Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL NSA Program Costs
NSA-500.02 Effective Date: October 1, 2016 No. of pages: 4
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Policy The Georgia WIC Program and the DPH Division of Finance record costs as “food costs” and “nutrition services and administration” (NSA) costs. NSA costs are recorded as either direct costs or indirect costs allowable as stated under 7 C.F.R § 246.14 – Program Costs, 2 C.F.R. Part 200, Subpart E Cost Principles and WIC Cost Allocation Guide. The Georgia WIC Program utilizes DPH’s indirect cost rate agreement approved by the United States Department of Health & Human Services (HHS) Division of Cost Allocation to determine its share of indirect costs (see DPH Indirect Cost Rate Agreement). As agreed, Georgia’s base is total direct costs excluding capital expenditures and that portion of each sub award in excess of $25,000 and flow-through funds. In determining Georgia WIC’s share of DPH’s indirect cost, the DPH indirect cost rate is not applied to a base containing food costs. Purpose This procedure identifies and describes the procedures used by the Georgia WIC Program and the DPH Division of Finance to identify, calculate and record program costs in compliance with 7 C.F.R. § 246.14 – Program Costs, 2 C.F.R. Part 200, Subpart E Cost Principles, WIC Cost Allocation Guide and Appendix VII to Part 200 - States and Local Government and Indian Tribe Indirect Cost Proposals Procedure I. Food costs – Georgia WIC classifies and records the following costs as food costs:
A. Cost of WIC Approved Food Listed Supplemental foods redeemed at authorized vendors, B. Cost of exempt infant formula, C. Cost of breast pumps and operationally necessary accessories D. All of these costs are recorded to Direct Benefits
II. Nutrition Services and Administration (NSA) Costs for Clinic Activities – Georgia WIC and its local agencies perform the following functions in order to meet WIC objectives. Georgia WIC classifies and records the following costs as NSA costs (see WIC Cost Allocation Guide for detail descriptions for the items below):
A. Participant Certification/Case Management Costs including:
1. Data collection and risk assessment for eligibility determination, 2. Case Management Costs
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B. Nutrition Education Costs including
1. Preparing, scheduling, providing group or individual nutrition education, 2. Preparing nutrition education materials, 3. Providing High risk nutrition counseling
C. Breastfeeding Promotion and Support Costs including:
1. Preparing, scheduling, and providing group or individual breastfeeding, promotion and support, 2. Preparing breastfeeding promotion and support materials
D. Food Delivery
1. Development and assignment of WIC food packages, 2. Issuing food instruments and accounting for food instrument issuances
E. Health Care Referrals
1. Some screening (excluding laboratory tests), 2. Referrals for other medical/social services such as immunizations, prenatal care, well child care and/or family planning, 3. Follow-up on participants referred for such services, 4. Only laboratory hematological tests for anemia such as a hemoglobin, hematocrit, or free erythrocyte protoporphyrin tests used to determine WIC eligibility. Laboratory tests to screen for other health conditions including, but not limited to, pregnancy, lead and diabetes are not allowable charges to the WIC grant
III. NSA Costs for Program Management Activities – Costs associated with the activities below necessary to meet WIC program objectives are allowable including:
A. Maintaining accounting records, B. Audits C. Budgeting D. Food instrument reconciliation, monitoring and payment E. Vendor Monitoring F. Outreach
IV. NSA Costs are recorded to accounts as required by the State Accounting Office. (see Georgia State Chart of Accounts)
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V. Cost Allocation
A. State WIC Office (SWO) Costs Allocation
1. Direct staff costs for salary, fringes and staff associated travel, regular operating costs and equipment costs are direct charged by department code. Salary costs are supported by timesheets recorded by each employee and approved by each employee’s supervisor through the TeamWorks HCM module. SWO staff are assigned only to WIC duties
2. Indirect staff costs for which some portion is allocable to WIC are allocated through timesheets as above or as an indirect cost allocated through the US HHS State and Local Governments Rate Agreement.
Indirect non-personal services operating costs such as rent or utilities are allocated through this agreement also or on some other equitable basis of distribution as described in the WIC Cost Allocation Guide. All costs are reviewed by SWO for reasonableness, necessity and allowability
B. Local agency costs
1. Direct staff costs for salary, fringes and staff associated travel, regular operating costs and equipment costs are direct charged. Salary costs are supported by timesheets recorded by each employee and approved by each employee’s supervisor. Only costs directly related to the WIC program may be charged to WIC. Staff are also required to enter their time into the Personnel Activity Report System (PARS). Employee timesheets reviewed by supervisors are the official supporting documentation for staff costs.
2. Indirect staff costs for which some portion is allocable to WIC are allocated through timesheets as above or a DPH approved indirect cost rate.
Indirect non-personal services operating costs such as rent or utilities are allocated through this rate also or on some other equitable basis of distribution as described in the WIC Cost Allocation Guide . Non-personal services costs specific to WIC such as rent for a stand-alone WIC clinic can be direct charged.
All costs should be reviewed by District WIC management for reasonableness, necessity and allowability
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VI. Costs Allowable with FNS Approval Costs requiring FNS approval are governed and approval is obtained through the State Request to Purchase Form and Georgia WIC District Request to Purchase Form. This form is compliant with WIC Policy Memorandum 98-3 and USDA 901 Handbook. VII. Use of Funds Recovered from Vendors, Participants or Local Agencies
A. Recovered funds are used to reduce programmatic costs in the fiscal year collected or in a future fiscal year to cover programmatic costs
B. Recovered funds are not credited until all hearings and reviews are completed
C. Recovered funds are reported through the FNS 798.
D. Documentation supporting recovered amounts is retained as required
VIII. Manufacturer rebates for formula redemptions are applied to food costs in the month in which the payment is received and reported through the 798 Authority 7 CFR § 246.14 2 C.F.R. Part 200, Subpart E Cost Principles WIC Cost Allocation Guide US HHS State and Local Governments Rate Agreement Appendix VII to Part 200 - States and Local Government and Indian Tribe Indirect Cost Proposals Georgia State Chart of Accounts Georgia WIC District Request to Purchase Form
Definition/Supporting Information (None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL NSA External Entities Audit Standards and Sanctions Policy No. NSA- 500.03 Effective date: October 1, 2016
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Policy Entities that contract with the Georgia Department of Public Health (DPH) must meet certain financial reporting requirements. These requirements are defined in the Single Audit Act Amendment of 1996; 2 CFR Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart F - Audit Requirements ; Contract Provisions; DPH Policy; and the O.C.G.A. §§50-20-1 through 50-20-8. The requirements vary according to the dollar amount expended by the entity during its accounting year. Purpose The purpose of the policy is to ensure that those non-federal entities which receive funds from the Department of Public Health (DPH) conform to the standards and requirements imposed by federal and state law and by DPH’s Contracts. Sanctions are imposed on those entities that do not comply with the standards and/or audit requirements.
Procedures I. The Georgia Department of Public Health (DPH) has established standards and sanctions for external entities’ audits under DPH
II. See DPH policy number AU-02001 for detail.
Authority 2 CFR § Part 200, 7 CFR § 277.17, O.C.G.A. §§50-20-1 through 50-20-8. DPH Policy AU-02001 Definitions/Supporting Information (none)
GEORGIA WIC PROGRAM PROCEDURES MANUAL NSA Distribution of Funds
Policy No. NSA- 500.04 Effective Date: October 1, 2016
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Policy
Georgia WIC accesses and distributes the WIC grant in accordance with 7 CFR §246.16, Distribution of Funds. Purpose This procedure identifies and describes processes for accesses and distributing the WIC grant. Procedure I. Distribution and application of grant funds to Georgia from USDA
A. Georgia WIC shall use all grant funds only for the purposes of the WIC program. Georgia WIC executes an annual agreement with USDA and obtains approval of its State plan prior to the receipt of the current fiscal year grant.
B. USDA awards funding to Georgia WIC each year based on funding formulas used to allocate funds to all State agencies for both food costs and nutrition services and administration (NSA).
C. Transfers of funds between fiscal years
1. Back spend authority Georgia WIC may back spend prior fiscal year funds in accordance with 7 CFR § 246.16(b)(3) when necessary and circumstances permit. If analysis of the necessity and circumstances indicate the implementation of back spend authority, the Deputy Director of Program Administration will make a recommendation to do so. 2. Spend forward authority
Georgia WIC may spend forward Nutrition Services and Administration (NSA) funds up to an amount of three (3) percent of its total grant (NSA and food grants) in any fiscal year. Georgia WIC may only use these NSA funds spent forward for NSA costs incurred in the next fiscal year. Funds spent forward must be the first funds expended by the state agency for costs incurred in the next fiscal year.
Upon prior approval by USDA, Georgia WIC may spend forward additional NSA funds up to an amount equal to 0.5% of its total grant for
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the development of a management information system, including an electronic benefit transfer (EBT) system in the next fiscal year . II. Distribution of funds to local agencies
A. Georgia WIC will provide to all its contracted local agencies and contractors providing WIC services all funds awarded to Georgia except funding necessary to operate the State WIC Office (SWO) and pay for food costs funded directly by the SWO. Georgia WIC does not advance local agencies funding. Local agencies are allocated budgets annually for planning and contracting purposes. Monthly, Georgia WIC reimburses local agencies the reported actual costs of operations in adherence with their allocated budgets. B. Since the SWO pays for food costs through food instrument redemption and contractors directly, Georgia WIC allocates no food funds to local agencies for food costs.
C. Annual Allocation
For each federal fiscal year (FFY), Georgia WIC will develop local assigned caseload targets. These targets are based on the prior FFY caseloads and adjusted for an appropriate targeted growth rate for the next FFY.
1. Local agencies that meet or exceed caseload targets using the current FFY four-month closeout, one month (30 day) caseload and one month (issued) caseload will be assigned a new target using the highest one- month participation.
2. Local agencies that do not meet caseload targets using the current FFY four-month closeout, one month (30 day) caseload and one month (issued) caseload will be assigned a six-month caseload target.
3. Each FFY, SWO establishes the amount of NSA funds to be made available to the local agency by the use of the following formulas:
a. Initial funding ÷ statewide caseload ÷ 12 months = Rate
b. Caseload x Rate x 12 months = Local Agency Allocation
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4. As additional NSA funds become available for local agency allocation, those funds will be allocated using the funding formula without an increase in assigned caseload.
D. Participant Cost Adjustment SWO may assess Local Agencies a participant cost adjustment when they do not average their assigned caseload for the current federal fiscal year. The adjustment will be based on the current FFY four-month closeout, one month (30 day) caseload and one month (issued) caseload. The adjustment is reflected as below: Current FFY initial funding rate x current six month average participation x 12 months = Participant Cost Adjustment. For Local Agencies that exceed their prior FFY assigned caseload, a participant cost adjustment will be allocated in the next FFY. This adjustment will be made based upon the availability of NSA funds and SWO discretion. The adjustment is reflected as below: Prior FFY initial funding rate x participation exceeding caseload x 12 months = Participant Cost Adjustment.
Authority 7 CFR § 246.16
Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL NSA Procurement and Property Management Policy No. NSA- 500.05 Effective Date: October 1, 2016
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Policy Georgia WIC conducts all procurement and property management processes in compliance with 2 CFR Subpart D Post Federal Award Requirements, Property Standards and Procurement Standards. Purpose This policy identifies and describes procedures for procurement conducted and management of property acquired by the WIC program. Procedures
I. Procurement – Georgia WIC adheres to DPH’s Procurement Policy and Procedures Policy PR-11001. This policy delineates the procurement procedures of the state with which the Department and program must comply. These procedures comply with 2 CFR Subpart D, Procurement Standards.
A. To further insure all state and local agency purchases comply with requisite USDA guidance, Georgia WIC purchases are made through the completion of the Georgia WIC Request to Purchase Form. This form includes instruction for completion. This form incorporates guidance detailed in the WIC Final Policy Memorandum 98-3, Non-Computer Equipment Purchases Less Than $25,000 and FNS Handbook 901.
B. To implement comparable policy at the Local Agency level, DPH includes requirements in its Contract with the County Boards of Health section 19. County Purchasing Activity. This section requires counties have in place a current purchasing policy that does not conflict with any Federal, State or local law.
II. Property Management – Georgia WIC adheres to DPH’s Asset Management Policy AM-01001. This policy delineates the property management procedures of the state with which the Department and program must comply. These procedures comply with 2 CFR Subpart D, Property Standards. To implement comparable policy at the Local Agency level, DPH includes requirements in its Contract with the County Boards of Health section 10. Property Management Requirements.
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Authority 2 CFR Subpart D Post Federal Award Requirements, Property Standards and Procurement Standards DPH Procurement Services Policy and Procedures Policy PR-11001 Georgia WIC Request to Purchase Form WIC Final Policy Memorandum 98-3, Non-Computer Equipment Purchases Less Than $25,000 FNS Handbook 901 Contract Between The Department of Public Health and County Board of Health DPH Asset Management Policy AM-01001
Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL NSA Local Agency Funding and Other Requirements Policy No. NSA-500.10 Effective Date: October 1, 2016
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Policy Local agencies must comply with the program requirements as delineated in 7 CFR § 246, Special Supplemental Nutrition Program for Women, Infants and Children, 2 CFR § 200 Grants and Agreements, Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards, the WIC Procedures Manual and the Contract between the Department of Public Health and County Board of Health.
Purpose To identify specific local agency and state agency requirements for funding. Procedures I. Local agencies must:
A. Comply with all terms of the Contract between the Department of Public Health and County Board of Health (commonly referred to as the Master Agreement) and its programmatic annexes.
B. Implement management controls to track and ensure accountability of program funds, assets and property, in accordance with WIC regulations. A penalty of up to $25,000.00 may be charged for the misuse or illegal use of program funds, assets or property. This applies to individuals that embezzle, willfully misapply, steal or obtain by fraud, assets or property, whether received directly or indirectly from USDA. Upon determination that a local agency collection is required due to the non- compliance with WIC or other regulations, comply with collections of funds for all claims. The state agency is responsible for monitoring local agency operations including financial management systems (7 C.F.R. Section 246.19(b)). If any food or NSA funding provided to a local agency is misused, diverted from program purposes, or lost as a result of thefts, embezzlements, or unexplained causes, the state agency should assess a claim against the local agency, as well as require the local agency to submit a corrective action plan.
C. Have a cost allocation plan that has prior approval from DPH, Division of Finance and the Georgia WIC Program.
D. Maintain complete and accurate documentation of allocated funds received and expended by employing General Accepted Accounting Principles (GAAP) and making these records available for audit upon request of the Georgia WIC Program or the Federal Agency.
E. In case of an audit exception, the local agency may be required to repay the Department from the local agency’s non-participating funds.
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F. Federal regulations require the Georgia WIC Program to spend 97% (ninety-seven percent) of its food grant dollars. Failure to meet this mandate may result in the imposition of a penalty. To be consistent with the federal mandate, each local agency will be expected to serve a minimum number of WIC participants as determined by the federal caseload mandate.
G. Complete all monthly Bank Exceptions Reports and Cumulative Unmatched Redemption (CUR) Reports received from Program Administration or the Data Processing Contractor and return within the specified time. Local agencies will monitor clinics for compliance. Failure to correct the errors on the CUR Report when moved to Part Two of the report will require a monetary payback to the Georgia WIC Program when the total amount of the redeemed vouchers exceeds $1,000.00 (one thousand dollars) monthly.
H. Place all employees who are paid entirely by WIC funds into the 301 cost pool.
I. Ensure WIC funds expended toward a computer system are in compliance with the Georgia WIC District Request to Purchase form and associated instructions.
J. The local agency that participates in Using Loving Support to Manage Peer Counseling agrees to the development, operation and evaluation of supervisory clinic staff and Peer Counselors (PC) as prescribed. All peer counseling grant funds will be available as grant-in-aid under Program #329. A Peer Counselor must be a current or former WIC participant and must have breastfed for at least six (6) months. The actual number of peer counselors employed may be determined by the Health Director. A Peer Counselor must be paid a minimum of eleven dollars ($11.00) per hour.
K. A Peer Counselor must be reimbursed for all approved work related expenses as stated in State Accounting Office Statewide Travel Policy (see Statewide Travel Policy - effective 7/1/2015). Georgia WIC recommends each local contractor hire and train alternate Peer Counselors .The purpose of alternate Peer Counselors is to have trained replacements immediately available, in the event of a Peer Counselor position vacancy. The grant award will include additional funds of ten dollars ($10.00) per hour for the training of the alternate Peer Counselors and when they perform any peer counseling duties. Local contractors may elect to hire additional Peer Counselors or increase the number of hours a Peer Counselor works instead of having alternates. Funds from this grant must not be used to supplant existing WIC financial resources.
L. Comply with the Georgia DPH Administrative Policy and Procedures for the administration of funds.
M. Acquire approval from the State (and USDA if necessary) for the purchase of regular operating expenditures and non-computer equipment having a unit cost of $25,000 or more, capital asset expenditures with a total cost of $5,000 or more,
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and information systems expenditures with a total project cost of $5,000 or more per the Georgia WIC District Request to Purchase Form.
N. Complete as required the Inter-Intra Agency Agreement. The Inter-Intra Agency Agreement is an agreement that must be used by all multi-county health districts with each of their counties. Your local agency may add additional terms but must not delete or change any of the existing terms in the agreement. Please note, that for Option II of the agreement, there are specific paragraphs that allow you to select the paragraph that is most applicable to the contractual arrangement between county boards of health (see paragraphs where there is an italicized option). See Inter-Intra Agency Agreement.
O. Complete as necessary the Georgia WIC Facility Renovation Package.
II. Georgia WIC, with the assistance of DPH Finance and DPH Audits, must:
A. Monitor and track local agency level expenditures and review those expenditures to insure they are allocable and allowable costs to the grants.
State administration staff, the WIC Finance Manager, WIC Financial Analysts and DPH Audit staff, will conduct aggregate analysis on a monthly basis to identify irregularities in expenditures by category. This analysis consists of reviewing expenditures by local agency budget and local agency cost category reports. This analysis also includes a determination whether these expenditures are compliant with 2 CFR § 200 Grants and Agreements, Cost Principles. These regulations provide the general requirements costs (expenditures) must meet to be an allowable and allocable charge to the WIC grant. These subsections also provide guidance on cost allocation to which local agencies must adhere. If an irregularity is identified, Program Administration will request explanation of the irregularity from the Board of Health or request the DPH Audits Section review the expenditures.
The DPH Audits Section will review sample MIER reimbursement requests. During its local agency audits, DPH Audits Section samples MIER reimbursement requests to insure documentation reconciles with the request submitted. It also reviews whether the cost associated with the reimbursement are: a) reasonable and necessary and b) allocable to WIC.
State administration staff also reviews specific expenditures with local agency staff as to their eligibility. This review is conducted in compliance with 2 CFR
Part 200, Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards, Subpart E – Cost Principles.
B. Ensure local agencies do not exceed their budgets.
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State administration staff and Division of Finance staff reconcile local agency budgets to each local agency’s allocation. Upon distribution of the Budget Allotment Summary Sheets and execution of the Master Agreements, the lead counties for each local agency are required to load budgets matching their allotments in the Uniform Accounting System (UAS). UAS is DPH’s subsystem for local agency accounting and reporting to the state of Georgia’s general ledger accounting system which DPH is required to use. Once the budget is properly loaded in UAS, the UAS budget prevents local agencies from exceeding their allocation. This is accomplished by UAS rejecting reimbursement requests until the allocations and budgets are adjusted as necessary.
C. Conduct Local Agency management reviews.
DPH Audits Section performs agreed upon procedures review of Local Agency Boards of Health. These are completed for half of the Public Health Districts (nine) each year on a rotating basis. The Audits Section performs the following procedures: a) review of previous audits, b) review of general accounting practices, c) review of expenditures, d) determination of whether the District has conducted its self-review and the results of that review, e) review of certification controls, f) review of benefit issuance controls, g) review of WIC voucher security, h) review of asset management, i) review of food instrument accounting, and j), review of Peer Counseling program.
Authority 7 CFR § 246, Special Supplemental Nutrition Program for Women, Infants and Children,
2 CFR § 200 Grants and Agreements, Uniform Administrative Requirements, Cost Principles and Audit Requirement for Federal Awards
WIC Procedures Manual Contract between the Department of Public Health and County Board of Health
Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM PROCEDURES MANUAL NSA Personnel Activity Report System (PARS) Policy No. NSA-500.17 Effective Date: October 1, 2016
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Policy Georgia WIC tracks Local Agency Level Wage and Salary Expenditures through a Personnel Activity Report System (PARS). Purpose This policy identifies the rules for PARS and provides a PARS handbook describing system access and usage. Procedures I. Rules for PARS
A. All 100% WIC paid employees must record a full day work by Program and Activity using PARS. B. All non WIC paid employees that perform any WIC services must record a full day of work by Program and Activity using PARS. C. Non WIC paid employees that do not perform any WIC services are not required to use PARS D. WIC funding will not be allocated to paid non WIC staff for paid time off (breaks, annual and sick leave, etc.) unless the non WIC paid employees record all Program and Activities for a full work day on a daily basis using PARS E. If a non WIC paid employee records a full day’s work by Program and Activity, WIC’s fair share may be allocated using PARS for charges distributed across all programs for paid time off. F. WIC cannot be charged for employees that are paid by the Local Agency’s State Approved Cost Allocation Plan (Indirect Cost) G. WIC cannot be charged for employees that are paid by the County’s Approved Central Services Cost Allocation Plan H. All history must be maintained for each employee regardless of the employee’s status change from WIC District to Non-WIC Direct.
II. See PARS Handbook for additional Information
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Authority PARS Handbook Definitions/Supporting Information (None)
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL OM No Smoking and Drug-Free Workplace Policy No. OM-400.02 Effective Date: October 1, 2016
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Policy
Local agencies must maintain a drug-free and non-smoking work environment.
