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(1.2)Minnesota WIC Operations Manual (MOM) Section 1.2: State WIC Staff and Role#

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Section 1.2: State WIC Staff and Role 5/2019 The Minnesota Department of Health administers the Minnesota WIC Program through the WIC Section of the Child & Family Health Division. (See State Staff Directory - WIC/CSFP) The Minnesota Operations Manual (MOM) is issued by the Minnesota Department of Health and is the primary document describing WIC policies and procedures. MOM provides both requirements and guidance for local WIC agencies and defines the requirements monitored during Management Evaluations and Financial Reviews. MOM is available on the WIC Program website. State staff set policy, evaluate local agencies, and monitor local operations. The state agency also provides management, financial, and nutrition consultation, technical assistance, and training to Local Agency staff and authorized WIC vendors. The state WIC program is comprised of four functional areas (units): Nutrition/Clinic Services; Management Information System (MIS) & Data; Breastfeeding, Training and Communications; and Food Delivery (Vendor). Another function at the state office is fiscal management. Nutrition & Clinic Services Unit This unit is located in the MDH St. Paul office and regional offices. The Consultants’ primary responsibility is to assist Local Agency staff in administering the WIC program, addressing nutrition and program administration issues, implementing policies, and responding to questions and concerns. ▪ Basic breastfeeding promotion and support ▪ Nutrition services: health and nutrition risk assessment; education and counseling ▪ Staffing policies, guidance, and technical assistance ▪ Food package policies, and WIC food approval process ▪ Infant formula policies, training, and technical assistance ▪ Training and technical assistance related to nutrition ▪ The monitoring and evaluation of nutrition services and health outcomes ▪ Outreach to health professionals, community partners, and the public ▪ Interface with other health and social service programs ▪ The monitoring and evaluation of Local Agency operations ▪ Staff training related to administrative and nutrition topics ▪ Evaluation of program planning and grant management ▪ Clinic administrative issues, e.g., food benefit issuance and security, participant eligibility, and participant rights and responsibilities ▪ The monitoring of Local Agency computer security ▪ Caseload management ▪ Record keeping and retention

S E C T I O N 1 . 2 : S T A T E W I C S T A F F A N D R O L E 2 ▪ The monitoring of Local Agency expenditures and requests. Assistance with Local Agency General Ledger and Financial Reviews. ▪ Support of participant centered customer service ▪ The monitoring of Local Agency Civil Rights procedures ▪ Provision of general technical assistance and consultation MIS and Data Unit This unit is located in the MDH St. Paul office. Staff are responsible for: ▪ Management of the WIC Information System ▪ Information System contract administration and oversight ▪ Coordination and design of software modifications and enhancements ▪ User acceptance testing ▪ Development of system-related on-line training modules ▪ Software release and report guidance ▪ Research and purchase of hardware used by Local Agency clinic staff ▪ Onsite technical assistance in specialized or critical situations ▪ Coordination of data requests used for program evaluation ▪ Evaluating WIC program and peer breastfeeding program data ▪ Nutrition surveillance of maternal and child health indicators ▪ Program participation and demographics ▪ Development, revision, and maintenance of the WIC website Breastfeeding/Training/Communications This unit is located in the MDH St. Paul office. Staff are responsible for: ▪ Breastfeeding promotion and support with Local Agencies and Community partners ▪ Training and technical assistance on breastfeeding promotion and support ▪ Administering, monitoring, and evaluating Local Agency peer breastfeeding support ▪ Coordinating and developing Staff training materials/conferences/modules related to administrative, nutrition, and breastfeeding topics ▪ Coordinating breast pump purchasing ▪ Developing and identifying breastfeeding education materials for Local Agencies to use for participant education ▪ Coordinating policy development and revisions ▪ Oversight of Civil Rights ▪ Assisting other state WIC staff with questions on breastfeeding ▪ Assisting with communication related to WIC Program outreach and assuring health equity ▪ Assisting with the evaluation of program planning, grant management, breastfeeding promotion, and support ▪ Supporting participant centered customer service

S E C T I O N 1 . 2 : S T A T E W I C S T A F F A N D R O L E 3 Food Delivery (Vendor) Unit This unit is located in the MDH St. Paul office. Issues related to the WIC-allowed foods and/or retail food delivery system should be directed to the Food Delivery (Vendor) Unit: ▪ Conducting WIC Vendor Activities as outlined below (see Exhibit 1H: Authorization and Monitoring of WIC Vendors – State Role for additional details) ▪ Authorizing, monitoring, and training WIC vendors ▪ Providing vendor resources and communications ▪ Developing vendor rules ▪ Assuring vendor program compliance ▪ Setting food price limits ▪ Addressing shopping experience concerns ▪ Coordinating the WIC food approval process and changes to the food list ▪ Maintaining an APL (Approved Product List) of MNWIC-allowed foods and addressing questions and new food submission requests ▪ Ordering medical formula for participants upon request of a Local Agency ▪ Identifying and following up on situations involving potential participant violations and Local Agency staff abuse ▪ See Exhibit 1H: Authorization and Monitoring of WIC Vendors – State Role Fiscal Management These staff are located in the MDH St. Paul office. They are responsible to: ▪ Track monthly participation ▪ Evaluate administrative and food costs to date and forecast future expenses ▪ Process/track monthly claim forms ▪ Calculate infant formula rebate monthly ▪ Compute local agency caseloads quarterly ▪ Review Request to Increase Administrative Funds (RIAF) and Local Agency Expense forms for supplemental funding ▪ Provide assistance on federal funding inquiries ▪ Monitor activities, costs, and effectiveness ▪ Financial/general ledger reviews Reference – Complete Listing of Hyperlinks State Staff Directory – WIC/CSFP (www.health.state.mn.us/docs/people/wic/localagency/program/ststfflst.pdf) MN Operations Manual (MOM) (https://www.health.state.mn.us/people/wic/localagency/mom.html) Exhibit 1-H Authorization and Monitoring of WIC Vendors Vendors-State Role (www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex1/1hnew.pdf)

S E C T I O N 1 . 2 : S T A T E W I C S T A F F A N D R O L E 4 Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164- 0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942. This institution is an equal opportunity provider.

(1.3)Minnesota WIC Operations Manual (MOM) Section 1.3: Local Agencies and Role#

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Section 1.3: Local Agencies and Role 01/2018 The Minnesota WIC Program is administered by the Minnesota Department of Health through grant agreements with local agencies throughout the state. Every five years the state awards WIC grants to local agencies in a geographic area based on the priority rule set forth in Minnesota Administrative Rule 4617 (Section 1.4: Grant Application Process). The WIC Program may be administered by the following local agencies according to state rules. 1. Community Health Board 2. Public or Private Nonprofit Health Service Agency 3. Public Human Service Agency 4. Private Nonprofit Human Service Agency Local agencies are responsible for determining eligibility of WIC Program applicants and for providing nutrition education, health care referral services, and issuing food benefits to participants. WIC services are available to residents of all 87 counties in Minnesota. Local agencies are responsible for adhering to all policies and procedures included in this manual. These policies, along with federal regulations, form the basis for WIC Program local agency operations and monitoring of these operations by state WIC staff. The role of local agencies is to implement and operationalize current state WIC policy in their own respective agencies and organizations. As independent local agencies and organizations implementing the WIC Program in Minnesota, these entities often have existing and related policies and procedures. It is the responsibility of the local agency to ensure that state WIC policy is adhered to and that any related local policy is not less stringent than state policy and does not conflict with state policy. Local agencies should consult with their State WIC Consultant on any questions related to local implementation of state WIC policy. Reference – Complete Listing of Hyperlinks Section 1.4: Grant Application Process (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_4.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(1.4)Minnesota WIC Operations Manual (MOM) Section 1.4: Grant Application Process#

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Section 1.4: Grant Application Process 11/2023 References: State Rules 4617 Policy: WIC Grant applications are available as per the MDH Master Grant Agreement schedule. WIC Program Grant Agreements are renewed at least once every 5 years. Local Agencies must apply for WIC grant funds according to the procedures listed below. See Exhibit 1-O: Grant Application Process for more information on the grant application process. The grant application is the process in which a local agency applies to the Minnesota Department of Health for grant funds to administer a WIC Program. This process is governed by Minnesota Administrative Rules. Applications are accepted for serving a geographic area(s) or special populations. Types of local agencies which may apply for a WIC grant are listed in order of their priority for application approval: 1. Community Health Board 2. Public or Private Nonprofit Health Service Agency 3. Public Human Service Agency 4. Private Nonprofit Human Service Agency A local agency is classified as either a health service agency or a human service agency, based on the type of services it primarily provides during its current fiscal year. The same priority system applies to all agencies, regardless of whether they have previously applied for or received WIC funding. Procedures ▪ The State WIC office will make the application and instructions available to apply for WIC Program funds. ▪ An agency must notify the Commissioner in writing of its intention to apply for WIC Program funds. ▪ Upon receipt of notice of intent to apply for WIC Program funds, the state WIC office will provide an application form and instructions to the requesting agency. ▪ An agency may apply to administer the WIC Program for a geographic area or for a special population.

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2 1 1 / 2 0 2 3 ▪ In conjunction with applying to administer the WIC Program, an agency may also apply for a Peer Breastfeeding Support Program Grant. ▪ Application materials must be received by the date stated in the Notice of Availability. For any questions about the grant application timeline or application process, contact the State WIC Office with the Questions and Feedback for the Minnesota WIC Program form. Reference – Complete Listing of Hyperlinks State Rules 4617 (https://www.revisor.mn.gov/rules/?id=4617&view=chapter) Exhibit 1-O: Grant Application Process (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex1/1o. pdf) Minnesota Administrative Rules (https://www.revisor.mn.gov/rules/4617.0010/) Questions and Feedback for the Minnesota WIC Program (https://redcap.health.state.mn.us/redcap/surveys/?s=YLFWF87TRW) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(1.6)Minnesota WIC Operations Manual (MOM) Section 1.6: Public Notification and Outreach#

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Section 1.6: Public Notification and Outreach 4/2021 References: 7CFR 246.4 (a)(7) Policy: Local Agencies must regularly inform potential participants of the availability of WIC services and benefits. Purpose: To ensure that eligible families have the information, encouragement, and access they need to apply for WIC services. Procedures At least annually: ▪ The State Agency will publicize the availability of program benefits and of the eligibility criteria for participation. ▪ The Local Agency will publicize information about the local WIC agency and clinics and conduct other outreach. ▪ The Local Agency will maintain adequate documentation of outreach efforts to be reviewed at their biennial Management Evaluation. See Guidance below. Guidance ▪ Disseminate program information to potentially eligible families using strategies such as social media, local agency or county websites, public or community displays, leaflets, brochures, bulletins, toll free phone number, newspapers, speakers for community organizations, and/or radio and television announcements. ▪ Convey the message of equal opportunity by using photographs or other graphics to show participants of different races, ethnicities, and abilities. ▪ Provide these materials in multiple languages, in addition to English, as needed. ▪ Follow Civil Rights Policy, Section 1.10: Civil Rights. ▪ Include the appropriate version of the Nondiscrimination Statement on outreach materials. If the short statement is used, the font size must be in the same font size as the rest of the text (or the majority of the text) used.

S E C T I O N 1 . 6 : P U B L I C N O T I F I C A T I O N A N D O U T R E A C H 2 ▪ Post both the “And Justice for All” poster and the state-provided Interpreter/ Accommodations poster in WIC clinic/office spaces. ▪ Inform participants, and potential participants, of any significant program changes, such as changes in eligibility standards, clinic hours, or location. ▪ Target outreach efforts to: ▪ Enroll pregnant women early in pregnancy ▪ Reach and enroll migrant farm families ▪ Encourage child participation until 5 years of age ▪ Distribute this information to offices and organizations that also serve or work with potentially eligible persons, particularly in low-income areas, such as: ▪ Health and medical organizations ▪ Hospital and clinics ▪ Employment offices ▪ Social service agencies ▪ Farm worker organizations ▪ Indian tribal organizations ▪ Organizations and agencies serving homeless individuals ▪ Religious and community organizations ▪ Child care providers ▪ Local businesses hiring low-income employees ▪ Document local outreach activities such as organized events and use of media. Include the date, name and/or brief description of the activity and name of staff. The outreach log below is an example showing adequate documentation. Outreach Log - example Date Outreach Activity Staff Responsible

▪ Maintain documentation for review at the next Management Evaluation.

S E C T I O N 1 . 6 : P U B L I C N O T I F I C A T I O N A N D O U T R E A C H 3 Reference – Complete Listing of Hyperlinks Section 1.10: Civil Rights (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_10.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(1.7)Minnesota WIC Operations Manual (MOM) Section 1.7: Data Privacy#

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Section 1.7: Data Privacy MAY 2019 References 7 CFR 246.26 (d-h) (d)(1)(i-ii)“Confidentiality of applicant and participant information — (1) WIC purposes. (i) Confidential applicant and participant information is any information about an applicant or participant, whether it is obtained from the applicant or participant, another source, or generated as a result of WIC application, certification, or participation, that individually identifies an applicant or participant and/or family member(s). Applicant or participant information is confidential, regardless of the original source and exclusive of previously applicable confidentiality provided in accordance with other Federal, State or local law. (ii) Except as otherwise permitted by this section, the State agency must restrict the use and disclosure of confidential applicant and participant information to persons directly connected with the administration or enforcement of the WIC Program whom the State agency determine have a need to know the information for WIC Program purposes. These persons may include, but are not limited to: personnel from its local agencies and other WIC State or local agencies; persons under contract with the State agency to perform research regarding the WIC Program, and persons investigating or prosecuting WIC Program violations under Federal, State or local law.” MN Statute 13.01-13.99 Policy: Local Agencies must protect and secure private WIC participant data at all times and may not disclose or release private data except under certain circumstances following specified procedures as outlined below. Purpose: Individual WIC applicant/participant information is private. This policy exists to maintain privacy and to protect the integrity of participant data. Definitions (from MN Statute 13) Private data on individuals are data made by statute or federal law applicable to the data: (a) not public; and (b) accessible to the individual subject of those data. Summary data means statistical records and reports derived from data on individuals but in which individuals are not identified and from which neither their identities nor any other characteristic that could uniquely identify an individual is ascertainable.

S E C T I O N 1 . 7 : D A T A P R I V A C Y 2 Procedures To ensure data privacy, Local Agencies must: ▪ Secure WIC participant data (paper records and/or electronic data) at all times, including during collection, printing, storage, and transport. ▪ Limit the release or sharing of private WIC data to instances in which the participant, custodial parent or legal guardian has provided signed consent to release such data and other instances as required by law. ▪ Provide annual training on data security to Local Agency staff and maintain documentation of the training. (See Security Training) ▪ Gather information in a private space so that others cannot hear. ▪ Allow time for participant/caregiver to read (or be read to) the Rights & Responsibilities; inform them how information might be used (Exhibit 1-K); and obtain signature from participant/caregiver regarding their acceptance of the Rights and Responsibilities. ▪ Protect participant private data and do not share except as allowed by law or authorized by the participant. ▪ Use appropriate security at clinic (see Section 9.3: Security of WIC Information System) ▪ Ensure that private data sent via email is appropriately encrypted, encoded, or protected. Releasing information: Private WIC data may only be released under certain circumstances 1. WIC data may be viewed and used by persons directly working with the administration, monitoring, or enforcement of the WIC Program, including local, state, and federal WIC staff. Aggregate or summary WIC data is considered public and may be used for a variety of purposes. 2. Private data may be released to other parties only with the written consent of the participant, custodial parent, or legal guardian. Written consent is obtained by asking the participant, custodial parent, or legal guardian to complete a Consent to Release Information form. These forms should be limited to authorize the release of data for continuity of care and for the benefit of the participant. WIC private data shared with appropriate consent may not be released to a 3rd party without written consent or authorization. A Consent to Release Information must include: ▪ Name of the participant for whom the data applies ▪ What data is being released ▪ The purpose for releasing the data/how the data will be used

S E C T I O N 1 . 7 : D A T A P R I V A C Y 3 ▪ To whom the data is being released (including name(s) of specific programs or providers rather than entire organizations so that participants can select appropriate recipients of the private data and choose not to select any programs they feel are not appropriate recipients) ▪ Notification that declining to sign the release will not impact the individual’s eligibility or participation in the WIC Program and that individual data will not be shared ▪ A statement of the individual’s right to revoke the authorization in writing ▪ Signature of the participant, custodial parent, or legal guardian ▪ An expiration date A Consent to Release Information must not include: ▪ Pre-checked boxes indicating broad entities with which to share the individual’s data, but rather, complete in an individualized way to meet the needs of each individual participant for care coordination and continuity of care and ensure the participant understands they can choose which programs with which sharing can occur and which programs no sharing can occur. An example form for Consent to Release Information can be found in Exhibit 1-C: Sample Authorization for Release of Information To ensure that there is no inferred coercion, release forms for private physicians or other health care providers may be included as part of the WIC application or certification process; however, all other requests to sign voluntary release forms must occur after the application and certification process is completed. 3. Exceptions when private data may be released without the written consent of the participant, custodial parent or legal guardian: ▪ Information regarding suspected or known child abuse or neglect must be released to the proper authorities according to the law (The Federal Child Abuse Protection and Treatment Act). ▪ A court order is required for the release of private data without a signed consent. If a search warrant or a court order is presented, local agency staff must notify the State Agency, and consult with their legal counsel for advice regarding how to respond and seek to limit the disclosure. A subpoena is not adequate for disclosure of private data. Data Breach: An unauthorized disclosure of private WIC data Private data is accessible to the subject of the data but is not accessible to the public. Some examples of a data breach include, but are not limited to: ▪ Lost or stolen bag, paper participant files/charts, removable storage device containing private data. ▪ Lost, stolen, or hacked laptop or desktop containing private data. ▪ Misguided or misaddressed email, post mail, or fax containing private data.

S E C T I O N 1 . 7 : D A T A P R I V A C Y 4 ▪ Any other situation in which an unauthorized person has access to private data. ▪ There are many other ways that data security can be breached. If you are unsure of whether a data breach has occurred, always report the incident, and see further guidance. Report Data Breaches (or Suspected Data Breaches) Immediately If you see or experience a breach or potential breach of private data, you must immediately notify the proper authority in your Local Agency that oversees private data and the State WIC Consultant. It is the Local Agency’s responsibility to work with their administrator/legal unit and the State Office to determine who else to contact and what actions to take. Information you provide regarding a data breach will be used to stop the breach, mitigate any problems, and possibly for investigative purposes. Contact the State WIC office with the following information: ▪ Agency name and number ▪ List of missing equipment ▪ Location where loss/theft occurred ▪ Date and time loss/theft occurred (actual, if known, or estimated) ▪ Date and time loss/theft was discovered ▪ Circumstances involved ▪ Provide a copy of the police report information, if applicable ▪ Name and telephone number of staff person to contact with questions Guidance ▪ If there is any uncertainty about the identity or authorization of an individual requesting access to private data, seek valid identification of the individual to ensure appropriate authorization. ▪ When working outside the main office, take only materials and records that are needed. ▪ When using a shared printer, collect copies immediately. ▪ Safeguard private data when communicating with participants outside of WIC clinic. Private data is described in MN Statute 13.01-13.99, including any information that would imply an individual’s application to or participation in the WIC program. Mail and Telephone ▪ If mailing information, WIC identifiers should not be visible on an envelope or on the outside of a postcard including the return address (using Public Health Address is permissible). ▪ If calling participants, confirm phone number at appointments and document any special instructions for leaving messages with others or on voice mail.

S E C T I O N 1 . 7 : D A T A P R I V A C Y 5 ▪ Give participants the opportunity to opt out of this type of communication. Document in the WIC Information System if the participant does not want to receive mail or telephone communication. Text and Email ▪ Minnesota Department of Health recommends obtaining written authorization prior to sharing any non-public data by email or text. The consent form should include a warning that sending information by text/email is not secure and provide the participant the opportunity to revoke the release at any time (See MOM Exhibit 1-C-Sample Authorization for Release of Information). Agencies are encouraged to consult with their county attorney or data privacy officer regarding these methods of communication. ▪ An appointment time and personal/individualized nutrition or breastfeeding information is considered private data. ▪ Education materials, such as nutrition education cards, are not considered private data and can be mailed (see mailing above), texted or emailed. Any materials posted on the WIC website are considered public information. ▪ If an agency is using a third-party vendor for text messaging, the consent for that texting service is adequate. It is not necessary to obtain an agency-specific secondary consent for that texting service. Contact your State WIC Consultant with any questions and for further guidance. Reference – Complete Listing of Hyperlinks 7 CFR 246.26 (d-h) (http://www.gpo.gov/fdsys/pkg/CFR-2012-title7-vol4/pdf/CFR-2012-title7- vol4-sec246-26.pdf) MN Statute 13.01-13.99 (https://www.revisor.mn.gov/statutes/?id=13) Security Training (https://www.health.state.mn.us/people/wic/localagency/infosystem/hubert/training/index.ht ml#security) Exhibit 1-K: Rights and Responsibilities (https://www.health.state.mn.us/people/wic/rights.html) Section 9.3: Security of WIC Information System (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch9/sct n9_3.pdf) Exhibit 1-C: Sample Authorization for Release of Information (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex1/1c. pdf)

S E C T I O N 1 . 7 : D A T A P R I V A C Y 6 Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(1.9)Minnesota WIC Operations Manual (MOM) Section 1.9: Compliance Monitoring of Local Agencies#

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1 Section 1.9: Compliance Monitoring of Local Agencies 09/2018 References: 7CFR 246.9 Policy: Local agencies participate in a Management Evaluation and Financial Review every two (2) years or more frequently if necessary. Purpose: To ensure compliance with federal regulations. Procedures Local Agency Coordinators monitor staff and provide ongoing training, to assure compliance with federal regulations. ▪ In cooperation with Local Agency WIC Coordinators, Administrators, and Financial Management staff, State WIC staff will schedule the activities necessary to complete the Management Evaluation and Financial Review. ▪ Local Agency staff will cooperate with State WIC staff to assure that necessary activities are carried out during monitoring visits: observing clinic procedures, examining office records, providing access to necessary records, performing chart reviews, and assessing compliance with regulations. ▪ Local Agency WIC and financial management staff will cooperate with State WIC staff during Financial Reviews to assess compliance with federal and state regulations regarding WIC expenditures. ▪ If required actions are identified during the Management Evaluation (including against Civil Rights requirements) and/or Financial Review, Local Agency staff will submit a corrective action plan for each required action within 30 days. It is the responsibility of the WIC Coordinator to implement the corrective action plan. The Local Agency may request technical assistance from State WIC staff for resolving required actions. ▪ State Staff will follow-up with Local Agency staff to ensure that the corrective action plan is completed, which may include an additional site visit by State Staff to a Local Agency clinic/office site.

S E C T I O N 1 . 9 : C O M P L I A N C E M O N I T O R I N G O F L O C A L A G E N C I E S 2 Guidance Local Agency WIC Coordinators consult with and seek advice from State WIC staff, as needed, especially before implementing changes related to policy, staffing structure or clinic function. WIC Coordinators perform ongoing self-evaluation of their agencies’ compliance with federal regulations and of program effectiveness, using available tools in (MOM – Chapter 4: Local Agency Management and Staffing) for staffing and various WIC Information System reports to monitor their performance. See: ▪ Exhibit 4-G: Staff Monitoring Plan ▪ Exhibit 4-H: Checklist for Certification Observations ▪ Exhibit 4-J: Chart Audit Form ▪ Exhibit 1-L: State Role in Participant Violations Related policies: ▪ Section 4.2: Local Agency Management ▪ Section 4.6: CPA Monitoring and Oversight ▪ Section 2.1: Introduction Program Costs Reference – Complete Listing of Hyperlinks Chapter 4: Local Agency Management and Staffing (https://www.health.state.mn.us/people/wic/localagency/mom.html#staffing) Exhibit 4-G: Suggested Monitoring Plan (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4g. pdf) Exhibit 4-H: Checklist for Certification Observations (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4h. pdf) Exhibit 4-J: Chart Audit Form (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4j. pdf) Exhibit 1-L: State Role in Participant Violations (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex1/1l. pdf) Section 4.2: Local Agency Management (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_2.pdf)

S E C T I O N 1 . 9 : C O M P L I A N C E M O N I T O R I N G O F L O C A L A G E N C I E S 3 Section 4.6: CPA Monitoring and Oversight (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_6.pdf) Section 2.1: Introduction (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch2/sct n2_1.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(1.10)Minnesota WIC Operations Manual (MOM) Section 1.10: Civil Rights#

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Section 1.10: Civil Rights 02/2024 References: 7CFR 246, FNS Instruction 113-1 Policy, MOU between USDA FNS Civil Rights Division and MDH, Other related regulations and legislation in Guidance Policy: Local Agencies must comply with all applicable federal and state civil rights laws and regulations in the provision of WIC services. Purpose: To ensure that all applicants and participants receive fair and equitable treatment and benefits without regard to race, color, national origin, age, sex (including gender identity and sexual orientation), or disability. Procedures: Local Agencies must comply with the following provisions and procedures: 1. Civil Rights Assurances Sign written assurances that the agency will be operated in compliance with the applicable nondiscrimination laws, regulations, instructions, policies, and guidelines as noted above and in Guidance. A civil rights assurance statement must be incorporated into all agreements between: ▪ Federal and State agencies ▪ State agencies and sub-recipient agencies ▪ Sub-recipient agencies and their local sites (if applicable) 2. Public Notification Inform applicants, participants, and potentially eligible persons, of program availability, program rights and responsibilities, the policy of nondiscrimination, and the procedure for filing a complaint. Outreach: ▪ Conduct outreach activities to notify potentially eligible persons of program availability. See Section 1.6: Public Notification and Outreach. ▪ Include the nondiscrimination statement (NDS, see below) on any local agency-developed outreach notices or materials.

S E C T I O N 1 . 1 0 : C I V I L R I G H T S 2 ▪ Make program materials available upon request. ▪ Inform the public and participants of changes to the Program in a timely manner. Rights & Responsibilities: ▪ Provide a copy of participant’s Rights and Responsibilities at certification. See Exhibit 1-K: WIC Rights and Responsibilities. “...And Justice for All” Poster: ▪ Display the most recent nondiscrimination “...And Justice for All” poster in prominent places throughout the WIC service area, including clinic waiting rooms, certification areas and lab rooms, where it is easily visible and readable by anyone who visits the agency. ▪ When the clinic, or the number of participants served by a clinic is large, posters should be displayed in numerous places throughout. Interpreter/Accommodations Poster ▪ Display notification that free interpreter services are available and that accommodations will be made for anyone with a disability, upon request. See Guidance section below for more information. ▪ Display the notification/poster any place the public goes and where it can be easily read by applicants/participants. This includes the waiting area, at a minimum, but also the WIC office. If the clinic is large, display more than one poster. Consider placing the smaller poster in cubicles where staff meet with participants, the lab, etc. ▪ If not using the State WIC poster, notifications used must be translated into appropriate languages. Nondiscrimination Statement (NDS): Include the FNS Nondiscrimination Statement (NDS) on all public WIC materials, outreach, and Program change notices developed by the State WIC office or a Local WIC Agency. WIC is required to use the NDS listed under “for all other FNS nutrition assistance programs”. ▪ Full, unedited NDS: Use the full, unedited NDS below on the local WIC Program’s website home page, and on all vital WIC documents. Vital documents include any document critical for purposes of eligibility/ineligibility or participation in WIC or obtaining benefits. Examples of vital documents include, but are not limited to: applications, consent forms, complaint forms, notices of rights and disciplinary action, and letters or notices that require a response from the participant. ▪ The shortened version of the NDS may be used if the document/material is not considered vital and is too small to accommodate the full statement above. o English: “This institution is an equal opportunity provider.” o Spanish: “Esta institución es un proveedor que ofrece igualdad de oportunidades.”

S E C T I O N 1 . 1 0 : C I V I L R I G H T S 3 ▪ Other translations of the NDS are available at: FNS Nondiscrimination Statement. WIC uses the NDS version for “All Other Programs.” See Guidance section below for more information. ▪ Font size: the font size for the shortened NDS must be the same size as the rest of the printed material (or average font if several font sizes). The font size for the full NDS need not be the same size as the rest of the printed document. However, it must be legible and can be no smaller than 8 point font. Full USDA Nondiscrimination Statement in English: In accordance with federal civil rights law and U.S. Department of Agriculture (USDA) civil rights regulations and policies, this institution is prohibited from discriminating on the basis of race, color, national origin, sex (including gender identity and sexual orientation), disability, age, or reprisal or retaliation for prior civil rights activity. Program information may be made available in languages other than English. Persons with disabilities who require alternative means of communication to obtain program information (e.g., Braille, large print, audiotape, American Sign Language), should contact the responsible state or local agency that administers the program or USDA’s TARGET Center at (202) 720-2600 (voice and TTY) or contact USDA through the Federal Relay Service at (800) 877-8339. To file a program discrimination complaint, a Complainant should complete a Form AD-3027, USDA Program Discrimination Complaint Form which can be obtained online at: https://www.usda.gov/sites/default/files/documents/ad-3027.pdf, from any USDA office, by calling (866) 632-9992, or by writing a letter addressed to USDA. The letter must contain the complainant’s name, address, telephone number, and a written description of the alleged discriminatory action in sufficient detail to inform the Assistant Secretary for Civil Rights (ASCR) about the nature and date of an alleged civil rights violation. The completed AD-3027 form or letter must be submitted 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; or 2. fax: (833) 256-1665 or (202) 690-7442; or 3. email: program.intake@usda.gov This institution is an equal opportunity provider.

