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by a vendor's owner, manager or employee;  charging more to WIC participants than other customers;  providing outdated or spoiled food items;  refusal to accept manufacturers' coupons, or other store discounts; and  Inadequate variety and/or quantity of WIC-authorized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.

GEORGIA WIC PROGRAM PROCEDURES MANUAL VM WIC Vendor Complaint Protocol Policy No. VM- 100.11 Effective Date: October 1, 2016

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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.

GEORGIA WIC PROGRAM PROCEDURES MANUAL VM WIC Vendor Complaint Protocol Policy No. VM- 100.11 Effective Date: October 1, 2016

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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.

GEORGIA WIC PROGRAM PROCEDURES MANUAL VM WIC Vendor Complaint Protocol Policy No. VM- 100.11 Effective Date: October 1, 2016

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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)

GEORGIA WIC PROGRAM PROCEDURES MANUAL VM WIC Vendor Complaint Protocol Policy No. VM- 100.11 Effective Date: October 1, 2016

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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.

GEORGIA WIC PROGRAM PROCEDURES MANUAL VM WIC Vendor Complaint Protocol Policy No. VM- 100.11 Effective Date: October 1, 2016

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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