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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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

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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.