Purpose
To ensure compliance with the “No Smoking” requirements as outlined by USDA and the federal and state drug-free workplace requirements.
Procedures
I. The Georgia WIC Program operates under the USDA Certification Requiring Drug- Free Workplace requirements. See USDA Form AD-1049
See the DPH Drug Free Workplace policy for additional information.
II. Mandatory No Smoking
A. The local agency shall post "No Smoking" signs in the areas occupied by the WIC staff and/or participants during the hours of WIC operations.
B. In the event the clinics for voucher issuance are being held at a satellite clinic, i.e., church, public housing, clinic site, community health center, or clinics that are open only once or twice per week, then the no smoking policy would only be in effect during WIC operation hours.
C. If the health department is a no-smoking facility, and such signs are displayed throughout the health department, then there is no need to display a WIC-specific “No Smoking” sign.
Authority
7 CFR § 246.6 (b)(4)
Drug-Free Workplace Act of 1988, Public Law 100-690, Title V, Subtitle D
2 CFR Part 182, Government-wide Requirements for Drug-Free Workplace
Definition/Supporting Information (None)
GEORGIA WIC PROGRAM POLICY AND PROCEDURES MANUAL OM Local Agency CPA Staffing
Policy No. OM-420.01 Effective date: October 1, 2016
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Policy Local agencies will appropriately recruit and classify Competent Professional Authority (CPA) staff into appropriate job codes.
Each WIC local agency must be staffed with: A minimum of one (1) full-time equivalent (FTE) Competent Professional Authority (CPA) providing direct client services for every one thousand (1,000) participants One (1) full-time equivalent (FTE) Registered and Licensed Dietitian (RD, LD) or Licensed Dietitian (LD) providing direct client services for every five thousand (5,000) participants
For example, a caseload of 6,000 participants would require six (6) FTE CPA staff; plus at least one (1) RD, LD or LD. District staff time providing direct client services can be counted towards these requirements; for example qualified district staff can perform both participant services and district responsibilities.
Purpose To ensure adequate and qualified staff for the provision of direct care services for Georgia WIC participants. Procedure
I. Local agencies will hire individuals that meet the CPA definition as defined below.
II. Local agencies will classify Registered and Licensed Dietitians into the appropriate nutritionist Job Code series.
III. Local agencies will classify Registered Nurses (RNs) into the appropriate nursing Job Code series.
IV. The local agency will classify a nutritionist with a Bachelor’s or Master’s degree in a nutrition field and has earned a verification statement of completion from an Academy of Nutrition and Dietetics Accreditation Council on Education in Nutrition and Dietetics (ACEND) accredited Didactic Program in Dietetics (DPD) into the appropriate nutritionist Job Code series.
V. The local agency will classify a nutritionist with a Bachelor’s or Master’s degree in a nutrition field from an ACEND accredited Didactic Program in Dietetics (DPD), but did not earn a verification statement into the appropriate health educator Job Code series.
A. The local agency can accept a letter from the DPD program director stating the individual successfully completed an ACEND approved program, but did not earn a verification statement.
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B. If the applicant is unable to produce a letter, then the coursework will be verified using the CPA Eligibility Verification Worksheet.
VI. The local agency will classify a nutritionist with a Bachelor’s or Master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics or Public Health Nutrition from an accredited college or university that meets the minimum specific coursework criteria into the appropriate health educator Job Code series.
A. The transcript can be reviewed and verified using the Non-DPD required coursework reference; CPA Eligibility Verification Worksheet.
B. Local agency shall keep the CPA Eligibility Verification Worksheet on file at the district office.
VII. Local agencies must ensure that all non-credentialed CPAs have oversight and on-going monitoring by a Licensed Dietitian at the local or district level.
VIII. Personnel Activity Reporting System (PARS) shall be used to determine FTE for staff who work varying hours for WIC each month.
Authority 7 C.F.R. § 246.2 7 C.F.R. § 246.6 (b) (2)
Definitions/Supporting Documentation Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials.
Nutritionist – a person with a Bachelor’s or Master’s degree in a nutrition field and has earned a verification statement of completion from an Academy of Nutrition and Dietetics Accreditation Council on Education in Nutrition and Dietetics (ACEND) accredited program; or a person with a Bachelor’s or Master’s degree in a nutrition field from an ACEND accredited Didactic Program in
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Dietetics (DPD), who did not earn a verification statement but has a letter from the DPD program director stating the individual successfully completed the program; or a person with a Bachelor’s or Master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, or Public Health Nutrition from an accredited college or university where coursework was verified using the Non-DPD required coursework reference; CPA Eligibility Verification Worksheet.
Non-credentialed – does not have current and valid professional license or registration as a nurse, dietitian, dietetic technician, physician, or physician assistant.
Registered Dietitian Nutritionist (RDN, LD) – Completed a minimum of a bachelor’s degree at a US regionally accredited university or college and course work accredited or approved by the Accreditation Council for Education in Nutrition and Dietetics (ACEND) of the Academy of Nutrition and Dietetics, completed an ACEND-accredited supervised practice program at a health-care facility, community agency, or a foodservice corporation or combined with undergraduate or graduate studies, passed a national examination administered by the Commission on Dietetic Registration (CDR), and completed continuing professional educational requirements to maintain registration. In Georgia, the RDN must also be licensed to practice. Licensed Dietitian (LD) – Meets the standards and requirements set forth in the Georgia Dietetics Practice Act. Maintenance of the license requires bi-annual application.
GEORGIA WIC PROGRAM PROCEDURES MANUAL OM
Licensed Practical Nurses (LPNs) Employed as a WIC CPA OM-420.02 Effective Date: March 2, 2017
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Policy Physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials are acknowledged and therefore, authorized to serve in the role as a Competent Professional Authority (CPA). Licensed Practical Nurses (LPNs) are not acknowledged as Competent Professional Authorities (CPAs) and are not authorized to serve in this role. As a result, LPNs shall not be hired or transferred to serve in this role after March 2, 2017. LPNs hired prior to March 2, 2017, and currently serving in a Georgia WIC CPA role may continue to work in this role.
Purpose To comply with federal regulations that define the CPA and ensure a smooth transition in Georgia WIC staffing implementation.
Procedure I. Nutrition Services Directors or designee will submit a list of LPNs working as WIC CPAs to the State WIC Office by June 30, 2017.
II. For LPNs serving in this role prior to March 2, 2017, the state WIC office will provide each district with a letter verifying that the LPN(s) currently serving in the role as a CPA are eligible to continue to provide CPA WIC Services.
III. Districts shall keep the state WIC office issued letter on file as proof of verification of their LPN’s status as WIC CPA’s.
IV. LPNs seeking to transfer to a WIC CPA position in another clinic or District must meet current qualifications for the desired position.
V. Once a LPN WIC CPA has a break in service of one or more business days or a termination of employment, they must meet current WIC CPA definition to be eligible to be hired as a WIC CPA.
VI. Districts will notify the State Program Operations and Nutrition Office when an LPN WIC CPA is no longer in the position for which the district received a letter verifying their status as an eligible WIC CPA. The employment status change will be reported to the State Program Operations and Nutrition Office within 15 days of the effective date.
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Authority Federal CPA definition
Definitions/Supporting Information Competent Professional Authority (CPA) – An individual on the local agency staff who is authorized to determine nutritional risk and prescribe supplemental foods. The following individuals may be authorized and trained to serve as a CPA: physicians, nutritionists (bachelor’s or master’s degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition), registered dietitians, licensed dietitians, registered nurses, and physician assistants (certified by the National Committee on certification of Physicians Assistants or certified by the State medical certifying authority), or State or local medically trained health officials. Break in Service – Separation from service for a period of one or more days.
GEORGIA WIC PROGRAM PROCEDURES MANUAL OM Site Hours of Operation
Policy No. OM- 420.04 Effective Date: April 1, 2017
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Policy Georgia Local WIC clinics must ensure that all the full time sites are open to provide WIC Services to reduce barriers to participation in the WIC Program in accordance with Federal guidelines. (See definition section). Purpose The purpose of this policy is to ensure the District clinics offer core and alternative/extended hours (see definition) of operation that reflect the best method to serve participants, accommodating the needs of working and student applicants/participants in the community. Districts shall provide WIC services to participants in accordance with the following definitions and guidelines, based on one of the three standards (minimum, recommended, and best practice), described below. Reasonable effort shall be made to ensure that alternative hours are distributed among clinics to ensure coverage of the entire service area. Procedures I. Establish Core Hours of Operation
A. The minimum standard hours of operation (required) for each fixed and full time site shall be 40 hours per week based on the district core hours of operation. Within the established core hours of operation, the clinic must include at least 10 alternate hours of operation per month, at the districts discretion. These hours may include a combination of the lunch hour, weekend, evening, and early morning hours, as needed, by the community.
B. The recommended standard hours of operation shall include at least 20 extended hours per month outside of core and alternative hours. Scheduling of the 20 extended hours of operation is at the districts discretion. These hours may include a combination of the lunch hour, weekend, evening, and early morning hours, as needed, by the community.
C. The best practice standard hours of operation shall be at least 40 extended hours per month outside of core hours. The scheduling of the 40 extended hours of operation is at the districts discretion. These hours may include a combination of the lunch hour, weekend, evening, and early morning hours, as needed, by the community.
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II. Publicizing Site Hours
A. Districts shall publicize the availability of alternate and extended hours to participants and applicants in outreach materials, on websites, in call centers and voice-mail messages, via social media, etc. Core hours and alternate/extended hours should be listed on or near the front entrance of the WIC office. Participants must be made aware of hours of operation during the orientation of the WIC program, or given information which states the service hours of operation and closure hours.
B. Working individuals or students shall be given priority consideration for appointments during alternate/extended hours of operation. Other WIC participants or applicants shall be allowed to fill appointments that are not taken by working individuals or students.
III. Full WIC Services
A. During alternate/extended hours of operation, clinics shall offer the same services provided during traditional clinic hours including certification, nutrition education and counseling, breastfeeding education and support, and food instrument issuance. Certain blocks of time, including extended hours, may be set aside exclusively for one or more of these activities as long as all of the services are offered during extended hours at times that meet the needs of working participants and students. In no case shall traveling, answering of telephone lines, or other administrative activity, by itself, be counted as extended clinic hours.
IV. Extended Hours Requirements for Increased Caseload
A. The SWO may at any time require implementation higher than the minimum hours of operation, based on reduction in participation levels to less than 90% of assigned caseload, over a three-month average.
V. Annual Operation Plan
Each district shall provide the State WIC Office (SWO) an Annual Plan of Operation that includes site hours for each site, which includes the required alternative hour plan. Justification will be required explaining why they will not have alternative hours available at a particular clinic site. In extraordinary circumstances where a WIC district cannot provide alternative hours, the district may request a
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temporary waiver. Waivers shall be approved only for the period of time necessary to resolve the extraordinary circumstances that preclude compliance with this policy. In no case shall the total period of time covered by a waiver(s) exceed one year.
VI. Staffing
A. Overtime pay may be used to cover extended hours upon request of the districts and approval of the SWO.
Authority 7 CFR § 246.7(b)(4) As stated in the CFR.246.7 (b) (4). Each local agency that does not routinely schedule appointments shall schedule appointments for employed adult individuals seeking to apply or reapply for participation in the WIC Program for themselves or on behalf of others so as to minimize the time such individuals are absent from the workplace due to such application.
Definitions/Supporting Information Alternative Hours - These are service hours of operation within the required 40 hours per week. The hours before 8:00 a.m. or after 5:00 p.m. during the business week, or on Saturday or Sunday; including the traditional lunch hour (12:00 p.m. to 1:00 p.m.). Hours will not take the clinic over 40 per week. Core Hours - Traditional business hours of 8:00 a.m. to 12:00 p.m. and 1:00 p.m. to 5:00 p.m. Monday through Friday. Extended Hours - Hours in addition to the 40 service hours per week. The hours before 8:00 a.m. or after 5:00 p.m. during the business week, or on Saturday or Sunday. The traditional lunch hour (12:00 p.m. to 1:00 p.m.) is also an extended hour. Fixed (permanent) Site - A site that is solely designated for WIC services e.g. a room or suite of rooms in a health center or business mall. Full time Site - A site that is open 32 - 40 hours per week or more. Mobile Site - A satellite site that is inside a mobile van or other vehicle. Part time Site - A site that is open less than 32 hours per week.
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Satellite Site - A site that is not designated solely for WIC services, such as, a community center. Staff must set up and take down equipment (e.g. laptops, informers, and printers).
GEORGIA WIC PROGRAM PROCEDURES MANUAL OM Emergency Plan
Policy No. OM-430.01 Effective Date: March 24, 2020
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Policy Local agency WIC staff must follow the emergency plans and procedures developed within their respective county public health departments. All emergency plans must align with the Georgia Department of Public Health Emergency Operations Plan. Notify disaster-related evacuees of their eligibility or ineligibility within ten (10) days of the date of the first request for program benefits. Contact the State Emergency Plan Coordinator when the following is needed: • Extension of processing standards (See Policy CT-830.04 Processing Standards Extension Request) • Automated Data Processing (ADP) Pre-printed Vouchers if unable to print at the local agency (ADP contractor has the ability for overnight delivery) • Defer blood testing for up to 90 days during a disaster with State Office approval. • Other requests, guidance or assistance WIC funds must only be used for continuation of WIC Services as no additional funds are designated by law for WIC disaster relief. WIC must operate within its current program context and funding even in disaster circumstances.
Purpose To maintain/restore WIC services to current participants, as soon as possible and to expand services to the eligible population during an emergency. To allow flexibility in program requirements and administration in order to support planning and preparation for continuation of benefits to participants during times of natural or other disasters or public health emergencies. Procedures I. At first sign of an emergency with potential to impact WIC services in the jurisdiction served by the local agency area:
A. Local Agency will:
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1. Provide Electronic Verification of Certification (EVOC) to every participant who is likely to relocate during a certification(See Policy CT-850.01 Transfer of Certification).
2. Provide WIC participants transferring into a clinic with a valid Verification of Certification appropriate WIC benefits without reassessing for eligibility (See Policy CT-850.01 Transfer of Certification).
B. Nutrition Services Director or Designee will:
1. Contact the State WIC Emergency Plan Coordinator to report operational status of district office and clinics.
2. Make a request for disaster guidance and /or assistance to the State WIC Emergency Plan Coordinator if/when needed.
3. Remain in contact with State WIC Emergency Plan Coordinator for specific emergency planning.
4. Utilize websites and district social media accounts to notify the public of changes in clinic and/or retailer operations.
5. Work with the State WIC Emergency Plan coordinator to determine which of the following procedures and adjustments are needed for:
a. Eligibility Procedures i. Treat displaced individuals residing with another family as a separate economic unit. (See Policy CT-800.08 Family, Household and Economic Unit) ii. Use the Client Statement Form for disaster victims when documentation of income, residency, or identification is not available. Follow current Client Statement Form procedure. (See Policy CT-800.02 Residency Requirements)(See Policy CT- 800.03 Income Eligibility Requirement) iii. Follow adjunctive eligibility procedures for Disaster Supplemental Nutrition Assistance Program (D-SNAP) benefits as for regular SNAP benefits. Utilize Thirty (30) day extension period. (Policy CT- 840.01 Certification Period). iv. Assign Risk code 801 (Homelessness) for disaster related evacuees. Conduct online (low risk) or phone (low or high risk) nutrition education contacts. (See Policy NS-200.11 Phone Contact- Nutrition Education)
b. Food Packages
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i. Promote that breastfeeding is the safest, healthiest choice for infants and young children during disasters. Fresh breastmilk should be used within four (4) hours when refrigeration is not possible. ii. Follow Policy NS-210.12 Medical Documentation for issuance of non-contract or exempt infant formulas and WIC-eligible nutritionals, and for participants needing Food Package III. iii. Refer medically fragile individuals in need of medical care to local medical providers to ensure the participant is linked to a health care system during a disaster. iv. Tailor food packages to accommodate those who are homeless, lack food storage or preparation facilities, or where water supply is unsafe or inadequate Policy NS-210.11 Food Packages for Homelessness, Migrancy and Disaster Situations v. Follow Policy FD-920.01 to replace lost/stolen/destroyed vouchers due to an emergency.
c. Voucher issuance
i. Mail vouchers as appropriate. (See Policy FD-940.01 Mailing/Delivery of WIC Vouchers). ii. Request assistance from State Emergency Plan Coordinator for ADP pre-printed vouchers and guidance on issuing, voiding, and tracking this type of voucher.
d. Facilities and Equipment
i. Complete the Surplus/Destruction Form # AM01001C and email to the State WIC Emergency Plan Coordinator if any equipment is destroyed, in need of repair, or transferred to an alternate location. ii. Access or print a copy of your master file. If access to the master file is not possible due to power outage, contact the State WIC Emergency Plan Coordinator who will obtain a copy.
Authority 7 C.F.R. §§ 246.7 and 246.10 Guide to Coordinating WIC Services during Disasters, U.S. Department of Agriculture, 2017 Georgia DPH Emergency Operations
Definitions/Supporting Information ADP- Automated Data Processing – The current ADP Contractor for GA WIC is DXC Technology
GEORGIA WIC PROGRAM PROCEDURES MANUAL OM Emergency Plan
Policy No. OM-430.01 Effective Date: March 24, 2020
No. of Pages: 4 Page 4 of 4
Master File – An enrollment report generated by DXC that lists participant information for all active WIC participants. This report can be found on GWISnet in either alphabetic format, based upon the participant’s last name, or numeric format, based upon the participant’s WIC ID number and clinic number. State Emergency Plan Coordinator – Designee of the State WIC Director who will coordinate with WIC Director, Deputies and Subject Matter Experts to identify the best course of action, and will provide the approved response as well as remain the Point of Contact at the State Office for the duration of the Emergency/Disaster.
GEORGIA WIC PROGRAM PROCEDURES MANUAL OM District Breastfeeding Staff
Policy No. OM-440.02 Effective Date: October 1, 2016
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Policy Each local agency must designate staff to coordinate breastfeeding promotion, education, support activities, breast pump inventory, and peer counselor supervision. Districts must maintain positions for breastfeeding promotion at a rate of one position per 10,000 participants. Purpose To efficiently and effectively impact breastfeeding service delivery and facilitate participant needs; utilizing staff who have appropriate education, skills, and /or experience while operating within their scope of practice.
Procedures I. The Local Agency will fill the Breastfeeding Coordinator position with a qualified Nutritionist, Nurse, Health Educator, International Board Certified Lactation Consultant (IBCLC), Certified Lactation Counselor (CLC), or Certified Lactation Educator (CLE). See Sample Job Description Senior Public Health Educator – Lactation Consultant and Sample Job Description District Breastfeeding Coordinator. II. Districts with greater than 10,000 participants should have more than one breastfeeding position. For example, a district with participation of 15,000 would want 1.5 FTE (Full Time Equivalent) for breastfeeding.
III. Districts with less than 10,000 participants may prorate breastfeeding hours based on participation. For example, a district with 7,500 participants would need at least 0.75 FTE for breastfeeding.
IV. Districts may count peer counselor supervisors meeting the above qualifications towards the recommended Full Time Equivalents.
Authority 7 C.F.R. § 246.3(e)(4) 7 C.F.R. § 246.4(a)(9) 7 C.F.R. § 246.11(c)(7) 7 C.F.R. § 246.11(c)(7) 7 C.F.R. § 246.11(d)
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7 C.F.R. § 246.11(e)
Definitions/Supporting Documentation International Board Certified Lactation Consultant (IBCLC): an individual who specializes in the clinical management of breastfeeding. They are certified under the direction of the US National commission for Certifying Agencies. (Adopted from http://www.ilca.org/main/why- ibclc/ibclc ) Certified Lactation Counselor (CLC): is an individual that has demonstrated knowledge to construct and maintain conditions that predispose mothers and babies to an uncomplicated breastfeeding experience through counseling, education, and support. (Taken from Healthy Children’s Project, Inc) Certified Lactation Educator (CLE): is an individual that educates, counsels, and supports families and the community by providing evidence based information about lactation and breastfeeding. (Adopted from http://www.cappa.net/lactation-educator )
GEORGIA WIC PROGRAM PROCEDURES MANUAL
Use of Text Messaging and Emails to Contact WIC Participants
Policy No. OM- 450.01 Effective Date: October 2019
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Policy Local agencies may choose to use text messages and emails to provide appointment reminders, to convey information about the WIC Program, and to promote WIC services and benefits to WIC participants who have previously signed a written authorization electing to receive text messages, emails, or both from the local agency. All text messages and emails sent by a local agency to a WIC participant must protect the confidentiality of a WIC participant’s PHI and confidential WIC information from unauthorized disclosure. Local Agencies must use an encrypted method when sending text or email messages that contain PHI or confidential WIC Information. Local Agencies may send text or email messages that do not contain PHI or confidential WIC information without encryption, although the State WIC Office recommends encryption for all text messages and emails. Examples of each type of message are included in Attachment A: Examples of WIC Confidential Information and Protected Health Information. A local agency must ensure that only the minimum PHI necessary to complete the intended purpose is included in the encrypted text message or email. Documentation of all two-way conversations with participants must be placed within the MIS system. Staff must delete all text messages and text conversations from their cell phones within five (5) days. While this policy must be used as a minimum standard, local agencies may create their own texting and email policy. However, any texting policy created by a district must, at a minimum, protect PHI under HIPAA and confidential WIC information under the federal regulations and in accordance with DPH policy and must be reviewed and approved by the state WIC office. Local agencies electing to utilize a third-party vendor to send text messages or emails to WIC participants, the third-party vendor must sign a HIPAA business associate agreement. In addition, the contract with the third-party vendor must specify that the vendor will use encryption to send any text message or email which contains PHI or confidential WIC information. If any staff member becomes aware of a possible disclosure of PHI that is not permitted under HIPAA or a possible disclosure of confidential WIC information that is not permitted under the federal regulations, the staff member must report the possible disclosure to the State WIC Office’s legal team within 24 hours.