S E C T I O N 1 . 1 0 : C I V I L R I G H T S 4 Full USDA Nondiscrimination Statement in Spanish: De acuerdo con la ley federal de derechos civiles y las normas y políticas de derechos civiles del Departamento de Agricultura de los Estados Unidos (USDA), esta entidad está prohibida de discriminar por motivos de raza, color, origen nacional, sexo (incluyendo identidad de género y orientación sexual), discapacidad, edad, o represalia o retorsión por actividades previas de derechos civiles. La información sobre el programa puede estar disponible en otros idiomas que no sean el inglés. Las personas con discapacidades que requieren medios alternos de comunicación para obtener la información del programa (por ejemplo, Braille, letra grande, cinta de audio, lenguaje de señas americano (ASL), etc.) deben comunicarse con la agencia local o estatal responsable de administrar el programa o con el Centro TARGET del USDA al (202) 720-2600 (voz y TTY) o comuníquese con el USDA a través del Servicio Federal de Retransmisión al (800) 877-8339. Para presentar una queja por discriminación en el programa, el reclamante debe llenar un formulario AD-3027, formulario de queja por discriminación en el programa del USDA, el cual puede obtenerse en línea en: https://www.usda.gov/sites/default/files/documents/ad- 3027s.pdf, de cualquier oficina de USDA, llamando al (866) 632-9992, o escribiendo una carta dirigida a USDA. La carta debe contener el nombre del demandante, la dirección, el número de teléfono y una descripción escrita de la acción discriminatoria alegada con suficiente detalle para informar al Subsecretario de Derechos Civiles (ASCR) sobre la naturaleza y fecha de una presunta violación de derechos civiles. El formulario AD-3027 completado o la carta debe presentarse a USDA por: 1. correo: U.S. Department of Agriculture Office of the Assistant Secretary for Civil Rights 1400 Independence Avenue, SW Washington, D.C. 20250-9410; o 2. fax: (833) 256-1665 o (202) 690-7442; o 3. correo electrónico: program.intake@usda.gov Esta institución es un proveedor que ofrece igualdad de oportunidades. 3. Racial and Ethnic Data Collection Collect data on racial and ethnic categories at the time of application or certification by allowing applicants to self-select one ethnic category and one or more racial categories. If the applicant refuses to self-select, see Guidance section below for more information for further actions.

S E C T I O N 1 . 1 0 : C I V I L R I G H T S 5 The categories are: Ethnicity: Hispanic or Latino Not Hispanic or Latino Race: American Indian or Alaska Native Asian Black or African American Native Hawaiian or Other Pacific Islander White 4. Complaints of Discrimination USDA defines discrimination as “different treatment which makes a distinction of one person, or a group of persons, from others, either intentionally, by neglect, or by the actions or lack of actions...” Individuals may submit their claims to the State or local office, or directly to USDA using the address on the complaint form. ▪ Provide the Federal Discrimination Complaint form (see U.S. Department of Agriculture USDA Program Discrimination Complaint Form or Nondiscrimination Statement for translations of the AD-3027 Complaint Form), explain how to file the complaint and assist the complainant in filling it out if needed. ▪ Instruct the complainant to send the form directly to USDA (the address is on the form). If a staff person is given a complaint or is requested to mail the complaint form, they must log it into their Civil Rights Complaint Log. See below for additional information on the Complaint log. ▪ Individuals need not use the complaint form but can also write a letter containing the information in the form. If a complaint of discrimination is brought forward, staff must: ▪ Never interfere with, or discourage, an individual from filing a complaint. ▪ Keep confidential all information associated with the complaint, including the name of the person filing the complaint. ▪ Keep a Civil Rights complaint log of complaints received either orally or in writing. The log should include the date and nature of the complaint, the name of staff who handled the complaint, and subsequent staff actions regarding the complaint. ▪ Restrict access of civil rights related records to authorized persons only, such as the clinic supervisor and state WIC staff. Ensure that electronic records are properly safeguarded, and password protected.

S E C T I O N 1 . 1 0 : C I V I L R I G H T S 6 ▪ Notify the State WIC Consultant and the State WIC Civil Rights Coordinator if a complaint is brought forward, or for guidance regarding handling discrimination complaints. ▪ The complaint must be filed within 180 days of the incident. ▪ No staff may retaliate against a complainant. 5. Compliance Reviews Provide Civil Rights related information to the State Office during the WIC grant application process and the Biennial Management Evaluation. Compliance topics include following the guidelines as outlined in this policy regarding: ▪ Providing public notification, including proper use of the nondiscrimination statement and proper display of the “And Justice for All” poster both of which ensure that potentially eligible persons have equal opportunity to participate ▪ Offering assurances in all contracts ▪ Providing Civil Rights Training ▪ Collecting and reporting racial/ethnic data in the WIC Information System ▪ Offering interpreter and translation services to persons with Limited English Proficiency ▪ Providing accommodations for persons with disabilities ▪ Following guidelines for handling potential complaints of discrimination ▪ Offering all applicants an equal opportunity to participate 6. Resolution of Noncompliance: Follow any direction or guidance provided by the State WIC office, or FNS, to correct areas of Civil Rights noncompliance, and/or address areas for improvement. 7. Civil Rights Training ▪ Ensure all frontline WIC staff, breastfeeding peer counselors, and volunteers who interact with program applicants or participants, and those persons who supervise frontline WIC and peer staff, participate in Civil Rights training at least once a year. ▪ Use the Civil Rights training materials provided by the State WIC Office, available on the WIC website. (See Civil Rights Training) ▪ Document the training by collecting the names, signature of the trainees, and the date of the training. The training log must be available for review during the agency’s Management Evaluation.

S E C T I O N 1 . 1 0 : C I V I L R I G H T S 7 ▪ A tracking system that requires individual log-ons and passwords, tracks training completion by staff, and generates a report of users who completed the training is acceptable for documentation. A signature would not be required when using this system. 8. Disability Compliance ▪ Ensure equal access to all services for persons with disabilities. Provide interpreter services and accommodations for persons with visual or hearing impairments, limited reading skills, and/or other physical disabilities. See Guidance section below for more information. ▪ Staff must know the name and contact information of their local Americans with Disabilities Act (ADA) Coordinator. The ADA Coordinator information should be posted where all staff can locate it. That could be on a bulletin board, shared electronic files, intranet, etc. 9. Limited English Proficiency (LEP) LEP applies to individuals who do not speak English as their primary language and/or who have a limited ability to read, speak, write, or understand English because of their national origin. ▪ Provide competent, accurate, timely, effective, and free interpreter and translation services to potentially eligible persons, applicants, and participants, who are limited English language proficient. ▪ Take reasonable steps to ensure “meaningful access” to the program and its activities. ▪ Display a notification that language interpretation is available free of charge to any person who has Limited English Proficiency. See Guidance section below for more information. 10. Citizenship and Immigration Status ▪ Serve all applicants regardless of citizenship and immigration status. ▪ Do not ask about or require proof of citizenship. 11. Civil Rights Impact Analysis for New Clinics, Closing Clinics, or Relocation of a Clinic ▪ Agencies planning to make any changes to their clinic locations must contact their State Consultant as soon as you learn that clinic could be closing, opening (including satellite sites), or relocating. ▪ Agencies must first complete and submit a Civil Rights Impact Analysis (CRIA) Survey to their State Consultant when planning on opening a new clinic, closing a clinic, or relocating a clinic. ▪ The CRIA survey is used to as a tool to help assess appropriateness and guide any change that may be required to meet the needs of participants in any protected class that your agency serves.

S E C T I O N 1 . 1 0 : C I V I L R I G H T S 8 ▪ Contact your State WIC Consultant for more information. Prohibited Discriminatory Practices Prohibited types of discrimination include, but are not limited to, the following situations: ▪ The exclusion of persons from participation in the program on the basis of race, color, national origin, age, sex (including gender identity and sexual orientation), or disability. ▪ The inequitable allocation of food to eligible persons on the basis of race, color, national origin, age, sex (including gender identity and sexual orientation), or disability. ▪ The issuance of WIC food benefits in a place, time, or manner that results in, or has the effect of denying or limiting the benefits on the basis of race, color, national origin, age, sex (including gender identity and sexual orientation), or disability. ▪ The segregation of persons in clinic waiting rooms or through an appointment system on the basis of race, color, national origin, age, sex (including gender identity and sexual orientation), or disability. ▪ The application of different eligibility standards to potentially eligible applicants on the basis of race, color, national origin, age, sex (including gender identity and sexual orientation), or disability. ▪ The certification of persons as eligible to receive benefits solely on the basis of race, color, national origin, age, sex (including gender identity and sexual orientation), or disability. ▪ The maintenance of a waiting list which makes distinctions on the basis of race, color, national origin, age, sex (including gender identity and sexual orientation), or disability. ▪ Retaliatory actions against a client or staff person who may have filed a discrimination complaint. Note: Program regulations define WIC participants as pregnant, breastfeeding, and postpartum individuals, and infants and children to age five (5); as such, program eligibility does not violate Civil Rights requirements regarding sex and age. Men and other caregivers are welcome and encouraged to apply for WIC benefits for eligible children. Guidance For more comprehensive guidance on civil rights compliance and the process for handling complaints, refer to FNS Instruction 113-1: Civil Rights Compliance and Enforcement and other materials as appropriate. Complaints of Discrimination: While staff must never interfere with or discourage anyone from filing a complaint, they may explore the situation with the complainant to correct potential misinformation or misunderstandings. For example, if a father said he wanted to file a complaint because he was not “allowed to participate in WIC” – staff could explain that program benefits are available only for eligible women, infants, and children, but that he could apply for benefits for his child.

S E C T I O N 1 . 1 0 : C I V I L R I G H T S 9 Once clarified, he might then decide not to file the complaint. If he does so freely, simply document what occurred. Nondiscrimination Statement ▪ Font size: o The font size of the NDS is determined by whether the document includes the full or abbreviated NDS. The abbreviated NDS must be in a font size that is the same as the rest of the document. o If the “document” contains only one size font (e.g., a letter to the participant), the NDS should be in the same size font as the text. In all cases the NDS must be legible and no smaller than 8 point font. o If the “document” has multiple font sizes (e.g., a poster which has a large title and smaller text), the NDS should be the size of the majority of the text, not the size of the title. ▪ Vital documents and letters: o A letter considered “vital” should have the same font size used for the letter. o It may work best in some cases to provide the long NDS on the back of the document in order to use the appropriate font size. ▪ Website home page: you may provide the NDS via a link to the full statement, using the title “USDA Nondiscrimination Statement”. ▪ As a general rule, if a material contains the WIC logo, it should have the NDS because it shows that the document represents the program. Anything that might be given or seen by WIC eligible participants should have the NDS if it is reasonable to put it on the item. ▪ If you have questions about when to use or not to use an NDS, reach out to the State Civil Rights Coordinator or your State Consultant. Training: State agencies are responsible for training local agencies. Local agencies are responsible for training any subrecipients, as well for training their staff. All staff, including frontline staff who interact with program applicants or participants, and those persons who supervise frontline staff, must complete civil rights training on an annual basis. Refer to: XI Civil Rights Training in FNS 113-1: Civil Rights Compliance and Enforcement. Documentation of Training: Documentation of annual training is required. Electronic signatures on the training log are acceptable. Additional Guidance for Civil Rights Training: Required: ▪ Receptionists and interpreters must receive training.

S E C T I O N 1 . 1 0 : C I V I L R I G H T S 1 0 Staff must be aware of and provide meaningful access to people with Limited English Proficiency and assist people with disabilities. This ensures a program participant’s rights are met. Not Required: ▪ Students who only observe and do not interact with participants. ▪ Volunteers – if they are not gathering information from participants, for example if they are only handing out materials. ▪ Interpreters who are not agency employees, but are employed by an external interpretation agency do not need to complete training. Race/Ethnicity: ▪ Allow applicants, parents, or proxies to self-select one ethnic category and one or more racial categories using available materials, such as a laminated copy of the choices. If an applicant or participant declines to self-select, staff must notify the participant that the staff will need to select the category(ies) based on perception. ▪ When prescreening applicants over the phone (including adding a new infant to a household), it is not necessary to collect racial/ethnic data at that time. Instead, collect this information when the applicant is in clinic for their certification appointment and can self- select. Accessibility: Ensure that all clinics are accessible to all applicants. ▪ Ensure an entrance to the clinic is accessible. ▪ Provide services on the main level or select a site accessible by elevator. ▪ See Section 5.9: Clinic Environment for a description of an ideal WIC clinic environment. ▪ Consider location of the clinic site to applicants/participants – accessible by public transportation; adequate and accessible parking; and client and staff safety. Accommodations: Modify procedures as needed to accommodate persons with special needs, such as: ▪ Adapting technique for weighing and measuring ▪ Certifying applicants at a site other than clinic (e.g., their home) Services: Provide culturally competent and appropriate services. ▪ Diversity o Recruit and hire persons of diverse races, cultures, and abilities that reflect the populations served by the Local Agency. o Hire individuals who are culturally competent and, when possible, bilingual, if they meet the WIC staffing requirements.

S E C T I O N 1 . 1 0 : C I V I L R I G H T S 1 1 o Convey the message of equal opportunity in photos and other graphics used to provide program information. ▪ Interpreters o Use interpreters who are fluent in the language needed. Using staff who have only a limited or basic understanding of the language does not meet the requirement to take reasonable steps to provide meaningful access. Using family members as interpreters is discouraged; children should never be used as interpreters. o Use the Language Line provided by MDH, TDD Relay service, and/or sign language interpreter, as needed. o See the Limited English Proficiency website for further guidance. o Use American Sign Language (ASL) interpreters when needed. The Minnesota Department of Human Services (DHS) provides listings of sign interpreters as a public service, but neither endorses, certifies, or guarantees the accuracy of information provided. See: ▪ Interpreter Agencies ▪ Freelance Interpreters - for a list of credentialed independent interpreters who asked to be included on the website listing ▪ Materials o Assure that written materials are written at an appropriate reading level. o Use translated written materials in the language(s) of participants. o For translations of the “… And Justice for All” poster, refer to the USDA And Justice for All Posters (Guidance and Translations) website [Note: Additional translations of the AJFA posters have been removed as of spring 2026]. Select the “AD-475A” version for posters applicable for WIC use. o The State WIC program provides the “Let us know if you need an interpreter or accommodations for a disability – both are free” poster which includes translations on it. If additional copies are needed, contact the State WIC Civil Rights Coordinator. o The State WIC program provides laminated copies of the Race/Ethnicity questions for use in clinic. Other Resources Applicable Civil Rights Legislation: Title VI Of The Civil Rights Act Of 1964 42 U.S.C. § 2000d Et Seq. S.557 - Civil Rights Restoration Act of 1987 Title IX of the Education Amendments of 1972, 20 U.S.C. §1681 et seq. A Layperson’s Guide to Section 504

S E C T I O N 1 . 1 0 : C I V I L R I G H T S 1 2 Age Discrimination Act of 1975 American with Disabilities Act of 1990, as Amended Executive Order 13166_2000~Improving Services for Persons with Limited English Proficiency CFR: 7 CFR Part 15 - Nondiscrimination Reference – Complete Listing of Hyperlinks 7CFR 246 (https://www.ecfr.gov/current/title-7/part-246) FNS Instruction 113-1 Policy (https://www.fns.usda.gov/fns-instruction-113-1) Section 1.6: Public Notification and Outreach (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_6.pdf) Rights and Responsibilities (https://www.health.state.mn.us/people/wic/rights.html) Nondiscrimination Statement (https://www.fns.usda.gov/cr/fns-nondiscrimination-statement) U.S. Department of Agriculture USDA Program Discrimination Complaint Form (https://www.usda.gov/sites/default/files/documents/ad-3027.pdf) Departamento de Agricultura de los EE. UU. (USDA) Formulario de Denuncia por Discriminación del Programa del USDA (https://www.usda.gov/sites/default/files/documents/ad-3027s.pdf) Civil Rights Training (https://www.health.state.mn.us/people/wic/localagency/training/civilrights.html) Exhibit 1-R: Civil Rights Impact Analysis Survey (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex1/1r. docx) Section 5.9: Clinic Environment (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_9.pdf) Limited English Proficiency (https://www.lep.gov/) Interpreter Agencies (https://mn.gov/deaf-hard-of-hearing/communication- access/interpreter/find/agencies.jsp) Freelance Interpreters (https://mn.gov/deaf-hard-of-hearing/communication- access/interpreter/find/freelancers.jsp) Title VI of the Civil Rights Act of 1964 42 U.S.C § 2000d et Seq (https://www.justice.gov/crt/fcs/TitleVI-Overview) S.557 - Civil Rights Restoration Act of 1987 (https://www.congress.gov/bill/100th- congress/senate-bill/557)

S E C T I O N 1 . 1 0 : C I V I L R I G H T S 1 3 Title IX of the Education Amendments of 1972, 20 U.S.C. §1681 et seq. (https://www.justice.gov/crt/fcs/TitleIX-SexDiscrimination) A layperson's guide to Section 504 (https://dredf.org/a-laypersons-guide-to-section-504/) Age Discrimination Act of 1975 (https://www.dol.gov/agencies/oasam/regulatory/statutes/age- discrimination-act) American with Disabilities Act of 1990, as Amended (https://www.ada.gov/pubs/adastatute08.htm) Executive Order 13166 (https://www.ada.gov/pubs/adastatute08.htm) 7 CFR Part 15 - Nondiscrimination (https://www.ecfr.gov/current/title-7/subtitle-A/part-15) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(1.11)Minnesota WIC Operations Manual (MOM) Section 1.11: Potential Participant Violations#

(1.11)(document-1)#

Section 1.11: Potential Participant Violations 03/2022 References: 7 CFR 246.7 (j) and (l); 7 CFR 246.12(u); 7 CFR 246.23(c) Policy: Local Agencies have a critical role in preventing fraud and abuse by WIC participants. Local Agency staff members must look for and report any possible program violations to the State Agency and follow State Agency direction in the investigation and resolution of the issues/cases. Examples of the most serious participant/applicant violations of the WIC Program include: ▪ Intentionally making a false or misleading statement, or intentionally misrepresenting, concealing, or withholding facts to obtain benefits. ▪ Applying for and/or receiving WIC benefits for the same person in separate households and/or in more than one WIC clinic or agency at the same time. ▪ Selling, or offering to sell, WIC Cards and benefits or supplemental foods through any means, including online sales. ▪ Physically harming or threatening to harm clinic or store staff. Participants are informed of WIC rules and about what they can expect from the program at certifications. See Exhibit 1-K: Rights and Responsibilities. Purpose: To preserve program integrity, all instances of potential violations, fraud and abuse must be investigated and resolved appropriately. Procedures Cases involving individuals providing false information to receive benefits ▪ Individuals will occasionally provide false information to the WIC Program to be deemed eligible and receive benefits. Examples include misrepresenting household income and falsely claiming to be pregnant. ▪ If you suspect someone has provided false information or receive a complaint alleging that someone has done so, gather all relevant information and report the situation to the State WIC Program Integrity Analyst. The State Agency will investigate the case and coordinate how it is to be handled.

S E C T I O N 1 . 1 1 : P O T E N T I A L P A R T I C I P A N T V I O L A T I O N S 2 Potential Duplicate Participant cases ▪ Local Agency staff members must follow the certification procedures located in the Minnesota Operation Manual, Chapter 5: Certification, to ensure certification of only eligible persons, and to avoid creating duplicate participants. ▪ Creation of duplicate participants can be prevented when CPAs utilize the WIC Information System Statewide search feature for all new or returning participants. ▪ Local Agencies must review and resolve potential duplicate participant cases weekly or monthly, depending on agency size and frequency of duplicates. See Guidance for instructions on how to review and resolve potential duplicates. ▪ Every local agency must have a staff member with “Role-10 LSA” access. Refer to WIC Information System User Roles & Definitions for details. This person has access to review and resolve cases of potential duplicate participants under the direction of the Coordinator. ▪ If it is difficult to determine whether a case represents a true duplicate, the Local Agency can request assistance from the State WIC Program Integrity Analyst. ▪ When a duplicate chart is found, Local Agency staff must review certification periods and issuance dates to determine whether excess/overlapping issuance has occurred. If it has, the Local Agency should contact the State WIC Program Integrity Analyst for guidance on how to proceed. Cases involving selling or offering to sell benefits ▪ Local Agency staff members must carefully explain all Rights and Responsibilities to participants and guardians, emphasizing that it is a participant violation to sell (or offer to sell) WIC benefits. ▪ Participants may be more likely to list formula for sale near their infant’s first birthday, once the need for it wanes. Remind parents/proxies at the 9 month appointment to only purchase the WIC formula and infant foods that their child will use. ▪ All suspected sales or postings of infant formula should be reported to the State WIC Program Integrity Analyst. Cases involving violence or threats toward clinic or store staff ▪ Violence or threats by participants or proxies should never be tolerated. See Exhibit 1-D: Sample Letter for Violation Threatening Harm. ▪ Coordinate with your State Consultant as necessary. Other cases Any other potential program integrity issue should be discussed with the State WIC Program Integrity Analyst. These include (but are not limited to) cases such as:

S E C T I O N 1 . 1 1 : P O T E N T I A L P A R T I C I P A N T V I O L A T I O N S 3 ▪ An individual potentially participating in WIC in two different states at the same time. ▪ Improper benefit redemption (using a WIC Card to purchase anything other than the foods listed on it). ▪ Presenting a WIC Card that belongs to another family. Case follow-up ▪ After a case is referred to the State Agency, Program Integrity members conduct investigations and data analysis to determine whether a participant violation has occurred. A Violations Committee reviews any case for which adverse action is recommended. ▪ If State Agency staff determine that a violation was unintentional on the part of the participant/proxy, they will advise the Local Agency on what actions must be taken, if any. ▪ In an unintentional case of duplicate participation resulting in excess issuance, Local Agency staff may need to let a proxy know that a WIC Card is being deactivated. For instance, if duplicate participation occurs in a dual-custody situation in which both parents enroll a child in WIC, the Local Agency may need to let one of the parents know their WIC Card is being deactivated. ▪ In an unintentional case in which a participant needs information to avoid further issues, the Local Agency may be asked to communicate the program requirements to the participant/guardian. ▪ If State Agency staff determine that a participant/proxy has intentionally committed a program violation, they will take action and/or enlist the Local Agency to do so based on requirements in federal regulations governing the WIC Program. ▪ If a participant/proxy commits a violation resulting in $100 or more in excess benefits, the State Agency is required to disqualify the participant, unless within 30 days of the WIC Program’s letter to the participant, the claim is paid in full, or a payment plan is agreed to. In the case of a child participant, the State Agency may make an exception to disqualification if a suitable alternate proxy can be assigned. The Local Agency may need to assist in finding and assigning a suitable proxy for such a case. The State Agency generally handles all correspondence related to participant claims, disqualifications, and potential appeals. ▪ If a violation involves less than $100 in excess benefits, the State Agency may ask the Local Agency to communicate with the participant/guardian about the issue. Per federal regulations, the State Agency may determine that it would not be cost- effective to seek repayment in such a case. Guidance ▪ Instructions on how to review and resolve potential duplicates can be found in the Duplicate Participants Overview.

S E C T I O N 1 . 1 1 : P O T E N T I A L P A R T I C I P A N T V I O L A T I O N S 4 ▪ See Exhibit 1-D: Sample Letter for Violation Threatening Harm as an example. ▪ The State Agency role in participant violations is further detailed in Exhibit 1-L: Participant Violations - State Agency Role. ▪ If a participant violation warrants disqualification of an infant or child, at the State Agency direction, the Local Agency will work with the parent or guardian to identify an alternate proxy to avoid disqualification. ▪ Local Agency staff can request State Agency assistance in assessing whether cases involve violations. Contact the State WIC Program Integrity Analyst and/or your State Consultant to begin the review process. Reference – Complete Listing of Hyperlinks Exhibit 1-K: Rights and Responsibilities (https://www.health.state.mn.us/people/wic/rights.html) Chapter 5: Certification (https://www.health.state.mn.us/people/wic/localagency/mom.html#certification) WIC Information System User Roles & Definitions (https://www.health.state.mn.us/docs/people/wic/localagency/winnie/roles.pdf) Exhibit 1-D: Sample Letter for Violation Threatening Harm (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex1/1d 3.docx) Duplicate Participants Overview (https://www.health.state.mn.us/people/wic/localagency/duplicate.html) Exhibit 1-L: Participant Violations - State Agency Role (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex1/1l. pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(1.12)Minnesota WIC Operations Manual (MOM) Section 1.12: Termination/Suspension of Program Benefits#

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Section 1.12: Termination/Suspension of Program Services 5/2019 References: 7 CFR 246.7(c)(3) Policy: Local Agencies must follow state agency guidance and procedures if WIC funding necessitates termination/suspension of WIC Services. Purpose: Federal WIC regulations allow for termination of services to program participants within a certification period if the state WIC agency experiences funds management problems, such as an inability to maintain its current level of participation for the remainder of the fiscal year. Such action will be taken only after alternative actions have been explored. This termination action will be planned to affect the least possible number of participants and will be directed first to those at least risk. Before terminating participants, the state WIC office will first explore alternative actions such as: ▪ Natural attrition combined with a moratorium on certifications ▪ Transfer of administrative funds to cover food costs ▪ Obtaining additional funding from private, local, state or federal sources ▪ Choosing lower-cost, but comparable food package items. Definitions Suspension of Services Suspension of services is a temporary action which allows WIC food benefits issuance to be resumed when funds are available without participant reapplication. This may be the choice of action if the funds management problem or overspending is small and affected participants can be accommodated in the near future. Termination of Services Termination is a more permanent action requiring terminated participants to reapply for program services and be certified again. This may be the course of action if the funds management problem or overspending is substantial, and distribution of services to affected participants is unlikely to be resumed in the current fiscal year.

S E C T I O N 1 . 1 2 : T E R M I N A T I O N / S U S P E N S I O N O F P R O G R A M S E R V I C E S 2 Procedures 1. Selecting Participants for Suspension or Termination Participants may be selected for suspension or termination in the following manner: ▪ by lowest nutritional risk priority (or priorities) ▪ participants who only have one month left in their certification period ▪ participants at higher income ranges 2. Notifying Participants Participants must be notified in writing prior to any termination/suspension of services not less than 15 days prior to the date of the proposed action. The state office will provide guidance related to this notification. The notification must include the reason for the suspension or termination and the right to a fair hearing. Reference – Complete Listing of Hyperlinks 7 CFR 246.7(c)(3) (https://www.ecfr.gov/current/title-7/part-246#p-246.7(c)(3)) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(1.13)Minnesota WIC Operations Manual (MOM) Section 1.13: Fair Hearing Procedure#

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Section 1.13: Fair Hearing Procedures 01/2018 References: 7CFR 246.6; Minnesota Rules, Section 4617.0100 Policy: An applicant/participant must be provided the opportunity to appeal decisions if they are: ▪ determined ineligible ▪ suspended or disqualified from the WIC program ▪ asked to repay the value of improperly issued benefits Purpose: To ensure that all applicants and participants receive fair and equitable treatment. Procedures Eligible/Ineligible 1. Inform each eligible adult applicant, parent, or guardian of their Rights & Responsibilities at certification, by providing the Rights & Responsibilities form (Exhibit 1-K) for them to read and capture signature on signature pad. If an applicant is unable to read, a staff person should read the information to them. 2. If an applicant is determined to be ineligible at WIC clinic, tell them the reason they are not eligible and of their right to appeal this decision, by providing a letter of ineligibility (Exhibit 5-GG: Sample Letter of Ineligibility). 3. If the applicant disagrees with the determination of ineligibility and wishes to appeal the decision, they may request a fair hearing verbally or in writing. ▪ If the participant wishes to submit a written appeal, provide the Request for Fair Hearing Form (Exhibit 1-N: Minnesota WIC Program Reqest for Fair Hearing) and assist them as needed. The applicant may send the form to the state or ask the local agency to send it. ▪ If the participant wishes to submit a verbal appeal, collect the information using the Request for Fair Hearing form and contact the State Office as soon as possible. 4. Confer with state staff and schedule a prehearing meeting with the person requesting the fair hearing, a representative of the local agency and state staff, if appropriate. The purpose of the meeting would be to resolve the issue.

