Vendor Management (VM) 3 High-Risk Vendor Identification Systems Reviewed: June 13, 2023

Page 1 of 1 Maine Center for Disease Control and Prevention WIC Nutrition Program

Effective: October 1, 2011 Policy No. VM-3 Revised: October 1, 2023

Vendor Management High-Risk Vendor Identification Systems Authority 7 CFR §246.12(j)(3)

Policy 1. A high-risk vendor is identified by the State Agency as a vendor having a high probability of committing a vendor violation. The State Agency utilizes, but is not limited to, the following criteria to make its determination: 1.1 Statistical analyses, including low variance in the redemption price and high mean value of WIC Benefits 1.2 Participant/staff complaints and/or observations 1.3 Review of vendor redemption reports and queries 1.4 Vendor history of program violations/non-compliance 1.5 Suspicious pattern of redemptions 1.6 Previous WIC or Supplemental Nutrition Assistance Program (SNAP) suspension 1.7 SNAP determination of high-risk 1.8 New vendors

Procedures 1. The State Agency maintains a formal system for receiving complaints about vendors through the following: 1.1 A toll-free number handled by State Agency staff 1.2 A standard complaint form that the complainant sends to the State Agency 1.3 E-mail 2. The State Agency uses the following in its high-risk vendor analysis: 2.1 A full monthly food package for a woman, child or infant 2.2 A standard food transaction with multiple food items (e.g. milk, cheese and cereal) 2.3 A three-month aggregate of the vendor’s redemptions 3. Vendor redemption patterns are compared to applicable peer group patterns. 4. The State Agency will identify high-risk vendors and generate high-risk vendor reports at least once per year.