Districts shall provide annual training.
Purpose To ensure that any text messages or emails sent to WIC participants by the local agency protect the confidentiality of PHI and confidential WIC applicant and participant information from unauthorized disclosure, in compliance with the requirements of HIPAA, the federal regulations, and DPH policy.
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Use of Text Messaging and Emails to Contact WIC Participants
Policy No. OM- 450.01 Effective Date: October 2019
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Procedures
I. Before sending a text message or email to a WIC participant, the local agency shall: A. Explain to each WIC applicant/participant/parent/caregiver that text messages and emails are not secure because:
1. Another person could see and read the text message or email; 2. The text message or email could inadvertently be sent to the wrong person or telephone number; 3. Text messages and emails can be viewed on multiple devices and can be saved electronically, printed out, or played on speakers; 4. Text messages and emails can be forwarded to other people; and 5. While encryption adds an additional layer of privacy protection, even encrypted text messages or emails might not be completely secure.
B. Ask each WIC applicant/participant/parent/caregiver to sign the WIC Participant Email and Texting Consent Form contained in WIC Participant Email and Text Consent Form, or another written authorization form that has been approved by the State WIC Office and which states that they have been informed of the risks of sending PHI and confidential WIC information via text messaging and email, and which states that they authorize the clinic to send them text messages, email, or both containing PHI and confidential WIC applicant or participant information, and which also states that their consent is valid for one (1) year, but they may withdraw the authorization at any time. C. Recommend that, if a WIC participant has any questions about a text message or email they have received from a local agency, the WIC participant call the clinic to ask the question instead of sending the question via text message or email. D. Explain how to download the application to the WIC applicant/participant/caregiver’s cell phone, If the local agency has elected to utilize an encrypted method to send text messages which requires that an application be downloaded to the person’s phone before text messages can be received. II. Provide an in-service training to staff on the appropriate use of texting and emailing to WIC participants. Topics covered must include: A. Protecting the confidentiality of PHI under HIPAA and confidential WIC information under the federal regulations. B. Security of devices and methods used for texting.
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Use of Text Messaging and Emails to Contact WIC Participants
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C. Using only WIC-issued or local agency-issued devices to send a text message to a WIC participant. D. Use of professional language in text messages and emails without use of abbreviations. E. Short, Concise Messaging (Less than 160 characters). F. Translation of messages into the preferred language of an applicant/participant/parent/caregiver with Limited English Proficiency (“LEP”), in accordance with the Department’s LEP Policy. G. Reporting lost or stolen devices immediately to a supervisor. H. Using text messages only for specific work-related purposes and not for business solicitations, religious or political causes, or any matters outside of a specific WIC- related purpose. I. When and how to document information sent via text message and email in patient’s medical record. J. Including a simple option for the recipient to opt out of future messages or emails, for example, by replying “STOP” to an incoming text message or clicking on an “unsubscribe” link in an email. III. Document all information sent to a WIC participant via text messaging or email and any information received from a WIC participant via text messaging or email in the patient’s medical record and in the participant’s WIC record immediately following the conversation, or no later than within 24 hours after the text message or email is sent or received. A. Documentation must include: 1. Date of entry; 2. Name of staff member sending or receiving the text message or email; 3. Date of conversation if not documented on the same day; 4. Brief summary of the communication; and 5. Documentation that the communication was conducted via text messaging or e-mail.
B. Delete messages when: 1. Conversation with participant has concluded. 2. Required documentation has been completed.
Authority Health Insurance Portability and Acountability Act of 1996 45 C.F.R. §§ 160, 162, and 164
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Use of Text Messaging and Emails to Contact WIC Participants
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DPH Policy # GC-09013, Confidentiality of Personal Health Information and Compliance with HIPAA
DPH Form GC-00901A Business Associate Agreement
7 CFR §§ 246.26(d) Definitions/Supporting Information Confidential WIC information - Any information about an applicant or participant, whether it is obtained from the individual, another source, or generated as a result of a WIC application, certification, participation, that individually identifies an applicant or participant and/or family member(s). Examples of confidential WIC information include a participant’s name, address, and telephone number. Covered entities - An entity that is subject to HIPAA because it is a health plan, healthcare clearinghouse, or healthcare provider that transmits any health information in electronic form in connection with a transaction covered by HIPAA. Examples of covered entities include DPH, the Public Health Districts, and the County Boards of Health. In addition, DPH has designated WIC as a covered entity that must comply fully with HIPAA. Protected Health Information (PHI) - Individually identifiable health information in any form, whether oral, written or electronic. Individually identifiable health information refers to information that: (a) relates to the individual’s past, present or future physical or mental health or condition; the provision of health care to the individual; or the past, present, or future payment for the provision of health care to the individual; and (b) identifies the individual or for which there is a reasonable basis to believe it can be utilized to identify the individual. Examples of PHI include a person’s name, home or email address, telephone number, and dates of treatment. HIPAA – the Health Insurance Portability and Acountability Act of 1996 , which contains a Privacy Rule that defines and limits the circumstance in which an individual’s Protected Health Information may be used or disclosed by covered entities. Generally, HIPAA provides that a covered entity may not use or disclose protected health information unless the patient has provided a written authorization or unless disclosure is otherwise permitted under HIPAA.
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Vendor Application and Authorization Process Policy No. VM- 100.01 Effective Date: October 1, 2016
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Policy Federal regulations require that Georgia WIC establish standards for vendor authorization to secure a sufficient number and distribution of vendors that will ensure reasonable participant access and permit effective management of the program. Georgia WIC may establish criteria to limit the number of stores it authorizes as long as the limiting criteria are applied consistently. The Georgia Women, Infants and Children Program shall not discriminate against an applicant or vendor on the basis of race, color, national origin, age, sex, handicap, disability or other impermissible basis as set forth in applicable state or federal law. The State agency must develop and implement criteria to select stores for authorization. The State agency must apply its selection criteria consistently throughout its jurisdiction. The State agency may reassess any authorized vendor at any time during the vendor's agreement period using the vendor selection criteria in effect at the time of the reassessment and must terminate the agreements with those vendors that fail to meet them. The vendor selection criteria must be included in the State Plan in accordance with § 246.4(a)(14)(ii).
Purpose The WIC program is funded by federal tax dollars. Because of this, serving as an authorized WIC vendor is a public trust. Vendor authorization is the process by which the State Agency assesses, selects, and enters into agreements with stores that apply or subsequently reapply to be authorized as WIC vendors. Authorization to participate in the program as a vendor is a privilege, not a right. As a steward of public funds, Georgia WIC must balance the need for participant access with the duty to obtain the lowest fair prices for WIC foods and to prevent fraud. The State Agency shall contract with a sufficient number of Vendors to serve all Georgia WIC participants. The State Agency may limit the number of vendors to enable the State Agency to effectively manage the program.
Procedures I. Number and Distribution of Authorized Vendors
The primary method of regulating the number of authorized vendors is through the use of a vendor-to-participant ratio. The vendor-to-participant ratios are determined prior to each application/authorization period. For vendor authorization, exceptions to the vendor-to- participant ratio conclusions may be considered under the following circumstances:
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A. The need to ensure that each food instrument issuance clinic site in the state has an authorized vendor within a 10 mile radius. B. The need to provide adequate service to participants in a population center of at least ten (10) individuals who have no access to an authorized vendor within a 10 mile radius of the population center.
C. The need to provide adequate service to participants when circumstances make it necessary. Those circumstances may include, but are not limited to, the following:
1. New clinic site opening; 2. Participant caseload increases; 3. New participant population center recognized; 4. Store closings, either voluntary or due to catastrophe; 5. Problems with WIC Program compliance; 6. Problems caused by non-compliance with Food Stamp regulations.
II. Applications for WIC vendor authorization are accepted during the following periods of each federal fiscal year:
A. October 1st to December 31st B. March 1st to May 31st
III. Application Denial
If an application for authorization is denied, the applicant will be barred from reapplication for period of one (1) year with the exception of the Denial Reasons listed below. Denial periods vary based on the reason that an application is denied. At the time that a notification of Denial is issued, applicants will be notified of their reapplication date. Irrespective of the reason for denial, once denied, an applicant who wishes to be reconsidered must allow their Denial Period to expire and re-submit a new application after that date has passed. Applications are not re-considered until new application materials have been submitted.
A. Accepting WIC vouchers prior to Authorization: The denial period is three (3) years. B. Business Integrity and Related Denials: For Business Integrity or Integrity-related reasons, the denial period will be two (2) years.
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C. All Other Reasons for Denial: The denial period is one (1) year. IV. Application Materials All authorization documents are located on the Vendor Information website http://dph.georgia.gov/vendor-information. Applicants are required to retrieve and complete all applicable documents to be considered for authorization as a vendor for Georgia WIC.
V. Categories of Vendors and Length of Agreements
Georgia WIC categorizes applicant/vendors based on the number of stores owned by a singular corporate entity. Vendors owning one (1) store under one (1) corporate entity are identified as ‘non-corporate’ and given a two (2) year agreement term upon authorization. Vendors owning two (2) or more stores under (1) corporate entity are identified as ‘corporate’ and given a three (3) year agreement term upon authorization.
An organization identified as a candidate for a 3 year agreement may request to establish separate 2 year agreements for each store location.
Application procedures vary marginally between the two term categories.
A. Non-Corporate/ Two Year Agreement Applicants
1. Non-corporate retail stores applying for WIC authorization shall submit all required application forms to the Office of Vendor Management (OVM) for review. Required documents include: vendor application, W-9 form, sales tax certificate, corporate information form, food sales establishment license, Supplemental Nutrition Assistance Program (SNAP) permit, lease, deed, or bill of sale, RD 1062 disclosure authorization form, and ACH form. All application forms must be completed, signed by an appropriate vendor representative and submitted within an open submission period.
2. Incomplete applications will be returned to all applicants, which may delay processing of the application. Once the applicant is notified of an incomplete application, the applicant must submit the missing information to OVM within seven (7) days of the written request. Failure to return missing information within seven (7) days will result in an application expiration.
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3. Once all documentation is reviewed for accuracy and alignment with the selection criteria, applicants will be scheduled to attend face-to-face authorization training. Representatives attending training must complete the post evaluation with a score of 80% or better and complete a training checklist to proceed to the preapproval phase of the authorization process.
4. Once training is completed successfully, the application packet will be forwarded to the Georgia DPH Office of the Inspector General (OIG) to schedule an on-site pre approval visit. OIG will coordinate an onsite visit at a time agreed upon by both parties. See policy/procedure OIG Policy and Procedure Manual, Pre-Approvals for details concerning the onsite pre approval visit. Additionally, OIG will conduct a desk audit, which entails a business integrity assessment of the business owners inclusive of background checks. The facility with be assessed based on information provided in the vendor application packet, including adherence to minimum inventory requirements. Once the on-site pre approval visit has been completed, OIG will compile findings from the onsite visit and the desk audit into a comprehensive report that is forwarded to the OVM Vendor Relations Unit.
5. If the applicant meets all applicable selection criteria, authorization will be completed. See Vendor Selection and Limiting Criteria Policy for specific details and guidance.
If the applicant does not meet the minimum inventory requirement, a second visit may be requested by the applicant. Failure to successfully meet minimum inventory requirements on the second visit will result in denial of the vendor application (See Application Denial for denial reasons and period of denial).
6. When all selection criteria are met, the applicant will be mailed two copies of a 2 year agreement for signature.
a. Once a signed agreement is received Authorization is designated by the issuance of a fully executed Vendor Agreement (signed by both Georgia WIC and the vendor approval authorities and issuance of one (1) self-inking vendor stamp. The non-corporate Vendor Agreement term is a fixed length of two (2) federal fiscal years, regardless of the actual authorization date within that two year timeframe. All
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documents and stamps are mailed via UPS next day delivery with delivery confirmation methods. b. For non-corporate vendors, the Vendor Agreement, stamp, shelf talkers, and window decals will be mailed to the individual store via UPS next day mail. Unless corporate and store addresses differ. c. Vendor stamps shall not be reproduced. i. If the vendor stamp is lost, stolen, or damaged, Georgia WIC must be notified immediately to reduce opportunities of fraud and abuse towards the program. Georgia WIC maintains surplus stamps on hand. If stamps are not on hand, Vendor Relations can order a replacement stamp with a guaranteed delivery within ten (10) business days. Once received the stamp will be mailed via UPS next day. ii. The vendor stamp is invalid upon agreement termination, disqualifications or voluntary withdrawal from the Program.
B. Corporate / Three Year Agreement Applicants
1. Corporate retail stores applying for WIC authorization shall submit all required application forms to the Office of Vendor Management (OVM) for review. Corporate applicants must submit a vendor application and corporate information form which contains information related to the corporate entity. In addition to the vendor application and corporate information form, applicants must submit the following documents for each store: corporate attachment, W-9 form, sales tax certificate, corporate information form, food sales establishment license, Supplemental Nutrition Assistance Program permit, lease, deed, or bill of sale, RD 1062 disclosure authorization form, and ACH form. All application forms must be complete, signed by an appropriate vendor representatives and submitted within open submission periods.
2. Incomplete applications will be returned to vendor which may delay processing of your application. Once the vendor is notified of an incomplete application, the applicant must submit the missing information to OVM within seven (7) days of the written request. Failure to return missing information within seven (7) days will result in application expiration.
3. Once all documentation is reviewed for accuracy and alignment with selection criteria, corporate vendors will be required to complete and submit a Corporate Training Checklist certifying store personnel has been trained by the corporation’s designated internal training coordinator in lieu
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of face-to-face training. The completed training checklist must be returned to the OVM prior to authorization.
4. Corporate, Peer Group C vendors, may proceed with an on-site pre approval visit once all required documentation has been accurately completed.
5. For corporate vendors, once successful training is complete, the application will be forwarded for an on-site pre approval visit conducted by representatives of the Georgia WIC Program. The representative with coordinate a date and time to complete an onsite visit at a time agreed upon by both parties. Representatives will assess owners for business integrity and complete background checks. The facility with be assessed based on information provided in the vendor application, including minimum inventory requirements. Once the on-site pre approval visits has been completed, Georgia WIC authorized representatives will compile findings into a concise report and forward to the Office of Vendor Management – Vendor Relations.
6. If the applicant meets all requirements, authorization will be completed. See Vendor Selection and Limiting Criteria Policy for specific details and guidance. If the applicant does not meet requirements due to a failure to meet minimum inventory requirements, a second visit may be requested by the applicant. Failure to successfully meet minimum inventory requirements during the second, scheduled visit will result in a denial of the vendor application. The application denial period is from one (1) to three (3) years depending on the reason(s) for a denial.
7. Once all selection criteria are met, including the successful completion of authorization training and the pre-approval visit, the vendor will be extended a vendor agreement.
a. Two copies of the vendor agreement are mailed to the responsible party of record for signature. Both signed, dated agreements must be returned to the Program. b. Both copies of the agreement are signed, dated by the Director of the Georgia WIC Program after they have been signed and returned by the applicant. c. Welcome packets are created for the authorized vendor. The corporate office will receive a packet which includes 1 copy of the fully executed agreement and 1 copy of the completed corporate attachment form,
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mailed to the corporate address as listed on the application via UPS next day mail with delivery confirmation methods.
The assigned vendor stamp, shelf talkers, and window decals will be mailed to each individual store listed on the corporate attachment via UPS next day mail with delivery confirmation methods.
8. Authorization is designated by the issuance of a fully executed Vendor Agreement (signed by both Georgia WIC and the vendor approval authorities), as well as the issuance of one (1) self-inking vendor stamp to each approved store location. The corporate Vendor Agreement term is for three (3) federal fiscal years regardless of when the vendor is approved during this term.
VI. Expiration of Vendor Agreement - Reauthorization
Upon expiration of the Vendor Agreement, all vendors (corporate and non-corporate), must complete all authorization documents if they intend to continue offering WIC approved food items. Applicants will be required to reapply to Georgia WIC as a new vendor for assessment including submission of all required documentation, successful completion of authorization training via face-to-face training or completion of a training checklist and pre approval visits. See Categories of Vendors and Length of Agreements section for required steps to complete reauthorization upon expiration of Vendor Agreement.
Authority 7 C.F.R. §§ 246.12(g), (h), and (i) 7 C.F.R. § 246.4(a)(14)(ii)
Definitions/Supporting Information VM-100.05 Number and Distribution of Vendors VM-100.02 Vendor Selection and Limiting Criteria VM-110.01 Vendor Training VM-100.04 Vendor Peer Group Criteria Corporate Vendor Agreement – 3 Year Non Corporate Vendor Agreement – 2 Year
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Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management – Vendor Relations and Adm. Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
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Policy The State agency must authorize a sufficient number and distribution of vendors in order to ensure the lowest practicable food prices consistent with adequate participant access to supplemental foods and to ensure effective State agency management, oversight, and review of its authorized vendors. The State agency may establish criteria to limit the number of stores it authorizes. The State agency must apply its limiting criteria consistently throughout its jurisdiction.
Purpose The WIC program is funded by federal tax dollars. Because of this, serving as an authorized WIC vendor is a public trust. Vendor authorization is the process by which the State Agency assesses, selects, and enters into agreements with stores that apply or subsequently reapply to be authorized as WIC vendors. Authorization to participate in the program as a vendor is a privilege, not a right. As a steward of public funds, Georgia WIC must balance the need for participant access with the duty to obtain the lowest fair prices for WIC foods and to prevent fraud.
Procedures I. Number and Distribution of Authorized Vendors
The Georgia Women, Infants and Children Program shall not discriminate against an applicant or vendor on the basis of race, color, national origin, age, sex, handicap, disability or other impermissible basis as set forth in applicable state or federal law. Federal regulations require that Georgia WIC establish standards for vendor authorization to secure a sufficient number and distribution of vendors that will ensure reasonable participant access and permit effective management of the program. Georgia WIC may establish criteria to limit the number of stores it authorizes as long as the limiting criteria are applied consistently.
The primary method of regulating the number of authorized vendors is through the use of a vendor-to-participant ratio. The vendor-to-participant ratios are determined prior to each application/authorization period. For vendor authorization, exceptions to the vendor-to- participant ratio conclusions may be considered under the following circumstances: A. The need to ensure that each food instrument issuance clinic site in the state has an authorized vendor within a 10 mile radius.
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B. The need to provide adequate service to participants in a population center of at least ten (10) individuals who have no access to an authorized vendor within a 10 mile radius of the population center.
C. The need to provide adequate service to participants when circumstances make it necessary. Those circumstances may include, but are not limited to, the following:
1. New clinic site opening; 2. Participant caseload increases; 3. New participant population center recognized; 4. Store closings, either voluntary or due to catastrophe; 5. Problems with WIC Program compliance; 6. Problems caused by non-compliance with Food Stamp regulations.
II. Selection Criteria and Continuing Compliance with Selection Criteria
The selection criteria represent the minimum requirements to be considered for authorization as a Georgia WIC vendor. All applicants1 and vendors must meet or exceed all of the selection criteria at the time of authorization and maintain compliance throughout the agreement period. Vendors are also required to adhere to any changes in the selection criteria made by Georgia WIC during their agreement period, or face termination. Georgia WIC may reassess any authorized vendor at any time during the vendor’s agreement period using the selection criteria in effect at the time of reassessment, and must terminate the agreement of any vendors that fail to meet the current criteria. Georgia WIC will deny an application or terminate the vendor agreement if it is determined that the applicant provided false information in connection with the application. During the application process, Georgia WIC may request additional information that must be provided within the time period specified in the request.
1 An applicant is defined as: anyone deemed associated with the ownership, management or operation of the applicant entity, including owners, officers, partners and, stockholders, registered agents, the immediate family of owners, officers, or partners. Any facts leading the agency to suspect that an applicant or vendor has a business or close personal connection with a WIC vendor that has a sanction history will be thoroughly investigated.
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All requested information must be provided in order to process the application. This includes, but is not limited to, Bill of Sale, Articles of Incorporation, Driver’s License or State issued ID card, Social Security card, food sales, etc. Applications will not be processed until all information is received by Georgia WIC. Vendor applications that are held pending receipt of additional information will expire ten (10) days after the date of the written request for information.
Failure or difficulty in meeting any of the selection criteria may be used as just cause for denial of a vendor application for authorization. Applicants who are denied authorization may reapply after the expiration of the appropriate denial period.
Exception to WIC Limiting and Selection Criteria
The Georgia WIC Program reserves the right to make exceptions to (waive) the limiting and/or vendor selection criteria to address inadequate participant access to supplemental foods. However, competitive pricing and meeting the minimum WIC approved food stocking requirements are not waivable, per federal regulations.
Inadequate Participant Access
Federal regulations require that the State Agency ensures that all WIC participants have adequate access to purchase their WIC food items. By ensuring adequate access to authorized vendors, the Program assists WIC participants in meeting their nutritional goals. Participant access is not defined as participant convenience or preference. Inadequate participant access would cause a hardship to participants. Denial based upon the selection criteria may be waived (see “Exception to WIC Limiting and Selection Criteria”). The Georgia WIC Program will review participant access on a case-by-case basis. Inadequate participant access occurs when the distance between authorized WIC vendors is ten (10) miles or more. Note: Should an applicant location be identified as an area where there is inadequate participant access, it does not absolve an applicant from the responsibility to comply with the terms of the application process as outlined, as a condition of authorization.