S E C T I O N 1 . 1 3 : F A I R H E A R I N G P R O C E D U R E S 2 5. If agreement is not reached at a prehearing meeting, the state will schedule a hearing at a time and location agreeable to the appellant. 6. If in the Fair Hearing process the applicant alleges discrimination, finish the Fair Hearing process and advise the applicant of their right to file a complaint with United States Department of Agriculture (USDA). Refer to Section 1.10: Civil Rights. Suspension/disqualification or Repayment Any actions regarding suspension/disqualification or repayment are the responsibility of the State Office. Your State Consultant or Compliance Officer will work with you on these actions. Denial/Dismissal of Request The request for a fair hearing may be denied or dismissed if: 1. The request is not received within the 60-day time limit 2. The request is withdrawn by the person requesting the hearing 3. The person requesting the hearing fails, without good cause, to appear at the scheduled hearing Continuation of Benefits A participant who is disqualified during a certification period and who requests a fair hearing within 15 days of the notification shall continue to receive program benefits until a hearing decision is reached or the certification interval ends, whichever occurs first. A request made after the 15-day limit shall not result in continued benefits. An applicant who is denied benefits at initial certification or at a subsequent certification may request a fair hearing but shall not receive benefits while awaiting the hearing. Guidance Staff must assist the applicant/participant in this process as needed. The applicant/participant must be provided translated materials and access to an interpreter if needed. Examples of decisions that cannot be appealed are: ▪ A determination of categorical ineligibility ▪ Termination due to expiration of certification period ▪ A decision by the CPA to provide a person less than the maximum amount of supplemental foods

S E C T I O N 1 . 1 3 : F A I R H E A R I N G P R O C E D U R E S 3 ▪ A decision by the CPA to provide food benefits monthly, bimonthly, or trimonthly Reference – Complete Listing of Hyperlinks Exhibit 1-K: Rights and Responsibilities (https://www.health.state.mn.us/people/wic/rights.html) Exhibit 5-GG: Sample Letter of Ineligibility (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5gg .docx) Exhibit 1-N: Request for a Fair Hearing (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex1/1n. pdf) Section 1.10: Civil Rights (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_10.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider

(1.14)Minnesota WIC Operations Manual (MOM) Section 1.14: Records and Records Retention Requirements#

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Section 1.14: Record Retention 5/2019 References: CFR 7 246.25 (a) (2); Agreement for the Administration of the Special Supplemental Nutrition Program for Women, Infants, and Children (WIC Program); MDH Master Grant Contracts; and Section 1.7 Data Privacy, Minnesota Statute 16B.98. Policy: Records concerning WIC Program operations are retained according to State and Federal regulations. Purpose: To ensure that WIC records are retained according to regulations and available for review during management evaluations. Procedures ▪ Retain all WIC records concerning Program operations for a minimum of six (6) years from the end of the grant agreement end date. ▪ Retain participant data for 6 years from the date of the last participant activity, then destroy. ▪ When duplicate records exist, only one form, either paper or electronic, must be retained. Records (either paper or electronic) to be retained Program Operations: ▪ Monthly Claim for Reimbursement and documentation of amounts claimed ▪ Civil rights and fair hearing records, if applicable (reviewed at Management Evaluation) ▪ Inventory Logs: ▪ Equipment Purchase and Inventory Logs ▪ Exhibit 7-I: Returned Formula Log ▪ Benefit Stock Packing Slips (pre- eWIC) ▪ Benefit Issuance (eWIC cards) Inventory Participant Data: ▪ Participant certification records not documented in the WIC Information System

S E C T I O N 1 . 1 4 : R E C O R D R E T E N T I O N 2 ▪ Other participant records or documents pertinent to the record such as Medical Formula Documentation Form (Minnesota WIC Program Request for Medical Formula) and Minnesota WIC Program Request for Medical Follow-up (MOM Exhibit 5-Y) ▪ Documentation of participant violation, including duplicate participation, lost or stolen food benefits, other types of participant violations ▪ Agencies that administer Peer Breastfeeding Support Programs: records with participant confidential information such as peer referral forms and client contact logs, including closed records. Record Storage ▪ Records should be available during business hours for authorized representatives of the Minnesota Department of Health, the state Legislative Auditor, the USDA and/or General Accounting Office of the United States for purposes of inspection, auditing and copying. ▪ When storing records, use practices to ensure data privacy (Section 1.7: Data Privacy). Record Destruction ▪ Due to the confidentiality of some records, care must be taken to ensure that those records are shredded or destroyed, or purged from electronic files in a way that protects confidentiality. ▪ Document the name of the record and date of destruction according to your agency policies. Guidance ▪ Records should be stored so that they can be easily retrieved. At least three years of records should be on site, if space permits, or stored electronically. ▪ Records may be kept longer if required by local agency policy. ▪ Other records not noted in this policy (Management Evaluations, Financial Reviews, CPA Performance Evaluations, etc.) should be stored and retained as long as they are useful. ▪ Although an inventory of only “Capital Equipment” is required to be kept, it may be advantageous to keep a simple inventory of WIC equipment for tracking equipment purchased with WIC funds and owned by the Program. This inventory may be kept as part of the large agency inventory, as long as WIC equipment is designated. Records to be retained for biennial Management Evaluation review: ▪ Civil Rights Training Log ▪ Security Training Module Tracking

S E C T I O N 1 . 1 4 : R E C O R D R E T E N T I O N 3 ▪ Documenting Clinic Scale Testing ▪ Returned Formula Log ▪ Breastpump Issuance and Inventory Log (if applicable) ▪ WIC Capital Equipment Inventory Log (items valued at $5,000 or more) ▪ Outreach Log ▪ see Section 1.6: Public Notification and Outreach for example ▪ Local Agency Chart Review Form ▪ New Staff Training Log ▪ see New Staff Training for more information ▪ Separation of Duties (SOD) Review ▪ See Local Agency Internal Chart Review for One-Staff Certifications for an example, per Local Agency SOD plan (Section 1.18: Separation of Duties to Assure Program Integrity) ▪ Voucher Stock Packing Slips (pre-eWIC) ▪ Benefit Issuance (eWIC cards) Inventory Reference – Complete Listing of Hyperlinks Section 1.7 Data Privacy (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_7.pdf) Returned Formula Log (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7i_ fill.docx) Minnesota WIC Program Request for Medical Formula (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7d. pdf) Medical Formula Documentation Form (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7d. pdf) Minnesota WIC Program Request for Medical Follow-up (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5y. pdf) Section 1.7: Data Privacy (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_7.pdf)

S E C T I O N 1 . 1 4 : R E C O R D R E T E N T I O N 4 Civil Rights Training Log (https://www.health.state.mn.us/docs/people/wic/localagency/program/civilrights/docform.d ocx) Security Training Log (https://www.health.state.mn.us/docs/people/wic/localagency/infosystem/training/security/tr ack.docx) Scale Testing Log (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5k. pdf) Breastpump Issuance and Inventory Log (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex6/6g1 .pdf) WIC Capital Equipment Inventory Log (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex2/2f. pdf) Section 1.6: Public Notification and Outreach (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_6.pdf) Local Agency Chart Review Form (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4j. pdf) New Staff Training (https://www.health.state.mn.us/people/wic/localagency/training/nst.html#NaN) Local Agency Internal Chart Review for One-Staff Certifications (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex/1q.d ocx) Section 1.18: Separation of Duties to Assure Program Integrity (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_18.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(1.15)Minnesota WIC Operations Manual (MOM) Section 1.15: Electronic Signatures#

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Section 1.15: Electronic Signatures 3/2024 References: MN Statutes, section 325L.18 Policy: A WIC participant or their authorized representative may use an electronic signature to sign forms necessary for participation in the WIC Program. Purpose: To identify acceptable methods for electronic signatures. Procedures Acceptable methods for electronic signatures include: ▪ A handwritten signature, mark, or command input on a display screen or an electronic signature pad (e.g., the signature pad used with the Minnesota WIC Information System). ▪ An electronic signature captured by a software product (e.g., DocuSign, REDCap) that complies with the requirements of the Electronic Signatures in Global and National Commerce Act (E-Sign Act), submitted with a completion certificate, audit record, or similar audit trail document.1 ▪ A digitized image of a handwritten signature transmitted electronically, such as by fax, email, or text message (e.g., a fax from a health care provider with their handwritten signature). ▪ A unique identifier (e.g., a code, password, or PIN). ▪ A form with a completed attestation and either a typed name or checked box indicating a signature. ▪ Example language for Attestation: ▪ By checking “I agree,” I understand that I am electronically signing this form. I attest and certify that the information provided is true and accurate. I understand that my electronic signature has the same legal effect and can be enforced in the same way as a handwritten signature. (Minn. Stat. Ch. 325L.07) ☐ I agree

1 Minnesota Department of Health permits the use of technology products that meet these requirements and do not endorse any specific product.

S E C T I O N 1 . 1 5 : E L E C T R O N I C S I G N A T U R E S 2 ▪ By typing my name in the signature field, I understand that I am electronically signing this form. I attest and certify that the information provided is true and accurate. I understand that my electronic signature has the same legal effect and can be enforced in the same way as a handwritten signature. (Minn. Stat. Ch. 325L.07) Criteria for Acceptance of Electronic Signatures 1. The signer’s intent to sign a specific form is clear. If the electronic signature is on the specific form or submitted with the form, this criterion is met. For a signature submitted apart from a form, the signer must include a short statement with the date of the signature, such as “I understand that I am signing [form name] and I agree to all the terms and conditions of the form.” 2. The electronic signature must be logically associated with or attached to the form. It must be clear that the signature is connected to a specific form. An electronic signature that is physically received by the agency on a form or submitted with the form meets these criteria. If a signature is not received on a form or submitted with the form, a written statement of intent, described in the first bullet, is needed to logically associate a signature with a form. 3. The electronic signature must provide a way to identify the signer. It must be clear who electronically signed the form. A legible handwritten signature transmitted electronically meets these criteria. A typed or handwritten name with a signature (legible or not) also satisfies this requirement. 4. The electronic signature must not be modifiable. The signature must be received in a form that is tamper-proof so the signature cannot be modified (e.g., DocuSign). An electronic signature gathered via software that complies with the Electronic Signatures in Global and National Commerce Act (E-Sign Act), submitted with a certificate of completion, audit record or similar audit trail document meets these criteria, and therefore fulfills the signature requirement on certification and recertification documents, and other eligibility forms (e.g., DocuSign, REDCap). Unacceptable electronic signatures These include, but are not limited to, the following: ▪ An image of a handwritten signature that is placed on a form by digitally copying and pasting it into the document. ▪ A typed name created by selecting a script or calligraphy font or any other font that has not been authenticated through electronic signature software. A signature gathered via electronic software that is not accompanied by a certificate of completion, audit record or audit trail.

S E C T I O N 1 . 1 5 : E L E C T R O N I C S I G N A T U R E S 3 Guidance Local WIC Agency procedures for available signature platforms: ▪ Local Agency Guidance for Implementing DocuSign ▪ Guidance - Participant Signature Form, REDCap multiple form option guidance Reference – Complete Listing of Hyperlinks 325L.18 (https://www.revisor.mn.gov/statutes/cite/325L.18) Electronic Signatures in Global and National Commerce Act (https://www.fdic.gov/resources/supervision-and-examinations/consumer-compliance- examination-manual/documents/10/x-3-1.pdf) Minn. Stat. Ch. 325L.07 (https://www.revisor.mn.gov/statutes/cite/325L.07) Local Agency Guidance for Implementing DocuSign (https://www.health.state.mn.us/docs/people/wic/localagency/docusign.pdf) Guidance - Participant Signature Form (https://www.health.state.mn.us/people/wic/localagency/pptsigform.html) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164- 0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(1.17)Minnesota WIC Operations Manual (MOM) Section 1.17: Emergency Actions#

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Section 1.17: Emergency Actions 10/2024 References: 7 CFR 246.4(a)(30), Guide to Coordinating Special Supplemental Nutrition Program for WIC Service During Disasters, WIC: Implementation of the Access to Baby Formula Act of 2022 and Related Provisions, FNS Program Guidance on Human Pandemic Response Policy: In the event of an emergency (e.g., flood, fire, prolonged power outage, public health emergency, etc.), Local Agencies must follow community/regionally developed disaster plans as well as state procedures/Minnesota WIC state agency procedures. Purpose: To ensure that WIC participants continue receiving WIC services and to secure WIC property and records. Procedures If an emergency prevents or limits a local agency’s ability to carry out normal operations of the WIC Program, the local agency should: 1. Contact your State WIC Consultant for guidance on how to minimize interruptions to WIC services. Report on the following: ▪ If assistance is needed ▪ The number of WIC staff and participants affected by the emergency ▪ The estimated length of service disruption ▪ If electricity and/or water service has been disrupted ▪ The safety of the water supply ▪ The plan for providing essential WIC services such as nutrition education, breastfeeding services, benefit issuance, referrals, etc. 2. Seek information regarding your community/regional disaster plan. Follow applicable emergency procedures. 3. Follow applicable emergency procedures as set forth by state agencies or other governing bodies. Guidance The following sections provide general guidance for emergencies. Additional WIC flexibilities maybe available which are tailored to the type and scope of the emergency. Your state consultant can provide additional information specific to the situation.

S E C T I O N 1 . 1 7 : E M E R G E N C Y A C T I O N S 2 Plan for Emergencies Local agencies are encouraged to have a plan in place for dealing with emergencies. The plan may include: ▪ Community disaster coordinator contact information. ▪ Staff members’ home phone numbers. ▪ Media contact information. ▪ Arrangements for securing computer/medical equipment, supplies, and participant records. Clinic and Participant Accommodations to Consider In consultation with state agency staff, consider clinic, and participant accommodations that can be made. Areas to consider (not every area may be applicable to the specific emergency situation): Clinic site ▪ Are any of your WIC sites located in areas that are vulnerable due to the emergency? If so, consider alternate sites, limiting sites, or using alternate clinic days. Staffing ▪ Extra CPA staff may be needed at WIC Clinics to make referrals and assess the appropriateness of the current WIC food package. ▪ Consider changing clinic and staff hours to include evenings and Saturdays to increase participant accessibility. ▪ Consider exchanging staff phone numbers, should there be a need to communicate from home or another site. ▪ In the case of a strike, it is the responsibility of the local agency administration and leadership to make decisions about staff contingencies. Protecting program records, supplies, and WIC Information System equipment from possible damage ▪ Secure and/or move computer/medical equipment, supplies, participant documents, and program records. Food Benefits ▪ Be prepared to review food packages and make adjustments to accommodate participants’ access to safe water, refrigeration, and cooking facilities. For additional information on food package adjustments see Chapter 7: Food Package, for example Section 7.4: Supporting Breastfeeding with the WIC Food Package and Section 7.8: Food Package 2 (for Infants 6-11 months).

S E C T I O N 1 . 1 7 : E M E R G E N C Y A C T I O N S 3 ▪ Consider flexibilities when issuing benefits and cards, such as remote issuance or connecting them to an alternate site. See Chapter 8: WIC Cards. Emergency food assistance ▪ Develop and maintain a list of emergency food resources to provide to victims of any disaster requiring food assistance. Referrals ▪ Become familiar with and expand referral to other resources or services that families may need, such as temporary shelters, tetanus shots, mass feeding sites, insurance assistance, well-water testing, Red Cross, FEMA, etc. Communications ▪ Use the media to inform participants and potential applicants of how to access WIC services, including clinic hours, and locations during the disaster. ▪ Notify your State Consultant of changes in office or clinic sites. Evacuations ▪ If large scale evacuations are planned, Verification of Certification (VOC) forms may be provided so participants can receive WIC services in other states. See Section 3.3: Transferring Participants. Water source ▪ Will the emergency affect the water supply? If the water supply is contaminated, follow instructions from the Minnesota Department of Health and local water safety experts. ▪ Be aware of how water safety may affect WIC participants and their need for, or use of, WIC foods. For example, infants may need ready-to-feed infant formula. The State WIC may notify local WIC vendors of the increased need for ready-to-feed formula in areas where water might be contaminated. The State WIC agency may facilitate shipping of other types of formula to WIC Clinics. ▪ Encourage breastfeeding mothers to exclusively breastfeed, eliminating the need to prepare formula and minimizing the infant’s exposure to unsafe water. Supporting breastfeeding during emergencies WIC encourages breastfeeding as the standard method of infant feeding. See Breastfeeding in Emergencies webpage for information on how to include breastfeeding in your emergency planning.

S E C T I O N 1 . 1 7 : E M E R G E N C Y A C T I O N S 4 Suggestions to simplify clinic and benefit issuance procedures Certification Procedures ▪ Utilize established flexibilities in certification procedures, such as using phone/Online Medical Assistance verification to serve as proof of identity, income, and residency if it includes all those areas and is up to date. If necessary, use a waiver for proof of identity, residency, or income. See Section 5.2: Certification Procedures. ▪ Certification procedures may be modified as described in Streamlined Certification Process, Exhibit 1-M: Streamlined Certification Process for Emergency Situations. Consult with State WIC Consultant before implementing. Lost eWIC card ▪ Families may have lost their WIC card. If so, search the WIC Information System database to locate participants coming in without their WIC cards and issue a new card as needed. See Section 8.5: Replacing WIC Cards. Lost or damaged food benefits ▪ Participant might lose or have food benefits damaged during an emergency. Those food benefits may be replaced. See Section 8.4: Issuing Food Benefits Mailing WIC cards ▪ Mailing/updating WIC nutrition and food benefits may be an option if the WIC Clinic is closed due to an emergency. Refer participants to a nearby clinic if available and convenient or mail replacement WIC cards as appropriate. See Section 8.5 Replacing WIC Cards. Homeless participants ▪ Mailing/updating WIC nutrition and food benefits may be an option if the WIC Clinic is closed due to an emergency. Refer participants to a nearby clinic if available and convenient or mail replacement WIC cards as appropriate. See Chapter 8: WIC Cards. ▪ Refer to Section 7.14: Food Package Options for Homeless Participants and Section 5.6: Homeless Applicants and Participants for additional information on how to support homeless participants. New Request for medical formula ▪ A written prescription is preferred, but if unavailable, attempt to get a ‘verbal’ prescription from the health care provider. Issue benefits for medical formula for one month and complete the documentation at the next benefit issuance. Follow normal issuance procedures in Section 7.6: Medical Documentation. Contact your State WIC Consultant if: ▪ Your agency is unable to serve all who are eligible.

S E C T I O N 1 . 1 7 : E M E R G E N C Y A C T I O N S 5 ▪ Your agency needs additional supplies, equipment, WIC cards, or other materials. ▪ Your agency or clinic is operating from a new address or at a different phone number. Statewide Emergencies In the case of a statewide emergency affecting WIC services to participants, USDA would assess the emergency and might approve the additional emergency actions to be implemented outside of normal WIC business authority. These could include: ▪ Mail/update food benefits from the WIC Information System directly to participants ▪ Coordinate commodity foods distribution from the USDA regional office ▪ Provide for alternate food delivery mechanisms – the Commissioner of Health may approve other food delivery mechanisms, if approved by USDA ▪ Permit formula shipments ▪ Provide ready-to-feed formula in the event that water is limited or unsafe ▪ Request financial assistance for additional costs Resources Infant Feeding During Disasters (HHS) Infant Feeding During Disasters and Emergencies (AAP) Infant and Young Child Feeding in Emergencies Toolkit (CDC) Safety Messages for Pregnant, Postpartum, and Breastfeeding People During Natural Disasters and Severe Weather (CDC) Reference – Complete Listing of Hyperlinks Guide to Coordinating Special Supplemental Nutrition Program for WIC Service During Disasters (https://www.fns.usda.gov/wic/guide-coordinating-wic-service-during-disasters) WIC: Implementation of the Access to Baby Formula Act of 2022 and Related Provisions (https://www.fns.usda.gov/wic/fr-121423) FNS Program Guidance on Human Pandemic Response (https://www.fns.usda.gov/disaster/pandemic) Chapter 7: Food Package (https://www.health.state.mn.us/people/wic/localagency/mom.html#foodpackage) Section 7.4: Supporting Breastfeeding with the WIC Food Package (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_4.pdf)

S E C T I O N 1 . 1 7 : E M E R G E N C Y A C T I O N S 6 Section 7.8: Food Package 2 (for Infants 6-11 months) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_8.pdf) Chapter 8: WIC Cards (https://www.health.state.mn.us/people/wic/localagency/mom.html#cards) Section 3.3: Transferring Participants (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch3/sct n3_3.pdf) Section 5.2: Certification Procedures (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_2all.pdf) Exhibit 1-M: Streamlined Certification Process for Emergency Situations (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex1/1m .pdf) Section 8.5: Replacing WIC Cards (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch8/sct n8_5.pdf) Section 8.4: Issuing Food Benefits (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch8/sct n8_4.pdf) Section 7.14: Food Package Options for Homeless Participants (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_14.pdf) Section 5.6: Homeless Applicants and Participants (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_6.pdf) Section 7.6: Medical Documentation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_6.pdf) Infant Feeding During Disasters (https://www.acf.hhs.gov/ohsepr/resource/infant-feeding- during-disasters) Infant Feeding During Disasters and Emergencies (https://s3.amazonaws.com/aws.upl/nwica.org/disasterfactsheet6-2020.pdf) Infant and Young Child Feeding in Emergencies Toolkit (https://www.cdc.gov/infant-feeding- emergencies-toolkit/php/index.html) Safety Messages for Pregnant, Postpartum, and Breastfeeding People During Natural Disasters and Severe Weather (https://www.cdc.gov/reproductive-health/emergency-preparation- response/safety-messages.html)

S E C T I O N 1 . 1 7 : E M E R G E N C Y A C T I O N S 7 Minnesota Department of Health - WIC Program, 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us; to obtain this information in a different format, call: 1-800-657-3942. This institution is an equal opportunity provider.

(1.18)Minnesota WIC Operations Manual (MOM) Section 1.18: Separation of Duties to Assure Program Integrity#

(1.18)(document-1)#

Section 1.18: Separation of Duties to Assure Program Integrity 04/2026 References: 7 CFR 246.4(a)(27), MOM Section 5.2, WIC Policy Memorandum #2016-5 Separation of Duties at WIC Local Agencies Policy: Controls and procedures must be in place to ensure Separation of Duties (SOD) during WIC certification. At a minimum, a single staff person may not determine both income eligibility and medical/nutrition risk for a participant. If only one person is available to determine both income and nutrition risk, a post review of the certification record must be completed by the WIC Coordinator or designee. Purpose: To ensure program integrity by involving two staff members in determining certification eligibility. Procedures Two WIC staff must be involved in each certification, and SOD must be auditable in each individual participant record. Local agencies must develop and maintain an SOD Plan describing how they will meet SOD requirements in all clinics. The plan must be approved by the State Agency and updated as necessary. Compliance will be reviewed by the WIC consultant during management evaluations. Refer to Exhibit 1-P: Two-Person SOD versus One-Staff Certifications for an overview of the SOD methods described below. Two-person SOD (preferred method) This is the preferred method of SOD and is recommended for use in nearly all situations, as it supports the highest level of program integrity. Two-person SOD requires: 1. Staff 1— must be Competent Professional Authority (CPA): Determines medical/nutrition risk and offers nutrition counseling. 2. Staff 2— does not need to be present during the certification: Verifies income or adjunct eligibility on the day of certification, or up to 21 days before.

S E C T I O N 1 . 1 8 : S E P A R A T I O N O F D U T I E S T O A S S U R E P R O G R A M I N T E G R I T Y 2 Note: Scanning or uploading verification documents may be necessary for later review. See Scanning/Uploading Verifying SOD Documentation below for details. Documenting two-person SOD During certification Participant Record- Income Page 1. Staff 1— The CPA determining medical/nutrition risk completes the certification after income or adjunctive eligibility has been verified and entered by a second staff. 2. Staff 2— The staff person verifying income or adjunct eligibility enters the verified information into the Income Page, while in Certification Mode, before the certification is finalized by the certifying CPA (steps 1 and 2 must happen on the same day). Outside certification (not in Certification Mode): SOD-Income Note 1. Staff 1— The CPA determining medical/nutrition risk documents the verified income in the income screen of the participant record during the certification. 2. Staff 2— The staff person verifying income or adjunct eligibility writes a SOD-Income Note detailing what they verified (e.g., “MA active” or HH size and total income). Document income eligibility up to 21 days before the certification or up to 14 days after the certification. Note: In the rare case where the original income verifier does not have access to the Information System, another staff person (other than the CPA determining nutrition/medical risk) may create the SOD-Income note, indicating who verified income. Discuss this with your State WIC Consultant for approval. Two-person SOD oversight The local agency coordinator or designee must review SOD reports quarterly to assess for missing SOD documentation. It is best practice to review SOD reports more frequently (e.g., bi- weekly or monthly) to maintain the highest level of program integrity. One-staff certifications One-staff certifications are an exception and should be avoided whenever possible. They occur when the certifying CPA determines both income eligibility and nutrition risk, and the agency lacks sufficient staff to complete the two-person SOD process for all certifications. See Guidance for examples of ways to implement two-person SOD in single staff clinics. Important: See Scanning/Uploading and Verifying SOD Documentation below for additional requirements. One-staff certification oversight The WIC Coordinator or designee must conduct, at a minimum, a bi-weekly post-review of all non-breastfeeding infant certification records and a sample of at least 20% of all other one- staff certification records. It is best practice to rotate staff coverage at clinics regularly using one-staff certifications.

S E C T I O N 1 . 1 8 : S E P A R A T I O N O F D U T I E S T O A S S U R E P R O G R A M I N T E G R I T Y 3 Post-review of one-staff certification records 1. Complete the post-review using Exhibit 1-Q: Local Agency Internal Chart Review for One-Staff Certifications. Retain these records for the next Management Evaluation (ME). Focus on key aspects of the certification process, including income, identity, residency, and nutritional risk. Prioritize records with one or more of the following characteristics: ▪ Transactions outside regular clinic hours ▪ Discrepancies between certification duration and benefits issued ▪ Infant records with no corresponding mother participant ▪ Missing or unreasonable height, weight, or blood test results ▪ Patterns of similar or repeated measurements (height, weight, blood) across multiple records. ▪ A high percentage of out-of-state transfers (VOCs) compared to other clinics during the same time 2. Document the completed post-review in a SOD-Review Note in the WIC information system. Documenting SOD for one-staff certifications Records identified through biweekly or quarterly SOD review: SOD-Review Note 1. Staff 1— The CPA completing the certification assesses income or adjunct eligibility and medical/nutrition risk at the time of the appointment and enters it into the participant record and scans/uploads required documents for post-review, as noted below. 2. Staff 2— The local agency coordinator or designee verifies scanned documents, completes a Post-Review of One-Staff Certification Records, and writes an SOD-Review note in the participant record, indicating the documents verified and that the Post Review is complete. Conduct a Post-Review of One-Staff Certification Records and complete a Quarterly SOD Review to identify and assess all known and potentially missed one-staff certifications. Scanning/uploading and verifying SOD documents If the agency has one-staff certifications, staff will need to scan/upload proofs into the participant record for later verification by a second person. Avoid scanning/uploading unnecessary documents. Adjunctively eligible participants: ▪ Certifier or designee: Scan/upload proof of identity for each participant certified (e.g., crib card, health benefits (insurance) card, photo ID, see: Exhibit 5-C: Identification Requirements by WIC Contact Type). ▪ Reviewer: Confirm active adjunctive eligibility (e.g., via phone/online system) and verify the scanned/uploaded ID in the participant record.

S E C T I O N 1 . 1 8 : S E P A R A T I O N O F D U T I E S T O A S S U R E P R O G R A M I N T E G R I T Y 4 Non-adjunctively eligible participants: ▪ Certifier or designee: Scan/upload the verified proof of income used for the certification (e.g., pay stub(s), W-2 forms, tax returns, written statement from the employer). ▪ Reviewer: Verify that the scanned/uploaded income document meets income guidelines and matches the income in the certification record. One-Staff Certifications: See Post-Review of One-Staff Certification Records for additional documentation requirements. Maintain scanned/uploaded proofs in the information system for review during Management Evaluation (ME). Delete scanned/uploaded proofs after SOD is completed and recorded. Ongoing local agency SOD oversight Local Agency WIC leadership is responsible for overseeing and monitoring SOD compliance and clinic and staff activities- refer to the Resources section for helpful reports. They must ensure: ▪ SOD procedures are implemented in all clinics. ▪ One-staff certification records are reviewed. ▪ The SOD plan submitted to the State Agency is up-to-date. Suspected fraud/abuse Deliberate efforts to defraud or abuse the Minnesota WIC Program shall be considered an act of employee misconduct. Report questionable certifications and benefit issuance to the state WIC consultant within one week of discovery. The State WIC Agency will investigate the issue accordingly. Guidance Two-person SOD in single-staff clinics Local agencies with one WIC staff on site should use the two-person SOD method. Examples of ways to implement two-person SOD in single-staff clinics include: ▪ A clerk, WIC Coordinator, or other designee verifies and documents adjunctive eligibility or pre-submitted income proofs up to 21 days before the certification. ▪ The certifying CPA connects with a second WIC staff person at a different location (via phone, messaging, or video) during the appointment. The second staff person verifies and documents income/adjunctive eligibility in real time. ▪ When one-staff certification occurs, the certifying CPA verifies income eligibility, scans the required information, and informs the WIC Coordinator or other designee. Within 14 days, the coordinator or designee reviews the scanned information, confirms participant eligibility, and writes an SOD note.