The established selection criterion for authorized WIC vendors is as follows:
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A. Complete, Accurate and Truthful Information and Documents All applicants and vendors must provide complete, accurate and truthful information and supporting documents during the application process or whenever requested. If it is later discovered that an applicant or vendor has misrepresented or omitted material information or documents, the application will be denied or the vendor agreement will be terminated. Failure to submit any documents or information requested by Georgia WIC within the required time frame will also result in a denial of the application or termination of the vendor’s agreement. B. Previous Sanction or Violation History with SNAP or WIC Program Applicants who have pending or current Terminations or Disqualifications (or were assessed Civil Money Penalties in lieu of Disqualification) that have not expired will not be authorized. Applicants who were assessed a Civil Money Penalty in lieu of Disqualification will not be authorized during the time period corresponding to the original Disqualification. Similarly, vendors who submit new applications after violations have been identified (during the course of an audit, investigation, etc.) or who may be awaiting the outcome of an appeal will not be authorized. If it is later determined that an applicant had unexpired sanctions at the time of authorization, the vendor agreement will be terminated immediately. C. Previous Applicant History An applicant’s prior application history with the program will be reviewed. Applicants whose information or documents are inconsistent with a previously submitted application or applicants who have engaged in serious fraudulent conduct or misrepresentation in connection with a previous application will be thoroughly investigated and will be denied if it is determined that the previous circumstances still exist. An applicant whose denial period has not expired may not be considered for authorization until after the denial period has expired and a new application has been submitted.
D. Competitive Prices All applicants and vendors are required to submit and maintain prices that are at, or lower than, other vendors currently participating in the program. Applicant – The prices, for the products listed on the application, will be reviewed and compared against the maximum prices allowed in the proposed Peer Group for vendors currently participating in the program. If a prospective vendor’s prices are more than ten (10) percent higher than the maximum prices of actual vendors in the applicant’s proposed Peer Group on more than three (3) items – the applicant will be notified that its pricing is not competitive and the applicant may receive technical assistance. Applicants will be given one (1) additional
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opportunity to re-submit prices after the initial notification. Upon the second submission, those applicants failing to submit prices that are lower than the allowable maximums will be denied authorization.
If this is a cost plus 10% store, the final price must be submitted on the price list as well as posted on the shelf or on signage in the aisle. This is the pricing that is used to determine competitiveness. Authorized vendor – Vendors are required to submit and maintain prices that are at, or lower than other vendors currently participating in the program, within their designated peer group. Vendors must submit shelf pricing each quarter, at a minimum. If a vendor’s prices are more than ten (10) percent higher than the maximum prices of others in its Peer Group on more than three (3) items – the vendor will receive a written notification that its pricing is not competitive. WIC vendors are required to maintain competitiveness during the entire agreement period. Vendors may be assessed at any time and those whose prices remain non-competitive for three (3) additional assessments, the vendor agreement will be terminated for a period of twelve (12) months. A cost plus 10% store must post the final price on the shelf or on signage in the aisle. Pricing must be submitted for all WIC eligible items sold or anticipated being sold at the store location.
E. Acquisition of permit as a vendor in the Supplemental Nutrition Assistance Program (SNAP) and Compliance with the Supplemental Nutrition Assistance Program (SNAP) Regulations. All vendors and applicants must acquire and maintain authorization as a SNAP retail provider. All applicants and vendors must adhere to the SNAP program rules and must remain in good standing. Information submitted by the SNAP program will become a part of an applicant or vendor file and communication from the SNAP program that indicates a vendor’s non-compliance with its rules and regulations will form the basis for a denial or removal from Georgia WIC Program. Applicants and vendors with a history of non-compliance with SNAP’s rules and regulations will be denied or removed from the Program. Also, Georgia WIC will not authorize or reauthorize any applicant once the program has been notified that a retailer has been assessed a Civil Money Penalty (CMP), disqualified or terminated by SNAP. Failure to maintain a SNAP permit for any reason whatsoever, including terminations due to voluntary withdrawal or for non-redemption will result in a denial or termination from Georgia WIC unless necessary to ensure participant access. Retailers who have been assessed a Civil Money Penalty from SNAP will also be denied or
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terminated from Georgia WIC. Pharmacies and military commissaries are exempt from this requirement. F. Length of Time as a SNAP Retailer and Previous Grocery Industry Experience All applicants, except pharmacies and military commissaries, must demonstrate a minimum of twelve (12) months experience as a retail grocer. All applicants must also have a minimum of twelve (12) consecutive months of retail sales history as a vendor under the SNAP Program. Experience can be shown by documentation such as a SNAP vendor permit, Federal/State tax records, or other documentation as the program may request. For those applicants who do not have the required history under the SNAP program, Georgia WIC may consider a waiver upon a written request showing the required SNAP history at another location under common ownership.
G. Business Integrity. All new applicants and vendors must demonstrate business integrity. Georgia WIC will consider business integrity and history of the following: owners, corporate officers, partners and affiliates, or the immediate family of owners, corporate officers, or partners. Georgia WIC will also consider the business integrity and history of anyone involved in the operation of the business or the corporate entity, including managers, stockholders or registered agents. Any of the foregoing people that have a history of fraud, embezzlement, trafficking or has engaged in any activity that Georgia WIC deems to be indicative of a lack of business integrity will not be authorized. This includes but is not limited to the following: 1. Criminal conviction or civil judgments during the past six years against the applicant, the applicant’s owners, officers or managers for any activity indicating a lack of business integrity such as fraud, antitrust violations, embezzlement, theft, forgery, bribery, falsification or destruction of records, making false statements, receiving stolen property, making false claims, or obstruction of justice. 2. Official records of removal from other federal, state or local programs will also be considered.
H. Business Integrity/Background Checks. All new applicants will be subject to background checks to determine the applicant’s business integrity as part of the screening process. Georgia WIC may rely on an investigation using outside sources or upon information already known in a vendor or applicant’s file. For each of the following people, entities or locations - owners, corporate officers, partners and affiliates, or the immediate family of owners, corporate officers, or partners and anyone involved in the operation of the businesses or the corporate
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entity, including managers, stockholders or registered agents, the below information must be disclosed:
Criminal records (current charges and/or past convictions or forfeited collateral for any crime).
1. Official records of removal from other Federal, State, or local programs including whether above mentioned people or corporation ever had a license denied, withdrawn, or suspended or been fined for license violations, such as, business, pharmacy or health licenses. This includes instances where there has been a relinquishment of a license or voluntary withdrawal from a program. 2. Judicial determinations in civil litigation reflecting adversely on the integrity of the above mentioned people, corporation, or affiliate(s). 3. Evidence of attempt to circumvent disqualification from WIC or SNAP a civil monetary penalty imposed for violations of WIC or SNAP. 4. Evidence of prior fraudulent behavior of the above mentioned people, corporation, or their managers. 5. Other evidence reflecting the business integrity history of the above mentioned people, corporation, or affiliate(s). 6. Previous involvement with any business who has submitted an application (regardless of subsequent authorization) to the WIC or SNAP program and the outcome of such application. 7. Previous violation history or Above-Fifty Percent assignment of the retailer.
I. Minimum Inventory of WIC-Approved Foods. Each vendor is required to stock and maintain daily the minimum inventory of approved WIC foods as well as a substantial amount of non-WIC foods. The inventory must be in the store or the store’s stockroom. All WIC minimum inventories must be within the expiration dates during the application process, including the pre-authorization visit. Expired foods do not count towards minimum inventory and is a sufficient ground for denying the application. Note: All observed concerns with sanitation and food safety will be immediately reported to the Georgia Department of Agriculture and may result in an application denial.
The minimum inventory requirements can be found at http://dph.georgia.gov/vendor-information. Pharmacies and military commissaries are exempt from minimum inventory requirements. The vendor must carry other foods outside of the WIC minimum inventory and WIC approved foods. It is expected that all applicants will meet and maintain minimum inventory requirements after the date stated on their application and at all times after the
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pre-approval visit is conducted. Applicants who have not met their minimum inventory requirements after their pre-approval visit has been conducted may make a written request for a second visit. Applicants must provide detailed reasons and corroborating evidence to support their reasons at the time the request is made. Requests will be granted for those who can show that: (1) sufficient merchandise was ordered but the supplier (due to no fault on the part of the retailer), was unable to deliver the merchandise; or (2) sufficient merchandise was in stock within forty-eight (48) hours of the visit but through unexpected customer purchases were depleted before the pre-approval visit; or (3) merchandise became damaged or destroyed after delivery; or (4) for other reasons beyond the control of the retailer. J. Authorization Training. A vendor applicant must attend training and pass the post-training evaluation with a score of 80 or above. Georgia WIC will provide an initial training session in an interactive format prior to authorization, and at least once every two or three years thereafter during the corresponding vendor re- authorization period. Georgia WIC will provide vendors with at least one alternate date on which to attend interactive training. Attendance at training will be documented, a checklist of items discussed must be signed by the vendor and a Post Vendor Training Evaluation test will be given. A passing score of eighty (80) points or higher is required to become authorized. Vendor applicants cannot attend the initial authorization training session until an application for authorization has been submitted and the vendor has registered to attend.
Upon request, the Georgia WIC Program will provide language assistance or accommodation to ensure meaningful access to training for vendor applicants and vendors with a language barrier or a disability.
K. Pre-approval visits. Only those vendor applicants that pass initial screening will receive on-site pre-approval visits from Georgia WIC representatives to verify the information listed on the application and inventory. For non-corporate vendors, pre-approval visits will not be conducted until the vendor has attended training and passed the evaluation with a score of 80 or above. For corporate vendors, only one authorized representative from the store is required to attend training. At least one (1) pre-approval visit is required for each applicant to verify the items listed on the application. The first pre-approval visit will be conducted at the date and time announced by the Georgia WIC staff. Georgia WIC reserves the right to follow up on any items in the application or observed on site at any time during the application process and may conduct additional visits to the applicant’s store
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as required without notice. Failure to cooperate with Georgia WIC during the pre- approval process will result in application denial. L. Re-Scheduling Announced Pre-approval visits. In the event that an applicant suspects that they may not be prepared for their announced pre-approval visit, they may re-schedule the visit twice during the application process. The applicant must contact the Georgia WIC office IMMEDIATELY to prevent denial of the application by calling 1-866-814-5468 or (404) 657-2900. The vendor will only be allowed to change this date twice—but must be completed within a thirty day period or the application will expire and be denied. M. Non-Profit Vendor. Non-profit vendors are not authorized in Georgia. N. Required Minimum Store Hours. To ensure adequate access to food items for participants, the store (with the exception of military commissaries and pharmacies) must be open for business at least eight (8) hours per day, six (6) days per week, and must be open during the hours specified on the Vendor Application. In the event an applicant or vendor’s hours are changed, they must notify Georgia WIC within twenty (20) days of the change. Military commissaries and pharmacies must be open for business at least five hours per day, five days per week. There should be no barriers to participant entry to the store during opening hours (e.g. required store membership or controlled access or entry to the store). O. Suitable Store Location. For new stores applying to Georgia WIC for the first time, the minimum square footage requirement for vendors is 3,000 square feet of continuous retail food sales space open to the public, excluding all administrative and storage space. Note: Not all areas of an applicant or vendor’s store are counted towards the minimum square footage requirement. The square footage areas that are not “continuous retail food sales space open to the public” and are used for other purposes that are irrelevant to the purpose of the Georgia WIC Program will not be considered as a part of the minimum square footage requirement. See Federal Regulations 7 C.F.R. § 246.12, which states: “Retail food delivery systems are systems in which participants, parents or caretakers of infant and child participants, and proxies obtain authorized supplemental foods by submitting a food instrument or cash-value voucher to an authorized vendor.” The program utilizes grocers as part of its retail food delivery service.
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No portion of the store may be located inside of a separate building, nor may any portion be located inside of a facility that is not food retail in nature (e.g. suite on the upper floors of an office building, inside of a community center, daycare, floral shop, etc.). The applicant must provide proof of a lease for at least a three-year period, or proof of ownership of the store location. There must be a store sign to identify the store with the name of the business clearly marked. P. Licensed by the Georgia Department of Agriculture. Each store must have a valid Retail Food Sales Establishment License in the current owner’s name and be in compliance with all state, municipal, and local sanitation standards. A current Health certificate must be posted in the store. Pharmacies and military commissaries are exempt from this requirement. Stores that are on the border of Georgia and another state must have a comparable food sales establishment license from that other state’s Department of Agriculture. Note: All observed concerns with sanitation and food safety will be immediately reported to the Georgia Department of Agriculture.
Q. Compliance with Georgia WIC Program Policies and Procedures. For existing vendors, any violations found during the re-authorization process may result in denial of the application for re-authorization. Vendors and applicants will be required to comply with all federal and state WIC policies.
R. Store Acquisition. Georgia WIC will not approve or continue the authorization of a store location that was sold or assigned to circumvent an unexpired sanction, claim or civil money penalty. Nor will Georgia WIC approve or continue the authorization of a store location that was later transferred to anyone involved in the ownership, operation, management or corporate structure (including registered agent) of location with unexpired sanctions, claims or civil money penalties. 1. The transfer or sale of a retail location with unexpired sanctions, claims or civil money penalties will be closely investigated before the location is authorized. In the event a vendor purchases or acquires a retail outlet that was in the process of being disqualified or which was disqualified from the WIC Program at the time of acquisition, the vendor's application for that outlet location shall not be considered until Georgia WIC makes a determination that the sale was a bona fide, arms-length transaction and that no one involved in the ownership, management, operation or corporate structure (including registered agents) will remain involved in the newly purchased store. If it is later determined that the applicant failed to abide by this provision, the vendor will be immediately terminated and subject to a claim.
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2. Ownership transfers of an authorized location to anyone related to the ownership, management or operation2 of vendor retail outlet having unexpired sanctions, claims or civil money penalties at the time of the transfer is prohibited. It if is later determined that there was a failure to abide by this provision, the vendor will be immediately terminated and subject to a claim.
S. Above 50% Criterion. All applicants, except pharmacies and military commissaries, will be assessed to determine whether they derive, or have the potential to derive, more than fifty (50) percent of their eligible food sales revenues from WIC food instruments. Vendors that meet the above 50% criterion will not be authorized unless denial of authorization for that applicant would result in inadequate participant access.
T. Infant Formula Suppliers. All vendor applicants are required to purchase infant formula solely from the suppliers selected and approved by Georgia WIC. The Program does not allow vendors to purchase infant formula from other program vendors. Only purchases from the approved list of manufacturers, distributors and wholesalers will be permitted. Records of infant formula purchases must be maintained for a minimum of three (3) previous years plus the current year (or until any pending investigations are closed). In the event of an investigation, only purchase invoices from those permitted suppliers will be considered as legitimate. The list of authorized manufacturers, distributors and wholesalers are posted on the Georgia WIC vendor website. The program may also require vendors to supply the program with written permission to confirm their infant formula purchase history with suppliers.
U. WIC Acronym and Logo. A WIC vendor or applicant may not use the WIC acronym, the WIC logo, or close facsimiles thereof, in total or in part, either in the official name in which the vendor is registered or in the name in which it does business. The WIC vendor or applicant may not use the WIC acronym, the WIC logo, or close facsimiles thereof, in total or in part, in an unauthorized manner on packages, product labels, proprietary materials including pamphlets and brochures, or in any form of marketing, promotional material or advertisement of the store.
2 A person associated with the ownership, management or operation of the applicant/vendor entity, includes owners, officers, partners and, stockholders, registered agents, the immediate family of owners, officers, or partners. Any facts leading the agency to suspect that an applicant or vendor has a business or close personal connection with a WIC vendor that has a history of violations will be thoroughly investigated.
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V. Purchase Invoice Receipts. Vendor Applicants must submit, upon request, purchase invoice receipts, bills of lading or recent invoices that show the purchase of items intended for sale in their stores. Failure to submit the requested documentation within the time frame stated in the request will result in denial of the vendor application.
W. Automatic Clearing House (ACH) Application. Vendors who are authorized for participation in Georgia WIC will receive an ACH enrollment form. Vendors will have five business days from the date of receipt of the form to enroll. Failure to enroll in ACH within the allotted timeframe will result in termination of the vendor agreement.
X. Provision of Incentive Items. Georgia WIC will not authorize or continue the authorization of a vendor that advertises, promises, provides, or indicates an intention to provide prohibited incentive items to customers. Incentives include, but are not limited to, free or complimentary gifts, home delivery of foods, store memberships, and other free or discounted services. Y. Pharmacies. A vendor who is placed in the Pharmacy Peer Group is only permitted to redeem special infant formulas and medical foods as specified on the Georgia WIC vendor website. All Pharmacy peer group vendors must be licensed and remain in good-standing with the Georgia State Board of Pharmacies to provide prescription drugs and special medical foods in Georgia. Pharmacies are not required to maintain a SNAP permit, nor are they required to undergo an Above Fifty-Percent assessment.
Authority 7 C.F.R. § 246.12(g) 7 C.F.R. §246.3(e) 7 C.F.R. § 246.4(a)(14)(ii)
Definitions/Supporting Information VM-100.05 Number and Distribution of Vendors VM-100.01 Vendor Application and Authorization Process VM-110.01 Vendor Training VM-100.04 Vendor Peer Group Criteria
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Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management – Vendor Relations and Adm. Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Above Fifty Percent Vendor Assessment Policy No. VM-100.03 Effective Date: October 1, 2016
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Policy Vendors that derive more than 50 percent of their annual food sales revenue from WIC food instruments, and new vendor applicants expected to meet this criterion under guidelines approved by FNS, are defined as above-50 percent vendors. Georgia WIC will conduct an annual assessment of each current vendor, except pharmacies and military commissaries, to determine if they derive more than fifty (50) percent of their food revenue from WIC food instruments. Vendors will also be assessed at re-authorization. New vendors will be assessed within six (6) months of authorization to determine if they derive more than fifty (50) percent of their food revenue from WIC food instruments.
Purpose To identify authorized vendors and vendor applicants that meet the criterion for above 50% vendors in compliance with the requirements of the federal regulations. Procedures The Georgia WIC Program’s Office of Vendor Management (VM) must conduct Above-50% (A50) vendor assessments for all new vendors within 6 months of authorization as well as annual A50 assessments of all existing vendors. The GAWIC-VM also must determine whether vendor applicants are expected to be A50 vendors prior to authorization. If any vendor is determined to be deriving more that 50% of their food sales from WIC redemption transactions, GAWIC will terminate the vendor’s contract for no longer meeting one of its selection criteria. If a vendor’s SNAP redemptions exceed its WIC redemptions, no further assessment is required. The vendor would be deemed a regular vendor.
The definition of “food sales” when identifying A50 vendors, is the sale[s] of all foods that are eligible items under the Supplemental Nutrition Assistance Program (SNAP). The annual period may be the most recent calendar year, fiscal year, or other 12-month period. If the food sales data obtained by GAWIC-VM covers less than a year (e.g., for a vendor that has been in operation for six months), GAWIC-VM will not annualize the amount of food sales. WIC redemption data used in the State agency’s calculations should cover the same period covered by the vendor’s food sales amount.
Although GAWIC-VM will take steps to minimize the reporting burden imposed on vendors (e.g., by using WIC and SNAP redemption data to identify the vast majority of vendors who are regular vendors), GAWIC-VM will need to obtain documentation of food sales data from vendors whose status cannot be determined based on data already available. It is the vendor’s responsibility to maintain and submit the documentation required by the program. The vendor must maintain inventory records used for Federal tax reporting purposes and other records GAWIC-VM may
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require for the period of time specified in the vendor agreement. Upon request, the vendor must make available all program-related records.
Vendors determined to be probable A50 must be provided the opportunity to refute the designation. For all vendors who are moved to Peer Group G, notification to the vendor is required. The notification must include the proposed peer group designation decision along with details specifying the vendor’s rights to an Administrative Appeal. GAWIC prohibits the use of incentives and will not except such goods or services. This is to ensure no conflict of interest or result in a liability for the WIC Program.
Step 1
GAWIC-VM must determine whether vendor applicants are expected to be above-50% vendors. GAWIC-VM must ask vendor applicants:
1. Whether they expect to derive more than 50 percent of their annual revenue for the sale of food items from transactions involving WIC redemptions. 2. If the store is dependent upon receiving WIC Authorization before it can open for business. 3. To indicate whether the store SNAP redemptions exceeded $2,100 for the prior tax year.
A vendor who answers in the affirmative must be treated as an above-50% vendor and will not be authorized as a WIC Vendor.
Step 2
SNAP TO WIC COMPARISION
The GAWIC-VM must reassess the status of new vendors within 6 months after authorization to determine whether or not the vendors are probable above-50% vendors. Upon completion of this assessment, if the vendor’s WIC Redemptions are more than 50% of total WIC and SNAP redemptions combined, the vendor is identified as potential A50. A Food Sales Calculation & Self Report Verification is performed to definitively determine the vendor’s Peer Group status.
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Based on the calculation of WIC redemptions as a percent of total WIC and SNAP redemptions combined for the same period, the GAWIC-VM must determine whether a currently authorized vendor meets the above-50% criterion. If GAWIC-VM determines WIC redemptions are more than 50% of total WIC and SNAP redemptions combined, the vendor must be deemed to be a probable above-50% vendor. A Food Sales Calculation & Self Report Verification must be performed. See Above 50% Verification Form for more information
WIC to SNAP redemption ratios for new and existing vendors are conducted by utilizing the WIC Reporting – A50 database, which also performs the total A50 evaluation. The Integrity Profile (TIP) system’s “Potentially Above 50% Vendor” report can be used for existing vendors, which also compares vendors’ WIC and SNAP redemptions.
Step 3
FOODS SALES CALCULATION
The next step in definitively determining the vendor’s Peer Group status, GAWIC-VM will collect food sales data from the vendor and compute the ratio of annual WIC redemptions to annual food sales in order to designate the vendor properly. After obtaining the annual food sales amount for a vendor, GAWIC-VM will calculate the ratio of annual WIC redemptions to total annual food sales (i.e., WIC redemptions divided by total food sales) and designate the vendor as an above-50- percent vendor or a regular vendor.