S E C T I O N 1 . 1 8 : S E P A R A T I O N O F D U T I E S T O A S S U R E P R O G R A M I N T E G R I T Y 5 Pending eligibility and presumptive eligibility For pending and presumptive eligibility, SOD is documented at two different times: 1. During the certification, and 2. When the participant provides proof of income (for pending eligibility) or proof of medical assistance enrollment (for presumptive eligibility). ▪ The staff person who verifies final income eligibility must be different from the one who determined nutrition risk at certification. ▪ Document income verification in an SOD-Income Note, following the same procedures used during certification, and include the name of the staff person who completed the verification. Resources The following Infoview reports can assist with Ongoing Local Agency SOD Oversight. Refer to the Infoview Report Template Reference for information on each report: ▪ “Certifications Completed by One Staff Person” ▪ “Daily Staff Productivity” ▪ “Benefits Issued & Certs Performed Outside of Information System Hours” Reference – Complete Listing of Hyperlinks WIC Policy Memorandum #2016-5 Separation of Duties at WIC Local Agencies (https://www.fns.usda.gov/wic/separation-duties) Exhibit 1-P: Two-Person SOD versus One Staff Certifications (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex1/1p. pdf) Exhibit 1-Q Local Agency Internal Chart Review for One Staff Certification- Sample (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex1/1q. docx) Exhibit 5-C: Identification Requirements by WIC Contact Type (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5c. pdf) Infoview Report Template Reference (https://www.health.state.mn.us/docs/people/wic/localagency/reports/infoview/reference.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(1.19)Minnesota WIC Operations Manual (MOM) Section 1.19: Avoid Conflict of Interest to Assure Program Integrity#

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Section 1.19: Avoid Conflict of Interest to Assure Program Integrity 0 4 / 2 02 1 References: 7 CFR 246.4(a)(27), MOM Section 5.2 Policy: Implement controls and procedures to avoid, or appropriately manage, potential conflicts of interest to assure program integrity. Purpose: To prevent and detect conflicts of interest and employee fraud/abuse; and to report suspected situations to the State WIC Consultant and Local Authorities. Conflict of Interest Examples: ▪ Certifying oneself ▪ Certifying relatives or close friends ▪ Promoting one’s own personal or business interest in WIC ▪ Referring participants to a grocery store or pharmacy owned by a family member ▪ Accepting payment for referrals to a grocery store or pharmacy ▪ Any personal, business, or financial interest/relationship between Local Agency staff and grocery store or pharmacy ▪ Allowing vendors of any type to sell or promote products in the WIC setting. Materials containing advertising for WIC-allowed products may not be used in clinic. Procedures: ▪ Local agency WIC staff and family members may participate in the WIC program, if eligible. However, the WIC Coordinator (or supervisor) and the staff member must assure there are no conflicts of interest. WIC staff shall not certify or issue food benefits to oneself or one’s children or grandchildren. This means that the WIC Information System record of a WIC employee/family member must indicate that eligibility was determined and Separation of Duties was documented by other WIC employees. In some situations, it may be preferable for another WIC agency to provide services for the WIC staff member. Please contact the WIC Consultant with questions about where staff should be served. ▪ Local agency WIC staff must advise their WIC Coordinator (or supervisor) about any relatives or close friends participating in WIC through that clinic/local agency that could

S E C T I O N 1 .1 9 : A VO I D C O N F L I C T O F I N T E RES T T O A S S U RE P RO G RA M I N T E GRI TY 2 present a conflict of interest. The Supervisor or WIC Coordinator should attempt to assign different staff to complete the certification. ▪ WIC staff shall not certify or issue food benefits to relatives or close friends. If there are no other staff available to do the certification, certifying relatives or close friends may only occur with prior approval by the local supervisor, and after notifying the WIC Consultant. In the rare situations where this occurs with supervisor approval, an individual other than the certifier must conduct a post review of all such records within two weeks of the certification. Documentation must be maintained in the WIC Information System ▪ Local agency staff must notify their supervisor of any conflict of interest with personal, business, or financial interest/relationship with any WIC related business. Local agency staff cannot be a manager, owner, shareholder, partner, or corporate officer (i.e., controlling person as defined in the Minnesota WIC Rules) of a WIC authorized grocery store or pharmacy. Potential conflicts of interest must be evaluated by local leadership and reported to the WIC Consultant. Fraud/Abuse ▪ Any deliberate effort to defraud or abuse the Minnesota WIC Program including, but not limited to the following, shall be considered an act of employee misconduct: ▪ Inappropriately issuing/taking WIC benefits, such as by giving or using false/misleading information, and/or certifying or issuing benefits to fictitious participants. ▪ Certifying or issuing benefits to oneself, one’s children or grandchildren, relatives or close friends without prior approval of local leadership and/or without having a monitoring plan in place. ▪ Theft of formula, food, or WIC-owned property. ▪ Local Agencies are required to report questionable certifications and benefit issuance and/or suspected staff fraud to their WIC Consultant or the State Agency within a week of the issue being identified. Any reported issues will be evaluated by the State WIC office. Guidance Consult your State WIC Consultant with any questions or concerns. Reference – Complete Listing of Hyperlinks Minnesota WIC Rules (https://www.revisor.mn.gov/rules/4617/) Section 1.18 (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_18.pdf)

S E C T I O N 1 .1 9 : A VO I D C O N F L I C T O F I N T E RES T T O A S S U RE P RO G RA M I N T E GRI TY 3 Minnesota Department of Health - WIC Program, 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us; to obtain this information in a different format, call: 1-800-657-3942.

(2.2)Minnesota WIC Operations Manual (MOM) Section 2.2: Financial Procedures#

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Section 2.2: Financial Procedures 10/2021 References: 7 CFR 246.14, 2 CFR Part 200 – Subpart E, Cost Principles, and 2 CFR Part 400 Policy: Local Agencies must assure that all program costs are allowable to be eligible for reimbursement and must follow required WIC financial procedures. Purpose: To identify and assure that the financial management requirements of the WIC program are clearly described and met. Procedures Local Agency funding is determined annually, depending on available federal funds, and is based on a monthly per participant caseload amount. WIC is a reimbursement grant based upon actual costs claimed. Federal WIC funding may not cover all costs incurred by a Local Agency to administer/operate the WIC Program. Local Agencies are responsible for funding any unreimbursed expenses needed to meet program requirements and provide quality services. The WIC Program’s goal is to improve the health and development of lower-income families in Minnesota. Communities benefit in various ways from the program: improved health and well-being, supplemental food purchases to local retailers, referral for families into other public health services and programs, etc. Grantee operational decisions about staffing and program administration affect overall costs. Other funding sources may be available to supplement WIC such as TANF and Child and Teen Checkup. Community Health Boards may also use the state Local Public Health (LPHA) grant to cover their WIC costs. If state WIC funds are available at the end of the federal fiscal year, the State Agency will provide a final reimbursement to Local Agencies to cover as much of their unreimbursed expenses as possible. To meet requirements, each agency must: ▪ Maintain accurate, current, and adequate records, which summarize and report the agency’s financial status on a federal fiscal year basis (October 1st through the following September 30th). Records that verify all expenses, whether categorized as direct or indirect, and including time reporting, payroll, and purchase records, must be maintained for six years from the end of the grant agreement end date. See Section 1.14: Record Retention (PDF). As part of this requirement:

S E C T I O N 2 . 2 : F I N A N C I A L P R O C E D U R E S 2 ▪ Costs charged to the WIC Program must be allowable costs under all federal and state regulations and standards. Examples and definitions of allowable and unallowable direct costs are in Exhibit 2-D: WIC Costs – Allowable and Unallowable (PDF). ▪ Costs charged to the WIC Program must be supported by documentation showing they are necessary, allocable, reasonable, and proper for the administration of the WIC Program. Costs related to the general operation and management of the Local Agency are not allowed except as documented direct costs or as part of an approved indirect cost rate. ▪ Use time reporting to support staff hours billed to WIC. This includes: 1. WIC staff who work in other agency programs must document the time spent in each program to assure equitable distribution of personnel costs. (Staff who only work in WIC do not need to do this.) Use: ▪ Daily time reporting or ▪ Quarterly time reporting, if not more frequently, of WIC and non-WIC program staff time, for a minimum of no less than 2 consecutive weeks 2. Staff must also document the time spent worked in each of the four WIC cost categories. Use: ▪ Daily time reporting or ▪ Quarterly time studies, if not more frequently, for a minimum of no less than two consecutive weeks See Section 2.2.1 Direct Cost Categories below for more information. ▪ Indirect rate: ▪ Annually, the Minnesota Department of Health (MDH) Community Health Division will contact CHBs to request the grantee’s indirect rate. See Indirect Cost Guidance for Community Health Boards (PDF). ▪ Grantees that do not have a federally approved rate may use an indirect rate up to 10%. ▪ Grantees with a federally negotiated indirect rate, such as Tribal and non-profit agencies, are required to complete an indirect questionnaire administered annually by State WIC staff. ▪ Expenses included in the indirect rate may not be claimed as direct costs. ▪ Administrative salaries are recorded under Indirect if no time reports are available to allocate time. ▪ Costs reported must be reduced by all applicable credits (e.g., discounts for timely payments, quantity discounts, etc.) prior to reporting. ▪ Provide timely and accurate reporting of costs which are allowable and allocable to the WIC Program.

S E C T I O N 2 . 2 : F I N A N C I A L P R O C E D U R E S 3 ▪ Submit the monthly WIC Program Claim for Reimbursement by the 20th day of the month following the reporting period. See exception below for the final claim. ▪ Properly allocate costs to the appropriate category: Program Management, Client Services, Nutrition Education, and Breastfeeding Promotion. See Section 2.2.1 WIC Cost Categories for definitions. ▪ For reporting purposes, indirect costs are recorded only under Program Management on the claim form. ▪ Once a claim has been processed, include any errors or changes into the next claim filed, with an explanation in the Remarks section of the claim form. ▪ The final September Claim for Reimbursement is due no later than December 20th of the same calendar year. The September claim must only contain costs that have been incurred and fully paid for by the Local Agency in the applicable Federal Fiscal Year. If an error is identified on the September claim after it has been submitted for payment, Local Agencies should contact state WIC fiscal staff as soon as possible. ▪ Discuss any planned single-item purchase or project over $5,000 with your State WIC Consultant early in the planning process. These requests must be submitted by the state to USDA for approval. See Section 2.2.2 Supplemental Funding for more information. ▪ Maintain a record of all capital equipment purchases. See, Exhibit 2-F: WIC Capital Equipment Inventory Form (PDF), for an example. ▪ Comply with the terms of all legally binding agreements between grantee and MDH. 2.2.1 WIC Cost Categories Use the following direct cost categories to complete the monthly WIC Program Claim for Reimbursement. ▪ Program Management ▪ Client Services ▪ Nutrition Education ▪ Breastfeeding Promotion To determine costs reported in these categories, use daily time reporting or quarterly time studies, for a minimum of no less than two consecutive weeks. When activities relate to more than one specific area, the costs must be divided based upon the percentages from the duties performed in each applicable category. For example, travel to a nutrition education activity should go under Nutrition Education. Travel to a satellite clinic from the main site would go under Client Services, while WIC services performed at the satellite site would be listed under the applicable category, such as Client Services, Nutrition Education, etc. Below are brief descriptions with examples of costs attributable to each category.

S E C T I O N 2 . 2 : F I N A N C I A L P R O C E D U R E S 4 Program Management General oversight & supervision, including chart audits (chart audits related to Nutrition Education should be categorized under that category) ▪ WIC Card inventory documentation ▪ Preparation of administrative records and timecards ▪ Paid leave (e.g., holidays, maternity leave, sick leave) ▪ Expenses related to audits, accounting, and program reports, including fiscal reporting ▪ Outreach activities ▪ Activities and items not included in other cost categories Client Services Client Services are all salary and supply costs related to eligibility determination, participant services, and issuing benefits. Examples include: ▪ Clinic preparations and scheduling, including participant communications ▪ Identity, residency, and income eligibility determination ▪ Anthropometric and hematologic assessment ▪ Nutrition assessment activities ▪ Referrals to other social or health services ▪ Benefit Issuance ▪ Travel to a satellite clinic from your main site ▪ Salaries of WIC staff providing general translation/interpreter services. ▪ Coordination with other programs ▪ Evaluating program effectiveness Nutrition Education An agency should use at least 17% of their WIC grant toward Nutrition Education (NE). These costs include all salaries and supplies needed to educate participants in understanding the importance of nutrition in health and to achieve positive change in dietary habits. Examples include: ▪ Providing individual or group education, including planning & preparation time ▪ Documenting nutrition education and follow-up ▪ Educating on how to use food benefits and shop for WIC foods; Food costs for foods used in nutrition education ▪ Providing educational materials, including development & printing, setting up displays

S E C T I O N 2 . 2 : F I N A N C I A L P R O C E D U R E S 5 ▪ Consultation with other health providers regarding a participant’s nutritional status ▪ Evaluating and monitoring nutrition services (chart audits related to other program services should be categorized under Program Management) ▪ Preparing the agency’s Nutrition Education Plan ▪ Attending NE trainings and workshops/conferences (including registration fees and travel expenses related to conference attendance) ▪ Interpretation and translation services provided by WIC staff for Nutrition Education activities Breastfeeding Promotion Breastfeeding promotion is an important and integral part of the WIC program. At least 2% of the WIC grant must be spent in this category. Examples include: ▪ Salaries and related costs of staff counseling participants about breastfeeding ▪ Documenting breastfeeding education and follow-up ▪ Producing breastfeeding education and training materials ▪ Breast pumps and other allowed accessories ▪ Setting up and maintaining a space for breastfeeding ▪ Peer program related costs and services – if not reimbursed by the Peer program ▪ Monitoring and evaluating breastfeeding services ▪ Documenting breastfeeding support activities ▪ Attending breastfeeding workshops and trainings (including registration fees and travel expenses related to workshop attendance) Any costs charged to a Peer Counseling Grant cannot be considered a Breastfeeding Promotion cost. 2.2.2 Supplemental Funding Annual Supplemental Funding The State Agency will provide $2,500 annually for grantees to use for non-recurring expenses that support WIC services, such as: ▪ Purchase or replacement of equipment and supplies ▪ Travel to state-sponsored meetings and trainings (mileage, parking and lodging if needed) ▪ Breast pumps and supplies ▪ Other necessary items (i.e., formula shipping, communication devices such as dual handset phones, audio visual equipment)

S E C T I O N 2 . 2 : F I N A N C I A L P R O C E D U R E S 6 The funding will be included in the Local Agency’s annual funding letter. ▪ Submit these expenses on the monthly Claim for Reimbursement form on the “Other” line or if included within another category on the form, provide an explanation of the purchased item in the “Remarks” section. ▪ Save all receipts or purchase documentation. ▪ The State Agency will monitor these expenses for appropriateness on the monthly claim forms and during biennial financial reviews. See Section 2.2.3 Financial Review below for more information. Request to Increase Administrative Funds (RIAF) ▪ If unexpected needs arise related to program improvement or general infrastructure, an agency may be eligible to request increased administrative funding to cover non-recurring expenses. Availability of these funds varies each year and is not guaranteed. ▪ Discuss the request with your State WIC Consultant. ▪ If determined appropriate, submit, Exhibit 2-C: Request to Increase Administrative Funds (PDF), to your State WIC Consultant. Infrastructure Grant Funding ▪ USDA periodically offers infrastructure funding grants. The focus of the grants varies each year, depending on USDA’s goals. The grant application typically happens in the spring and is competitive nationally. Local Agencies will be notified by their State WIC Consultant when the grants become available. ▪ If interested, discuss with your State WIC Consultant. Supplemental Clinic Travel Funding (SCTF) ▪ A grantee whose clinic travel expense is estimated to be > $2,000/year (including both staff travel time and mileage to the clinic site) may apply annually to receive Supplemental Clinic Travel Funding. ▪ Potential agencies will receive a worksheet from State WIC staff at the beginning of the federal fiscal year. Approval of additional funding will be determined upon completion of the application. ▪ This funding should be used to augment the WIC grant and defray the costs of staff travel time and mileage to WIC clinic sites claimed on the monthly Claim for Reimbursement. ▪ SCTF expenses will be monitored during financial reviews. ▪ If miles driven or staffing changes occur during the fiscal year, notify your State WIC Consultant so the SCTF can be revised as needed.

S E C T I O N 2 . 2 : F I N A N C I A L P R O C E D U R E S 7 2.2.3 Financial Review ▪ In compliance with Federal WIC regulations and the WIC Grant Agreement, Local Agencies receiving grant funds are subject to a financial review. USDA requires a review be conducted every other year. ▪ A member of the Minnesota Department of Health (MDH) staff will perform a review of one month’s invoice/Claim for Reimbursement, requesting from Local Agency administrative or financial staff documentation for costs claimed on the invoice/form. ▪ If further review is needed, additional documentation may be requested and/or an onsite visit may be conducted. ▪ Local WIC Agency staff and management will be notified in writing of the results of the review and any follow-up action needed to resolve compliance issues identified. Guidance ▪ Contact your State WIC Consultant if you have questions about whether an expense is WIC- allowed or you are seeking additional funds. ▪ Local Agencies are responsible for general training costs for staff and for maintaining and building staff expertise. Local Agency WIC grant funding should be used for those costs. See Section 4.5: Staff Training (PDF) for more information. ▪ See Section 4.8: Breastfeeding Peer Support (PDF), for information about the Breastfeeding Peer program financial procedures. Reference – Complete Listing of Hyperlinks 2 2 CFR Part 200 (https://www.ecfr.gov/current/title-2/subtitle-A/chapter-II/part-200) Section 1.14: Record Retention (PDF) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_14.pdf) Exhibit 2-D: WIC Costs – Allowable and Unallowable (PDF) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex2/2d. pdf) Indirect Cost Guidance for Community Health Boards (PDF) (https://www.health.mn.gov/communities/practice/lphact/lphgrant/docs/indirectcostguidance .pdf) Exhibit 2-F: Capital Equipment Inventory Log (PDF) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex2/2f. pdf)

S E C T I O N 2 . 2 : F I N A N C I A L P R O C E D U R E S 8 Exhibit 2-C: Request to Increase Administrative Funds (RIAF) Form (PDF) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex2/2c. pdf) Section 4.5: Staff Training (PDF) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_5.pdf) Section 4.8: Breastfeeding Peer Support (PDF) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_8.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(3.1)Minnesota WIC Operations Manual (MOM) Section 3.1: Introduction#

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Section 3.1: Introduction 3/2016 Federal funds are distributed to State WIC Programs based on the state’s participation level, with funds specifically allocated for either food or nutrition services/administration. Funding to Local Agencies is based on the federal funds the State receives and on the number of WIC participants a Local Agency has served. As long as adequate federal funds are available, the State Agency intends to serve all eligible applicants to WIC. Local Agencies must ensure that all WIC applicants are served promptly. To ensure timely and fair screening of applicants and to ensure that eligible applicants are promptly certified and provided the WIC services for which they are eligible, local agencies must follow federal requirements and State policies for scheduling certification appointments. Providing WIC services to currently certified individuals (i.e., “transfers”) must also follow federal and state guidelines. To maintain a local agency’s funding, it is essential that the Local Agency manage its participation level. Utilizing data from the WIC Information System reports and implementing effective program management practices (such as strategic “overbooking” and flexible scheduling, ongoing outreach efforts) can help ensure a stable or growing participation level. In the event that federal funds become inadequate to serve all eligible applicants, the State Agency might instruct Local Agencies to implement waiting lists or reduced-emergency services (See Section 3.4: Waiting List). When funding is inadequate to serve all eligible applicants, Waiting Lists ensure that WIC services are made available fairly and consistently statewide to eligible applicants with the greatest need, according to the federal WIC priority system. Reference – Complete Listing of Hyperlinks Section 3.4: Waiting List (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch3/sct n3_4.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(3.2)Minnesota WIC Operations Manual (MOM) Section 3.2: Processing Standards - Timeframes for Scheduling Certification Appointments#

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Section 3.2: Processing Standards-Timeframes for Scheduling Certification Appointments APRIL 2017 References: 7 CFR 246.7 (f)(2) Policy: Offer applicants a certification appointment to determine eligibility for WIC services within the timeframes specified below. Purpose: To provide WIC services as soon as possible to eligible applicants in nutritional need. ▪ Applicants are defined as: ▪ All persons who have never received WIC services; ▪ All pregnant women: including those who are new to WIC, those who have a current WIC postpartum record, and those who have a previous record in the WIC Information System; ▪ Any WIC participant whose certification period has ended (his/her last certification end date is prior to the current date). ▪ Following are the timeframes, or Processing Standards for scheduling appointments: ▪ For applicants who request an appointment and who are at special nutritional risk (pregnant women, infants less than six months of age, and migrant families), offer them an appointment within 10 calendar days. ▪ For other applicants, offer them an appointment within 20 calendar days. ▪ For pregnant women who miss their first WIC appointment, contact them to reschedule the appointment. ▪ For participants transferring to Minnesota from out-of-state whose VOC (Verification of Certification) indicates that they are not in a current certification period, schedule a certification appointment as soon as possible (see Section 3.3: Transferring Participants). Procedures ▪ Applicants who appear to meet eligibility criteria must be offered an appointment within the 10 and 20 day timeframes (Processing Standards) listed above. If the Local Agency cannot meet the scheduling guidelines specified in this policy, the WIC Coordinator should take steps to resolve the situation, including contacting the State WIC Consultant to discuss the situation.

S E C T I O N 3 . 2 : P R O C E S S I N G S T A N D A R D S - T I M E F R A M E S F O R S C H E D U L I N G C E R T I F I C A T I O N S 2 ▪ The date of the first appointment offered relative to the Initial Contact date determines whether the timeframes for Processing Standards are being met. These should be documented in the WIC Information System. ▪ Document the Initial Contact date. This is the date the applicant first contacted the WIC office to request an appointment. ▪ Document the date of the first appointment offered. The first appointment offered date may be different than the actual date of the scheduled appointment. ▪ If no appointments are available, use the comment field in the WIC Information System to document the reason an appointment could not be offered when the applicant contacted the WIC office. ▪ Complete the date of the first appointment offered in the WIC Information System when an appointment is available and can be offered to the applicant/participant. This may need to be documented in the Comment field. Guidance ▪ Offer a new appointment as soon as possible when an applicant asks to reschedule an appointment. ▪ Provide an appointment as soon as possible for all applicants requesting WIC services within the 10 and 20 calendar day timeframe. ▪ Use the scheduling feature in the WIC Information System to increase efficiencies and utilize the full reporting functions. ▪ Local Agencies are encouraged to: ▪ Offer a variety of flexible scheduling options including: ▪ Same-day or next day appointments; ▪ Walk-in appointments as time allows; ▪ Early morning, lunchtime or late day appointments; ▪ Prescheduled appointments in the future. ▪ Set aside appointment times convenient for pregnant women, young infants, and migrant families to meet the timeframes for processing applicants. ▪ Overbook the schedule based on the agency’s “no-show” rate. ▪ Contact your State WIC Consultant to discuss other ideas.

S E C T I O N 3 . 2 : P R O C E S S I N G S T A N D A R D S - T I M E F R A M E S F O R S C H E D U L I N G C E R T I F I C A T I O N S 3 Reference – Complete Listing of Hyperlinks Section 3.3: Transferring Participants (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch3/sct n3_3.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(3.3)Minnesota WIC Operations Manual (MOM) Section 3.3: Transferring Participants#

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Section 3.3: Transferring Participants 2/2020 References: 7 CFR 246.7(k), 7 CFR 247.26(d)(l)(ii), Policy Memorandum 2016-4 Policy: Certified participants who are transferring from another state or local agency are eligible to continue receiving WIC services through their current certification period. Purpose: All transferring participants will continue to receive WIC benefits for the duration of their original certification period without being re-screened and without regard to their risk status or assigned priority. Data Privacy ▪ Participant information collected by WIC is confidential and may only be used for WIC program purposes (except as otherwise permitted by regulation). ▪ WIC agencies should share information about transferring participants with other state or local WIC agencies without prior consent or a written release from the participant. Participants should not be asked to sign a release for transfer information. ▪ The Health Insurance Portability and Accountability Act of 1996 (HIPAA) does not apply to WIC information. Processing Standards ▪ Normal processing standards apply for all participants transferring into a local agency. See Section 3.2: Processing Standards-Timeframes for Scheduling Certification Appointments. In-State Transfers ▪ An adult participant or the parent/guardian must show proof of identity and residency when transferring into a new agency. ▪ If proof of identity or current residency is not yet available, issue only 1 month of benefits and place an Alert in the participant record to ensure those documents are provided at the next visit before additional benefits can be issued. ▪ See Section 5.2: Certification Procedures for acceptable forms of identity and residency. ▪ Local agency staff will: ▪ Initiate the transfer in the WIC Information System.

S E C T I O N 3 . 3 : T R A N S F E R R I N G P A R T I C I P A N T S 2 ▪ Review the participant record. ▪ Document the new address and the proofs of identity and residency. Update proxies if needed. ▪ Offer nutrition education, breastfeeding support and referrals if needed. Determine when the next visit should take place. ▪ Issue food benefits if not yet issued. Do not remove valid benefits issued by the previous agency unless the participant needs a food package change. ▪ Provide a list of local vendors, as appropriate. Out-of-State Transfers  coming from another state to Minnesota Verification of Certification (VOC) forms are used for out-of-state transfers to provide documentation of eligibility to the new agency. 1. Verify out-of-state transfer eligibility: ▪ If the participant has a valid Verification of Certification (VOC) or other document from the original state, enroll him/her if, at a minimum, there is adequate information documenting: ▪ the participant’s name ▪ the certification start and end dates The local agency may need to obtain additional certification information from the previous state in order to ensure continuity of care or to clarify any questionable information listed on the VOC. ▪ If the participant does not have adequate certification information from the previous state, verify current eligibility, including certification start and end dates, nutritional risk factors, and any unredeemed benefits by contacting the local agency in the previous state. ▪ If contact information for the previous agency is not available, refer to the FNS WIC Program Contacts listing for that state’s contact who can provide transfer information. ▪ If acceptable documentation of current eligibility cannot be determined, the participant must be offered a certification appointment within a timeframe that meets the appropriate processing standard. See Section 3.2: Processing Standards-Timeframes for Scheduling Certification Appointments. ▪ If the certification will expire soon, a recertification may be done instead for the participant’s convenience. 2. Initiate a VOC transfer in the WIC Information System. ▪ Determine whether the participant/household has an existing record in the Minnesota WIC Information system or whether to create a new record.

S E C T I O N 3 . 3 : T R A N S F E R R I N G P A R T I C I P A N T S 3 ▪ An adult participant or the parent/guardian must show proof of identity and residency when requesting a transfer, even if s/he has a valid VOC from another state. Document these in the WIC Information System. See Section 5.2: Certification Procedures for acceptable forms of identity and residency. ▪ The VOC document may be used as proof of identity for the child only. ▪ If VOC documentation can be verified, but proof of identity and/or current residency is not yet available, issue only 1 month of benefits and place an Alert in the participant record to ensure those documents are provided at the next visit. Additional benefits cannot be issued until those are provided or a waiver signed. ▪ Record the certification end date. This is the last date of the month in which the certification ends. (e.g., certification end date from the previous state is 9/7/20; the date to record in the system is 9/30/20) ▪ Transferring participants in a current certification do not need an Initial Contact. ▪ However for participants new to Minnesota, the WIC Information System will require the user to open and close the Initial Contact field. ▪ For these situations, it is not necessary to document any dates in the Initial Contacts fields. 3. Provide WIC Services ▪ Review certification risk codes as possible to determine nutrition education and follow up needs. Provide nutrition services or determine when the nutrition education visit is needed. See Chapter 6: Nutrition Education. ▪ Make referrals, as appropriate. ▪ Review the Rights and Responsibilities (signature not needed). ▪ Assign and explain the Minnesota WIC food package. ▪ Review the WIC Shopping Guide and how to identify the foods provided at the store. ▪ Explain how to use benefits at the store. ▪ Provide a list of local WIC vendors or explain how to find on the WIC App. ▪ Issue food benefits for which the participant is eligible. ▪ Collect any food benefits or eWIC card that the participant has brought. Once reviewed, destroy these via confidential disposal. ▪ Determine if there are unused benefits for the current month, including partially used benefits. It may be necessary to contact the previous state to verify. Provide those foods so that the participant does not miss out on foods he/she was not able to use before moving. ▪ If available, review the Medical Documentation form for participants receiving Food Package 3.

S E C T I O N 3 . 3 : T R A N S F E R R I N G P A R T I C I P A N T S 4 ▪ If the form is not available, contact the previous state to verbally confirm that information and document in a Note. ▪ Participants do not need to provide new documentation from a Minnesota provider if the Medical Documentation from the previous state is still valid. ▪ Follow MOM guidelines to determine when a new Minnesota WIC Program Request for Medical Formula form will be needed in the future. See Section 7.6: Medical Documentation Medical Documentation. ▪ Provide information about Medical Assistance, health care providers, and other resources as needed to help the participant establish a new health care home and ensure follow up of the high risk condition requiring Food Package 3. 4. Document the VOC transfer in the WIC Information System. ▪ Scan the VOC form (and Medical Documentation form if any) into the WIC Information System. Do not scan non-essential WIC materials from the other state such as the eWIC card. OR ▪ Write a Note, documenting the source of the transfer information and any information that would facilitate continuity of care. Out-of-State Transfer  moving from Minnesota to another state Participants who will be moving out of state: WIC staff will ▪ Print and sign a VOC from the WIC Information System for migrants and for any participant that may be planning to move out of state. Participants can take the VOC to the new state as documentation of current eligibility if they move. ▪ Provide a copy of the Medical Documentation form for any participant receiving Food Package 3. ▪ Explain to participants how to transfer WIC services to another state: ▪ Their WIC services will continue in the new state until the end of their certification period. ▪ Take the VOC form, and Medical Documentation form if there is one, to the new WIC agency. ▪ Or if they don’t have the VOC form when they arrive, take their WIC Card to the new agency. ▪ Or have the new agency call the MN local agency or state office.