The food sales amount used in this calculation must be a documented amount that includes sales of SNAP-eligible items only. A documented food sales amount is an amount that is supported by written sales or financial statements, reports, tax forms, or other records sufficient for establishing SNAP-eligible food sales. SNAP-eligible food sales amount from a vendor’s annual gross food sales amount can be determined by utilizing the WIC Reporting – A50 Database. The other measures included in the Food Sales Calculation are:
1. WIC Redemption Total Exceeds 50% of Gross Sales 2. WIC Redemption Total Exceeds 50% of Exempt Sales 3. WIC Redemption Total Exceeds 50% of Estimated Food Sales 4. WIC Redemption Total (2X) Exceeds Vendor Calculated Food Sales
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Step 4
VENDOR SELF REPORT VERIFICATION
In order to ensure vendors are providing the correct information, basic reliability and validity of self-reported information is tested. Since there may be many sources of bias in self reporting, it is important to demonstrate external validity for self-reports even when face validity is very high. The Vendor Self Report Verification process seeks to identify discrepancies that exceed the reporting threshold of 15%. Legitimacy of self-reported data can be determined by utilizing the WIC Reporting – A50 database. These measures include:
1. GDOR Gross Sales To Vendor Self-Reported Gross Sales Differs By 15% 2. GDOR Exempt Sales To Vendor Self-Reported Exempt Sales Differs By 15% 3. GA-WIC Calculated Eligible Food Sales To Vendor Self-Reported Eligible Food Sales Differs By 15% 4. GDOR Taxable Sales To Vendor Self-Reported Taxable Sales Differs By 15%
Step 5
VENDOR EVALUATION
This is a multi-criteria decision making process based on set parameters. The WIC Reporting – A50 database performs a series of one-to-one comparisons, thereby synthesizing the results. There are established relationships between the aforementioned parameters. Any changes for the parameters will result in a different evaluation status. The process examines the relationship between:
1. WIC Redemption Total (2X) Exceeds Vendor Calculated Food Sales (In combination with 1,2 & 3) 2. WIC Redemption Exceeds $300,000 Per Year (In combination with 1,2 & 3) 3. Vendor Square Footage Is More Than 10,000 (In combination with 1,2 & 3)
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Step 6
VENDOR NOTIFICATION
The vendor is notified of the Probable A50 Status and provided the opportunity to refute the designation. The vendor is moved to PG-G in VIPS in 15 days if the vendor fails to respond to the notification and within 25 days if the refutation process fails. In the notification, the vendor is provided 15 days to communicate an objection to the Probable A50 Status and provide appropriate documentation that supports the objection. If the vendor follows the procedure to object and fails to refute their Probable A50 status or if the vendor fails to follow the proper procedure to object within 15 days of notification, the vendor will receive a final designation as a A50 vendor along with a notice to begin using new redemption rates within 25 days of the original notification. The final designation will also include details specifying the vendor’s rights to an Administrative Appeal.
Authority 7 CFR Part 246.12(g)(4)(I) 7 CFR Part 246.12(h) 7 CFR Part 246.18(a) Interim Guidance On WIC Vendor Cost Containment, June 2006 Fiscal Year 2014 State Plan for the Georgia WIC – File Code: FNS-16-1 (GA) WIC Program
Definitions/Supporting Information Above-50-percent vendors- Vendors that derive more than 50 percent of their annual food sales revenue from WIC food instruments, and new vendor applicants expected to meet this criterion under guidelines approved by FNS.
Food sales- The sale[s] of all foods that are eligible items under the Supplemental Nutrition Assistance Program (SNAP).
WIC Reporting – A50 Database Georgia WIC A-50 Reporting Database – Functional Overview Georgia WIC A-50 Vendors Decision Document Georgia WIC Process Steps for Above 50% Vendors – Standard Operating Procedures
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Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management Cost Containment & Analytics Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Vendor Peer Group Criteria Policy No. VM-100.04 Effective Date: October 1, 2016
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Policy The Georgia WIC Program must establish a vendor peer group system using at least two criteria, one of which must be a measure of geography, such as metropolitan or other statistical areas that form distinct labor and product markets, unless the state agency receives a waiver from the USDA’s Food and Nutrition Services (FNS).
Purpose Federal regulation defines a vendor peer group system as a classification of authorized vendors into groups based on common characteristics or criteria that affect food prices, for the purpose of applying appropriate competitive price criteria to vendors at authorization.
The Georgia WIC Program must inform all vendors of the criteria for peer group, and must inform each individual vendor of its peer group assignment.
Procedures I. Authorized vendors are classified into seven different peer groups based on square footage of the store (excluding administrative and storage space), the number of store locations, and assessment findings.
II. Authorized vendors identified as having derived more than fifty (50) percent of their annual food sales revenue from WIC food instruments will not remain active in the program unless denial of authorization for that applicant or vendor would result in inadequate participant access. If denial of authorization for an applicant would result in inadequate participant access, the applicant is authorized and moved to Peer Group G. For more information see Application for Vendor Authorization. If denial of authorization for an active vendor would result in inadequate participant access, the vendor is moved to Peer Group G.
Peer Group
Type
Description
A
Small
3,000 to 10,000 square feet of continuous retail space open to the public, excluding administrative and storage space.
B
Medium
10,001 to 15,000 square feet
C
Chain
20 or more locations in operation
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Authority 7 C.F.R. § 246.12(g)(4) 7 C.F.R. § 246.2
Definitions/Supporting Information VMCC 0002 Cost Containment VM-100.03 Above 50% Vendor Assessment VM-100.01 Vendor Application and Authorization Process VM-100.07 Termination of Vendor Agreement
D
Large Independent
15,001 or more square feet and less than 20 locations
E
Military Commissary
Located on Military Bases serving military personnel only F Pharmacy Pharmacy – Redeem exempt and/or special infant formulas only including medical foods. No contract formula stated infant formula or other standard WIC foods are allowed for this peer group. Vendors must be licensed by and in good standing with Georgia State Board of Pharmacies.
G Above 50% Vendors and applicants found to be an actual above fifty (50) % vendor where denial of authorization for that applicant or vendor would result in inadequate participant access.
Note: Above 50% Applicants identified as actual or potential above fifty percent (A-50) vendors at application will not be authorized. Vendors assessed as A-50 during the first six-month assessment, during the annual assessment or at re-authorization will be terminated from the program. Pharmacies and military commissaries are exempt from this assessment.
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Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management – Vendor Relations and Adm. Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Number and Distribution of Authorized Vendors Policy No. VM-100.05 Effective Date: October 1, 2016
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Policy The State agency must authorize a sufficient number and distribution of vendors in order to ensure the lowest practicable food prices consistent with adequate participant access to supplemental foods and to ensure effective State agency management, oversight, and review of its authorized vendors. The State agency may establish criteria to limit the number of stores it authorizes. The State agency must apply its limiting criteria consistently throughout its jurisdiction. Any vendor limiting criteria used by the State agency must be included in the State Plan.
Purpose As a steward of public funds, Georgia WIC must balance the need for participant access with the duty to obtain the lowest fair prices for WIC foods.
Procedures Georgia WIC has established criteria to assess the number and distribution of authorized vendors throughout the state of Georgia. The primary method of regulating the number of authorized vendors is through the use of a vendor to participant ratio.
I. Number and Distribution of Authorized Vendors
The vendor-to-participant ratio utilizes the following methodology:
A. Classification of Counties
A classification scheme for distinguishing counties as Rural, Suburban or Urban is employed. The scheme is based on population density data from the National Center for Health Statistics (NCHS), Georgia 2010: Population and Housing Unit Counts, U.S. Bureau of the Census (USCB), and the 2010 Redistricting data - Georgia Department of Community Affairs (DCA). The classifications are as follows:
Population Density - USCB (Square Miles) Population Density - GA-DCA (Per Acre) County Type Participant To Vendor Ratio 8.5 to 288.8 .013 to .5 Rural 40:1 288.9 to 633 .0501 to 1 Suburban 100:1 633.1 and Above 1.001 and Above Urban 145:1
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1. Apply Classification
The aforementioned classification scheme is applied to both certified participants and authorized vendors from the previous federal fiscal year and according to the county code on record.
a. The county code for participants is the code associated with the participant’s home address and the local health in which they certified b. The county code for vendors is the code associated with their physical location and not the mailing or corporate address.
Participants and vendors are then mapped according to their county code.
B. Participant-to-Vendor Ratio Calculated
The participant -to-vendor ratio is calculated based on the number of certificated participants per county code to authorized vendors per county code. Based on the county type (Rural, Suburban or Urban) a vendor saturation analysis is performed to ascertain the need for additional vendors in a geographic area or if new vendors should be limited due to saturation.
C. Frequency of Analysis
The state vendor saturation analysis is determined prior to the start of an application/authorization period. At a minimum, the analysis is executed annually and just prior to the start of the Federal fiscal year by the Vendor Cost Containment Unit and distributed to the Vendor Relations and Adm. Unit for applicant screening.
1. Applications for WIC vendor authorization are accepted during the following periods of each federal fiscal year:
a. October 1st to December 31st b. March 1st to May 31st
D. Utilization of Analysis Results
The results of the analysis, vendor-to-participant ratios, are used to inform the Vendor Relations Staff about the distribution of authorized vendors and to identify areas of saturation that do not require new store authorizations.
New applicants with addresses in the saturated geographic areas may not be considered for authorization. The application packet will be returned to the applicant unprocessed.
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E. Exceptions to the Participant-to-Vendor Ratio
1. For vendor authorization, exceptions to the vendor-to-participant ratio conclusions may be considered under the following circumstances:
a. The need to assure that each food instrument issuance clinic site in the state has an authorized vendor within a 10 mile radius.
b. The need to provide adequate service to participants in a population center of at least ten (10) individuals who have no access to an authorized vendor within a 10 mile radius of the population center.
c. The need to provide adequate service to participants when circumstances make that necessary. Those circumstances may include, but are not limited to, the following:
i. New clinic site opening; ii. Participant caseload increases; iii. New participant population center recognized; iv. Store closings, either voluntary or due to catastrophe; v. Problems with WIC Program compliance; vi. Problems caused by non-compliance with Food Stamp regulations.
Authority 7 C.F.R. § 246.12(g) 7 C.F.R. § 246.3(e) 7 C.F.R. § 246.4(a)(14)(ii)
Definitions/Supporting Information VM-100.01 Vendor Application and Authorization Process VM-100.02 Vendor Selection and Limiting Criteria
Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management – Vendor Relations and Adm. Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Approval of WIC Infant Formula Suppliers Policy No. VM-100.06 Effective Date: October 1, 2016
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Policy Authorized WIC vendors are required to purchase infant formula, to be exchanged for WIC food instruments, directly from suppliers or manufacturers selected and approved by the Georgia WIC Program and are listed on its Approved Infant Formula Suppliers List. The list includes manufacturers registered with the Food and Drug Administration (FDA) as well as licensed wholesalers, distributors, and suppliers. Only Georgia WIC approved Infant Formula is eligible for purchase and distribution. The Georgia WIC Program does not permit authorized vendors to purchase WIC approved infant formula from other authorized vendors or retailers. Approved infant formula suppliers are categorized on the approved list as manufacturers or wholesalers/distributors, and are sub-categorized by location. Vendors may not appeal the State Agency’s decision to include or exclude an infant formula wholesaler, distributor, or manufacturer from the approved list.
Purpose Federal WIC Regulations require that Georgia WIC authorized vendors purchase all infant formula provided to WIC participants from authorized wholesalers and retailers contained on a list developed and maintained by the Georgia WIC Program.
Procedures I. Approved infant formula suppliers are categorized on the approved list as manufacturers or wholesalers/distributors, and are sub-categorized by location. Vendors may not appeal the State Agency’s decision to include or exclude an infant formula wholesaler, distributor, or manufacturer from the approved list.
Licensing Food Firms – Wholesalers, Distributors and Suppliers
A. Georgia based corporations must be registered with the Georgia Secretary of State with an Active/Compliance status. B. Georgia based wholesalers, distributors, and suppliers must have a Food Sales Establishment license from the Georgia Department of Agriculture and be in good standing. Licenses are renewed annually beginning on July 1st. C. Non-Georgia based entities must be approved by another state's WIC program. Note: All suppliers approved prior to November 1, 2014 are grandfathered onto the list.
II. HOW SUPPLIER INFORMATION IS REQUESTED
A. A current approved list is posted on the Georgia WIC Office of Vendor Management (OVM) website and is available to applicants and authorized vendors. The Approved Infant Formula Suppliers List will be updated as suppliers
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are approved and added, or at a minimum, annually. Annual updates shall observe the Federal Fiscal year of October 1st through September 30th.
III. HOW NEW SUPPLIER REQUESTS ARE PROCESSED
A. New or prospective suppliers may be added to the list of approved infant formula suppliers via two scenarios: (1) an authorized WIC vendor that would like to purchase infant formula from a source that is currently not on the approved list; or, (2) a supplier that would like to be added to the list. The authorized WIC vendor or prospective supplier must contact the OVM and submit a formal request to be added to the list.
B. The prospective supplier will be directed to the Infant Formula Supplier Request Form located on the Georgia WIC Vendor Management Website. The completed Formula Supplier form must be returned to the OVM, by a traceable method of delivery (e.g. certified mail) for processing. All Georgia corporations will be verified for active and compliant registration status with the Georgia Secretary of State. Georgia suppliers must submit a copy of their Food Sales Establishment license, and they must be in good standing with the Georgia Department of Agriculture at the time the request is submitted to OVM. Suppliers based outside of Georgia must submit a Food Sales Establishment license that is in good standing with their resident state and its governing statutes.
C. The OVM will notify the supplier of its decision within 5 to 7 business days of receipt of the completed Infant Formula Supplier Request Form. The notice will be prepared using the form letter entitled, Formula Supplier Notification Letter, and will be issued to the requestor via certified mail.
D. A supplier will be added to the approved list within 2 business days after an affirmative decision to recognize the supplier as an authorized source of infant formula purchases has been issued. A member of the Vendor Relations Unit will post an updated listing to the Vendor Information webpage.
E. The newly posted approved list will have an effective date that reflects the date that the last supplier(s) was added to the approved list.
Authority 7 CFR § 246.4(a)(14)(xviii) 7 CFR § 246.12(g)(11) 7 CFR § 246.18(a)(1)(iii)(D) 21 CFR § 106.96(i)
O.C.G.A. §§ 26-2-21 and 26-2-25
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Definitions/Supporting Documentation See Approved Infant Formula Suppliers: http://dph.georgia.gov/infant%20formula%20supplier Infant Formula Supplier Request Form: http://dph.georgia.gov/Infant%20Formula%20Supplier%20Request%20Form
N: Vendor Section/Form and Form Letters/Formula Supplier Notification Letter https://dph.georgia.gov/wic-formula-resources http://www.fda.gov/AboutFDA/Transparency/Basics/ucm336546.htm Notice for Request of Formula Invoice(s) VMVR 0003 – Auditing WIC Infant Formula Supplier Receipts
Contact Information Georgia Department of Public Health Georgia WIC Program - Office of Vendor Management Vendor Relations and Administration Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Termination of Vendor Agreement Policy No. VM-100.07 Effective Date: October 1, 2016
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Policy Georgia WIC will immediately terminate the vendor agreement if it determines that the vendor provided false information or made a material omission in connection with its application for authorization or re-authorization. The vendor may re-apply, as a new applicant, no sooner than one (1) year after being terminated from Georgia WIC. To re-apply, the vendor must complete the application process in its entirety.
Purpose To describe the circumstances under which the vendor agreement may be terminated.
Procedures I. Termination upon Notice
Georgia WIC may terminate the vendor agreement for cause after providing at least fifteen (15) days advance written notice. Use of the vendor stamp shall be discontinued fifteen (15) days after the date of the termination notice. Any food instruments submitted for payment after fifteen (15) days of the date of the termination notice will not be paid. All terminations shall remain in effect during the administrative review process.
II. Reasons for termination may include, but are not limited to, the following:
Three Month Termination Period A. Voluntary withdrawal from the WIC program.
B. The decision to sell the store.
C. Two (2) failed attempts by Georgia WIC to contact the vendor during business hours at the vendor’s reported address and telephone number.
D. Failure to enroll in ACH within the time specified.
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Page 2 of 4 Revised November 5, 2021 Six Month Termination Period E. Failure to provide Georgia WIC with written notice of a change in the vendor’s business within at least twenty-one (21) days in advance of the change (including but is not limited to a change in ownership, name, location, corporate structure, sale or transfer of the business, or cessation of operation.)
F. Determination that the vendor’s SNAP license is invalid or not current.
G. Identification by Georgia WIC of a conflict of interest as defined by applicable state laws, regulations, and policies, between the vendor and Georgia WIC or its local agencies.
H. Failure to meet the selection criteria in effect at the time of assessment at any time throughout the agreement period.
I. Less than $2,000.00 in annual WIC redemptions or not redeeming any WIC food instruments in sixty (60) days, except pharmacies and military commissaries.
J. Vendors that are determined to be an A-50 vendor will be terminated from the program, unless it is determined that termination would result in inadequate participant access.
Nine Month Termination Period K. Failure to provide food instruments, inventory records, food sales or tax information upon request.
L. Reproducing the WIC vendor stamp or the use of a stamping device to redeem vouchers that was not issued by the Georgia WI Program.
Twelve Month Termination Period
M. Use of the WIC acronym, WIC logo, or close facsimiles thereof, in total or in part, in a manner that violates the provisions of this vendor handbook.
N. Accepting food instruments through the mail or mailing any approved formula/medical food directly to the WIC customer.
O. Failure to complete and submit documentation for annual training by the deadline specified by Georgia WIC.
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Page 3 of 4 Revised November 5, 2021 P. Intentionally providing false information or vendor records, other than information or records provided in connection with a vendor application for authorization or re- authorization.
Q. Failure to allow monitoring by WIC representatives, or harassing or threatening any WIC representative.
R. Forging a participant’s signature on a WIC food instrument.
S. Four (4) failed assessments for non-competitive prices within a 12-month period or less.
T. Providing prohibited incentive items as part of a WIC transaction, in a manner that violates the provisions of this handbook.
U. Violation of any federal or state law or regulation, or terms of the WIC Vendor Agreement or Vendor Handbook not otherwise covered by the sanction system.
III. After being terminated from the Georgia WIC Program, the vendor will not be automatically reinstated as an authorized WIC vendor. The vendor may re-apply, as a new applicant, no sooner than the completion of the specified termination period outlined by Georgia WIC. To re-apply, the vendor must complete the application process in its entirety. See Rules of the Department of Public Health for more information.
Authority § 7 C.F.R. § 246.12 (h)(3)(xvii)
Definitions/Supporting Information
VM-100.01 Vendor Application and Authorization Process VM-100.02 Vendor Selection and Limiting Criteria VM-120.02 Assessment of Sanctions for Vendor Violations and Participant Access Determinations VM-130.02 Vendor Civil Money Penalties VM-140.01 Vendor Appeals
Contact Information
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Page 4 of 4 Revised November 5, 2021 Georgia Department of Public Health Georgia WIC Program Office of Vendor Management – Vendor Relations and Adm. Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Confidentiality of WIC Retailer Information Policy No. VM-100.08 Effective Date: October 1, 2016
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Policy
Confidential vendor information is any information about a vendor (whether it is obtained from the vendor or another source) that individually identifies the vendor, except for vendor’s name, address, telephone number, Web site/email address, and vendor type and authorization status. The Georgia WIC Program will apply the same limitations to the use and release of information obtained from USDA-Supplemental Nutrition Assistance Program (SNAP) regarding SNAP retailers, whether or not the retailer is a WIC retailer. Except as otherwise permitted by this section, the Georgia Women, Infants and Children Program (GAWIC) must restrict the use or disclosure of confidential vendor information to:
(1) Persons directly connected with the administration or enforcement of the WIC Program or the Georgia Department of Human Services – Supplemental Nutrition Assistance Program (SNAP) or whom GAWIC Legal Unit determines have a need to know the information for purposes of these programs.
(2) Persons directly connected with the administration or enforcement of any Federal or State law or local law or ordinance. Prior to releasing the information to one of these parties (other than a Federal agency), GAWIC must enter into a written agreement with the requesting party specifying that such information may not be used or disclosed except for purposes directly connected to the administration or enforcement of a Federal, or State law; and
(3) A vendor that is subject to an adverse action, including a claim, to the extent that the confidential information concerns the vendor subject to the adverse action and is related to the adverse action.
Purpose The State of Georgia strongly supports public access to records in an effort to promote transparent and open government, and, thus, finds that public records should be made available for public inspection without delay, except when specifically required by federal statute or regulation to be kept confidential. The federal statute and regulations governing the administration of the Georgia WIC Program (GAWIC) requires that confidential vendor information must be protected from disclosure except as authorized by the federal regulations.
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Procedures I. Generally, all Open Records Act requests made by the public must be immediately forwarded to the Open Records Act Officer immediately, preferably within the same day as the request is received by a DPH employee, in accordance with GDPH Policy #GC- 09002. In the alternative such requests must be immediately forwarded to the GAWIC Legal Unit, preferably the same day the request is received.
II. Where vendor information is requested by persons directly connected with the administration or enforcement of WIC or SNAP, or persons directly connected with the administration and enforcement of Federal, State, or local laws/ordinances, such requests must be made directly to the GAWIC Legal Unit. To process requests in a timely, consistent and orderly manner, and to track receipt and fulfillment of request, the requests must be submitted by email to:
wic-vm@dph.ga.gov
A. When submitting a request through the designated email address above, the following information must be provided:
1. Date of the request 2. Requestor’s name and Title/Position 3. Requestor’s full mailing address (organization, street address, city, state, ZIP) 4. Requestor’s day time phone number 5. A complete description of the information requested 6. Purpose for which the information is being requested
III. If a requestor does not provide the information listed above, the request will be considered incomplete and GAWIC’s consideration of the request will be delayed pending receipt of the additional information needed. A request is considered received when the GAWIC Legal Unit has confirmed receipt of the emailed request. Requests made by phone will not be accepted.