S E C T I O N 3 . 3 : T R A N S F E R R I N G P A R T I C I P A N T S 5 Request for transfer information from another state for participants who have already moved: ▪ WIC transfer information requested by other states must be provided no later than the next business day. ▪ Phone requests from other state WIC programs for transfer information are acceptable. If WIC staff are uncertain if the caller is legitimate, they may call that agency back at the official phone number or have that agency fax them the request on official letterhead to authenticate the source. (Reminder: WIC staff cannot request a release of information be signed by the participant to share this information) ▪ Terminate the WIC certification in the WIC Information System. Guidance It is important to maintain continuity of care and appropriate follow up for all transfers. As appropriate, Local Agencies should assure that participants know about and understand the VOC process, including that: ▪ WIC services will continue if they move to another state. ▪ The local agency can provide a VOC form for them to take to facilitate the transfer. There are various ways to do this, such as: ▪ Point out and explain the VOC availability information on the WIC Rights and Responsibilities (Exhibit 1-K) or through the WIC App. ▪ Ask participants if they plan to move before their next appointment. Participants leaving Minnesota: ▪ When printing a VOC from the WIC Information System, it is not necessary to terminate the record if the move is not certain or there are other reasons for keeping the record active. Participants arriving in Minnesota: ▪ If documenting a VOC transfer into the agency with a Note, staff may choose to use the General Note heading titled “VOC” to more easily track those situations. ▪ If a participant arrives with complete VOC information, local agencies are encouraged to contact the previous state to notify them of the transfer so that the participant’s record and/or eWIC card in that state may be inactivated to ensure program integrity. Resources: WINNIE Training - Transfers

S E C T I O N 3 . 3 : T R A N S F E R R I N G P A R T I C I P A N T S 6 Reference – Complete Listing of Hyperlinks Section 3.2: Processing Standards-Timeframes for Scheduling Certification Appointments (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch3/sct n3_2.pdf) Section 5.2: Certification Procedures (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_2all.pdf) WIC Program Contacts (https://www.fns.usda.gov/wic/program-contacts) Chapter 6: Nutrition Education (https://www.health.state.mn.us/people/wic/localagency/mom.html#education) Rights and Responsibilities (https://www.health.state.mn.us/people/wic/rights.html) Minnesota WIC Program Request for Medical Formula (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7d. pdf) Section 7.6: Medical Documentation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_6.pdf) WIC Rights and Responsibilities (https://www.health.state.mn.us/people/wic/rights.html) WINNIE Training - Transfers (https://www.health.state.mn.us/people/wic/localagency/winnie/training.html#transfers) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(3.4)Minnesota WIC Operations Manual (MOM) Section 3.4: Waiting Lists#

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Section 3.4: Waiting List AUGUST 2004 References: C 7CFR 246.7 (f)(l) Policy: The Local Agency must serve all eligible individuals in each priority, unless otherwise instructed by the State Agency. If the State Agency determines a Waiting List is necessary, the Local Agency must follow these procedures. Purpose: As long as adequate federal funds are available; the Minnesota WIC Program intends to serve all eligible applicants. If funds become inadequate, this policy is to ensure fair and consistent access statewide to WIC benefits by persons with the greatest need, according to the federal WIC priority system. Procedures A Waiting List is a list of applicants who have met the general eligibility criteria of category (WIC type), residency, and income, but who cannot currently be enrolled in the Program. Do not implement a Waiting List unless specifically instructed to do so by the State Agency. In the event that the State Agency determines that Waiting Lists are necessary, the State will notify Local Agencies of the category(s) temporarily not being served. The Local Agency must then create, manage and enroll from the Waiting List as described below. A. Creating a Waiting List Minimum Waiting List Information When notified by the State Agency that a Waiting List is necessary, the Local Agency must collect from new applicants, the following information: ▪ Applicant name ▪ Applicant address and/or telephone number ▪ DOB

S E C T I O N 3 . 4 : W A I T I N G L I S T 2 ▪ WIC Type (pregnant, postpartum breastfeeding woman, postpartum non-breastfeeding woman, infant, or child) ▪ Date of application This information can be collected in Prescreening in the WIC Information System or by some other method identified by the Local Agency. Determining Date Placed on Waiting List ▪ New applicants: the date the person requested WIC benefits, whether by phone, mail, e- mail, or in person. ▪ Transfers (person in a valid certification period transferring from another state or local agency): this person must be placed at the top of the waiting list, and served before all non- transferring applicants. Organization of the Waiting List ▪ The Waiting List must be organized by category (WIC Type) and within each category, organized by date applicants are placed on the Waiting List. B. Notification Requirements Local Agencies must notify applicants of their placement on a Waiting List within 20 days of their initial request for services. C. Enrolling from the Waiting List ▪ When an appointment becomes available, local Agency staff must notify the next person on the Waiting List. Staff must reevaluate income and residency eligibility before enrolling the individual. ▪ Once an appointment is scheduled, it may not be cancelled by the local Agency or given to another person who may apply (even if higher risk/priority). ▪ Persons must be notified that they can be removed from the Waiting List for missed appointments and if they reapply, the reapplication date will be used to determine their place on the Waiting List. ▪ No person can be denied the right to apply to the Program, regardless of how many appointments he/she has missed. Guidance In establishing clinic schedules, Local Agencies should always set aside appointment times for certifying pregnant women, infants, migrants, and other high-risk applicants, to meet processing standards.

S E C T I O N 3 . 4 : W A I T I N G L I S T 3 If the State Agency determines that Waiting Lists are necessary, the State will provide additional guidance to Local Agencies on creating and managing a Waiting List, including information for using HuBERT to accomplish this. See related policies: Section 3.2: Processing Standards-Timeframes for scheduling certification appointments (PDF) Section 3.3: Transferring Participants (PDF) Reference – Complete Listing of Hyperlinks Section 3.2: Processing Standards-Timeframes for scheduling certification appointments (PDF) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch3/sct n3_2.pdf) Section 3.3: Transferring Participants (PDF) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch3/sct n3_3.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(4.2)Minnesota WIC Operations Manual (MOM) Section 4.2: Local Agency Management#

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Section 4.2: Local Agency Management 10/2006 References: 7 CFR 246.3(f); 2646.6 (a-b); WIC Nutrition Service Standards, Standard 1, FNS/USDA; and relevant MOM Policies referenced throughout Policy: Each Local Agency must designate a WIC Coordinator (and other staff as needed) to manage the Local WIC Program Purpose ▪ To ensure responsible and effective management of the WIC grant for meeting program requirements. ▪ To provide leadership in developing quality WIC nutrition and customer services. ▪ To serve as the key contact for communication with the state agency. Procedures ▪ The local agency must designate a WIC Coordinator to oversee all functions of the program. ▪ Program activities may be accomplished by any number of responsible, qualified staff, but the WIC Coordinator is responsible for management and oversight. ▪ The WIC Coordinator must ensure that the following functions are performed, (either personally or by another staff person): ▪ Manage the WIC grant and coordinate program activities. ▪ Hire, train, and supervise staff so the program is administered effectively and efficiently. ▪ Plan and coordinate WIC clinic activities. ▪ Plan and coordinate nutrition services. ▪ Ensure participants receive quality services and appropriate benefits. Guidance Qualifications of a WIC Coordinator: ▪ The qualifications of the WIC Coordinator will vary depending on the needs and staffing patterns of the local agency. It is highly desirable that the WIC Coordinator have a degree in

S E C T I O N 4 . 2 : L O C A L A G E N C Y M A N A G E M E N T 2 a health-related profession such as dietetics, nutrition, or nursing, and coursework and/or experience in: ▪ Management -- including program planning and evaluation; personnel management; and budget management ▪ Community/Public Health ▪ Maternal, Child, and Infant Nutrition ▪ It is strongly recommended that the WIC Coordinator be a qualified Competent Professional Authority (CPA) and have experience, or obtain experience, working as a CPA. Local Agency Management and WIC Coordinator Activities include: 1. Manage the WIC grant and coordinate WIC activities to meet program requirements. ▪ Complete and submit the grant application. ▪ Plan use of grant funds, ensuring adequate and appropriate staffing for providing quality WIC nutrition services. ▪ Prepare the Expenditure Plan and modify the plan to accommodate variations in funding. ▪ Monitor spending regularly to ensure full utilization of the WIC grant. ▪ Coordinate with local agency fiscal staff to ensure complete, accurate, and timely reporting. ▪ Manage caseload based on available funding; promote growth as funding allows. ▪ Assure compliance with MN WIC policies and procedures and applicable federal regulations, policies, and instructions. ▪ Refer to most up-to-date policies. ▪ Plan, implement, and follow-up on policy changes with staff. ▪ Read communications from the state agency (e.g., WIC Updates and WIC Information System Release Documents), share information with staff, and ensure successful implementation of program changes. ▪ Participate in Management Evaluations. ▪ Perform on-going self-evaluation of compliance with federal requirements and of program effectiveness. ▪ Provide leadership for staff in identifying problems and seeking solutions. ▪ Respond to Management Evaluation. Plan and implement corrections as needed. ▪ Communicate with and seek advice from the supervisor and/or local administrator about key issues in WIC. ▪ Consult with and seek advice from state staff as needed.

S E C T I O N 4 . 2 : L O C A L A G E N C Y M A N A G E M E N T 3 ▪ Attend state meetings/trainings and share information with staff. ▪ Plan and implement outreach as needed, when funding and opportunities allow. (See Section 1.6: Public Notification and Outreach) 2. Hire, train, and supervise staff so that the program is administered effectively and efficiently. ▪ Ensure that staff qualifications, skills, and competencies match program needs for nutrition services and administrative functions. When filling staff vacancies, consider the effectiveness of staffing structure in meeting WIC program needs. ▪ Provide adequate initial and on-going training. ▪ Provide staff supervision, monitoring, and evaluation, and coach to build competence (see CPA Performance Evaluation policy, Section 4.6: CPA Performance Evaluation). ▪ Conduct regular performance reviews to evaluate staff performance of their WIC functions. ▪ Schedule appropriate staff and adequate hours for providing clinic services, and for accomplishing office and other WIC duties. ▪ Schedule and conduct regular WIC staff meetings to facilitate communication and coordinate services. ▪ Regularly communicate program information and policy changes to staff. ▪ Plan and oversee the use of volunteers and interpreters. (See Chapter 4: Local Agency Management and Staffing.) 3. Plan and coordinate WIC clinic activities. ▪ Arrange to provide WIC services at sites/locations that will provide reasonable access to applicants/participants in your service area (see Section 5.9: Clinic Environment) ▪ Ensure compliance with all civil rights laws and regulations, including accessible-sites (see Civil Rights policy, Section 1.10: Civil Rights). ▪ Assure adequate appointments and staffing to meet “10/20 day” scheduling standards (see Section 3.2: Processing Standards-Timeframes for Scheduling Certification Appointments). ▪ Maintain adequate certification and WIC information System equipment for clinic operation. ▪ Ensure security of staff, WIC Information System equipment and vouchers at every clinic site (see Section 9.4: Network, Browser, and User Access Security) ▪ Oversee staff use of WIC Information System. Designate and train Local Systems Administrator staff.

S E C T I O N 4 . 2 : L O C A L A G E N C Y M A N A G E M E N T 4 ▪ Periodically evaluate and modify operations and clinic flow for optimal services and maximum efficiency. ▪ When WIC clinic is co-located w/ other health services (e.g., Maternal and Child Health; Immunizations; Family Planning, etc.), coordinate services as possible. When not co- located, establish effective referral procedures. 4. Plan and coordinate nutrition services. ▪ Use WIC data to identify nutrition problems in population served by your agency, and plan and evaluate nutrition services to address them. ▪ Develop and implement the agency’s Nutrition Education Plan (See Section 6.10: Local Agency Nutrition Education Plans). ▪ Comply with all state and federal requirements in provision of nutrition services to WIC participants (accurate assessments, appropriate nutrition education, referrals, and food packages). ▪ Assure that adequate and appropriate nutrition education materials are available (see Section 6.9: Nutrition Education Materials). ▪ Develop and implement a plan for promoting breastfeeding. Designate a breastfeeding coordinator (see Section 4.4: Breastfeeding Coordinator). ▪ Periodically evaluate and modify nutrition practices and procedures for providing optimal service. ▪ Oversee/manage the agency’s issuance of infant formulas (contract, non-contract, and medical formulas) and formula samples. Communicate with local medical providers regarding formula issues (see Section 7.4: Supporting Breastfeeding with the WIC Food Package). ▪ Coordinate medical referrals to physicians and other health care providers (see Section 6.6: High Risk Individual Nutrition Care Plans). ▪ Coordinate referrals to other services such as MAC, Social Services, and Food Shelves (see Section 5.7: Referrals). ▪ (See Chapter 6: Nutrition Education) 5. Ensure participants receive quality services and appropriate benefits. ▪ Maintain participant confidentiality and protect data privacy (see Section 1.7: Data Privacy). ▪ Train staff on Civil Rights requirements and monitor compliance (see Section 1.10: Civil Rights). ▪ Respond to potential participant abuse (see Section 1.11: Potential Participant Violations).

S E C T I O N 4 . 2 : L O C A L A G E N C Y M A N A G E M E N T 5 ▪ Promote good customer service by training and building staff skills. ▪ Solicit feedback from WIC participants and respond to participant suggestions and complaints. Reference – Complete Listing of Hyperlinks Section 1.6: Public Notification and Outreach (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_6.pdf) Section 4.6: CPA Performance Evaluation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_6.pdf) Chapter 4: Local Agency Management and Staffing (https://www.health.state.mn.us/people/wic/localagency/mom.html#staffing) Section 5.9: Clinic Environment (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_9.pdf) Section 1.10: Civil Rights (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_10.pdf) Section 3.2: Processing Standards-Timeframes for Scheduling Certification Appointments (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch3/sct n3_2.pdf) Section 9.4: Network, Browser, and User Access Security (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch9/sct n9_4.pdf) Section 6.10: Local Agency Nutrition Education Plans (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_10.pdf) Section 6.9: Nutrition Education Materials (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_9.pdf) Section 4.4: Breastfeeding Coordinator (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_4.pdf) Section 7.4: Supporting Breastfeeding with WIC Food Package (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_4.pdf)

S E C T I O N 4 . 2 : L O C A L A G E N C Y M A N A G E M E N T 6 Section 6.6: High Risk Individual Nutrition Care Plans (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_6.pdf) Section 5.7: Referrals (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_7.pdf) Chapter 6: Nutrition Education (https://www.health.state.mn.us/people/wic/localagency/mom.html#education) Section 1.7: Data Privacy (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_7.pdf) Section 1.11: Potential Participant Violations (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_11.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider

(4.3)Minnesota WIC Operations Manual (MOM) Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities#

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Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities 9/2018 References 246.2 Definition of competent professional authority 246.6(b)(2) Perform certification procedures 246.7(e) Determine nutritional risk 246.7(i)(7) Sign certification form 246.10(a)(2)(iii) Prescribe supplemental food 246.11(e)(5) Provide individual care plan USDA WIC Nutrition Services Standards, Nutrition Services Staffing, Standard 3 (M, N,O) Policy: Grantees are responsible for employing qualified CPAs in sufficient numbers to determine nutrition risk eligibility, provide nutrition education, and prescribe an appropriate food package for each participant. Purpose: To ensure that qualified professionals are making decisions about eligibility and nutrition risk, and providing appropriate, competent nutrition services. Definitions ▪ Competent Professional Authority (CPA): In the local agency (LA), a CPA is authorized to conduct nutrition and health assessments, determine nutrition risk, provide individualized nutrition education, and prescribe supplemental foods. The specific role of an individual CPA will depend on his/her education, experience, and professional credentials. ▪ Registered Dietitian Nutritionist (RDN): An individual with a minimum of a bachelor’s degree in an accredited nutrition program and registered with the Commission of Dietetic Registration (CDR). RDNs have completed 1200 hours of supervised practice and passed a national exam. ▪ Licensed Dietitian (LD): An individual with a minimum of a bachelor’s degree in an accredited nutrition program and licensed by the State of Minnesota Board of Dietetics and Nutrition Practice; Minnesota Statutes, Section 148.621 to 148.633. LDs have completed 900 hours of documented supervised practice in nutrition or have a doctoral degree from an accredited college with a major course of study in nutrition. LDs may also have valid current registration with the Commission of Dietetic Registration.

S E C T I O N 4 . 3 : C P A Q U L A I F I C A T I O N S A N D R E S P O N S I B I L I T I E S 2 ▪ Licensed Nutritionist (LN): An individual with a master’s or doctoral degree in an accredited nutrition program and licensed by the State of Minnesota Board of Dietetics and Nutrition Practice; Minnesota Statutes, Section 148.621 to 148.633. LNs have completed 1000 hours of documented supervised practice in nutrition or have received certification from the Certification Board for Nutrition Specialists. ▪ Nutrition and Dietetics Technician, Registered (NDTR): An individual educated and trained in nutrition and dietetics practice for the delivery of safe, culturally competent, quality food and nutrition services. NDTRs work under the supervision of an RDN. Successful completion of a Dietetic Technician accredited program includes 450 hours of supervised practice with at least a two year associate degree and successful completion of the Registration Examination for Dietetic Technicians. ▪ Paraprofessional CPA: An individual who has not attained a college degree to otherwise qualify for hiring as a CPA, but who is of a culture and/or speaks a language needed to serve participants from that community. To work as a paraprofessional CPA, such an individual must receive extensive training and mentoring to assure they acquire and maintain the minimum competencies needed in WIC. This individual can serve low risk participants under continuous supervision, and with ongoing training and mentoring from a local agency’s nutrition professionals. See Section 4.3.1 below. ▪ CPA Competencies: Skills and tasks necessary to certify and serve WIC applicants and participants. The competencies will be attained through training and assured through initial and on-going monitoring of performance. ▪ Cultural Competency: For the purpose of this policy, cultural competency is defined as having extensive knowledge and experience of the cultural patterns and practices of a specific community, especially related to the beliefs and practices affecting maternal and child health and nutrition. Procedures WIC is a nutrition program in which individuals are assessed for nutrition risk, provided targeted nutrition education and referrals, and a food package. While many participants are considered “low risk”, WIC serves many vulnerable individuals at high nutrition risk. The MN WIC Program is committed to assuring that Local Agencies have the staff to address these special nutrition needs. 1. The goal of the MN WIC Program is for LAs to employ or contract with a credentialed nutrition professional (i.e., an RDN, Minnesota LD or LN) to plan and oversee the nutrition services for the agency. The credentialed nutrition professional should be designated to serve high risk participants and/or oversee high risk services provided by the agency’s other (non-nutrition credentialed) CPAs. See Guidance for other suggested roles and responsibilities for credentialed staff.

S E C T I O N 4 . 3 : C P A Q U L A I F I C A T I O N S A N D R E S P O N S I B I L I T I E S 3 ▪ If the Grantee does not employ an RDN/LD/LN, when a staff opening occurs the grantee must attempt to recruit and hire one. See Guidance for suggestions. State WIC Consultants are available to assist. 2. In addition to CPAs with nutrition credentials, LAs may hire individuals with other credentials and/or related post-secondary education to function as a CPA. Agencies must ensure these individuals receive appropriate training before functioning as a CPA. The following are acceptable credentials/education: ▪ Bachelor’s or Master’s Degree in Nutrition such as Nutritional Sciences, Community Nutrition, Clinical Nutrition or Dietetics. ▪ Registered Nurse Licensed by the Minnesota Board of Nursing pursuant to Minnesota Statutes, Section 148.171 to 148.285. Preference should be given to nurses with a bachelor’s degree or higher. ▪ Bachelor’s or Master’s Degree in Health or Home Economics field with applicable coursework in nutrition. At a minimum, coursework must include: ▪ 10 semester (or 15 quarter) credits in Food and Nutrition, including coursework in general human nutrition, and in nutrition for infants, children, and women during prenatal, postpartum, and breastfeeding stages; and ▪ 3 semester (or 4 quarter) credits in the principles of counseling and/or adult education; and ▪ 3 semester (or 4 quarter) credits in Chemistry or Biological Sciences. Use Exhibit 4-A: Local Agency Application of Applicant Coursework to evaluate health and home economic coursework, and consult with your State WIC Consultant as needed. ▪ Nutrition and Dietetics Technician, Registered by the CDR. ▪ Paraprofessional CPA requirements are addressed in Section 4.3.1 below. Also see Exhibit 4-L: Written Plan for Local Agency to Complete Before Hiring a Paraprofessional CPA and Exhibit 4-K: Staffing Roles Grid for Nutrition Services 3. Preparation and training requirements – All CPAs must: ▪ Complete nutrition modules and training in certification procedures, based on the individual’s credentials and experience. ▪ Successfully complete all phases of the Staff Training Policy (Section 4.5: Staff Training). Each phase incrementally builds skills to increase the CPA’s capacity and role. ▪ Successfully complete the Minnesota WIC Nutrition Modules before the end of the training period for all individuals without nutrition credentials. See Section 4.5: Staff Training. ▪ Demonstrate proficiency in CPA competencies per Local Agency Staffing Policy, Section 4.6: CPA Monitoring and Oversight.

S E C T I O N 4 . 3 : C P A Q U L A I F I C A T I O N S A N D R E S P O N S I B I L I T I E S 4 ▪ Participate in on-going staff development and training. See Section 4.5: Staff Training. 4. All CPAs are responsible for certifying participants, including the following activities: ▪ Nutrition and health assessments ▪ Nutrition risk determination ▪ Final eligibility/ineligibility determination. ▪ Providing nutrition education addressing participants’ nutrition risks. ▪ Conducting follow-up nutrition assessments as needed, with corresponding nutrition education. ▪ Prescribing appropriate supplemental foods based on participant category and individual needs and preferences. ▪ Referring all requests for Medically Prescribed Formula to a CPA designated to serve high-risk participants. See Section 6.6: High Risk Individual Nutrition Care Plans. Guidance 1. If the number of credentialed nutrition professional(s) (RDN, LD or LN) and/or their hours are limited, Local Agencies should prioritize how their skills and time can best be utilized in the program. Below are a number of WIC program roles or functions, for which individuals with nutrition credentials would be uniquely qualified. ▪ WIC Coordinator ▪ Nutrition Education Coordinator ▪ Breastfeeding Coordinator ▪ Staff person designated to serve “high risk” participants and/or to oversee high risk services provided by the agency’s other (non-nutrition credentialed) CPAs. ▪ Assist in assessing staff nutrition competencies and identifying training needs. ▪ Resource to other staff in increasing their nutrition knowledge and understanding, and as a consultant to others on nutrition issues. ▪ Participate in on-going staff development and nutrition training. See Section 4.5: Staff Training. ▪ Develop (or participate in developing) and implementing the Nutrition Education Plan for the agency or grantee. ▪ Be fully trained to function as a CPA, as needed by the LA. 2. If a Grantee contracts with an RDN/LD/LN, the contracted hours should be adequate for accomplishing the nutrition-related responsibilities and training requirements. 3. Recruiting credentialed nutrition professionals:

S E C T I O N 4 . 3 : C P A Q U L A I F I C A T I O N S A N D R E S P O N S I B I L I T I E S 5 ▪ Consider contacting colleges with dietetics programs and advertising on the Minnesota Academy of Nutrition and Dietetics (MAND) website. Your State WIC Consultant can assist you with contact information. ▪ Contact your State WIC Consultant if unable to find suitable applicants with the desired credentials. 4.3.1 Paraprofessional CPAs Policy: To meet the cultural and/or language needs of participants served by a LA, the agency may be approved to hire a para-professional CPA who speaks the language and/or is of the culture. Since these individuals lack the specified post-secondary education and nutrition credentials, they require extensive training and on-going monitoring. Purpose: To meet the language and/or cultural needs of participants in order to best serve them, and to increase the diversity of the WIC workforce to better reflect the communities WIC serves. Procedure A written plan must be developed and approved before a paraprofessional CPA is hired. Local agencies must work with their State WIC Consultant from the beginning of the process. Paraprofessional CPAs may be hired if the plan is approved, and the LA assures that the following requirements will be met throughout the paraprofessional CPA’s employment. See Exhibit 4-L: Written Plan for Local Agency to Complete Before hiring a Paraprofessional CPA. 1. Local agencies must demonstrate their need to hire a paraprofessional CPA: ▪ The local agency must first attempt to hire a CPA with professional credentials who could meet the cultural and/or language needs of participants. ▪ The local agency serves participants of a non-majority culture and/or participants who speak another language than English. 2. Local agencies must demonstrate their ability to meet the requirements involved in employing a paraprofessional CPA: ▪ The local agency must have demonstrated compliance with WIC policies and procedures and had minimal required actions at recent management evaluations before taking on the responsibility of training, supervising, and mentoring a paraprofessional CPA. ▪ Paraprofessional CPAs require extensive preparatory and on-going training and mentoring throughout their employment. ▪ The local agency must have nutrition professionals (RDN, LD, or LN) on staff and available to provide the required training, mentoring and continuous supervision at all clinic sites.

S E C T I O N 4 . 3 : C P A Q U L A I F I C A T I O N S A N D R E S P O N S I B I L I T I E S 6 ▪ Larger local agencies with multiple RDNs on staff would be better able to meet this requirement. Paraprofessional qualifications: 1. Candidates for serving a local agency’s non-English speaking participants, must be proficient in the community’s language and knowledgeable of their culture. ▪ A high school diploma, or GED equivalent, and a year of employment that includes customer service is required. Consult your State WIC Consultant if it is not possible to find a candidate with these requirements to meet a language need. ▪ Candidates with some post-secondary education are preferred. ▪ Candidates must be willing and able to successfully complete the required training. See training requirements below. 2. Candidates for serving a particular cultural group must be a member of that cultural community, with extensive knowledge of their culture and socioeconomic conditions. ▪ Candidates must have completed an associate or bachelor’s degree, in any of the following disciplines: ▪ Public health; Community health education; Health education; Health science; Exercise science or other health-related degrees. ▪ Biology; Family consumer science; Psychology; Adult and/or early childhood education; Human services; Social work; Sociology; Family social science; Global development/global studies. ▪ Strong consideration should be given to candidates with coursework in nutrition, biology, and chemistry. ▪ Candidates must be willing and able to successfully complete the required training. See training requirements below. Paraprofessional CPAs must complete their training prior to certifying low risk participants: ▪ At minimum, complete two college-level nutrition courses within one year of hire: ▪ 3 semester credits in a general nutrition course. This course should cover the following areas: Fundamental concepts of nutrition, nutrient functions, human nutritional requirements, food sources, role of nutrition in chronic disease. ▪ 3 semester credits in a lifecycle nutrition course. This course should cover the following areas: Nutrition for infants, children, and women during prenatal, postpartum, and breastfeeding stages. ▪ The State WIC Consultant will review documentation and provide guidance. ▪ Complete and document required WIC New Staff Training:

S E C T I O N 4 . 3 : C P A Q U L A I F I C A T I O N S A N D R E S P O N S I B I L I T I E S 7 ▪ New staff training must be completed within six months of hire. ▪ Nutrition modules must be completed within two months after completing the college nutrition courses. ▪ Successfully complete training in basic skills needed to function in the position and specific competency areas. ▪ Demonstrate attainment of required working skills. ▪ Paraprofessionals must receive extensive training to identify participants at higher nutritional risk to refer to a nutrition professional. Ongoing and frequent training for paraprofessional CPAs is required: ▪ The RDN/LDN/LN must assess the paraprofessional CPA’s training needs and assure that training is provided as needed; quarterly at a minimum. ▪ Paraprofessionals must continue to meet minimum standards as assessed by periodic evaluation and identified training needs. ▪ Documentation of ongoing training must be kept for review at the Management Evaluation. ▪ Also, see Section 4.5: Staff Training. Supervision of paraprofessional CPAs: ▪ Paraprofessional CPAs and the local agency must meet the continuous supervision and training requirements specified in Local Agency Staffing Policy, Section 4.6: CPA Monitoring and Oversight. ▪ This requirement is ongoing throughout the employment of the paraprofessional CPA, including during any time periods where staff turnover makes this supervision difficult. Paraprofessional CPAs have a limited scope of practice: ▪ Paraprofessional CPAs are best suited to serve low risk participants. ▪ If the paraprofessional identifies that a participant has a high risk condition, the local agency must have a plan in place to assure that the participant receives appropriate care from a high risk CPA at follow-up appointments. ▪ See Exhibit 4-L: Written Plan for Local Agency to Complete Before Hiring a Paraprofessional CPA. Approval of paraprofessional CPAs: ▪ Approval of a paraprofessional CPA is provisional and may be revoked for the following reasons: ▪ The local agency is not adequately training and/or supervising the individual.

S E C T I O N 4 . 3 : C P A Q U L A I F I C A T I O N S A N D R E S P O N S I B I L I T I E S 8 ▪ The individual has not adequately attained skills and competencies necessary to function as a CPA. ▪ The individual is working outside the approved scope of practice. ▪ If state-approval for employing the paraprofessional CPA is revoked, that individual may no longer function as a CPA. Guidance: ▪ Local agency staff must work with their State WIC Consultant from the beginning of the process. A representative from the local agency should meet with their State WIC Consultant. ▪ Documentation of all training, chart reviews and observations should be kept for review at the Management Evaluation. ▪ Best practice is to test candidates on their language proficiency. Contact your State WIC Consultant for a list of test sites. Reference – Complete Listing of Hyperlinks WIC Nutrition Services Standards (https://wicworks.fns.usda.gov/sites/default/files/media/document/wic-nutrition-services- standards_0.pdf) Exhibit 4-A: Local Agency Application of Applicant Coursework (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4a. pdf) Exhibit 4-L: Written Plan for Local Agency to Complete Before hiring a Paraprofessional CPA (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4l. pdf) Exhibit 4-K: Staffing Roles Grid for Nutrition Services (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4k. pdf) Section 4.5: Staff Training (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_5.pdf) Nutrition Modules (https://www.health.state.mn.us/people/wic/localagency/training/nutmodules.html) Section 4.6: CPA Monitoring and Oversight (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_6.pdf)

S E C T I O N 4 . 3 : C P A Q U L A I F I C A T I O N S A N D R E S P O N S I B I L I T I E S 9 Section 6.6: High Risk Individual Nutrition Care Plans (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_6.pdf) MAND (https://www.eatrightmn.org/) WIC New Staff Training (https://www.health.state.mn.us/people/wic/localagency/training/nst.html#NaN) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(4.4)Minnesota WIC Operations Manual (MOM) Section 4.4: Breastfeeding Coordinator#

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Section 4.4: Breastfeeding Coordinator 11/2025 References: 7 CFR 246.11 Policy: Each local WIC agency shall designate a Breastfeeding Coordinator. The Breastfeeding Coordinator is responsible for planning and coordinating local breastfeeding promotion and support activities, including developing the breastfeeding related components of the nutrition education plan. Purpose: To assure all breastfeeding-related activities are completed. Qualifications ▪ The Breastfeeding Coordinator should be an individual who meets the qualifications of CPA with a Bachelor’s or Master’s degree, or is a Registered Nurse. Other CPAs or non-CPAs with specialized advanced training and experience (such as an International Board Certified Lactation Consultant, IBCLC) are also qualified to function in the role of the Breastfeeding Coordinator. They may be designated Breastfeeding Coordinator after consultation with the State WIC Consultant and/or State Breastfeeding Coordinator. ▪ The Breastfeeding Coordinator should be an individual who possesses the following specialized skills and knowledge: ▪ Knowledge of general breastfeeding techniques and resolution of common breastfeeding concerns. Generally, the Breastfeeding Coordinator or another staff member who does breastfeeding counseling should receive additional training to help with more challenging breastfeeding problems or questions in the WIC clinic. Knowledge should be based on professional training and current breastfeeding research. ▪ Knowledge of effective counseling and educational concepts and methods. ▪ Ability to prepare and/or evaluate breastfeeding education materials and to prepare and deliver (or plan for the delivery of) breastfeeding in-service training for local agency staff. Roles of the Breastfeeding Coordinator include ▪ Coordinate breastfeeding promotion and support activities for the local agency. ▪ Develop and review/evaluate breastfeeding materials. ▪ Coordinate the development and dissemination of local WIC agency breastfeeding policies.