IV. HOW REQUESTS ARE PROCESSED
A. The GA WIC Legal Unit will provide a formal response to a request for confidential vendor information within three business days of receipt of a request. If a request is received after 5 p.m., the request will be considered received on the next business day. The formal response will include: 1. A description of the records
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2. An estimate of the time necessary to compile the records containing the information requested, if the records are available but will take more than three days to compile 3. A request for clarification of the request 4. Data Use Agreement Form (If applicable) 5. Denial of the request accompanied by an explanation of the basis for the denial.
If the formal response asks for clarification of the request, no further response will be made to the requestor until the clarification is received by the GAWIC Legal Unit. Where the request is extraordinarily large such that extensive use of information technology resources or extensive clerical or supervisory assistance by personnel is required, the GAWIC Legal Unit will respond to the requestor to discuss the most appropriate procedure to efficiently meet the request.
B. Information requests are not continuing in nature. Therefore, a request only applies to information available at the time of the request. If additional information becomes available after the date of the original request, the requestor must submit a new request for this information. Any information or portions of information made available by GAWIC will be provided to the requestor in the same format they are maintained by the GAWIC.
If the requestor specifies a preference for a specific format, information will be produced in the requested format if:
1. It is determined that the information exists and is subject to release 2. GAWIC is capable of providing the information in the format requested 3. The format requested is consistent with how the information is maintained
C. Requests for information will be addressed and fulfilled according to the order in which they are received. Multiple requests from the same requestor and/or different requestors from the same organization will be addressed and fulfilled according to the order in which they are received, unless otherwise specified by the requestor or the organization.
D. Confidential vendor information will be transferred using the most secure, permissible modes of transmission to a requestor. Transmissions via email may only be made if encrypted.
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Authority 7 CFR § 246.26(e), (f) GDPH Policy #GC-09002 7 CFR § 278.1(q) O.C.G.A. § 50-18-70 O.C.G.A. § 50-18-71 O.C.G.A. § 50-18-72
Definitions/Supporting Information Related Tools: Microsoft Outlook – Mailbox for wic-vm@dph.ga.gov.
Other Documents: Data Use Agreement Form
Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management Cost Containment & Analytics Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Employee Conflict of Interest Policy No. VM- 100.09 Effective Date: October 1, 2016
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Policy To ensure the integrity of the WIC Program, both of the Vendor Management oversight functions shall ensure that no undeclared conflict of interest or the appearance of a conflict of interest exists for any employees of the Office of Vendor Management (OVM) and the Department of Public Health (DPH) Office of the Inspector General (OIG). Both offices shall ensure that no conflict of interest exists between their personnel and authorized retailers. A conflict of interest will be deemed to exist when an employee of a vendor oversight function is also a worker, owner or has relatives who work at or own a WIC approved retailer/vendor.
WIC OVM and OIG employees shall not engage in any activities which creates a conflict of interest between the employees’ assigned functions and any other interests or obligations or those of immediate family members or business associates.
WIC OVM and OIG employees shall not engage in activities which violate federal or state laws, WIC Policies, or which, in any way, diminish the integrity, efficiency, or quality of the WIC Program. WIC OVM and OIG employees shall not perform their official duties in a manner that would result in preferential or discriminatory treatment to any vendor.
WIC OVM and OIG employees shall not, directly or indirectly, ask for, give, receive, or agree to receive any compensation, gift, reward, or gratuity for performing, omitting, or deferring the performance of any job related duties.
WIC OVM and OIG employees shall not abuse, misuse, or disclose confidential information in a manner that can result in a direct benefit to employee or immediate family member or business associate.
WIC OVM and OIG employees must refrain from directing or recommending that a WIC participant choose or stay away from a specific vendor/retailer to redeem benefits.
WIC OVM and OIG employees must refrain from knowingly making a decision intended to benefit or to disadvantage a specific authorized WIC vendor/retailer.
An owner or spouse of an owner of a WIC authorized vendor is prohibited from being concurrently employed by WIC.
Note: Failure to comply with the terms of this policy may result in the employee being subject to appropriate disciplinary or corrective action, including dismissal.
All conflicts of interest issues or complaints shall be reported directly to the DPH Office of Human Resources.
This policy does not intend to deny any employee opportunities available to all other citizens of the state to acquire private economic or other interests so long as this does not interfere with their WIC duties or disadvantage the WIC Program in any manner. Conflicts of interest are not necessarily unwarranted, unethical or illegal, nor are they always avoidable. Rather, it is the failure to disclose conflicts or potential conflicts to appropriate authorities; to comply with approved
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conflict of interest polices; to continue to engage in a conflict after disapproval by appropriate authorities; or to further conduct oneself in a manner that unethically hurts, hinders, or disadvantages the WIC Program that must be avoided.
Purpose To define what may constitute a conflict of interest between the staff responsible for vendor management oversight and an authorized WIC vendor. To ensure staff safeguard the confidentiality of WIC vendor information.
Procedures I. The OVM shall establish a written conflict of interest policy. Through education and supervision of OVM and OIG staff, OVM will ensure that no conflict of interest exists between OVM and OIG staff and/or vendors (retailers). All federal regulations, state statutes and OVM policies that address the avoidance of a conflict of interest and the safeguarding of vendor information will be reviewed with each OVM and OIG staff within the 1st week of employment and every two (2) years thereafter. See WIC Vendor Management Employee Conflict of Interest Statement
II. All OVM and OIG staff members shall sign a COI statement upon employment and once every two (2) years to coincide with the state agencies Management Evaluation. The employee’s supervisor shall also sign and date the COI statement. A copy of the completed and signed statement for each staff member shall be maintained in the employee file in the Office of the State WIC Director.
III. Each DPH Employee signs a Confidentiality Agreement during New Employee Orientation. The agreement is comprehensive and safeguards the sensitive information about vendors or potential vendors and addresses the commitment to not show prejudice or favoritism toward vendors or potential vendors. Additionally, the signee agrees to not share information with any person or entity that may result in an unfair advantage for any vendor as it related to the Department of Public Health procurement activities.
IV. The signed agreement is maintained in the Office of Human Resources. The tenets of the Confidentiality Agreement will be reviewed at the time that the staff member signs a conflict of interest statement for clarity and understanding.
Authority 7 C.F.R. § 246.26 (e) 7 C.F.R. § 246.26 (f) 7 C.F.R. § 246.12 (r)
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7 C.F.R. § 246.12 (t) O.C.G.A. § 12-3-572
Definitions/Supporting Information Policy Confidentiality of Retailer Information Policy Request for Confidential Retailer Information WIC Vendor Management Employee Conflict of Interest Statement Georgia Department of Public Health Confidentiality Agreement
Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM WIC Retailer Agreements Policy No. VM- 100.10 Effective Date: October 1, 2016
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Policy The Georgia WIC Program extends either a 2 or 3 year agreement to retail applicant locations that meet selection criteria at the time of application.
The Program enters into three (3) year agreements with those food retailers, pharmacies or commissaries that meet the Program’s definition of a corporate vendor. The Georgia WIC Program defines a Corporate Vendor as an authorized vendor that is owned by a corporate entity. A corporate vendor can be a publicly or privately owned corporation or a limited liability company. If an incorporated applicant is seeking authorization for two or more stores.
All other entities enter into two (2) year agreements as non-corporate food retailers or pharmacies.
Each authorized store location will be assigned a vendor number and will receive a vendor stamp with that identifying number. Vendors are not permitted to redeem food instruments at any location until each location is authorized. A newly authorized store cannot begin accepting food instruments until it has received a vendor stamp with its assigned vendor number.
Vendor Eligibility and Location:
1. An eligible vendor is a business entity that is 1) licensed by the Georgia Department of Agriculture and, 2) without a debarment or suspension from United States Department of Agriculture. Military commissaries and pharmacies do not have to be licensed by the Georgia Department of Agriculture. 2. An eligible vendor is a business entity that is 1) registered and licensed by the United States Department of Agriculture Food & Nutrition Service as a retail participant in the Supplemental Nutrition Assistance Program or SNAP (formally the Food Stamp Program) and 2) is in good standing without debarment or suspension from the United States Department of Agriculture or the SNAP program. Military commissaries and pharmacies do not have to be SNAP participants. 3. An eligible vendor must have a fixed location with an official physical address. 4. An eligible vendor must meet all requirements as described in the most recent version of the Georgia WIC Program Vendor Handbook and all addendums. 5. The vendor must comply with the selection criteria, including any changes to those criteria, throughout the agreement period. The Georgia WIC Program may reassess any authorized vendor at any time during the vendor agreement period using the current vendor selection criteria, and will terminate the agreement if the vendor fails to meet those criteria. 6. A vendor authorized as a military commissary or pharmacy will be given certain exceptions to the vendor agreement. The exceptions are outlined in the vendor agreement and the Georgia WIC Program Vendor Handbook.
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Purpose The purpose of a vendor agreement is to establish the terms and conditions for an authorized vendor to sell prescribed supplemental foods under the Georgia WIC Program, in accordance with federal and state laws and regulations. Procedures I. The Georgia WIC Program enters into three (3) year agreements with those food retailers that meet the Program’s definition of a corporate vendor and two (2) year agreements with non-corporate food retailers.
The Georgia WIC Program defines a Corporate Vendor as an authorized vendor that is owned by a corporate entity and seeking authorization for two or more stores. A corporate vendor can be a publicly or privately owned corporation or a limited liability company.
II. Three (3) Year Agreements A. Incorporated applicants must complete and submit a Corporate Information Form along with the vendor authorization application. The Corporate Information Form is available as an electronic document via the program website or a hardcopy of this form may be obtained by calling the Office of Vendor Management, at (404) 657-2900 or toll free within Georgia at (866) 814-5468.
B. If an incorporated applicant is seeking authorization for two (2) or more stores, it must also complete and submit, with its application, a corporate attachment form for each store location. An authorized representative must sign the application and each Corporate Attachment Form.
C. If an entities application packet has been approved, the Georgia WIC Program will extend two original copies of the vendor agreement for signature. Both originals must be returned completed, signed and dated within the designated timeframe. The vendor certifies, through the signature of the owner, or an authorized representative, that he or she understands and accepts all terms of the vendor agreement. The individual signing the vendor agreement certifies that they are authorized to sign the agreement on behalf of the vendor.
D. The designated Georgia WIC Program representative will sign and date both original, returned copies of the vendor agreement. The agreement becomes valid only upon the signature of an authorized representative of the Georgia WIC Program and upon receipt, by the vendor, of an executed copy along with vendor stamps for each authorized store location.
E. A corporate vendor will receive one, fully executed vendor agreement and one will be retained at the State WIC Office. The Corporate Attachment Forms serve as verification of each store location that is authorized under the vendor agreement and, therefore, are addendums to the vendor agreement.
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F. Each authorized store location will be assigned a vendor number and will receive a vendor stamp with that identifying number. Vendors are not permitted to redeem food instruments at any location until each location is authorized.
G. A newly authorized store cannot begin accepting food instruments until it has received a vendor stamp with its assigned vendor number.
Note: If a store location, under a corporate vendor, begins transacting and/or redeeming food instruments before it receives its vendor stamp, that store location will be denied authorization for a period of three (3) years. Amending the 3 Year Agreement If a currently authorized corporate vendor wishes to seek authorization for additional stores during the agreement period, it must submit an updated vendor authorization application, a Corporate Information Form, Corporate Vendor Training Checklist and a Corporate Attachment Form for each proposed store. The authorization of additional stores will not require the execution of a new vendor agreement. The Corporate Attachment Form for each newly authorized store will be an additional addendum to the existing corporate vendor agreement. If one store in the chain violates the Georgia WIC Program regulations and is disqualified, the remaining stores are not affected. III. Two (2) Year Agreements
A. If an entities application packet has been approved, the Georgia WIC Program will extend two original copies of the vendor agreement for signature. Both originals must be returned completed, signed and dated within the designated timeframe. The vendor certifies, through the signature of the owner, or an authorized representative, that he or she understands and accepts all terms of the vendor agreement. The individual signing the vendor agreement certifies that they are authorized to sign the agreement on behalf of the vendor.
B. The designated Georgia WIC Program representative will sign and date both original, returned copies of the vendor agreement. The agreement becomes valid only upon the signature of an authorized representative of the Georgia WIC Program and upon receipt, by the vendor, of an executed copy along with vendor stamps for the authorized store location.
C. The vendor will receive one, fully executed vendor agreement and one will be retained at the State WIC Office. The authorized store location will be assigned a vendor number and will receive a vendor stamp with that identifying number. Vendors are not permitted to redeem food instruments at the applying store location until the location is authorized.
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D. A newly authorized store cannot begin accepting food instruments until it has received a vendor stamp with its assigned vendor number.
Note: If a store location begins transacting and/or redeeming food instruments before it receives its vendor stamp, the store location will be denied authorization for a period of three (3) years. See the Vendor Agreement for a detailed outline of Vendor and Georgia WIC Program responsibilities, termination of the vendor agreement, sanctions, sanctions/violations from previous agreement periods, claims assessed and collected against vendors, criminal penalties, adverse actions and review procedures, severability, renewability, and non-transferability. The vendor agreement does not constitute a license or property interest. If the vendor wishes to continue to be authorized beyond the period of the agreement, the vendor must apply for re- authorization. If the vendor is disqualified, the Georgia WIC Program will terminate the current agreement, and the vendor will have to re-apply to be authorized after the disqualification period is over. The vendor’s new application will be subject to the vendor selection criteria and any vendor limiting criteria in effect at the time of re-application. The Georgia WIC Program Vendor Handbook is part of the vendor agreement, and is incorporated by reference.
Authority 7 C.F.R. § 246.12 (h)
Definitions/Supporting Information VM-100.02 - Vendor Selection and Limiting Criteria VM-140.01 - Vendor Appeals VM-130.03 - Vendor Violations and Sanctions VM-100.07 - Termination of Vendor Agreements VM-130.01 - Establishing and Collecting Vendor Claims VM-100.03 - Above 50 Percent Vendor Assessment VM-130.02 - Vendor Civil Monetary Penalty VM-110.01 - Vendor Training
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Non-Corporate Vendor Agreement - 2 Year Corporate Vendor Agreement - 3 Year Corporate Attachment Form Vendor Annual Training Checklist
Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management Vendor Relations and Adm. Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM WIC Vendor Complaint Protocol Policy No. VM- 100.11 Effective Date: October 1, 2016
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Policy The Georgia WIC Office is very concerned about all forms of program abuse and takes all complaints seriously. WIC participants are not allowed to verbally abuse retail store employees or violate the proper procedures for processing food instruments or cash value vouchers. Equally, WIC authorized vendors are held accountable for observing the program’s policies, procedures and honoring the terms of the vendor agreement. The Georgia WIC Program must document all complaints from applicants, participants, parents or caretakers of infants and children, proxies, retailer/vendors, staff and general public. Complaints of civil rights discrimination must be handled in accordance with 7 C.F.R. § 246.8(b)
Examples of Complaints Filed Against Participants Participant complaints are those complaints filed by authorized WIC vendors or others against WIC participants. These complaints include, but are not limited to: adverse treatment of a vendor's owner, manager or employees; use of altered WIC food instruments (i.e., changing dates, names, or food amounts); purchase or attempted purchase of unauthorized foods with WIC food instruments; persistent attempts to purchase larger quantities of an authorized supplemental food item than listed on a WIC food instrument; transaction of WIC food instruments outside of the valid period; transaction of WIC food instruments at an unauthorized vendor; sale of WIC food instruments or other Food and Nutrition Service (FNS) authorized coupons; and transaction of WIC food instruments by a person not listed on the Georgia WIC Program ID Card (WIC ID). Examples of Complaints Filed Against Vendors Vendor complaints are those complaints filed by WIC participants or others against a vendor. Vendor complaints include, but are not limited to: adverse treatment of a WIC participant by a vendor's owner, manager or employee; charging more to WIC participants than other customers; providing outdated or spoiled food items; refusal to accept manufacturers' coupons, or other store discounts; and Inadequate variety and/or quantity of WIC-authorized supplemental food items.
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Complaints of Civil Rights violations will be handled in accordance with Federal Law and the Department of Agriculture (USDA) policy. The policy states: In accordance with Federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, the USDA, its Agencies, offices, and employees, and institutions participating in or administering USDA programs are prohibited from discriminating based on race, color, national origin, sex, disability, age, or reprisal or retaliation for prior civil rights activity in any program or activity conducted or funded by USDA.
Persons with disabilities who require alternative means of communication for program information (e.g. Braille, large print, audiotape, American Sign Language, etc.), should contact the Agency (State or local) where they applied for benefits. Individuals who are deaf, hard of hearing or have speech disabilities may contact USDA through the Federal Relay Service at (800) 877-8339. Additionally, program information may be made available in languages other than English.
To file a program complaint of discrimination, complete the USDA Program Discrimination Complaint Form, (AD-3027) found online at: http://www.ascr.usda.gov/complaint_filing_cust.html, and at any USDA office, or write a letter addressed to USDA and provide in the letter all of the information requested in the form. To request a copy of the complaint form, call (866) 632-9992. Submit your completed form or letter to USDA by:
(1) mail: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-9410;
(2) fax: (202) 690-7442; or
(3) email: program.intake@usda.gov.
This institution is an equal opportunity provider.
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Purpose
The purpose of the procedure is to capture, document and resolve any complaint regarding program operations at the local and/or state program level related to food delivery and/or concerning any civil rights discrimination. These complaints may be received from applicants, participants, parent or caretakers of infants and children, proxies, vendors, staff or the general public. Participants/authorized representatives/proxies and Vendors have obligations and responsibilities to the Georgia WIC Program.
Procedures I. The Georgia WIC Program will take the appropriate follow up action on all complaints received.
A. Responding to/Resolving Participant Complaints: Vendors may file a complaint against a WIC participant/proxy by calling the Customer Service Hotline or by contacting the Office of Vendor Management by mail. The Office of Vendor Management will log and document the complaint onto the Georgia WIC Vendor Management Complaint log and refer the participant complaint to the Office of Program Integrity and Strategy for follow up and resolution.
B. Responding to/Resolving Retailer/Vendor Complaints: The Office of Vendor Management will accept, investigate, take the appropriate follow up action and resolve all reported vendor related complaints. When a complaint against a WIC vendor is received, the Georgia WIC Vendor Management Complaint form must be completed in its entirety by a staff member of the Vendor Relations Unit. All complaints are logged onto the Georgia WIC Vendor Management Complaint log located on the “K” drive at the following web address: K:\VENDOR MANAGEMENT SECTION/VENDOR RELATIONS C. Resolution Process for Complaints Against Vendors: 1. Complainant must be contacted within (1) one business day of receipt of complaint. a. Verify if complainant wants to be contacted by whom complaint is being logged against.
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b. If resolution takes place on initial call (i.e. policy clarification, verification of WIC approved foods), complete call and document applicable forms and systems as required. 2. Complaint is documented on the Complaint Form with the following information: a. Type of complaint b. Who reported complaint c. Specific details of complaint d. Corrective action/Final Resolution e. Follow-up date (if applicable) 3. WIC Vendor identified in complaint is contacted. a. Discuss specific details of complaint. b. Provide technical assistance (if applicable) c. Ask vendor to state their corrective action plan for resolution. i.e. i. Train employees ii. Contact complainant (if permitted) iii. Proactively correct non-compliance complaint d. Refer to Office of Investigation (OIG), if applicable i. Follow up with complainant ii. Document final resolution in VIPS system and Complaint Log
4. WIC Participant identified in complaint is contacted. a. Discuss specific details of complaint. b. Provide Clarification on Georgia WIC Policies. c. Provide details of complaint to the appropriate Nutrition Services Director or Clinic Representative. 5. Complaints resolved on the initial call a. Document notes section of VIPS with brief summary i. Nature of complaint ii. Who reported complaint iii. Name of person who was contacted at complaint location iv. Corrective Action/Final resolution/Follow-up (if applicable) b. Contact Nutrition Services Director or clinic Representative (if applicable)
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i. Advise outcome of complaint c. Complete Complaint Log i. Date incident reported ii. Vendor number iii. Name of complainant iv. Complaint and resolution
6. When a complaint cannot be resolved on initial call: a. Negotiate a follow-up date for call back agreed upon with the complainant. b. Investigate details of complaint received. c. Contact complainant as agreed. d. Provide final disposition of complaint.
7. After complete resolution has taken place, all parties involved are contacted to ensure satisfactory resolution has taken place.
8. VIPS notations are made and a copy of the vendor Complaint Form is placed in the vendor’s file.
9. All applicable columns related to the complaint log entry are completed to capture all appropriate actions and final disposition(s) of communication of the resolution.
D. Complaints of Civil Rights violations will be handled in accordance with Federal Law and the Department of Agriculture (USDA) policy. The Office of Vendor Management will log and document the complaint onto the Georgia WIC Vendor Management Complaint Form. 1. If the referral is participant related, the complaint will be documented and referred to the Office of Program Integrity and Strategy for follow up and resolution. 2. All vendor complaints will be handled in the usual manner. The complaint form will be updated as the process progresses and updates will be provided to the Office of Program Integrity and Strategy for interim and final reporting to the USDA.
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Authority 7 C.F.R. § 246.12(o) 7 C.F.R. § 246.8(b)
Definitions/Supporting Information Related Tools: VMVR 0014 - Georgia WIC Vendor Management Complaint Log VMVR 0014 - Georgia WIC Vendor Management Complaint Form
Other Related Information: Completed complaint forms and the log are located on the “K” drive; Vendor Management Section/Vendor Relations folder at the following web address: K:\VENDOR MANAGEMENT SECTION/VENDOR RELATIONS Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management – Vendor Relations and Adm. Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Restrictions on Vendor Incentive Items Policy No.VM-100.12 Effective Date: October 1, 2016
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Policy
Federal WIC Regulations require WIC authorized vendors to offer WIC Program participants, parents or caretakers of infant and child participants, and proxies the same courtesies that are offered to other (non-WIC) customers. Accordingly, WIC-authorized vendors are prohibited from offering incentive items solely to WIC participants in an effort to encourage participants to redeem their WIC food benefits at their store locations. Similarly, WIC-authorized vendors may not treat WIC customers differently from non-WIC customers by excluding them from in-store promotions. This includes disallowing the use of coupons or other vendor discounts in WIC transactions that are allowed in non-WIC transactions.