S E C T I O N 4 . 4 : B R E A S T F E E D I N G C O O R D I N A T O R 2 ▪ Train new staff regarding their role in breastfeeding promotion and support or delegate the task to another appropriate staff member. ▪ Utilize Exhibit 4F: Topics for WIC Staff Breastfeeding Orientation which outlines the topics that new staff should understand. ▪ Provide ongoing oversight and support of local agency breastfeeding staff to assure all staff have adequate breastfeeding training for their role. ▪ Keep current with up-to-date breastfeeding information and disseminate this information to local agency staff, including but not limited to, new resources and information provided by the State WIC office. ▪ Identify, coordinate, and collaborate with other community breastfeeding programs. ▪ Participate in the development of the local agency’s Nutrition Education Plan. ▪ Monitor local agency breastfeeding rates to identify trends and plan breastfeeding promotion and support activities to meet identified agency needs. ▪ Read breastfeeding related communications from the state agency (e.g., WIC Weekly Update, and communications from the State Breastfeeding Coordinator), share information with staff, and ensure successful implementation of program changes. ▪ Communicate with and seek advice from the WIC Coordinator and/or supervisor about breastfeeding issues in WIC. ▪ Consult with and seek advice from state staff as needed. ▪ Attend state meetings/trainings and share information with staff. ▪ Ensure that breastpump issuance, inventory, and maintenance are logged and monitored. References WIC Nutrition Services Standards (https://wicworks.fns.usda.gov/resources/wic-nutrition- services-standards) FNS/NWA WIC Nutrition Services Standards Revision Workgroup, U.S. Department of Agriculture, Food and Nutrition Service, August 2013. Breastfeeding Policy and Guidance (https://wicworks.fns.usda.gov/sites/default/files/media/document/WIC-Breastfeeding-Policy- and-Guidance_1.pdf) United States Department of Agriculture, Food and Nutrition Service, July 2016. Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(4.5)Minnesota WIC Operations Manual (MOM) Section 4.5: Staff Training#

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Section 4.5: Staff Training 03/2019 References: 7CFR 246.11; USDA WIC Nutrition Services Standards, Standard 5 (A)(1)(a-e) Policy: Local Agencies will make available ongoing training for WIC staff within the designated timeframes. Purpose: To ensure ongoing staff development that broadens knowledge and competencies on various topics related to nutrition, breastfeeding, WIC, and public health, and enhances staff skills in providing quality participant centered services to best meet the needs of WIC participants. Procedures: The WIC Coordinator, or designee, will: 1. Develop a training plan that will provide opportunities for all staff to obtain annually, a specified number of training hours related to their job duties. The training plan will: ▪ Include a proposed schedule for training new staff and for required annual trainings (e.g., Civil Rights, WIC Information System security training for system users). ▪ Be based on a formal, or informal, needs assessment to ensure that all staff have the abilities and skills required to competently perform their assigned duties. 2. Ensure staff training is appropriate and completed within designated timeframes. New WIC Staff Training A new staff person must complete all activities outlined in the New Staff Training Plan complete an equivalent training plan outlined by the local agency. ▪ A local agency-developed training plan must include all topics and competencies included in the State-developed plan. Maintain outline for review at Management Evaluations. ▪ Document the date each activity on the New Staff Training checklist (or equivalent) is completed. ▪ Maintain the checklist for review at the next Management Evaluation.

S E C T I O N 4 . 5 : S T A F F T R A I N I N G 2 Annual Required Trainings Two trainings are required annually: Civil Rights training (for all staff) and WIC Information System Security training (for Information System users). ▪ These trainings must be completed annually by all WIC staff, including contracted providers, interpreters, volunteers, students, and interns who have contact with WIC participants. ▪ New employees must complete each of these trainings within 6 months of hire. ▪ Staff must use the training materials provided by the state WIC program. Training materials provided by your local leadership would be in addition to materials provided by the state. ▪ Documentation of required trainings must include the staff’s name and signature and date the training was completed. Maintain documentation until reviewed at a Management Evaluation. Continuing Education Minimum Requirements All WIC CPA staff will complete a minimum of 10 hours of staff development training relevant to the WIC program services each year. Staff development training should occur throughout the year. ▪ At least one training each year will focus on breastfeeding education. ▪ Training on emerging health issues may be required as directed by the State WIC Program or in response to a Management Evaluation corrective action plan. ▪ Civil Rights Training and Information System Security training do not count towards the minimum training hours. ▪ Training modes include, but are not limited to, in-services, staff-led trainings, online training, webinars, self-study modules, journal article review, college courses, seminars, and conferences. ▪ Completing the “new staff training plan” meets the 10-hour requirement for a new employee’s first year. Additional training to develop knowledge and skills is encouraged. Role-specific training ▪ Para-professional CPAs must meet the on-going training and certification observation requirements outlined in Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities. ▪ Support staff (such as clerks) will participate in a customer service training and breastfeeding promotion training annually, but they are exempt from other training hour requirements. 3. Document completed staff training and education. ▪ Documentation will include:

S E C T I O N 4 . 5 : S T A F F T R A I N I N G 3 ▪ Date(s) & length ▪ Name of training, and/or brief description ▪ Topic(s) or Learning Objectives ▪ Type of training (e.g., webinar, in-service, conference, seminar, self-study, etc.) ▪ Person(s) attending Guidance Assessing Training Needs: The purpose of a needs assessment is to determine areas in which training is needed or desired for staff to develop competencies, and to identify ways in which these needs can be met. A formal assessment is not required. ▪ In assessing training needs, consider the following factors: ▪ Training needs identified during Management Evaluations, site visits, individual certification observations, and/or chart audits ▪ Local agency nutrition education and breastfeeding goals outlined in the agency’s nutrition education plan ▪ Current staff skills and experiences ▪ The need for general versus specialized training, based on current staff needs, and relevance of training to WIC services ▪ Participant needs, changes in population served, and health trends in your WIC population ▪ Sponsorship of trainings (e.g., State Agency provided training, training by established professional organization, on-line trainings, webinars etc.) ▪ Reasonableness of training cost ▪ Use observations and evaluations already in place, including: ▪ CPA observations ▪ Chart audits ▪ PCS mentoring observations ▪ Informal discussion activities ▪ Individual assessment of needs ▪ Sample tools for assessing and documenting training needs are available. ▪ Training Needs Assessment – Activities and surveys to determine training needs. Continuing Education Overview ▪ Training Plan and Log. Continuing Education Overview

S E C T I O N 4 . 5 : S T A F F T R A I N I N G 4 Resources for Training: WIC Nutrition Continuing Education Resources Training Topics: See WIC Nutrition Services Standard 5 (C) (Page 24) for an extensive list of potential training topics for WIC staff. Also refer to the topics on the optional needs assessment. Training Plan: After determining training needs, develop a written plan, outlining potential training resources to meet identified needs and general timeline of when the training will be offered. The plan should be updated as needed, or at least annually. The training plan is intended to be a working tool for your agency. You are encouraged to update it throughout the year as training needs are identified and/or training opportunities become available. A template of a training plan and log is available. Trainings to Maintain Professional Credentials: Trainings attended by an employee to maintain their credentials would count towards WIC training requirements if the training is within the scope of WIC services. Trainings outside the scope of WIC may not be included in the hours. Mandatory Civil Rights Training: Local staff must use Civil Rights training materials provided by the State WIC Program. The State WIC Civil Rights Coordinator is also available to assist you. Mandatory trainings require staff signature. Civil Rights Training available at the MN WIC website. Documentation of Training: Training can be documented in any organized manner that you prefer and that allows for review at Management Evaluations. Mandatory trainings require staff signature. Options include: ▪ Agency-wide documentation, of all staff: ▪ Electronic tracking form ▪ Simple spread sheet ▪ Documentation by Individuals: ▪ Training log for maintaining credentials (RDN, RN, etc.) ▪ Training record from an existing staff development plan ▪ Other individual tracking procedure Training Costs: The cost for WIC-related trainings is an allowable WIC expense and should be budgeted as part of the WIC grant. Out-of-State Trainings: Out-of-state travel using WIC funds must be preapproved. Discuss with your State WIC Consultant. Definitions: Paraprofessional CPA: An individual who has not attained a college degree to otherwise qualify for hiring as a CPA, but who is of a culture and/or speaks a language needed to serve participants from that community. To work as a Para-professional CPA, such an individual must receive extensive training and mentoring, to assure they acquire and maintain the minimum competencies needed in WIC. This individual can serve low risk participants under continuous

S E C T I O N 4 . 5 : S T A F F T R A I N I N G 5 supervision, and with ongoing training and mentoring from a local agency’s nutrition professionals. See Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities. Reference – Complete Listing of Hyperlinks Nutrition Services Standards (https://wicworks.fns.usda.gov/sites/default/files/media/document/wic-nutrition-services- standards_0.pdf) New Staff Training Plan (https://www.health.state.mn.us/people/wic/localagency/training/nst.html) Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_3.pdf) Continuing Education Overview (https://www.health.state.mn.us/people/wic/localagency/training/contedassess.html) WIC Nutrition Continuing Education Resources (https://www.health.state.mn.us/people/wic/localagency/training/conted.html) Civil Rights Training (https://www.health.state.mn.us/people/wic/localagency/civilrights.html) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(4.6)Minnesota WIC Operations Manual (MOM) Section 4.6: CPA Monitoring and Oversight#

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Section 4.6: CPA Monitoring and Oversight 5/2023 References: 7 CFR 246.19 (b)(6); 246.6 (b) (2); FNS/USDA WIC Nutrition Service Standards: Standard 1 (Sec. C, D, & F); Standard 3 (Sec. A & B); Standard 8 (Sec. A & B); Standard 10 (Sec. A & B); and Standard 13 (Sec. B, C & D). Policy: The local agency must have a plan for supervising and monitoring CPA staff that assures CPAs are performing WIC functions according to MN WIC policies and procedures, and in compliance with federal WIC regulations. Purpose: To ensure that the Local Agency is in compliance with WIC federal requirements and that quality nutrition services are provided to WIC participants. Definitions Reviewer: The person responsible for monitoring and evaluation of CPA staff. The reviewer should be someone with expertise in nutrition and extensive knowledge of WIC requirements and procedures. In most local agencies the reviewer will be the WIC Coordinator or Nutrition Education Coordinator. However, if more appropriate because of knowledge and skills, a CPA may be delegated this responsibility. In such a case, the designated CPA should meet the qualifications of a high-risk CPA (see Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities or Chapter 6: Nutrition Education for high-risk CPA qualifications). Procedures Monitoring Each local agency must monitor and evaluate CPA staff and maintain documentation of the monitoring. Monitoring Plan ▪ An agency must indicate in their Nutrition Education Plan how they will implement and document CPA staff monitoring. An agency may follow the state-developed Exhibit 4-G: Staff Monitoring Plan or follow agency-specific monitoring protocols/procedures as indicated in their Nutrition Education Plan.

S E C T I O N 4 . 6 : C P A P E R F O R M A N C E E V A L U A T I O N 2 ▪ If a local agency develops a plan, it should be customized to fit its specific staffing situation. Monitoring and evaluation should be based on the qualifications and activities of each CPA and meet the minimum requirements as indicated in Exhibit 4-G: Staff Monitoring Plan. Monitoring Frequency ▪ The Staff Monitoring Plan (Exhibit 4-G) uses a graduated schedule of monitoring. In this plan, monitoring is more frequent and intensive during the initial months of employee training. This allows the reviewer to assess an employee’s performance and progress toward attaining the necessary skills and provide constructive feedback. As an employee demonstrates mastery of CPA competencies, the frequency and intensity of monitoring can be decreased. The schedule of monitoring should be customized and adjusted for each employee as needed. ▪ Monitoring plans developed by the local agency should also utilize a graduated schedule of supervision and include the following: ▪ After attaining CPA competencies, an evaluation of CPA proficiency must be done annually at a minimum. ▪ CPAs qualified under the classifications Paraprofessional CPAs or LPNs-Prior Approval (hired before January 1, 2001) have additional, more intensive supervision requirements. See Exhibit 4-G: Staff Monitoring Plan for the minimum supervision requirements for these classifications. Monitoring Activities ▪ Exhibit 4-G: Staff Monitoring Plan includes a variety of activities that provide opportunities for evaluating all CPA functions. These functions include certification, additional education contacts, and high-risk contacts. Local agency developed monitoring plans must include a variety of activities and opportunities for evaluating all CPA functions. A monitoring plan should include the following activities: ▪ Observation of certifications and other clinic activities. The reviewer should be present for the entire certification process to observe all data collection, assessment, counseling and education, referrals, food package assignment, and documentation completed by the CPA. The Exhibit 4-H: Checklist for Certification Observation or a similar form may be used. ▪ Chart reviews. A chart review is an examination of a participant chart and includes documentation of areas reviewed. Areas that should be reviewed are outlined in Exhibit 4-J: Local Agency Chart Review Form. This form or a similar form may be used. See guidance below. Oversight Each local agency must provide oversight of CPA staff via on-site supervision.

S E C T I O N 4 . 6 : C P A P E R F O R M A N C E E V A L U A T I O N 3 On-site supervision On-site supervision means the reviewer is available to observe certification counseling activities, provide guidance, and answer questions. When providing in-person services, the reviewer is present in the counseling area and when staff are working remotely, the reviewer is available at all times for consultation with the CPA. In the initial phases of training, in-person supervision is encouraged with both the reviewer and CPA present. Continuous on-site supervision ▪ CPA staff must have continuous supervision until they demonstrate competencies for all phases of New Staff Training. ▪ Paraprofessional CPAs must be supervised at all times and may not work alone. See Section 4.3: Competent Professional Authority (CPA) Qulifications and Responsibilities for CPA Requirements. Procedures ▪ The reviewer conducting on-site supervision must be physically present in the counseling area when staff are working in-person. The reviewer may be involved in other work but should be aware of the general counseling environment and observe counseling interactions. ▪ The reviewer conducting on-site supervision when staff are working remotely must be available at all times for consultation with the CPA and be able to observe counseling interactions via audio or video. ▪ The reviewer should also be available to the CPA for consultation on any questions that arise during certifications or other clinic activities. ▪ As needed, the reviewer should discuss activities observed during “on-site supervision” to support or coach the CPA for improved performance. ▪ Ideally, the reviewer should provide all on-site supervision. If the reviewer is not available, another CPA may provide the supervision. However, Paraprofessional CPAs and LPNs may not provide on-site supervision. ▪ Follow-up: This is a system for providing feedback to the CPA. The reviewer should discuss with the employee their strengths and areas for skill development identified during monitoring activities. Ideally, this follow-up occurs shortly after the information is gathered. Suggested procedures for follow-up include: ▪ Discuss observations made during on-site supervision, chart review, and/or certification. The reviewer should identify the CPA’s strengths, as well as any needed changes in performance. ▪ Develop a workplan identifying skills to be developed and specifying timeframes. ▪ Check progress on the workplan as appropriate.

S E C T I O N 4 . 6 : C P A P E R F O R M A N C E E V A L U A T I O N 4 Documentation Each local agency must maintain documentation of the monitoring and evaluation of local agency CPA staff. Guidance ▪ Peer review may be used for conducting the CPA monitoring. This may be particularly helpful in small agencies. ▪ A registered dietitian who is contracted by the agency may complete the monitoring activities. The registered dietitian should be familiar with WIC policy and procedures. ▪ Information System reports may be used for identifying specific areas to monitor. ▪ For chart reviews, reviewers are encouraged to evaluate records for participants with additional documentation requirements (for example: high risk participants, participants on medical formula, new participants). ▪ Additional monitoring for quality is encouraged. Exhibit 4-M: Rubric for Assessment and Counseling Skills or a similar tool may be used to guide CPA staff in developing and advancing assessment and counseling skills. ▪ Peer Breastfeeding support supervision requirements can be found in Section 4.8: Breastfeeding Peer Support. Reference – Complete Listing of Hyperlinks Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_3.pdf) Chapter 6: Nutrition Education (https://www.health.state.mn.us/people/wic/localagency/mom.html#education) Exhibit 4-G: Staff Monitoring Plan (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4g. pdf) Exhibit 4-H: Checklist for Certification Observations (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4h. pdf) Exhibit 4-J: Local Agency Chart Review Form (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4j. pdf) Section 4.8: Breastfeeding Peer Support (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_8.pdf)

S E C T I O N 4 . 6 : C P A P E R F O R M A N C E E V A L U A T I O N 5 Exhibit 4-M: Rubric for Assessment and Counseling Skills (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4m .pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164- 0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942. This institution is an equal opportunity provider.

(4.7)Minnesota WIC Operations Manual (MOM) Section 4.7: Designated Breastfeeding Expert#

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Section 4.7: Designated Breastfeeding Expert MAY 2023 References: 7 CFR 246.11; USDA WIC Nutrition Services Standards; USDA Breastfeeding Policy and Guidance Policy: The WIC Designated Breastfeeding Expert (DBE) is an individual with special training and experience who assists WIC participants with complex lactation problems that are outside the scope of practice of peer counselors and other WIC staff. The DBE operates within the policies and procedures of the WIC program and within the context of WIC’s role for breastfeeding support. Each WIC Grantee shall identify a minimum of one Designated Breastfeeding Expert. Local agencies (LA) may have additional DBEs as needed. The local agency Breastfeeding Coordinator may also serve as the DBE if they meet the qualifications of the DBE. If the breastfeeding coordinator and DBE are not the same person, then these staff members should work closely together to coordinate lactation efforts in the clinic. WIC Grantees that are unable to meet the staffing standards must develop and submit a plan in writing to the state Breastfeeding Coordinator for referring participants with complex lactation concerns. The plan should include justification regarding the inability to meet the staffing standard, and identify at least one organization that will receive referrals from WIC and a process for how referrals will be made. Purpose: To support lactating families throughout the continuum of prenatal and postpartum services and to ensure families feel supported in their feeding decisions. Procedures Qualifications The WIC Grantee ensures that the WIC-Designated Breastfeeding Expert has all the following qualifications: ▪ Successful completion of the WIC Breastfeeding Curriculum (levels 1-4). ▪ More information on the WIC Breastfeeding curriculum is available: ▪ WIC Breastfeeding Curriculum ▪ WIC Breastfeeding Curriculum- Topic of the month ▪ Minimum of one year of experience in counseling lactating parent/infant dyads.

S E C T I O N 4 . 7 : D E S I G N A T E D B R E A S T F E E D I N G E X P E R T 2 ▪ Meets the education requirements: ▪ Is an International Board-Certified Lactation Consultant (IBCLC), or ▪ Professional with a nutrition degree (Master’s or Bachelor's degree in Nutritional Sciences, Community Nutrition, Clinical Nutrition, Dietetics, Public Health Nutrition or Home Economics with emphasis in Nutrition), or ▪ Licensed or Registered Dietitian, or ▪ Registered Nurse, or ▪ Physician’s Assistant certified by the National Committee on Certification of Physician’s Assistants, or ▪ Has completed a minimum of 8 college courses from an Accredited Institution in the Health Sciences (suggested coursework includes, but is not limited to, the following areas: Human Anatomy, Human Physiology, Biology, Infant Growth and Development, Nutrition, Counseling Skills, Sociology, Introduction to Clinical Research, etc.). Responsibilities of the Designated Breastfeeding Expert include: ▪ Provides expertise and care for more complex lactation problems when WIC staff face situations outside of their scope of practice. ▪ Provides follow-up lactation support to participants. ▪ Acts as a referral source for other WIC staff providing evidence-based information and clinical skills. ▪ Assesses and counsels parents and infants with complex lactation situations and contributes towards the development of a care plan. ▪ Communicates care plan to the WIC breastfeeding team, as appropriate. ▪ Documents contacts in the WIC Information System. ▪ Makes referrals to appropriate providers (e.g., physician, IBCLC, pediatrician) when encountering situations outside the DBE’s scope of practice, for further assessment and medical care, and/or to support continuity of care. ▪ May serve as a lactation resource and mentor for WIC agency staff. ▪ May provide lactation training for WIC staff. ▪ May promote lactation within the community. ▪ Maintains lactation credentials and certifications, if applicable, and acquires ongoing continuing education, including opportunities to shadow an IBCLC, as appropriate, to stay abreast of current lactation profession information and enhance skills. ▪ Attends state meetings/trainings and share information with staff. ▪ Consults with and seeks advice from state staff as needed.

S E C T I O N 4 . 7 : D E S I G N A T E D B R E A S T F E E D I N G E X P E R T 3 ▪ A sample job description for the Designated Breastfeeding expert is found in Exhibit 4-B: Sample Job Description for the WIC Designated Breastfeeding Expert. Guidance ▪ All local agencies would benefit from identifying community resources for complex lactation concerns and developing relationships and referral processes with these providers. Reference – Complete Listing of Hyperlinks USDA WIC Nutrition Services Standards (https://wicworks.fns.usda.gov/sites/default/files/media/document/WIC_Nutrition_Services_St andards.pdf) USDA Breastfeeding Policy and Guidance (https://wicworks.fns.usda.gov/sites/default/files/media/document/WIC-Breastfeeding-Policy- and-Guidance_1.pdf) WIC Breastfeeding Curriculum (https://wicworks.fns.usda.gov/resources/wic-breastfeeding- curriculum) WIC Breastfeeding Curriculum- Topic of the month (https://www.health.state.mn.us/docs/people/wic/localagency/topicmonth/bfcurriculum.pdf) Exhibit 4-B: Sample Job Description for the WIC Designated Breastfeeding Expert (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4b. pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(4.8)Minnesota WIC Operations Manual (MOM) Section 4.8: Breastfeeding Peer Program Management#

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Section 4.8: Breastfeeding Peer Program Management 1/2025 References: WIC Nutrition Services Standards; WIC Breastfeeding Policy and Guidance; WIC Breastfeeding Curriculum; WIC Breastfeeding Model Components for Peer Counseling Policy: Local agencies may initiate breastfeeding peer support programs to supplement existing WIC breastfeeding education and support. Purpose: To supplement the prenatal and postpartum breastfeeding support available to WIC participants, and to ensure that breastfeeding peer support staff are qualified, trained, supervised, and perform appropriate duties. Procedures Contacts provided by peer counselors must be in addition to the required nutrition education contacts (see Section 6.2: General Nutrition Education). Peer Coordinator(s) - The local agency must designate staff to manage their peer support program. ▪ Responsibilities may be split between two or more staff if all roles are assigned and clearly defined. At least one staff person must be an IBCLC (on staff or by contract). The agency may request to fulfill the requirement for an IBCLC with a person who has been certified as an IBCLC (and can provide documentation of their previous IBCLC status) and is continuing to meet the continuing education requirements set forth by IBLCE from the date of their IBCLC certification to the present, but who has elected not to retake the IBCLC certification exam. Documentation of continuing education must be submitted with the annual end-of- year report, required of the local peer program. ▪ Responsibilities include, but are not limited to: ▪ Policy development ▪ Hiring peer counselors ▪ Initial and ongoing training for peer counselors ▪ Supervision, including:

S E C T I O N 4 . 8 : B R E A S T F E E D I N G P E E R P R O G R A M M A N A G E M E N T 2 ▪ Monthly spot checks for each peer counselor during the first year of employment, quarterly spot checks thereafter. If a supervisor determines a peer counselor needs additional coaching, the number of spot checks should be increased to facilitate coaching. ▪ Reviewing peer contact logs at least monthly (ideally bi-weekly). ▪ At least weekly contact and monthly individual meetings with peer counselors. ▪ Periodic meetings with all peer counselors. ▪ Integrating WIC peer support activities into WIC operations (e.g., involvement in staff meetings; explanation of peer support to all WIC staff; identifying how WIC staff will refer participants to a peer counselor.) ▪ Providing back-up for peer counselors who encounter situations beyond their scope, both during and after normal clinic hours, and developing a plan for backup if a WIC peer coordinator, supervisor, or other designated WIC staff person is not available. ▪ Maintaining electronic and paper records of all required peer / peer program documentation, see below for additional details. ▪ Overseeing peer program data collection in the WIC information data system as outlined in the latest version of the Breastfeeding Peer Program Data Collection Guidance and Definitions available from the State WIC Peer Coordinator. ▪ Completing and submitting to the State Office an annual budget, progress report, and work plan as specified by the State Office timeline. ▪ Peer coordinators must be trained using the WIC Breastfeeding Curriculum Staff Roles: Peer Counselor Management dashboard. ▪ Peer coordinators and all other staff providing back-up must have at least annual continuing education in breastfeeding management. Required Peer Program Documentation and Record Retention Records to demonstrate that peer program implementation is consistent with the peer program requirements must be maintained in the WIC office. This documentation should include: ▪ Signed confidentiality statements ▪ Records of spots checks ▪ Training records ▪ Peer logs ▪ Other records to support activities of the peer program The above documentation should follow the current WIC record retention policy according to Section 1.14: Record Retention.

S E C T I O N 4 . 8 : B R E A S T F E E D I N G P E E R P R O G R A M M A N A G E M E N T 3 WIC Peer Counselors Peer counselors funded with WIC peer support funds must meet the minimum WIC definition of a peer counselor: ▪ Paraprofessional: those without extended professional training in health, nutrition, or the clinical management of breastfeeding who are selected from the group to be served and are trained and given ongoing supervision to provide a basic service or function. Paraprofessionals provide specific tasks within a defined scope of practice. They assist professionals, but are not licensed or credentialed as healthcare, nutrition, or lactation consultant professionals. ▪ Recruited and hired from WIC's target population, and, to the extent possible, representing the same racial/ethnic background as the parents they support ▪ Available to WIC participants outside usual clinic hours and outside the WIC clinic environment. ▪ Previous experience with breastfeeding, having breastfed at least one baby. ▪ A sample job description for peer counselors is found at Exhibit 4-C: Peer Breastfeeding Support Program Sample Descriptions. Work parameters ▪ Peer support staff must receive compensation for their work and reimbursement for mileage and communication device charges, if applicable. ▪ Peers hired in dual-role positions (e.g. peer and WIC clerk) must meet the definition of a peer counselor in the current WIC Breastfeeding Model Components for Peer Counseling. Peer funds used for the portion of time spent as a peer counselor may not be used for non- peer duties. ▪ Peers may not function as WIC certifiers/CPAs. ▪ Peers who take on additional administrative and/or training responsibilities may be designated Senior Peer Counselors and should be compensated accordingly. See Exhibit 4-C: Peer Breastfeeding Support Program Sample Descriptions. Training New peer counselors must receive the following training as outlined in the Required Training by Job Classification and WIC Clinic Roles: ▪ Level 1 and 2 of the WIC Breastfeeding Curriculum ▪ Appropriate scope of practice and provided written information on situations that must be referred or “yielded” to their supervisor and/or participant’s medical provider (see Exhibit 4-E: Guidelines for Breastfeeding Peer Counselors to Yield to a Lactation Expert or Health Care Provider).

S E C T I O N 4 . 8 : B R E A S T F E E D I N G P E E R P R O G R A M M A N A G E M E N T 4 ▪ Confidentiality and sign a confidentiality agreement (see Exhibit 4-D: Breastfeeding Peer Support Confidentiality Checklist and Agreement). ▪ The confidentiality statement must be reviewed with, and signed by, each peer annually. ▪ Staff who work from home must be provided a locking file box for securing their records. When transported in a car, the locking file box must be kept in a locked trunk. ▪ Peer staff must be trained to assure that confidential information is neither seen nor overheard by family members or guests. Required annual trainings are outlined in WIC Annual Required Trainings. Peer Counselor documentation requirements Peer counselors must document all contacts (and attempted contacts) with WIC participants. Documentation must include: ▪ Participants’ names (parent and infant) ▪ Date of the contact or attempted contact ▪ Participant’s questions, concerns, or comments ▪ Topics discussed ▪ Referrals ▪ Plan for follow-up ▪ Peer contact time (e.g. weekly activity report) ▪ When a participant is no longer receiving peer services, the peer must give all documentation related to peer services for that client to their supervisor for filing in the WIC office. Other WIC staff ▪ The local agency must have an adequate number of trained IBCLCs or designated breastfeeding experts (see Section 4.7: Designated Breastfeeding Expert) to handle questions and issues beyond the scope of the peer counselors. Most peer programs will need back up staff beyond the required peer coordinator. ▪ All WIC staff should be trained on the role of peer staff and how to refer to peer staff, and have the opportunity to meet the staff.