Purpose To describe State agency requirements regarding WIC-authorized vendors’ use of incentive items and other in-store promotions.
Procedures I. Georgia WIC will not authorize nor continue the authorization of a vendor that advertises, promises, provides, or indicates an intention to provide prohibited incentive items to customers.
II. Minimal customer courtesies of the retail food trade, such as bagging or helping load groceries are exceptions.
III. The WIC acronym or WIC logo cannot be used in total or in part on any form of marketing, promotional materials, or advertisements of the store. IV. Permissible In-Store Promotions.
A. Buy One, Get One Free (BOGO) B. Buy One, Get One at a Reduced Price C. Bonus Size Items
V. Terminable and Sanctionable Offenses. Vendors who use advertisements to solicit the business of WIC participants, or who offer prohibited incentives/ incentive items or delivery services to participants, will be subject to sanctions as explained in the Vendor Agreement and the Georgia WIC Program Vendor Handbook.
A. Terminable Offenses. Georgia WIC may terminate the Vendor Agreement for:
1. Misuse or unauthorized use of the WIC acronym; or, 2. Georgia WIC may terminate the vendor agreement for cause if a vendor provides prohibited incentive items as part of a WIC transaction.
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B. Georgia WIC Sanction Schedule. Georgia WIC will impose a sanction against a vendor if it engages in:
1. A pattern of failing to allow in-store or manufacturers’ promotional or free item with a WIC purchase, which corresponds to a six month disqualification upon commission of the third instances of this violation in a 12 month period. 2. A pattern of providing unauthorized food items in exchange for food instruments or cash value vouchers, including charging for supplemental foods provided in excess of those listed on the food instrument, or if an above-50-percent vendor1 provides prohibited incentive items to customers.
Authority 7 C.F.R. § 246.12(h)(3)(iv)
7 C.F.R. § 246.12(h)(8)
WIC Policy Memo #2014-3-Vendor Management: Incentive Items, Vendor Discounts and Coupons.
Definitions/Supporting Information Incentive or Incentive Item: Incentives are defined as an item or service provided by a vendor to attract customers or encourage customer loyalty. . Incentives or incentive items may include, but are not limited to, free or complimentary gifts, such as free food or merchandise, cash prizes, lottery tickets, transportation or home delivery of foods, sales or specials, store memberships, and other free or discounted services.
In-store Promotion: A sales promotion in which a vendor may offer incentive items, vendor discounts or coupons in order to increase sales of certain items or to encourage customer loyalty to the vendor.
Prohibited Incentive Item: An incentive item or promotion that is not equitably provided by a WIC-authorized vendor to both WIC and non-WIC customers. This includes incentives or promotions that are used solely provided to solicit the patronage of a WIC participant or to that
1 The Georgia WIC Program does not authorize applicants, nor will continue authorization of authorized vendors, who meet the criteria for being classified as an Above 50 Vendor. However, in instances where removal of an Above 50 vendor would create an inadequate participant access issue, Georgia WIC will place them in the Peer Group G category until such time as the vendor can be removed from the Program.
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are offered to WIC customers to entice them to transact food instruments; or, that are only offered by a vendor to its non-WIC customers. Prohibited incentive items include cash and lottery tickets. Georgia WIC Program Vendor Handbook Georgia WIC Non-Corporate Vendor Agreement -2 year Georgia WIC Corporate Vendor Agreement -3 year
Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management Vendor Relations and Administration Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Vendor Training Policy No. VM-110.01 Effective Date: October 1, 2016
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Policy Vendor training is conducted to ensure that all vendors are familiar with the Georgia WIC Program’s policies, procedures and prohibited incentive items.
Purpose The State Agency shall provide vendor training designed to assure the most effective, efficient and courteous delivery of service to WIC participants. The policy and procedure describe the vendor training process and all necessary documentation the Georgia WIC Program utilizes to ensure that vendors are prepared to comply with the requirements outlined in the vendor agreements.
Procedures I. The Georgia WIC program has the sole discretion to designate the date, time, and location of all interactive training, except that the Program will provide the vendor with at least one alternative date on which to attend such training. The vendor must inform and train cashiers and other staff on program requirements.
II. Annual vendor training may be provided in a variety of formats, including newsletters, videos, videoconferences, and interactive training sessions.
A. Retail food delivery systems: Vendor training—General requirements. The State agency must provide training annually to at least one representative of each vendor. Prior to or at the time of a vendor’s initial authorization, and at least once every three years thereafter, the training must be in an interactive format that includes a contemporaneous opportunity for questions and answers. The State agency must designate the date, time, and location of the interactive training and the audience (e.g., managers, cashiers, etc.) to which the training is directed. The State agency must provide vendors with at least one alternative date on which to attend interactive training. Examples of acceptable vendor training include on-site cashier training, offsite classroom-style train-the-trainer or manager training, a training video, and a training newsletter. All vendor training must be designed to prevent program errors and noncompliance and improve program service. B. Content. The annual training must include instruction on the purpose of the Program, the supplemental foods authorized by the State agency, the minimum varieties and quantities of authorized supplemental foods that must be stocked by vendors, the requirement that vendors obtain infant formula only from sources included on a list provided by the State agency, the procedures for transacting and redeeming food instruments and cash-value vouchers, the vendor sanction system, the vendor complaint
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process, the claims procedures, the State agency’s policies and procedures regarding the use of incentive items, and any changes to program requirements since the last training. III. The State agency must document the content of and vendor participation in vendor training. Every authorized vendor must participate in at least one type of training annually, regardless of the date of their initial authorization. The Georgia WIC program has the sole discretion to designate the date, time, and location of all interactive training, except that the Program will provide the vendor with at least one alternative date on which to attend such training. The vendor must inform and train cashiers and other staff on program requirements. Annual vendor training may be provided in a variety of formats, including newsletters, videos, videoconferences, and interactive training sessions.
IV. Pre-Authorization and Re-Authorization Training
Vendors must register to attend training and must attend on the date they have selected. If the vendor is unable to attend training on the date selected, they must alert Georgia WIC with an alternate date. For authorization training, vendors are required to show a government issued picture ID prior to admission. See Vendor Authorization Training Checklist.
Vendor applicants cannot attend the initial authorization training session until an application for authorization has been submitted and the vendor has registered to attend. A representative of a corporate vendor with multiple store locations must initially complete the authorized training session and receive a passing score of eighty (80) points or higher. After completing and passing the training session, the corporate vendor is allowed to conduct authorization training for: 1) existing authorized stores at the time of re-application and, 2) new unauthorized stores that will be added to an existing Vendor Agreement. The corporate vendor must conduct authorization training for existing and new locations. The representative must ensure that all training topics are provided to a management representative in each authorized store. Attendance at a training session, prior to becoming an authorized vendor, does not grant the right to begin accepting WIC food instruments. Only a fully executed vendor agreement that is signed by both parties and the receipt of a vendor stamp constitutes authorization.
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V. Annual Training
Authorized vendors must provide documentation of participation in annual training by the deadline specified. In addition, corporate vendors must ensure that each store listed in the current Vendor Agreement receives annual training by the deadline specified. Failure to do so will result in termination of the Vendor Agreement. Failure to provide documentation that each store participated in annual training will result in termination of the store(s).
VI. Customized Training
The Office of Vendor Management will request that a vendor specify the desired training topic(s), type of training and number of employees who will attend the training session. Georgia WIC and the WIC vendor will mutually agree upon location and dates for the customized training.
Authority 7 CFR §246.4(a)(14)(xi) 7 CFR §246.12(ii)
Definitions/Supporting Information (None)
Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management – Vendor Relations and Adm. Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
GEORGIA WIC PROGRAM PROCEDURES MANUAL VM Establishing and Collecting Assessed Vendor Claims Policy No. VM- 130.01 Effective Date: October 1, 2016
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Policy
The State agency may establish a claim in the amount of the full or partial purchase price of each food instrument or cash-value voucher that contained a vendor overcharge, Civil Money Penalty (CMP) or other error. Monetary claims must be paid by the vendor within thirty (30) days of notification.
Purpose When the State WIC Office (SWO) has determined that a vendor has committed a vendor violation that affects the payment to the vendor, it must delay payment or establish a claim to pursue collection of the claim from the vendor. There is a separate procedure utilized to notify vendors of a disqualification from the WIC Program.
Procedures I. ESTABLISHMENT OF CLAIM AMOUNT A. The assigned Vendor Relations Compliance Specialist will send a request to the WIC Vendor Cost Containment Senior Data Analyst, requesting an independent calculation of the claim amount within 5 business days. Once that claim amount has been established: 1. The WIC Vendor Cost Containment Senior Data Analyst will send an audit document to the Vendor Relations Compliance Specialist outlining the dollar amount. 2. The audit document will be utilized to complete the notification to the vendor. 3. The audit document will be filed in the vendor folder and on the WIC drive with the notification letter. 4. The WIC Vendor Cost Containment Senior Data Analyst will follow Policy VMCC 00011 – Adverse Referral & Claim Collections Monitoring to account for all vendor claims assessed.
II. NOTIFICATION OF ASSESSMENT OF CLAIM/OPPORTUNITY TO JUSTIFY AND CORRECT CLAIM AMOUNT. A. The assigned Vendor Relations Compliance Specialist will send a notice of assessment of a claim to the vendor within 90 days of either the date of detection of the vendor violation or the completion of the review or investigation giving rise to the claim (whichever is later). The communication to the vendor will include: 1. Overview of the basis of the claim; 2. Amount of the claim;
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3. Disclaimer that the assessed claim is not subject to administrative review; 4. Notification of vendor’s opportunity to submit documentation to either justify or correct the claim amount within 15 days of notice date; 5. Notification that should the vendor elect not to refute the amount of the claim assessed, vendor has the option to settle the claim by submitting a negotiable instrument for the claim amount, made out to ”Georgia WIC”, within 15 days of the Notice date. Payment must be addressed to: Department of Public Health – Georgia WIC State Office Attn: Deputy Director of Program Administration c/o WIC Finance Manager Georgia State WIC Office 2 Peachtree Street N.W., Floor 10 Atlanta, GA. 30303
a. Georgia WIC will provide the Georgia Department of Public Health, Division of Finance a monthly report detailing vendor claims. i. Upon receipt of vendor remittances in the form of a negotiable instrument (personal check, money order, bank check or other instrument), the WIC Finance Manager will forward remittances to the WIC Financial Analyst for processing.
ii. The WIC Financial Analyst will accept the remittance and complete the Georgia Department of Public Health Receipt Form. The form contains line item data (fund code, funding source code, project code, and class code) necessary to the processing of the revenue (see attached Receipt Form).
iii. The WIC Financial Analyst will forward the original vendor remittance correspondence and a photocopy of the financial instrument to the WIC Vendor Administrative Coordinator.
iv. Upon completion of the form, the WIC Financial Analyst will forward the Receipt Form and remittance to the DPH Division of Finance, Accounts Receivable for deposit.
v. All funds from vendors will be deposited in the WIC Federal Holding Account, Bank of America Account # XXXXXXXXXXXX.
vi. All funds will be credited to the WIC Food Account with the appropriate WIC Department Code, WIC FFY Funding Source and Project Code. The WIC
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Financial Analyst will log, track and reconcile all receipts processed to the WIC Food Account monthly.
vii. All claims will be reported monthly on the WIC Financial Management and Participation Report, Form FNS-798 (9-11), line 9 Post-payment Vendor Collections.
B. If vendor responds and submits documentation to challenge the original assessed claim amount within 15 days, SWO Vendor Relations and Compliance Consultant will complete the following actions within 5 days of receipt of vendor’s request for correction:
1. Review the vendor submission for a final decision on the amount of the claim; 2. Draft and submit a Notice to vendor notifying vendor of the newly finalized claim amount, or confirming the original assessed claim amount in the event SWO does not accept the documentation submitted by vendor. 3. If vendor does not challenge the claim amount within 15 business days of the original Notice with a justification or correction to the original claim amount, the originally assessed claim terms are as originally submitted and are not negotiable.
C. The WIC Vendor Administrative Coordinator will file a vendor remittance package in the vendor file and scan an electronic copy for distribution via email to WIC Legal Team, WIC Vendor Cost Containment Data Analyst and WIC Vendor Relations and Compliance Consultant. An electronic copy of the scanned remittance package will be placed on the WIC Network Drive, in the Vendor Management Section Folder.
D. The WIC Vendor Cost Containment Senior Data Analyst will follow Policy VMCC 00011 – Adverse Referral & Claim Collections Monitoring to account for all vendor claims assessed, all subsequent payments remitted in response to satisfying those claims, as well as the final disposition of each claim assessed.
III. POST PAYMENT VENDOR CLAIMS COLLECTION. If there is no ability to collect the claim in full, within 30 days of the notice, the following process will apply: A. Send a notice (demand letter) to the vendor that it has 30 days to remit final payment of the outstanding amount to satisfy the claim. The demand letter will include the following: 1. Overview of the basis for the State Agency establishing and collecting a claim; 2. Amount of the claim; 3. Timeframe in which to remit payment of the assessed claim (30 days);
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4. Disclaimer that the assessed claim is not subject to administrative review; 5. Notice that alternative collection options against the vendor may be pursued. 6. Opportunity for payment by check to satisfy the balance and detail for submission of balance via a negotiable instrument for the claim amount, made out to “Georgia WIC”. Payment must be addressed to: Department of Public Health – Georgia WIC State Office Attn: Deputy Director of Program Administration c/o WIC Finance Manager Georgia State WIC Office 2 Peachtree Street N.W., Floor 10 Atlanta, GA. 30303
a. Upon receipt of remittances in the form of a negotiable instrument (personal check, money order, bank check or other instrument), see previous Section I. A. 5. a. for next steps.
IV. INITIATION OF LITIGATION FOR PURPOSES OF COLLECTING AN OUTSTANDING VENDOR CLAIM. If the State Agency is unable to collect the vendor claim administratively, it will turn over collection efforts to the State Attorney General’s (AG’s) Office. A. The Vendor Relations and Compliance Consultant will submit a Claims Request Packet to the State AG’s Office for any outstanding or uncollected claim amounts. The Claims Request Packet will include: 1. Letter of request for representation. 2. Vendor documentation of the basis for establishing and collecting the claim and the SWO’s efforts to collect the claim. This will include the following information: Vendor name, reason for the claim, amount of the claim, evidence of vendor’s opportunity to justify or correct the assessed claim amount; and any dates of collection, if applicable. 3. The initial follow-up with the AG’s Office by the State Agency will occur after the first 30 days from the date the Claims Request Packet is submitted. All subsequent follow-up by the State Agency will occur every 30 days thereafter until the claim is satisfied, or the AG’s Office identifies that all efforts to satisfy the claim have been exhausted (in writing). 4. For any vendor claim that is partially or fully collected from the efforts of the State AG’s Office, the money collected will be remitted by the AG’s Office to the SWO, as a negotiable instrument, within 14 days of its receipt of the collected funds from the court in which the debt collection was initiated along with all relevant documentation (e.g., court order).
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5. Negotiable instruments received from the AG’s Office will be handled and reported as outlined in Section I. A. 5. a.
V. RECORD-KEEPING. All stages of the claims collection process will be documented and retained in the vendor’s file and the Vendor Claims Database within the Office of Vendor Management. See Policy VMCC 00011 – Adverse Referral & Claim Collections Monitoring.
VI. UNCOLLECTED VENDOR CLAIMS. If a vendor claim is not satisfied after all of the above efforts have been exhausted, the vendor or any owner, officer, or other interest holder, will be barred from attempting to seek authorization of the same business or a new business until the outstanding claim is satisfied. The Vendor Claims Database and the vendor file will be updated with the final status from the AG’s Office.
Authority 7 C.F.R. § 246.12(h)(3)(ix) 7 C.F.R. § 246.12(k)(2), (k)(3), and (k)(4) 7 C.F.R. § 246.14(e)
7 C.F.R. § 246.4
WIC Policy Memorandum #2005-3 GA SAO Statewide Accounting Policy & Procedure: Section Revenues and Receivables
Definitions/Supporting Information Policy VMCC 00011 – Adverse Referral & Claim Collections Monitoring VM-100.08 Confidentiality of Retailer Information Georgia Department of Public Health Confidentiality Agreement
Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
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Policy A Civil Monetary or Money Penalty (CMP) may be assessed against vendors in lieu of a disqualification, in order to emphasize the seriousness of Program compliance and to allow the vendor to continue to serve an otherwise inadequately covered WIC participant population. A CMP does not relieve a vendor of financial liability for previous compliance issues or outstanding claims. All liabilities must be paid in addition to an assessed CMP.
Purpose Under special circumstances, the Georgia WIC Program may impose Civil Monetary Penalties where the disqualification of a vendor would result in inadequate participant access, causing a hardship to WIC participants.
Procedures I. Prior to disqualifying a vendor for any federal mandatory or state agency violations, Georgia WIC must determine if disqualification of the vendor will result in inadequate participant access (IPA). Inadequate participant access occurs when there is not another authorized WIC vendor within ten (10) miles of the vendor who has committed the violation. Only when Georgia WIC determines and documents that disqualification of the vendor would result in inadequate participant access, a civil money penalty must be imposed in lieu of disqualification. CMPs will only be assessed for both state and federal mandatory sanctions in the event of inadequate participant access, as determined by Georgia WIC. The CMP shall not exceed $11,000.00 per violation, or $49,000.00 for multiple violations occurring during a single investigation.
II. CMPs must be paid within thirty (30) days of the notice of approval. Installments may be considered up to a maximum of six (6) months. If a vendor does not pay, partially pays, or fails to pay a CMP assessed in lieu of disqualification on time, the Georgia WIC Program will disqualify the vendor for the length of the disqualification corresponding to the violation for which the CMP was assessed. A CMP does not relieve a vendor of the financial liability for timely payment of claims assessed for vendor violations or errors. Assessed claims must be paid in addition to the CMP.
III. CMP Methodology for State Agency Sanctions
A vendor may be assessed a CMP in lieu of disqualification if the disqualification will result in inadequate participant access. Upon assessment of a CMP, the disqualification period will be waived. Subsequent visits may be conducted during a waived disqualification period. If violations occur during a subsequent visit, a vendor will be assessed a warning for those violations and may be issued another CMP in lieu of disqualification if the requisite pattern of violations is met. Only two (2) CMPs may be assessed against a vendor. A vendor will be disqualified from the Georgia WIC Program for third and subsequent sanctions.
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CMPs will be assessed in lieu of disqualification for State Agency sanctions based on the chart below.
Civil Money Penalty Formula for State Agency Sanctions Based on Six Month WIC Redemption Category For $0 to $11,000 in Redemptions (CMP Base Rate) For Redemption Amount Above $11,000 (CMP= Base Rate + % of Total Redemption over $11,000) Category I $500 $500 + 1% of redemption over $11,000 Category II $1,000 $1,000 + 2% of redemption over $11,000 Category III $1,500 $1,500 + 3% of redemption over $11,000
For State agency Sanctions, the first CMP will be reduced by fifty (50) percent if the vendor presents documented proof that they had an effective training program in place. At a minimum, the training content must be centered around cashier operations which have a direct impact on the quality of adhering to WIC policies and procedures as an authorized WIC vendor. The vendor is responsible for informing and training all of its cashiers and other staff on the most current WIC policies and procedures, at all times.
The submitted training documentation must show proof of the following: A. An outline of training content covered B. The name of the store personnel administering the training C. The signature, date of signature by the trainer next to a statement attesting to having administered the content as outlined D. A list of the names of the personnel trained E. A signature of personnel in attendance next to their listed name F. The date and location of the training Note: this training must be held during the fiscal year and before the disqualification notification.
CMPs cannot exceed $11,000.00 per violation or $49,000.00 per investigation. If more than one (1) violation is detected during a compliance investigation, a CMP must be imposed for each violation (up to the $11,000.00/$49,000.00 limits). Only two (2) CMPs can be assessed against a vendor. CMPs cannot be imposed in lieu of disqualification for third and subsequent sanctions in these categories.
IV. CMP Methodology for Mandatory Sanctions
For a violation that warrants permanent disqualification, the amount of the CMP shall be $11,000.00 for each violation, not to exceed $49,000.00.
For each violation subject to a mandatory sanction, the following formula will be used to calculate the amount of the CMP imposed in lieu of disqualification.
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A. Determine the vendor’s average monthly redemptions for at least the six (6) months ending immediately preceding the month during which the notice of the adverse action is dated. B. Multiply the average monthly redemptions figure by ten (10) percent. C. Multiply the amount from step 2 above by the number of months for which the store would have been disqualified. This is the amount of the civil money penalty, provided that the civil money penalty shall not exceed $11,000.00 per violation. The total amount of the CMP assessed for violations that occur during a single investigation may not exceed $49,000.00.
If a vendor who received a Categories IV, V or VI sanction receives a second sanction in any of these categories, the second sanction must be doubled. However, CMPs can only be doubled up to the limits stated above. CMPs cannot be imposed in lieu of disqualification for third and subsequent sanctions in these categories.
V. Disqualifications and CMPs
A. If a vendor has been assessed a CMP in lieu of disqualification for a SNAP violation, the vendor agreement will be terminated for the initially issued SNAP disqualification period.
B. Disqualification from the WIC Program may also result in a civil money penalty or disqualification from SNAP. Such disqualification may not be subject to administrative or judicial review under SNAP.
C. If a vendor is disqualified or assessed a civil money penalty (CMP) for a federal mandatory sanction from the WIC Program in another state (see federal mandatory sanctions), the vendor will be disqualified from the Georgia WIC Program for the same period of time.