S E C T I O N 4 . 8 : B R E A S T F E E D I N G P E E R P R O G R A M M A N A G E M E N T 5 Peer program funding An overview of peer funding can be found in Module 5: Peer Program Funding and Reimbursement of WIC Financial Training Modules. Claims for reimbursement Local agencies receiving designated peer counseling funds through the Minnesota WIC Program must follow specified procedures, using the appropriate claim form, to request reimbursement for activities related to the peer support program. Contact the state WIC office for the claim form for the current fiscal year. Allowable costs ▪ Allowable Costs for Breastfeeding Peer Counseling Programs chart is updated annually. Key considerations in claiming peer program allowable costs include: All, or a portion of, a WIC staff person’s salary may be billed to the peer support funds for time spent on activities directly related to the peer support program. ▪ The local agency must maintain records to document all expenses, including staff time, billed to WIC peer support funds. ▪ Time and other expenses that are billed to peer support funds must not be claimed on the local agency’s monthly WIC claim for reimbursement. ▪ Expenses charged to the peer grant cannot exceed the amount of the grant award. Peer- related expenses in excess of the peer grant amount, may be claimed on your monthly WIC claim for reimbursement. Subcontracted community partnerships If your agency plans to work with a non-WIC organization to provide WIC peer support services, you must first discuss this with the State WIC Peer Coordinator to develop a memorandum of understanding (MOU). ▪ A WIC staff person, designated as the peer program manager or peer program coordinator, must be, and must remain, actively involved with the peer program. ▪ If the plan is approved, and if WIC peer funds will be used to train paid staff from another entity/program as peer counselors for WIC, an MOU must be established with the other entity ensuring: ▪ That the peer counselors will operate under the same parameters as required for WIC peer breastfeeding support programs. ▪ Compliance with WIC requirements and Minnesota WIC peer policy and peer grant agreement.

S E C T I O N 4 . 8 : B R E A S T F E E D I N G P E E R P R O G R A M M A N A G E M E N T 6 Guidance Considerations when hiring Peer Counselors ▪ In addition to the required qualifications of a peer counselor, research has shown that peer counselors may be more effective when they: ▪ Have enthusiasm for breastfeeding ▪ Possess good basic communication skills ▪ Have previous breastfeeding experience (ideally > 6 months) ▪ Are similar to WIC participants they will serve (i.e., in ethnicity, age, and language spoken) ▪ Are currently, or have been, a WIC participant ▪ Basic computer proficiency and current communication technology ▪ In cases when a peer with specific language or cultural skills is needed and you are unable to identify a peer who meets all of the background requirements contact the State WIC breastfeeding peer coordinator. ▪ Peer counselors should have access to reliable transportation to and from the WIC clinic for required meetings. ▪ Peer counselors should be provided with a cell phone or cell phone stipend and a laptop computer. ▪ Peer counselors should understand work expectations (e.g. training, documentation and confidentiality requirements, contact with direct supervisor, attendance at required peer meetings, etc.). Sample job descriptions are found in Exhibit 4-C: Peer Breastfeeding Support Program Sample Job Descriptions. Work parameters ▪ Peer counselors make contacts primarily via phone, text, and/ or email. Peer contacts can include face-to face contacts in the WIC clinic. ▪ Peer counselors may make home and hospital visits as approved by their peer coordinator. ▪ WIC peer counselors may bring their nursing infants to work with them if permitted by agency policy.

S E C T I O N 4 . 8 : B R E A S T F E E D I N G P E E R P R O G R A M M A N A G E M E N T 7 Peer contact frequency ▪ More frequent contacts with pregnant and breastfeeding women increases the effectiveness of peer support. WIC recommends the following contact schedule as most effective: ▪ Pregnant women: ▪ Monthly ▪ More frequently as due date nears. ▪ Early weeks postpartum: ▪ Within 24 hours if there are problems ▪ Every 2 – 3 days during the first week ▪ Weekly the rest of the first month ▪ After the first month: ▪ The peer counselor and the WIC participant can determine the contact schedule. (The peer coordinator can provide guidance in frequency of contacts.) ▪ WIC recommends monthly contacts during the first year, and 1-2 weeks before the participant returns to work or school, and 1-2 days after the return to work or school. Compensation and reimbursement of peer counselors ▪ Many WIC programs offer peer counselor salaries similar to a clerk or community health worker. ▪ Other recommendations: ▪ Provide mileage reimbursement for home/hospital visits and outreach events. ▪ Cover training and continuing education expenses. ▪ Provide benefits if possible. Peer coordinator ▪ A sample job description for WIC staff that manage the peer support program is found as Exhibit 4-C: Peer Breastfeeding Support Program Sample Job Descriptions. ▪ If responsibilities are split between two or more staff, the roles for each must be clearly defined and include all required responsibilities.

S E C T I O N 4 . 8 : B R E A S T F E E D I N G P E E R P R O G R A M M A N A G E M E N T 8 WIC IBCLC ▪ The IBCLC may be a WIC employee or a contracted employee. Contact the State WIC Peer Coordinator for a sample contractor MOU. ▪ Contact the State WIC Peer Coordinator for additional information on training your WIC staff to become IBCLCs or on finding an IBCLC in the community. Training ▪ Peer counselors should receive orientation to WIC so that they are familiar with services being received by participants. ▪ Provide opportunities for peer counselors to “shadow” or observe other peer counselors, lactation experts, and WIC staff who are trained in breastfeeding support. ▪ The WIC Breastfeeding Curriculum has guidance for career path options for peer support staff (e.g., training/experience to become senior level peer counselors; training to become IBCLC). ▪ If peer staff attend conferences or workshops on breastfeeding, the contents of the workshop in relationship to peer’s scope of practice should be discussed after the workshop. Community collaborations Community partnerships enhance the effectiveness of a WIC peer support program. ▪ Designate a WIC staff person to establish and maintain communication with other organizations that work with pregnant and breastfeeding woman and inform them of the WIC peer support. These might include: breastfeeding coalitions; businesses and community organizations; cooperative extension program; lactation consultants; La Leche League; home visiting programs; private clinics; hospitals; and others. Reference – Complete Listing of Hyperlinks WIC Nutrition Services Standards (https://wicworks.fns.usda.gov/sites/default/files/media/document/wic-nutrition-services- standards_0.pdf) WIC Breastfeeding Policy and Guidance (https://wicworks.fns.usda.gov/resources/wic- breastfeeding-policy-and-guidance) WIC Breastfeeding Model Components for Peer Counseling (https://wicworks.fns.usda.gov/sites/default/files/media/document/WIC_Breastfeeding_Model .pdf) Section 6.2: General Nutrition Education (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_2.pdf)

S E C T I O N 4 . 8 : B R E A S T F E E D I N G P E E R P R O G R A M M A N A G E M E N T 9 Section 1.14: Record Retention (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_14.pdf) Exhibit 4-C: Peer Breastfeeding Support Program Sample Job Descriptions (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4c. pdf) Required Training by Job Classification and WIC Clinic Roles (https://www.health.state.mn.us/docs/people/wic/localagency/training/nutrition/nst/required .pdf) Exhibit 4-E: Guidelines for Breastfeeding Peer Counselors to Yield to a Lactation Expert or Health Care Provider (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4e. pdf) Exhibit 4-D: Breastfeeding Peer Support Confidentiality Checklist and Agreement (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4d. pdf) WIC Annual Required Trainings (https://www.health.state.mn.us/people/wic/localagency/training/annual.html) Section 4.7: Designated Breastfeeding Expert (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_7.pdf) WIC Financial Training Modules (https://www.health.state.mn.us/people/wic/localagency/training/finance.html) Allowable Costs for Breastfeeding Peer Counseling Programs (https://www.health.state.mn.us/docs/people/wic/localagency/program/finance/peerallowabl e.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.2)Minnesota WIC Operations Manual (MOM) Section 5.2: Certification Procedures#

(5.2)(document-1)#

Section 5.2: Certification Procedures Certification Procedures 5/2023 References: 7CFR 246.7, 246.12 Policy: Staff must follow prescribed procedures during the certification process. Purpose: To accurately assess and enroll all eligible applicants for WIC services. Procedures 1. Maintain Separation of Duties in the certification process.  One employee cannot determine both income eligibility and medical/nutrition risk in the certification process for the same participant. See Section 1.18: Separation of Duties to Assure Program Integrity.  WIC staff shall not complete any part of the certification or issue food benefits to oneself, one’s children or grandchildren, relatives or close friends. See Section 1.19: Avoid Conflict of Interest to Assure Program Integrity. 2. At the certification appointment, the CPA must assess the applicant’s eligibility in each of the following areas:  Category (Woman, Infant, Child)  Minnesota residency  Identity  Income  Health and nutritional risk 3. When the applicant is determined to meet the category, residency, identity and income requirements at certification, the CPA must:  Obtain anthropometric measurements and bloodwork as required.  Provide a health and nutrition assessment.  Provide nutrition education appropriate to the participant’s nutritional need and interests.

S E C T I O N 5 . 2 C E R T I F I C A T I O N P R O C E D U R E S 2  Discuss available food choices with the participant/parent/guardian (PPG) and determine an appropriate food prescription based on nutrition needs and preferences.  Provide referrals as appropriate.  Sign the signature pad as confirmation that the participant was determined eligible. 4. The CPA or other appropriate staff must:  Review the Rights & Responsibilities with the participant and obtain a signature from the participant to acknowledge agreement. See Guidance for signature options.  Issue food benefits as designated by the CPA.  Explain the food benefits and how to shop for WIC foods (see Section 7.2: Allowed WIC Foods).  Assure that participants have the following information, which may be provided as written materials or by demonstrating how to access them through electronic means, such as with the WIC app:  Welcome to WIC Handbook (Exhibit 5-FF)  WIC Shopping Guide  List of WIC approved vendors in their area. Refer to the WIC Grocery Stores search function to identify vendors  How to use the MN WIC app 5. A proxy may stand in for the participant/parent/guardian (PPG) at a certification, if the PPG is not able to be present.  By designating the proxy to represent them and sending the proxy to the WIC clinic in his/her place, the PPG has given implied consent for WIC staff to share information with the proxy as appropriate for the type of appointment or interaction being conducted.  The PPG may designate up to two proxies to represent them at the WIC clinic.  The proxy must be a competent person, at least 16 years old.  See Section 8.3: Issuing WIC Cards for information about proxies and the WIC Card. 6. All information about the participant is private data. A signed release from the participant, or a court order, is required to release information to anyone other than the parent/ participant/guardian. See Section 1.7: Data Privacy for more information. Guidance One document can be used as proof for multiple areas of eligibility including identity, residency, and income. For example, a current pay stub or Phone/Online Medical Assistance verification could potentially serve as proof of identity, income, and residency if it includes all those areas and is up-to-date.

S E C T I O N 5 . 2 C E R T I F I C A T I O N P R O C E D U R E S 3 If staff are unable to collect a participant signature at the certification on the signature pad, use one of the following options to obtain the signature. Scan the form into the Information System:  Obtain an electronic signature using the Participant Signature Form or by another electronic signature platform such as DocuSign.  Use the Exhibit 5-B: Registers for Manual Signatures. Manual Certification Forms Manual Certification forms can be used to record information required to complete a certification when the Information System is unavailable, for example during a power failure or internet outage. Manual Certification forms include:  Exhibit 5-II1 Manual Certification – Infants and Children  Exhibit 5-II2 Manual Certification - Women  Exhibit 5-II3 Manual Certification – Proof of Eligibility Completed forms include private data and must be secured. Once Information System access is restored, enter the certification information as soon as possible so the participant can access their benefits. Manual Certification forms need to be immediately disposed of in a confidential manner.  Refer to Section 1.17: Emergency Actions for considerations during an emergency, such as a prolonged power outage. Reference – Complete Listing of Hyperlinks Section 1.18: Separation of Duties to Assure Program Integrity (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_18.pdf) Section 1.19: Avoid Conflict of Interested to Assure Program Integrity (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_19.pdf) Rights & Responsibilities (https://www.health.state.mn.us/people/wic/rights.html) Section 7.2: Allowed WIC Foods (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_2.pdf) Exhibit 5-FF (https://www.health.state.mn.us/docs/people/wic/ewic/welcometowic.pdf) WIC Shopping Guide (http://www.health.state.mn.us/docs/people/wic/vendor/fpchng/shopguide.pdf) WIC Grocery Stores (https://www.health.state.mn.us/forms/cfh/wicstores/)

S E C T I O N 5 . 2 C E R T I F I C A T I O N P R O C E D U R E S 4 Section 8.3: Issuing WIC Cards (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch8/sct n8_3.pdf) Section 1.7: Data Privacy (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_7.pdf) Participant Signature Form (https://redcap.health.state.mn.us/redcap/surveys/?s=TDCP4PEJPT) 5-B Registers for Manual Signatures (WORD) (www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5b.docx) Exhibit 5-II1 Manual Certification – Infants and Children (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5ii1 .pdf) Exhibit 5-II2 Manual Certification - Women (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5ii2 .pdf) Exhibit 5-II3 Manual Certification – Proof of Eligibility (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5ii3 .pdf) Section 1.17: Emergency Actions (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_17.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164- 0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942. This institution is an equal opportunity provider.

(5.2.1)Minnesota WIC Operations Manual (MOM) Section 5.2.1: Categories#

(5.2.1)(document-1)#

Section 5.2: Certification Procedures 4/2020 5.2.1 Category References: 7CFR 246.7 (c) Policy: Each applicant must be in a category that is eligible for WIC participation. Eligible categories are: pregnant women, postpartum women, postpartum breastfeeding women, children less than age five, and infants. Purpose: To ensure that applicants are eligible for the WIC program. Procedures Determine if the applicant is one of the following:  A pregnant woman determined to have one or more embryos or fetuses in utero (proof of pregnancy is not required)  A post-partum woman within 12 months of the end of a pregnancy who is breastfeeding or providing breast milk to her infant an average of once per day or more  A postpartum non-breastfeeding woman within six months of termination of a pregnancy. The end of a pregnancy is the date the pregnancy terminates (i.e., date of delivery, abortion, fetal death or miscarriage).  An infant under one year of age ▪ A child who has had her/his first birthday but has not yet reached her/his fifth birthday Certification Periods Services are to be provided to participants throughout their certification period as long as they remain income eligible, unless the participant chooses not to continue, or in cases of participant abuse/fraud. ▪ Pregnant Women are categorically eligible through the duration of their pregnancy and up to six (6) weeks postpartum. Following delivery, women may receive one food package before being certified as a postpartum woman. To continue beyond the 6-week postpartum period, the woman must be certified as either a breastfeeding or non- breastfeeding woman. ▪ Breastfeeding women are categorically eligible for up to one year, ending with the last day of the month in which her breastfed infant turns one. A postpartum woman who provides

5 . 2 . 1 : C A T E G O R Y 2 breast milk to her infant at least once a day (on average), is considered a “breastfeeding woman.” A mid-certification is required. See Section 5.10: Mid-Certification. ▪ Breastfeeding women are either fully breastfeeding (her infant is fully breastfed, and receives no formula) or partially breastfeeding (her infant is breastfed and receives some formula; the woman is categorized as mostly- or some-breastfeeding depending on how much formula her infant receives from WIC). The certification periods are the same, but the WIC food package the woman is eligible to receive depends on how much she is breastfeeding, how much formula her infant is taking, and her infant’s age. See Chapter 7: Food Package. ▪ Some-Breastfeeding after six months postpartum: women who continue to provide breastmilk at least daily after six months postpartum remain active participants, and can continue receiving nutrition services (including nutrition education and a mid-certification), but they are no longer eligible to receive WIC food benefits. See Section 7.12. The local agency is reimbursed for these services. ▪ If a breastfeeding woman becomes pregnant, she should be (re)certified as a pregnant woman, and is then eligible through the duration of the pregnancy and up to six (6) weeks postpartum. ▪ If a breastfeeding woman reduces her breastfeeding to less than once a day, the CPA must change her category in the participant record to a non-breastfeeding postpartum woman (see below). ▪ If her infant is less than 6 months old, she is categorically eligible to receive services as a non-breastfeeding postpartum woman until the last day of the month in which her infant turns 6 months old. Nutrition risk codes and priority are not changed at this time. ▪ If her infant is 6 months or older, she is given 15 days notification of pending ineligibility. If she is due to receive benefits within the 15 days, CPAs may issue a final month of food benefits. See Section 5.4: Notification of Ineligibility/Disqualification. ▪ Non-breastfeeding postpartum women are categorically eligible for up to 6 months from the end of the pregnancy. This includes a woman who had an abortion, a miscarriage, or a fetal death. ▪ Infants under 6 months of age are categorically eligible until the last day of the month in which they turn 1 year old. A mid-certification is required. See Section 5.10: Mid- Certification. ▪ Infants 6 months of age and over are categorically eligible for a six-month period. ▪ Children are categorically eligible at one year intervals, ending with the last day of the month in which the child reaches the 5th birthday. A mid-certification is required. See Section 5.10: Mid-Certification.

5 . 2 . 1 : C A T E G O R Y 3 Note: In situations where there is difficulty scheduling the appointment for a pregnant woman, postpartum breastfeeding woman, infant, and child, the certification period may be shortened or lengthened by a period not to exceed 30 days. Reference – Complete Listing of Hyperlinks Section 5.10: Midcertification (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_10.pdf) Chapter 7: Food Package (https://www.health.state.mn.us/people/wic/localagency/mom.html#foodpackage) Section 7.12: Food Package 6 Some-Breastfeeding and Nonbreastfeeding Postpartum Women (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_12.pdf) Section 5.4: Notification of Ineligibility/Disqualification (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_4.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.2.2)Minnesota WIC Operations Manual (MOM) Section 5.2.2: Residency#

(5.2.2)(document-1)#

Section 5.2 Certification Procedures 6/2024 5.2.2 Residency References: 7 CFR 246.7, Local Agency Grant Agreement Policy: An applicant must reside in Minnesota to be eligible to receive Minnesota WIC services. Applicants must provide proof of residency (including a physical address) at certification. ▪ Participants must reside in the state at the time of benefit issuance and during the time for which benefits are intended. ▪ Participants who are (or intend to be) out of the state, or out of the country, are not eligible to receive Minnesota WIC benefits until they return to Minnesota. ▪ Benefits may not be given to a proxy for the purpose of mailing food benefits to members of a family who are out of Minnesota. Purpose: To ensure that applicants are eligible to receive WIC benefits in Minnesota, and that eligible applicants are served at whatever local agency or clinic they choose. Procedures Assessing Residency Eligibility  At the certification, review documentation of residency (i.e., location or address where the applicant/participant routinely lives or spends the night). Either paper or electronic documentation (such as a proof viewed on the participant’s phone), is acceptable. Examples of acceptable proof of residency include: ▪ Bill, with the billing address included ▪ Driver’s license ▪ Immunization Record/Registry ▪ Mail addressed to applicant ▪ Pay stub (paper or electronic) ▪ Phone/Online system such as MA ▪ Rental or lease agreement, or rent receipt

S E C T I O N 5 . 2 . 2 : R E S I D E N C Y 2 ▪ Signed statement verifying residency from a landlord, employer, shelter worker, staff engaged in public or private social services, legal services, law enforcement, or health services. ▪ Safe at Home participation card (see information below)  Even if applicants are known to staff, they must still provide documentation of residency at the initial certification. “Known to Staff” may not be used for anyone at the initial certification. Staff should routinely ask, “Did you bring something with your name and address on it, such as a driver’s license or paystub?”  If the information is adequate, document the source in the WIC Information System.  For infants and children, proof of the parent or guardian’s residency may be used.  A post office box may not be used as the physical residence address except for participants enrolled in the Safe at Home program. A post office box may be used for the mailing address.  Safe at Home: Below are procedures for working with families enrolled in the Safe at Home program, a statewide Address Confidentiality Service administered by the Office of the Secretary of State for victims of abuse. ▪ Minnesota Statutes Chapter 5B and Minnesota Rules Chapter 8290 mandate that all public and private entities must accept a participant’s assigned Safe at Home address (PO Box) as their actual address of residence. ▪ Use the participant’s Safe at Home program participation card to verify enrollment in the program. ▪ Use the participant’s Safe at Home PO Box address for both the physical residence and mailing addresses. All Safe at Home participants have the same PO Box number, but each will have an individual “lot number” that goes with it. ▪ Write a brief note in the participant record explaining that the participant is enrolled in Safe at Home.  Proceed with certification. Temporary Eligibility – if documentation is not available If required documentation for residency is not available at the certification appointment, the CPA should complete the certification process and notify the participant that his/her eligibility is temporary, pending receipt of the required documentation within 30 days.  Finish the certification using “Pending Proof” in the drop-down menu for documentation of residency.  Issue only one month of food benefits.  Explain their options for providing documentation and give them a reminder to: ▪ Submit the pending proof electronically (email, text, etc.), or

S E C T I O N 5 . 2 . 2 : R E S I D E N C Y 3 ▪ Return the following month (or sooner) with the required documentation for additional benefits.  Review the pending documentation when received, and make a determination of eligibility. ▪ Enter the information (i.e., what documentation was provided) into the participant record. Delete/destroy any electronic documents received. ▪ Issue food benefits if appropriate, or ▪ Initiate ineligibility procedures if documentation is not provided or is not acceptable. See Section 5.4: Notification of Ineligibility/ Disqualification.  Under no circumstances may a second 30-day temporary eligibility period be allowed. Waiver - limited situations when a waiver may be used for lack of residency documentation In limited circumstances, staff may determine that the applicant is in a situation in which written documents are not available. Examples include: ▪ Fire ▪ Theft ▪ Disaster ▪ Migrant farmworker families (Individuals whose principal employment is in agriculture on a seasonal basis and who establish, for the purposes of such employment, a temporary abode.) ▪ Homeless individual or family ▪ Landlord who refuses to provide a written statement documenting residency 1. Complete the certification using “Waiver Signed” in the drop down menu for the documentation of residency. 2. Generate and complete the appropriate form from the Information system, obtain signature, and import/scan the document into the Information System for all applicable household members. 3. Assess the individual situation and issue the appropriate set(s) of benefits that best meets the needs of the applicant. Guidance  While most applicants/participants will request services from a local WIC provider in their county of residence, some may prefer to receive services from a WIC provider in another service area (e.g., the county in which they work).

S E C T I O N 5 . 2 . 2 : R E S I D E N C Y 4 ▪ For these requests, explore whether the participant is aware of services available in the area in which they reside or work, in case that option might work better for them. ▪ Assist participants to find a WIC agency/clinic that best meets their needs.  Personal knowledge of the participant’s residence by WIC staff at subsequent certifications may be allowed once initial proof of residency has been established.  If residency has been documented for one family member within the last 3 months, it can be used for other family members being certified within that 3-month period.  Staff should assist applicants by suggesting ways to meet the residency requirement, such as bringing in an envelope mailed to them at their current address.  One document can be used as proof for multiple areas of eligibility including identity, residency, and income. For example, a current pay stub or Phone/Online Medical Assistance verification could potentially serve as proof of identity, income and residency if it includes all those areas and is up-to-date.  Applicants do not need to be U.S. citizens to receive WIC services.  Contact your State Consultant with any questions or concerns regarding residency. Reference – Complete Listing of Hyperlinks Safe at Home (http://www.sos.state.mn.us/safe-at-home/) Minnesota Rules Chapter 8290 (https://www.revisor.mn.gov/rules/8290/) Section 5.4: Notification of Ineligibility/Disqualification (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_4.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.2.3)Minnesota WIC Operations Manual (MOM) Section 5.2.3: Identity#

(5.2.3)(document-1)#

Section 5.2: Certification Procedures 6/2024 5.2.3 Identity References: 7CFR 246.7 (c)(2)(i) Policy: Applicants must provide proof of identity at each certification. If the applicant is an infant or child, proof of identity for the parent, foster parent, or guardian is also required. Purpose: To establish the identity of the applicant. Procedures Certification with Proof of Identity: 1. Verify proof of identity for the applicant/participant. Paper or electronic documentation of identity, such as that displayed on a phone, is adequate. Examples of acceptable forms of proof of identity include: ▪ Baptismal certificate ▪ Birth certificate ▪ Driver’s license ▪ Health benefits (insurance) card ▪ Hospital crib card - for infant only ▪ Immunization record ▪ Passport ▪ Pay stub ▪ Phone/Online system such as MA ▪ Photo ID: Acceptable forms include, but are not limited to, photo ID issued by governments (including tribal governments and governments of other countries), employers, and schools. ▪ Social Security card ▪ Social services benefit card ▪ Valid Verification of Certification (VOC) - for infant or child only ▪ Voter Registration card Additional forms of participant identification acceptable at re-certifications, once initial proof of identification has been documented, include: ▪ Known to staff ▪ WIC Card 2. Document the source of identification verified in the participant record. 3. Proceed with the certification.

S E C T I O N 5 . 2 . 3 : I D E N T I T I Y 2 Identity of the Authorized Representative (e.g., parent/guardian) or proxy must be verified during an infant or child certification prior to issuing a WIC card and/or food benefits. See Guidance below. Refer to Exhibit 5-C: Identification Requirements by WIC Contact Type for acceptable forms of parent/guardian or proxy identification. Certification without Proof of Identity Temporary Eligibility – pending proof If documentation of the applicant/participant identity is not available at the certification appointment, the CPA should complete the certification process and notify the participant that their eligibility is temporary, pending receipt of the required documentation within 30 days. 1. Finish the certification; select “Pending Proof” in the Proof of Identification drop-down menu. 2. Issue only one month of food benefits. 3. Explain how the participant may provide the required documentation; remind them to: ▪ Submit the pending proof via secure electronic platform, or ▪ Return within a month with the required documentation for additional benefits. 4. Review the pending documentation when received and determine eligibility. 5. Enter the source of documentation provided into the participant record. Then delete/destroy any electronic documents received. 6. Issue food benefits if appropriate, or initiate ineligibility procedures if documentation will not be provided. See Section 5.4: Notification of Ineligibility/Disqualification. Under no circumstances may a second 30-day temporary eligibility period be allowed. Waiver – limited situations when a waiver may be used for lack of identification documentation ▪ In limited circumstances, staff may determine that the applicant is in a situation in which written documents are not available. Examples might include: ▪ Fire ▪ Theft ▪ Disaster ▪ Migrant farmworker families (Individuals whose principal employment is in agriculture on a seasonal basis and who establish, for the purposes of such employment, a temporary abode.) ▪ Homeless individual or family

S E C T I O N 5 . 2 . 3 : I D E N T I T I Y 3 ▪ Applicant whose spouse or partner refuses to provide identity documentation (such as a birth certificate for a child) 1. Complete the certification using “Waiver Signed” in the Proof of Identification drop-down menu. 2. Generate and complete the appropriate form from the Information system, obtain signature, and import/scan the document into the Information System for all applicable household members. 3. Assess the individual situation and issue the appropriate set(s) of food benefits that best meets the needs of the applicant. Guidance ▪ Verify the identity of the Authorized Representative (i.e., parent/guardian) or proxy at the beginning of the appointment to ensure their authorization to obtain WIC services on behalf of an infant or child. ▪ If the parent/guardian or proxy lacks proof of identification: ▪ For initial certification: Document pending proof of parent/guardian identification in an alert and/or note; then follow procedural steps 2-6 outlined in “Certification without Proof of Identity” for Temporary Eligibility – Pending Proof. ▪ For re-certification: Verify the identity verbally by following these steps: 1. Confirm the person’s identity by cross-referencing their name with that of an adult participant, authorized representative, or proxy listed in the participant record, and 2. Request validation of at least two of the following details: o The Primary Card Holder’s (PCH’s) date-of-birth, o The zip code of the household’s mailing address, and/or o The names of household members participating in WIC. ▪ Staff should assist applicants by suggesting ways to meet the identity requirement. ▪ For applicants known to staff, documentation of identity is still required at the initial certification. Staff should routinely ask, “Did you bring something with your name and address on it, such as a driver’s license or paystub?” ▪ Applicants do not need to be US citizens to receive WIC services and food benefits. ▪ One document can be used as proof for multiple areas of eligibility including identity, residency, and income. For example, a current pay stub or Phone/Online Medical Assistance verification could potentially serve as proof of identity, income, and residency if it includes all those areas and is up to date. ▪ Contact your State Consultant with any questions or concerns regarding identity. Reference – Complete Listing of Hyperlinks

S E C T I O N 5 . 2 . 3 : I D E N T I T I Y 4 Section 5.4: Notification of Ineligibility/Disqualification (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_4.pdf) Exhibit 5-C: Identification Requirements by WIC Contact Type (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5c. pdf) Minnesota Department of Health – WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.2.4)Minnesota WIC Operations Manual (MOM) Section 5.2.4: Income#

(5.2.4)(document-1)#

Section 5.2: Certification Procedures 6/2024 5.2.4 Income References: 7CFR 246.7 (d) Policy: Each applicant must provide proof of income eligibility for WIC, either through an automatic/adjunctive program or with documentation of household income at each certification. Purpose: To establish income eligibility of the applicant. Definition: Household For WIC purposes, “household” is defined as a group of related or non-related individuals who usually (although not necessarily) live together as an economic unit and who share income and the consumption of goods and services. Other examples: ▪ A pregnant woman should be counted as two or more, taking into account the number of unborn fetuses. ▪ Children with parent(s) on active military duty: children of a military family who are in temporary care can be certified in the following ways: ▪ Count the absent parent(s) and their children as the economic unit, as would have been the case prior to the parental deployment. ▪ Count the children as a separate economic unit from their parents and caretakers. To be considered a separate economic unit, the unit must have its own source of income. The CPA must decide whether the income is adequate to sustain the economic unit. If the child allotments are not considered adequate, then another certification option can be used. ▪ Consider the children to be part of the economic unit of the person(s) with whom they are residing. ▪ Split or joint custody: When the custody of the child is split, the child shall be considered a member of the household in which they live the majority of the time. If the parents share custody 50/50, the child can only qualify for WIC in one parent’s household. ▪ Parents can be encouraged to share the food and list the other parent as an alternate representative.