D. A vendor may be assessed (CMP) in lieu of disqualification, if the disqualification will result in inadequate participant access. Upon assessment of a CMP, the disqualification period will be waived. Subsequent visits may be conducted during a waived disqualification period. If violations occur during a subsequent visit, the vendor will be disqualified for a period equal to the period that the CMP was assessed or a second CMP may be imposed.
The imposition of a civil money penalty in lieu of disqualification is subject to full administrative review upon the timely request by the vendor. The following adverse actions shall be subject to abbreviated administrative review upon timely request by the vendor: A. denial of authorization based on the vendor selection criteria for business integrity or for a current SNAP disqualification or civil money penalty for hardship; B. disqualification based on the imposition of a SNAP civil money penalty for hardship; C. a civil money penalty imposed in lieu of disqualification based on a mandatory sanction imposed by another WIC State agency;
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D. a civil money penalty imposed in lieu of disqualification based on a SNAP disqualification.
The following adverse actions are not subject to administrative review: A. The validity or appropriateness of the State agency’s vendor limiting criteria or vendor selection criteria for minimum variety and quantity of supplemental foods, business integrity, and current SNAP disqualification or civil money penalty for hardship;
B. The validity or appropriateness of the State agency's participant access criteria and the State agency's participant access determinations;
C. Disqualification of a vendor as a result of disqualification from SNAP.
Authority 7 C.F.R. § 246.12(g)(3)(iii) 7 C.F.R. § 246.12(l) 7 C.F.R. § 246.4(a)(14)(iii) and (v)
Definitions/Supporting Information Civil Money Penalty- A monetary penalty that can be assessed in lieu of a sanction. VM-120.02 Assessment of Sanctions For Vendor Violations and Participant Access Determinations VM-130.03 Vendor Violations and Sanctions
Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management – Vendor Relations and Adm. Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
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Policy Any authorized WIC vendor found to be in violation of federal regulations or Georgia WIC policy will be assessed a sanction consistent with the severity and nature of the violation. Vendor violations means any intentional or unintentional action of a vendor’s paid or unpaid owners, officers, managers, agents or employees, with or without the knowledge of management, that violates the WIC Vendor Agreement or federal or state statutes, regulations, policies or procedures governing the Program. There are seven (7) categories of sanctions: three (3) categories of state agency sanctions and four (4) categories of federal mandatory sanctions. State agency sanctions are established by Georgia WIC program representatives and have been approved by the United States Department of Agriculture (USDA) prior to implementation. State agency sanctions include disqualification, and civil money penalties assessed in lieu of disqualification in the event of inadequate participant access. Federal mandatory sanctions are established by the USDA. Both state agency and federal mandatory sanctions must be enforced when violations occur.
Violations are categorized by the nature and severity of the violation. Each category has a prescribed period of disqualification. Sanctions shall be assessed as follows:
A. In the event of multiple violations, the highest sanction assessed to a vendor shall determine the period of disqualification. B. All State agency violations assessed are retained in the vendor's file for a period of one (1) year and will roll off at the end of that period. C. If both mandatory and state agency sanctions result from a single investigation, and the disqualification for a mandatory sanction is not upheld during the administrative review process, then Georgia WIC may impose the state agency sanction.
Georgia WIC will notify a vendor in writing when an investigation reveals an initial incidence of a program violation for which a pattern of incidences must be established to impose a sanction before another violation is documented, unless Georgia WIC determines that notifying the vendor would compromise an investigation.
Purpose To define the vendor violations and the corresponding sanctions that constitute the Georgia WIC Program’s sanction schedule.
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Procedures I. Disqualification
A vendor will be disqualified from Georgia WIC for committing certain program violations. The actual disqualification period is determined using the same criteria for every vendor.
A. Georgia WIC will not accept voluntary withdrawal as an alternative to disqualification.
B. A vendor that has been disqualified from SNAP will be disqualified from WIC for the same period of time. If a vendor has been assessed a CMP in lieu of disqualification for a SNAP violation, the vendor agreement will be terminated for the initially issued SNAP disqualification period.
C. Disqualification from the WIC Program may also result in a civil money penalty or disqualification from SNAP. Such disqualification may not be subject to administrative or judicial review under SNAP.
D. If a vendor is disqualified or assessed a civil money penalty (CMP) for a federal mandatory sanction from the WIC Program in another state (see federal mandatory sanctions), the vendor will be disqualified from the Georgia WIC Program for the same period of time.
E. A vendor may be assessed (CMP) in lieu of disqualification, if the disqualification will result in inadequate participant access. Upon assessment of a CMP, the disqualification period will be waived. Subsequent visits may be conducted during a waived disqualification period. If violations occur during a subsequent visit, the vendor will be disqualified for a period equal to the period that the CMP was assessed or a second CMP may be imposed.
II. Effective Date of Adverse Actions
Denials of vendor authorization and permanent disqualifications are effective on the date of receipt of the notice of the adverse action, at which time the vendor stamp will be discontinued. All other adverse actions against a vendor are effective fifteen days after the date of the notice of the adverse action. For those adverse actions resulting in disqualification (other than denials of vendor authorization and permanent disqualifications), use of the vendor stamp shall be discontinued fifteen days after the date of the notice of the adverse action. Any food instruments submitted for payment after fifteen days of the date of the notice of the adverse action will not be paid. All adverse actions shall remain in effect during the administrative review process.
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Vendor Sanctions Below is a description of the Georgia WIC sanction system and how it works. For those violations that require a pattern, a pattern is established when the same violation occurs at least twice.
III. State Agency Sanctions
If a violation occurs in Category I, the vendor will receive written warning for the first offense. If the same violation occurs a second time within twelve (12) months from the date of this first offense warning notification, the vendor will receive another warning for the second offense. If the same violation occurs a third time within twelve (12) months from the date of this first offense warning notification, the vendor will be disqualified for the time period specified for that category (six months).
If a violation occurs in Category II, the vendor will receive written warning for the first offense. If the same violation occurs a second time within twelve (12) months from the date of this first offense warning notification, the vendor will receive another warning for the second offense. If the same violation occurs a third time within twelve (12) months from the date of this first offense warning notification, the vendor will be disqualified for the time period specified for that category (eight months.) If a violation occurs in Category III, the vendor will receive written warning for the first offense. If the same violation occurs again within twelve (12) months from the date of this first offense warning notification, the vendor will be disqualified for the time period specified for that category (ten months). If a vendor receives a warning letter and desires further explanation, the vendor may call Georgia WIC and speak with the Vendor Relations Unit Manager or submit a written request for further explanation to Georgia WIC.
IV. State Agency Sanctions Category I - Disqualification for six months on third violation
A. Stocking or selling out of date and/or inconsumable WIC food commodities to WIC participants. This will include any WIC product that has a specific expiration date, sell by, best if sold by or similar wording with a date printed on the container. Note: All observed concerns with sanitation and food safety will be immediately reported to the Georgia Department of Agriculture.
B. Failure to allow in-store or manufacturers’ promotional or free item with a WIC purchase.
C. Failure to submit or return requested documentation, other than food instruments or inventory records, food sales, tax information, or documentation for annual training, by the stated deadline.
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D. Failure to stock the required inventory of contract formula.
E. Failure to stock the required inventory of any WIC food items other than contract formula.
F. Claiming reimbursement for a food item for which there has been no submitted shelf price.
V. State Agency Sanctions Category II - Disqualification for eight months on third violation A. Allowing the purchase of WIC foods in unauthorized container sizes.
B. Requiring WIC participants to show any identification other than the WIC identification card.
C. Use of a non-approved label by a bread manufacturer in the vendor’s store.
D. Prices not marked on or near WIC foods with the exception of Infant Formula or Fruits or Vegetables. VI. State Agency Sanctions Category III - Disqualification for ten months on second violation
A. Failure to ring up a sale of WIC purchases.
B. Failure to write the price on a food instrument before the participant signs in plain sight of the participant during the WIC transaction.
C. Refusing to accept a valid WIC food instrument from a participant.
D. Allowing the substitution of one WIC approved food item listed on the food instrument for another WIC approved food item not listed on the food instrument.
E. Failure to repay charges within thirty (30) days.
F. Contacting WIC participants for any reason regarding a WIC transaction.
G. Requiring participant to pay cash to redeem WIC food instruments, except for personal payments for amounts over the maximum amount of a Cash Value/Fruit and Vegetable Food Instrument.
H. Allowing the purchase of any formula other than the one specified on the front of the food instrument.
I. Failing to provide a WIC participant with the same courtesies as other customers
J. Prices not marked clearly on or near WIC infant formula.
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K. Allowing WIC food items to exceed the quantity specified on the food instrument (except for manufacturers’ or in-store promotional or free items that are offered to all customers.)
L. Failure to allow the purchase of any WIC food item.
M. Issuing a “rain check”/IOU for WIC approved foods.
N. Charging sales tax on a WIC food item other than on the amount that exceeds the value of the Cash Value Fruit and Vegetable Voucher.
O. Failure to provide WIC participants with a receipt.
P. Failure to check a WIC customer’s WIC ID card/folder.
Q. Tampering with the manufacturer dates on any food item.
VII. Federal Mandatory Sanctions
If a vendor previously has been assessed a Mandatory Sanction for any of the violations carrying one, three or six year disqualifications, and receives another sanction for any of these violations, then the second sanction will be doubled. If a civil money penalty is imposed in lieu of disqualification, then the amount of that penalty will be doubled up to the maximum limits per violation.
If a vendor previously has been assessed two or more sanctions for any of the violations carrying one, three or six year disqualifications, and receives another sanction for any of these violations, then the third sanction and all subsequent sanctions will be doubled. Civil money penalties shall not be imposed in lieu of disqualification for third or subsequent sanctions. VIII. Federal Mandatory Sanctions Category IV - Disqualification for one year
A. A pattern of providing unauthorized food items in exchange for food instruments or cash value vouchers, including charging for supplemental foods provided in excess of those listed on the food instrument.
B. A pattern of an above-50-percent vendor providing prohibited incentive items to customers. IX. Federal Mandatory Sanctions Category V - Disqualification for three years
A. A pattern of receiving, transacting, or redeeming food instruments or cash-value vouchers outside of authorized channels, such as at locations different from the authorized location
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listed on the Vendor Agreement, or the use of an unauthorized vendor or an unauthorized person. This includes but is not limited to delivering WIC food items to WIC participants, collecting WIC food instruments prior to completing the WIC transaction or collecting the WIC food instruments prior to the “first date of use” on the food instrument.
B. A pattern of providing credit or non-food items (other than alcohol, alcoholic beverages, tobacco products, cash, firearms, ammunition, explosives or controlled substances) in exchange for WIC food instruments or cash-value vouchers.
C. A pattern of vendor overcharges.
D. A pattern of charging for supplemental food not received by the participant. This includes but is not limited to vendor representatives receiving WIC foods not received by the participants. The WIC participant does not have the authority to give WIC foods to vendor or its representatives and neither does the vendor or its representatives have the authority to accept such WIC food items.
E. A pattern of claiming reimbursement for the sale of an amount of a specific supplemental food item which exceeds the store’s documented inventory of that supplemental food item for a specific period of time.
F. One incidence of providing alcohol or alcoholic beverages or tobacco products in exchange for WIC food instruments or cash-value vouchers.
X. Federal Mandatory Sanctions Category VI - Disqualification for six years
A. One incidence of buying or selling WIC food instruments or cash value vouchers for cash (trafficking). B. One incidence of selling firearms, ammunition, explosives, or controlled substances, in exchange for food instruments or cash-value vouchers.
XI. Federal Mandatory Sanctions Category VII - Permanent disqualification
A. Conviction for trafficking in food instruments or cash-value vouchers
B. Conviction for selling firearms, ammunition, explosives, or controlled substances in exchange for food instruments or cash value vouchers.
XII. Additional Notes on Violations
A. Vendors who commit fraud or abuse in the program are subject to criminal prosecution. Those who have willfully misapplied, stolen or fraudulently obtained program funds will be subject to a fine of not more than $25,000.00 or imprisonment for not more than five years,
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or both, if the value of the funds is $100.00 or more. If the value is less than $100.00, the penalties are fines of not more than $1,000.00 or imprisonment for not more than one year, or both. Georgia WIC will refer all criminal activity including theft and fraud to law enforcement.
B. When Georgia WIC determines that a vendor has committed a vendor violation that affects payment to the vendor, Georgia WIC will delay payment and establish a claim. In addition to delaying payment and asserting a claim, Georgia WIC may sanction the vendor for vendor overcharges or other errors in accordance with the sanction schedule. Payment of food instruments submitted through the banking system by the vendor will be suspended as of the date of the notice of adverse action pending review by Georgia WIC. The vendor will be instructed to submit all outstanding food instruments to Georgia WIC for review and payment consideration.
Authority 7 C.F.R. § 246.12(h)(5) 7 C.F.R. § 246.12(l)
Definitions/Supporting Information VM-120.02 Assessment of Sanctions for Vendor Violations and Participant Access Determinations VM-130.02 Vendor Civil Money Penalties VM-140.01 Vendor Appeals
Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management – Vendor Relations and Adm. Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303
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Policy A vendor may appeal certain adverse action(s) imposed by Georgia WIC. Vendors are required to adhere to Georgia WIC procedures if requesting review of an adverse action.
Purpose To describe the adverse actions which may and may not be appealed by a vendor and to describe the administrative review process, as required by the federal regulations.. Procedures I. After a vendor requests an appeal, Georgia WIC will issue a written decision, including the basis for it, within ninety (90) days of the date of receipt of the vendor’s request. This timeframe is an administrative timeframe only – it does not provide a basis for overturning an adverse action by Georgia WIC if a decision is not made within the specified timeframe.
II. If reimbursement is owed to Georgia WIC by the vendor as a result of the adverse action being affirmed after administrative review, neither the vendor nor its affiliates shall be eligible to participate as an authorized WIC vendor until the reimbursement is paid in full. The vendor may not circumvent reimbursement by selling or otherwise making any changes or amendments to its corporate structure that was in place since the time of its initial authorization.
III. Procedures for Vendor Administrative Review, Hearings and Appeals
A. Effective Date of Adverse Actions Unless a later date is specified in the notice of adverse action against a vendor by the State agency, all adverse actions (except denials of vendor authorization and permanent disqualifications which are effective on the date of receipt of the notice) shall be effective fifteen days after the date of the notice of the adverse action. All adverse actions shall remain in effect during the administrative appeal process.
B. Full Administrative Review 1. The following adverse actions shall be subject to full administrative review upon timely request by the vendor: a. denial of authorization based on the application of the vendor selection criteria for minimum variety and quantity of authorized supplemental foods, or on a determination that the vendor is operating a store sold by its previous owner in an attempt to circumvent a sanction, as stated in 7 C.F.R. § 246.12(g)(7); b. termination of an agreement for cause; c. disqualification; and
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d. imposition of a fine or a civil money penalty in lieu of disqualification.
2. These procedures shall be followed in cases meriting full administrative review:
a. The State agency shall give written notice to the vendor of the adverse action, the procedures to follow to obtain full administrative review, the causes for and the effective date of the action. When a vendor is disqualified due in whole or in part for any of the violations listed in 7 C.F.R § 246.12(l)(1), the notice shall include the following statement: "This disqualification from WIC may result in disqualification as a retailer in SNAP. Such disqualification is not subject to administrative or judicial review under SNAP." b. A vendor seeking review must send a written request for review to the Commissioner of the State agency within fifteen days from the date of the notice of adverse action, with a copy of the decision to be reviewed and any documents, argument, or information that the vendor contends would justify reversal; c. Upon receiving a timely request for review, the Commissioner shall refer the case to the Office of State Administrative Hearings (OSAH) for initial decision. d. The hearing before OSAH shall be conducted in accordance with the Georgia Administrative Procedures Act and the rules of OSAH. In addition, the Administrative Law Judge (ALJ) shall ensure that the vendor is given: i. Adequate advance notice of the time and place of the administrative review to provide all parties involved sufficient time to prepare for the review; ii. The opportunity to present its case and at least one opportunity to reschedule the administrative review date upon specific request; iii. The opportunity to cross-examine adverse witnesses. When necessary to protect the identity of WIC Program investigators, such examination may be conducted behind a protective screen or other device to conceal the investigator’s face and body; iv. The opportunity to be represented by counsel; and v. The opportunity to examine prior to the hearing the evidence upon which the State agency's action is based. e. The ALJ’s determination shall be based solely on whether the State agency has correctly applied Federal and State statutes, regulations, policies, and procedures governing the WIC Program, according to the evidence presented at the review. f. The Commissioner shall appoint an attorney from the Office of General Counsel as a reviewing official to review the ALJ’s initial decision at the request of either party within ten days of the date of the ALJ’s initial
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decision, to ensure that it conforms to approved policies and procedures, and to render the final agency decision in accordance with O.C.G.A. § 50- 13-41. If neither party requests that the ALJ’s decision be reviewed, then the ALJ’s decision shall become the final agency decision thirty days after it was entered. g. When the ALJ’s decision is reviewed at the request of either party, the reviewing official shall provide written notification of the final agency decision, including the basis for the decision, and the vendor’s right to seek judicial review pursuant to O.C.G.A. § 50-13-19, within the time period prescribed by O.C.G.A. § 50-13-41. If the adverse action under review has not already taken effect, the review official’s decision shall be effective on the date of receipt by the vendor.
IV. Abbreviated Administrative Review A. The following adverse actions shall be subject to abbreviated administrative review upon timely request by the vendor:
1. denial of authorization based on the vendor selection criteria for business integrity or for a current SNAP disqualification or civil money penalty for hardship; 2. denial of authorization based on the application of the vendor selection criteria for competitive price; 3. the application of the State agency’s vendor peer group criteria and the criteria used to identify vendors that are above-50-percent vendors or comparable to above-50-percent vendors; 4. denial of authorization based on a State agency-established vendor selection criterion if the basis of the denial is a WIC vendor sanction or a SNAP withdrawal of authorization or disqualification; 5. denial of authorization based on the State agency's vendor limiting criteria; 6. denial of authorization because a vendor submitted its application outside the timeframes during which applications are being accepted and processed as established by the State agency; 7. termination of an agreement because of a change in ownership or location or cessation of operations; 8. disqualification based on a trafficking conviction; 9. disqualification based on the imposition of a SNAP civil money penalty for hardship; 10. disqualification or a civil money penalty imposed in lieu of disqualification based on a mandatory sanction imposed by another WIC State agency; 11. a civil money penalty imposed in lieu of disqualification based on a SNAP disqualification; and 12. denial of an application based on a determination of whether an applicant vendor is currently authorized by SNAP.
B. These procedures shall be followed in cases meriting abbreviated
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administrative review:
1. The State agency shall give written notice to the vendor of the adverse action, the procedures to follow to obtain an abbreviated administrative review, the causes for and the effective date of the action; 2. A vendor seeking review must send a written request for review to the Commissioner of the State agency within fifteen days from the date of the notice of adverse action, with a copy of the decision to be reviewed and any documents, argument, or information that the vendor contends would justify reversal; 3. Upon receiving a timely request for review, the Commissioner shall appoint a decision-maker who is someone other than the person who rendered the initial decision on the action to review the information provided to the vendor concerning the causes for the adverse action and the vendor's response, and to make a determination based solely on whether the State agency has correctly applied Federal and State statutes, regulations, policies, and procedures governing the Program;
4. The decision-maker shall provide written notification of the final agency decision, including the basis for the decision, and the vendor’s right to seek judicial review pursuant to O.C.G.A. § 50-13-19, within 90 days of the date of receipt of the request for an administrative review. If the adverse action under review has not already taken effect, the decision-maker’s ruling shall be effective on the date of receipt by the vendor.
V. Actions not Subject to Administrative Review A. The following adverse actions are not subject to administrative review: 1. The validity or appropriateness of the State agency’s vendor limiting criteria or vendor selection criteria for minimum variety and quantity of supplemental foods, business integrity, and current SNAP disqualification or civil money penalty for hardship;
2. The validity or appropriateness of the State agency’s selection criteria for competitive price, including, but not limited to, vendor criteria and the criteria used to identify vendors that are above-50-percent vendors or comparable to above-50-percent vendors;
3. The validity or appropriateness of the State agency's participant access criteria and the State agency's participant access determinations;
4. The State agency's determination to include or exclude an infant formula manufacturer, wholesaler, distributor, or retailer from the list required pursuant to §246.12(g)(11);
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5. The validity or appropriateness of the State agency’s prohibition of incentive items and the State agency’s denial of an above-50-percent vendor's request to provide an incentive item to customers pursuant to §246.12(h)(8);
6. The State agency's determination whether to notify a vendor in writing when an investigation reveals an initial violation for which a pattern of violations must be established in order to impose a sanction, pursuant to §246.12(l)(3);
7. The State agency's determination whether a vendor had an effective policy and program in effect to prevent trafficking and that the ownership of the vendor was not aware of, did not approve of, and was not involved in the conduct of the violation;
8. Denial of authorization if the State agency’s vendor authorization is subject to the procurement procedures applicable to the State agency;
9. The expiration of a vendor's agreement;
10. Disputes regarding food instrument or cash-value voucher payments and vendor claims (other than the opportunity to justify or correct a vendor overcharge or other error, as permitted by §246.12(k)(3); and
11. Disqualification of a vendor as a result of disqualification from SNAP.
All adverse actions shall remain in effect during the administrative review process.
Authority 7 C.F.R. § 246.12(h)(6) 7 C.F.R. § 246.12(l)(4) 7 C.F.R. § 246.18 O.C.G.A. § 50-13-19
Definitions/Supporting Information VM-100.07 Termination of the Vendor Agreement VM-120.02 Assessment of Sanctions for Vendor Violations and Participant Access Determinations VM-130.02 Vendor Civil Money Penalties
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Contact Information Georgia Department of Public Health Georgia WIC Program Office of Vendor Management – Vendor Relations and Adm. Unit 2 Peachtree Street, NW, 10th Floor Atlanta, Georgia 30303