S E C T I O N 5 . 2 . 4 : I N C O M E 2 ▪ If custody papers are available, staff should consider custody arrangements when issuing food benefits. ▪ If an adult in the household is making child support payments for a child not living in this household and who is not receiving WIC food benefits in another household, this child may be counted as a member of the household. Child support payments do not reduce family income. ▪ A foster child, who is living with a family but remains the legal responsibility of a social service or other agency, should be considered a family of one. These children are usually eligible for Medicaid (MA). If siblings enter the same foster care home, the number of siblings can be considered the household size and one household ID number assigned to them. For certain situations where several individuals or families are living together, additional questions may be needed to determine whether the participant is in a separate household. Questions to Ask to Determine Separate Household Question Household Size Does the household provide free food, clothing, shelter, etc. with no expectation of payment or in-kind donation such as foods.* if Yes  applicant is not counted as a separate household – include in the household size if No  count as a separate household Does the applicant pay the household for living in their home? if Yes  count as a separate household if No  include in the household size Does the applicant exchange work, (e.g., household chores, babysitting) for the ability to live in the home? if Yes  count as a separate household Does the applicant share income and expenses with other people in the household? if Yes  include in the household size if No  count as a separate household Can the applicant provide current eligibility of Minnesota Health Care Programs, SNAP benefits, or MFIP? if Yes  count as a separate household *If a separate household, WIC foods may not be shared with another household as payment for or contribution towards household expenses.

S E C T I O N 5 . 2 . 4 : I N C O M E 3 Procedures Applicants are determined to be income eligible in one of these ways: ▪ Automatic/Adjunctive eligibility based on being currently enrolled in another specific program with comparable income guidelines or being a member of a household in which a family member is currently enrolled in an adjunctive/automatic program. ▪ Traditional Income Determination based on household size and income. Automatic/Adjunctive Eligibility If anyone in the household is currently certified eligible for an adjunctive or automatic eligibility program, members of the household are WIC-eligible. Adjunctive/automatic eligibility programs are: Eligibility at Household Level Medicaid/Medical Assistance (MA) Minnesota Care Minnesota Family Investment Program (MFIP) Supplemental Nutrition Assistance Program (SNAP, previously Food Stamps) Free/Reduced Price School Lunch Head Start Fuel Assistance Eligibility at Individual Level Supplemental Security Income (SSI) or Tax Equity Fiscal Responsibility Act (TEFRA)  Household/ family members of the SSI or TEFRA-eligible applicant are not adjunctively eligible for WIC. At certification ▪ Staff must verify current income eligibility using one of the following: ▪ Notice of Eligibility Letter from the adjunct program ▪ Other written documentation of eligibility from the appropriate agency ▪ On-line or telephone access to adjunct programs that verify current enrollment ▪ Direct contact with the appropriate agency ▪ Note: A Minnesota Health Services Card alone is not adequate unless staff have verified current enrollment in MA. ▪ Either paper or electronic documentation (such as proof viewed on the participant’s phone) is acceptable.

S E C T I O N 5 . 2 . 4 : I N C O M E 4 ▪ Self-reporting of income is not adequate. ▪ When current eligibility is determined, document this information in the participant record and proceed with the certification. Temporary Eligibility - Pending Proof If proof of adjunctive eligibility cannot be verified at the certification and screening determines the participant is adjunctively-income eligible, he/she is temporarily eligible for 30 days. ▪ Select the adjunctive program and the “Pending Proof” dropdown option in the Income screen to indicate this. ▪ Finish the certification and issue only one month of food benefits. ▪ Explain how the participant may provide that documentation and give a reminder to: ▪ Submit the pending proof electronically (email, text, etc.), or ▪ Return by the following month with the required documentation for additional benefits. ▪ Review the pending documentation when received and make a determination of eligibility. ▪ Enter the information (e.g., what documentation was provided) into the participant record. Then delete/destroy any electronic documents received. ▪ Issue food benefits if appropriate, or initiate ineligibility procedures if documentation will not be provided. See Section 5.4: Notification of Ineligibility/Disqualification ▪ Document Separation of Duties at both the initial certification and again when the participant provides proof of income. See Section 1.18: Separation of Duties to Assure Program Integrity ▪ Under no circumstances may a second 30-day temporary eligibility period be allowed. Traditional Income Determination If the applicant is not eligible under an adjunct program, determine household size and proceed with eligibility determination based on traditional income guidelines. Income Determination ▪ Income means gross cash income before deductions. If the applicant is self-employed or farms, use the Total Income line from the most recent federal income tax return to verify income. ▪ Local agencies are encouraged to define current income as all income received by the household during the 30 days prior to the date of the WIC application. However, there are situations where a household’s current income is more accurately determined by including income in the past 12 months or income anticipated in the next 30 days. Examples of these situations include, but are not limited to:

S E C T I O N 5 . 2 . 4 : I N C O M E 5 ▪ If the household has a recent decrease in income (e.g., the sole support of the family has just been laid off) WIC staff can use prospective income (current income that will be available to the household in the next 30 days). ▪ Annual income may be more appropriate to reflect a household’s financial circumstances for: ▪ Self-employed individuals, including farm income ▪ A household where a family member who is on maternity leave will return to her job ▪ Teachers who are on a temporary leave for the summer ▪ College students who work only during the summer months and school breaks ▪ Household member with frequent overtime pay ▪ Seasonally employed workers whose income fluctuates Income sources include but are not limited to the following ▪ Monetary compensation for services, such as wages, salary, commissions, or fees ▪ Net income from farm or self-employment (use the Total Income line on the most recent tax return) ▪ Social Security benefits ▪ Dividends or interest on savings or bonds, income from estates, or net rental income ▪ Public assistance or welfare payments ▪ Unemployment compensation ▪ Government civilian employee, or military retirement or pensions, or veteran’s payments ▪ Private pensions or annuities ▪ Alimony or child support payments ▪ Regular contributions from persons not living in the household ▪ Net royalties ▪ Other cash income. This includes, but is not limited to: ▪ Cash amounts received or withdrawn from any source, including savings ▪ Investments ▪ Insurance premiums/benefits ▪ Bonds ▪ Tribal per capita income from casino profits ▪ Trust accounts ▪ Other resources that are readily available to the family

S E C T I O N 5 . 2 . 4 : I N C O M E 6 ▪ Student financial assistance, such as grants and scholarships, except those from programs funded under Title IV of the Higher Education Act of 1965. See next section for those exclusions. Income does not include the following ▪ Student loans and grants funded by programs funded in whole or part under Title IV of the Higher Education Act of 1965 and used for tuition, student fees, the costs for rental or purchase of any required equipment, materials, supplies, books, transportation, and miscellaneous personal expenses for a student. The following is a list of these exclusions: ▪ Pell Grant ▪ Supplemental Educational Opportunity Grant ▪ State Student Incentive Grant (SEOG) ▪ PLUS ▪ College Work Study ▪ Byrd Honor Scholarships ▪ National Direct Student Loans ▪ Payments under the Carl D. Perkins Vocational Education Act as amended by the Carl D. Perkins Vocational and Applied Technology Act Amendments of 1990 ▪ Loans, either from a bank or from a personal resource (friend, church, etc.), since these funds are only temporarily available and must be repaid. ▪ Mandatory salary reduction amount for military service personnel to fund the Veteran’s Educational Assistance Act of 1984 (GI Bill) ▪ Military Pay (certain types of income as listed below) ▪ Basic allowance for housing (BAH) received by military services personnel residing off military installations or in privatized housing, whether on- or off-base. ▪ Cost-of-living allowance provided to a member of uniformed services who is on duty outside the contiguous states of the United States (OCONUS COLA). ▪ Payments made to members of the armed forces and their families for Family Subsistence Supplemental Allowance (FSSA), if the inclusion of this amount makes the family ineligible for WIC. ▪ Combat pay and hostile fire pay for household members who are on active military duty; detail may be found in the Entitlements column of the military Leave and Earning Statement (LES). ▪ Payments pursuant to Agent Orange Compensation Exclusion Act. ▪ Funds received from Filipino Veteran Equity Compensation Fund.

S E C T I O N 5 . 2 . 4 : I N C O M E 7 ▪ The value of in-kind housing or other in-kind benefits. An in-kind benefit is anything of value that is not provided in the form of cash. ▪ Loans, except amounts to which the applicant has constant or unlimited access. ▪ Any child care payments from the following programs: ▪ At-Risk Child Care Programs ▪ Child Care Development Block Grant ▪ Any Program under Section 402 of the Social Security Act ▪ The value of assistance to children or their families from the following programs: ▪ School Lunch Program ▪ Farmer’s Market Nutrition Program ▪ Supplemental Nutrition Assistance Program – SNAP (previously Food Stamps) ▪ Lump sum payments that represent reimbursements, including those received from insurance companies for loss or damage of property and payments of medical bills resulting from an accident or injury. ▪ Payments received under the Job Training Partnership Act from the following programs: ▪ Adult and Youth Training Programs ▪ Summer Youth Employment and Training Programs ▪ Dislocated Worker Programs ▪ Programs for Native Americans ▪ Migrant Seasonal Farm-workers Program ▪ Veterans Employment Program ▪ Job Corps ▪ Payments under the Low Income Energy Assistance Act, as amended. ▪ Any payment to volunteers under Title 1 (VISTA and others) and Title 11 (RSVP, foster grandparents, and others) of the Domestic Volunteer Service Act of 1973. ▪ Payment to volunteers under Section 8 (b)(1)(B) of the Small Business Act (SCORE and ACE). ▪ Payments under the Disaster Relief Act of 1974, as amended by the Disaster Relief and Emergency Assistance Amendments of 1989. ▪ Payments received for Wartime Relocation of Civilians under the Civil Liberties Act of 1988. ▪ Reimbursements from the Uniform Relocation Assistance and Real Property Acquisition Policies Act of 1970. ▪ Payments received under the Old Age Assistance Claims Settlement Act, except for per capita shares in excess of $2000.

S E C T I O N 5 . 2 . 4 : I N C O M E 8 ▪ Payments received under the Judgment Award Authorization Act, as amended. ▪ Payments received under the Cranston-Gonzales National Affordable Housing Act, unless the income of the family equals 80 percent of the median income of the area. ▪ Payments received under the Housing and Community Development Act of 1987, unless the income of the family increases at any time to not less than 50 percent of the median income of the area. ▪ Payments received under the Alaska Native Claims Settlement Act. ▪ Federal compensation to the following Native American groups: ▪ Chippewa in Mississippi, in Michigan, the Red Lake Band of Chippewa (Minnesota), and the Turtle Mountain Band of Chippewa (Arizona) ▪ Blackfeet, Grosventre, and Assiniboine tribes (Montana) ▪ Papago (Arizona) ▪ Grand River Band of Ottawa Indians ▪ Yakima Indian Nation (Indian Claims Commission payments) ▪ Apache Tribe of the Mescalero Reservation (Indian Claims Commission payments) ▪ Navaho and Hopi Tribe (relocation assistance) ▪ Saginaw Chippewa (Saginaw Indian Tribe of Michigan Distribution of Judgement payments) ▪ Sac and Fox tribe (claims agreement payments) ▪ Passamaquoddy Tribe and Penobscot Nation (Maine Indian Claims Settlement Act of 1980 payments) ▪ Income from submarginal U.S. land held in trust for certain Indian tribes ▪ Tribal per capita income not from casino profits: If an enrolled member’s per capita payment is not from casino profits and meets the income exclusions per 7 CFR 246.7(d)(2)(iv), then the income can be excluded. ▪ Disability insurance payments, disability court settlements, and one-time disability payments. Documentation of Income 1. At the certification, determine household size, and use the Income Eligibility screen in the WIC Information System to calculate total income. The applicant must provide documentation of income. Acceptable forms of proof of income include: ▪ Alimony ▪ Child support payments/letter ▪ Military pay documentation

S E C T I O N 5 . 2 . 4 : I N C O M E 9 ▪ Pay stub ▪ Social Security/SSI documentation ▪ Tax return ▪ Unemployment documents ▪ W-2 forms ▪ Written statement from the employer 2. If the information is adequate, and the applicant meets income guidelines, document sources and amount of income in the participant record. 3. Proceed with the certification. Temporary Eligibility - Pending Proof ▪ Reported income does not exceed 185% Federal Poverty Guidelines (FPG) If proof of income eligibility cannot be verified at the certification and screening determines the participant’s income does not exceed 185% FPG, (refer to Exhibit 5-A: Minnesota WIC Income Eligibility Guidelines) they are temporarily eligible for 30 days. ▪ Enter the income as reported by the participant and select the “Pending Proof of Income” checkbox. ▪ Finish the certification and issue only one month of food benefits. ▪ Explain how the participant may provide that documentation and give a reminder to: ▪ Submit the pending proof electronically (email, text, etc.), or ▪ Return by the following month with the required documentation for additional benefits. ▪ Review the pending documentation when received and make a determination of eligibility. ▪ Enter the income and what documentation was provided into the participant record. Delete/destroy any electronic documents received. ▪ Issue food benefits if appropriate, or initiate ineligibility procedures if documentation will not be provided. See Section 5.4: Notification of Ineligibility/ Disqualification. ▪ Document Separation of Duties at both the initial certification and again when the participant provides proof of income. See Section 1.18: Separation of Duties to Assure Program Integrity. ▪ If the applicant fails to provide the required documentation: do not issue benefits until the participant provides the required documentation. Under no circumstances may a second 30-day temporary eligibility period be allowed. Temporary eligibility does not apply to applicants whose income is above traditional income guidelines, but is within the Minnesota Health Care Program (MHCP) guidelines. See Presumptive Eligibility.

S E C T I O N 5 . 2 . 4 : I N C O M E 1 0 Presumptive Eligibility ▪ Applicants may be presumptively eligible for WIC if their household income is greater than 185%, but within the income guidelines for the Minnesota Health Care Program (MHCP) (see Exhibit 5-A: Minnesota WIC Eligibility Guidelines). Staff must see income documentation in order to determine that the applicant is presumptively eligible (PE). Self- reported income is not adequate. After verifying income documentation, staff may issue up to 3 months of food benefits pending the determination of eligibility for MHCP. ▪ Inform the applicant that they must agree to apply for Minnesota Health Care Programs as soon as possible. ▪ Write an alert and a “Presumptive Eligibility (PE)” note. Include family size, the income, and type of income proof provided in the note. ▪ Determine current status of the MHCP application at the next visit and document status in the participant income record. ▪ Write a “PE Update” note about how the presumptive eligibility was resolved. ▪ If verification can be determined that the MHCP application is still pending, an additional 3 months of food benefits may be issued. ▪ This extension may be provided on a case-by-case basis, but may never be extended beyond the second 3-month period. ▪ Document Separation of Duties at both the initial certification appointment and again when the participant provides documentation of MHCP enrollment. See Section 1.18: Separation of Duties to Assure Program Integrity. ▪ Initiate ineligibility procedures if documentation will not be provided. See Section 5.4: Notification of Ineligibility/Disqualification. Applicants Reporting Zero Income - Traditional Income Eligibility ▪ For applicants declaring a zero income: ▪ Ask probing questions about how they obtain basic living necessities such as food, shelter, medical care, and clothing in a non-judgmental manner. Document the explanation for the zero income situation in a Note, using the “Income Information” subject heading. ▪ Choose “Self Declaration” for the Proof of Income in the WIC Information System. “Self Declaration” is the only proof option that will accept a zero income amount. This proof option cannot be used for any other situation. ▪ Provide referrals and assistance to the family and document the information in the participant record. Examples of questions to ask are: ▪ Do you need assistance in finding a place to live, or food for your family? ▪ What challenges do you have finding shelter or food?

S E C T I O N 5 . 2 . 4 : I N C O M E 1 1 Waiver - limited situations when a waiver may be used for lack of income documentation In limited circumstances, staff may determine that the applicant is in a situation in which written documents are not available. Examples might include: ▪ Fire ▪ Theft ▪ Disaster ▪ Migrant farmworker families (Individuals whose principal employment is in agriculture on a seasonal basis and who establish, for the purposes of such employment, a temporary abode.) ▪ Homeless individual or family ▪ Applicant whose spouse or partner refuses to provide documentation 1. Complete the certification using “Waiver Signed” in the drop down menu for the documentation of income. 2. Generate and complete the appropriate form from the Information system, obtain signature, and import/scan the document into the Information System for all applicable household members. 3. Assess the individual situation and issue the appropriate set(s) of benefits that best meets the needs of the applicant. Reassessment of Income Eligibility During the Certification Participants are not required to report income changes during the certification period nor are local agency staff required to inquire about changes. However, if both the following conditions are met for an active participant, local agency staff must reassess income eligibility: ▪ Staff receives credible information indicating a change in the participant’s income or a change in family size that would result in that person/family no longer qualifying for WIC services. ▪ It is more than 90 days until the end of the certification period. If both of these conditions are met, then staff should reassess income eligibility, including screening for adjunctive eligibility and/or traditional income eligibility. Explore all other options for participation in programs that may grant adjunctive eligibility for WIC. ▪ Participants found to no longer be eligible, must be disqualified and informed of their ineligibility. This must be done at least 15 days before the date of termination. Staff may issue a partial food package to the date of the termination. Section 5.4: Notification of Ineligibility/Disqualification.

S E C T I O N 5 . 2 . 4 : I N C O M E 1 2 ▪ Participation of other active household members will be terminated if it is determined that another member of the household is no longer income-eligible for the WIC program. Staff may issue a partial food package to the date of the termination. ▪ If staff determine that a participant and other active household members who are becoming ineligible should be issued food benefits, this must be done before initiating ineligibility procedures in the WIC Information System. ▪ Staff must enter new information (such as new income or change in family size). A ‘Notice of Ineligibility’ will be generated by the system and must be given to the participant. Staff must document in a note the reason for reassessment and termination in the record. Migrants Income eligibility for in-stream migrant farmworkers must be documented only once in 12 months. The date of the last income determination is available in the WIC Information System. Migrant farmworker means an individual whose principal employment is in agriculture on a seasonal basis, who has been so employed within the last 24 months, and who establishes, for the purposes of such employment, a temporary abode. Guidance ▪ If income has been documented for one family member within the last 3 months, it can be used for other family members being certified within that 3-month period. ▪ Staff should assist applicants by suggesting ways to meet the proof of income requirement. ▪ Applicants do not need to be a U.S. citizen to receive WIC services and food benefits. ▪ One document can be used as proof for multiple areas of eligibility including identity, residency, and income. For example, a current pay stub or Phone/Online Medical Assistance verification could potentially serve as proof of identity, income and residency if it includes all those areas and is up-to-date. ▪ Contact your State Consultant with any questions or concerns regarding income. Reference – Complete Listing of Hyperlinks Section 5.4: Notification of Ineligibility/Disqualification (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_4.pdf) Section 1.18: Separation of Duties to Assure Program Integrity (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_18.pdf)

S E C T I O N 5 . 2 . 4 : I N C O M E 1 3 Exhibit 5-A: Minnesota WIC Income Eligibility Guidelines (https:/www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5a.p df) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.2.5)Minnesota WIC Operations Manual (MOM) Section 5.2.5: Physical Presence#

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Section 5.2: Certification Procedures 10/2021 5.2.5 Physical Presence References: 7CFR 246.7 (o) Policy: Applicants must be physically present for the initial and subsequent certifications, except in certain limited circumstances. Local agencies should accommodate applicants/ participants who are unable to come to clinic for services for health reasons (see exceptions below). Purpose: To maximize benefits to participant families through full and active participation in WIC. Procedures ▪ Physical presence must be documented. Staff must check the box “Physically Present” in the participant record. ▪ The physical presence requirement may be met when a certification is completed at a site other than the regular WIC clinic (e.g., the participant’s home, health care clinic, etc.). Allowable exceptions to physical presence: Illness: If an applicant is too ill to come to clinic, his/her existence may be verified by another health professional/agency. Individual with disabilities: If an applicant or parent/guardian has a disability and is unable to be physically present at clinic because of his/her disability, the individual may be certified without being physically present. His/her existence may be verified by another health professional/agency. Examples include:  A medical condition that necessitates the use of medical equipment that is not easily transportable  A medical condition that requires confinement to bed  A serious illness that may be made worse by coming to the clinic No persons with disabilities are automatically exempt from the requirement to be physically present, nor does an exemption for the initial certification automatically exempt them from being physically present for the subsequent certifications.  If the participant applies for re-certification, the circumstances of exception must be reassessed.

5 . 2 . 5 P H Y S I C A L P R E S E N C E 2  In the case of long-term or permanent disability or medical condition, an extended exemption to the physical presence requirement may be allowed. Receiving ongoing health care: An infant or child who has documented ongoing health care from a provider other than WIC would not have to be physically present for a re-certification if being physically present would pose an unreasonable barrier to participation. Ongoing health care means that the child is receiving well-child care following the American Academy of Pediatrics (AAP) Schedule of Well-Child Care Visits for screenings and assessments. Verbal confirmation is acceptable. Working parents or caretakers: WIC staff should work with parents and caretakers to arrange an appointment that will work for the family, whenever possible. However, a child under the care of a working parent whose work condition poses a barrier to bringing the child to clinic, would not have to be physically present for a re-certification if he/she were present at the initial certification and had been present at a WIC contact, at a minimum, once during the prior year. Note: High risk follow-up may necessitate being seen more often than once annually. See Section 6.6, High Risk Individual Nutrition Care Plans. If the applicant is not physically present:  Proof of identity, income, and residency is still required.  A reason for the exception to being physically present must be documented in the participant record.  Referral data may be used for height/length, weight, and/or hemoglobin. This information could be obtained during a home visit or from another health professional/agency, if measurements meet the timing requirements specified in Sections 5.3.2.2 (for hematologic date) and 5.3.1.1 (for height/length and weight). Guidance:  Participants will receive the greatest benefit from WIC through full and active participation.  Agencies should schedule clinic hours to accommodate families whenever possible.  In the event of a participant’s illness, it may be preferable to reschedule the participant’s appointment.  When a participant is certified at a site other than the WIC clinic, document the location of the certification in Notes.  Contact your State Consultant with any questions or concerns regarding residency. Reference – Complete Listing of Hyperlinks Schedule of Well-Child Care Visits (https://www.healthychildren.org/English/family-life/health- management/Pages/Well-Child-Care-A-Check-Up-for-Success.aspx)

5 . 2 . 5 P H Y S I C A L P R E S E N C E 3 Section 6.6: High Risk Individual Nutrition Care Plans (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_6.pdf) Sections 5.3.2.2: Hemotologic Assessment (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_3_2.pdf) Section 5.3.1.1: Antropmetric Data (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_3_1.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.3)Minnesota WIC Operations Manual (MOM) Section 5.3: Nutrition Risk Assessment Overview#

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Section 5.3: Nutrition Risk Assessment 2/2021 Section 5.3: Nutrition Risk Assessment Overview References: WIC Policy Memo #98-9, 7 CFR 246.7(e) (1)-(3) Policy: Local Agency CPAs must conduct a thorough assessment of nutrition risk during the certification process. Purpose: Nutrition risk assessment is the process of obtaining and synthesizing information about a participant’s nutrition and, as appropriate, breastfeeding status in order to provide the most appropriate individualized WIC services. The nutrition assessment is the foundation on which all subsequent nutrition services are based: nutrition education, an individualized food package, and referrals to other health and/or social services providers. The nutrition risk assessment includes an evaluation of: ▪ Anthropometric information ▪ Hematologic information ▪ Health and medical history ▪ Dietary information ▪ Breastfeeding information, as appropriate Procedures The assessment process is meant to be a conversation between the CPA and participant/caregiver. To conduct a WIC nutrition assessment, CPAs must: 1. Accurately collect anthropometric, hematologic, health and dietary information. Anthropometric and hematologic assessments should be done first. Identifying any height, weight, or blood-iron concerns first, provides a context for assessment information collected in the Information System. ▪ Anthropometric and hematologic information should be obtained using standard procedures outlined in the anthropometric and hematologic assessment policies. ▪ Health and dietary information must be collected using the questions in the Information System. Probing questions should be used as appropriate to collect relevant, accurate information. This helps the CPA assess a participant’s health, nutrition practices, cultural values, preferences, and other pertinent areas.

S E C T I O N 5 . 3 : N U T R I T I O N R I S K A S S E S S M E N T O V E R V I E W 2 2. Clarify and synthesize the information that has been collected. 3. Identify and assign all applicable risk codes and any other relevant concerns. 4. Document the assessment in the Information System, including all applicable risk codes. 5. Follow up on previous assessments, as appropriate. 6. After all components of the WIC assessment are completed, provide education based on highest priority risk conditions and participant’s interests. Note: it is not expected, nor is it recommended, that all nutrition risks be addressed (i.e., counseled/educated on) at the initial certification. See Guidance. Guidance A value-enhanced nutrition assessment (VENA) requires: ▪ A systematic approach to collecting and evaluating information provided by participants ▪ Good communication skills and an ability to establish rapport with each participant ▪ Knowledge of nutrition and breastfeeding ▪ Critical thinking 1. It is best practice to review previous assessments and relevant notes in the participant’s record prior to beginning the new assessment. 2. To enhance the value of the assessment, it is critical the assessment be conducted in space that provides privacy to participants. 3. Only after all information has been reviewed and all nutrition risks identified, should education or counseling be provided. ▪ Conclusions based on incomplete information might be incorrect. ▪ Education based on incorrect conclusions is likely to be inappropriate. It is important to understand the underlying causes before exploring possible solutions with participants. For example, it would be inappropriate to discuss dietary recommendations for addressing low hemoglobin before completing all aspects of the assessment. Until the nutrition assessment has been completed, the CPA would not know what dietary factors may be related to the low blood iron. CPAs should prioritize the nutrition issues to be addressed, in collaboration with each participant. Those of greatest importance and/or interest should be addressed first. Other concerns can be addressed at subsequent WIC nutrition visits. Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.3.1)Minnesota WIC Operations Manual (MOM) Section 5.3.1: Anthropometric Data#

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Section 5.3: Nutrition Risk Assessment 2/2021 Section 5.3.1: Anthropometric Data References: 7 CFR 246.7(e)(1)(i)(A and B) and 246.7(e)(1) (ii) Policy: Local Agency staff must obtain and record accurate anthropometric data reflective of the participant’s category at certification, re-certification, and mid-certification. The data must have been measured within the previous sixty days. Purpose: To ensure that accurate applicant/participant anthropometric data is included in the health status assessment so that correct risks are identified, risk codes assigned, and relevant education provided. Procedures 1. Local agency staff must obtain anthropometric data either by: ▪ Measuring height/length and weight using appropriate equipment and following the procedures described in the Minnesota WIC Program Anthropometric Manual or ▪ Obtaining anthropometric data from a medical provider through referral. See Section 5.3.1.1 below – Use of Referral Weight and Height/Length Data. Self-reported anthropometric information may not be used. Procedures for measuring height/length and weight are described in the Minnesota WIC Program Anthropometric Manual (Part II, pages 11 – 36): ▪ Measuring recumbent length of infants and young children, page 11 ▪ Weighing children younger than 24 months of age, page 18 ▪ Measuring standing height of older children and adults, page 24 ▪ Weighing older children and adults, page 29 2. Local agency staff must accurately record anthropometric data in the Information System, documenting: ▪ Date measurements were taken and ▪ Whether the length/height was measured in standing or recumbent position 3. CPA staff must assess anthropometric data using the appropriate assessment tools.

S E C T I O N 5 . 3 . 1 : A N T H R O P O M E T R I C D A T A 2 ▪ Using the growth charts displayed in the Information System, assess anthropometric data for Infants and children and assign risk codes. ▪ For infants and children < 24 months of age: weigh and measure recumbent length. The Information System will plot length-for-age, weight-for-age, and weight-for-length. ▪ For children between 24 and 36 months of age, either recumbent length or standing height (preferred) can be measured. Refer to the Minnesota WIC Program Anthropometric Manual for information and guidance on selecting appropriate measurement (height or length). o If height is measured, standing must be indicated in the Information System and the system will display and plot BMI-for-age. o If length is measured, recumbent must be indicated in the Information System and the system will display and plot weight-for-length. ▪ For children > 36 months of age, weigh and measure standing height. The Information System will plot height-for-age, weight-for-age, and BMI-for-age. Note: Other growth grids (e.g., for children with Down Syndrome or for premature infants) may be used for education and assessing the infant/child, but not for assigning risk codes. ▪ Women’s anthropometric data will be assessed based on the National Academies of Sciences’ recommendations in their report: Weight Gain During Pregnancy: Reexamining the Guidelines. ▪ The Information System will display the grid appropriate for the woman’s weight status (underweight, normal weight, overweight, or obese). Refer to the Minnesota WIC Program Anthropometric Manual for information and guidance on using and interpreting pregnancy weight gain charts. o For pregnant women and women < 6 months postpartum, pre-pregnancy BMI is used to assess weight status. o For breastfeeding women > 6 months postpartum, current BMI is used to assess weight status. ▪ Staff should assess the woman’s weight gain during her pregnancy if currently pregnant, and total amount of weight gained if Postpartum. 4. Local agencies must have equipment that meets the guidelines in the Minnesota WIC Program Anthropometric Manual. Local agencies must check the accuracy of clinic scales at least twice each year, approximately 6 months apart. See the Minnesota WIC Program Anthropometric Manual (pages 18 and 29) for specific instructions and requirements. Results of scale checks must be recorded and the local agency must be able to provide records of scale checks during the local agency’s management

S E C T I O N 5 . 3 . 1 : A N T H R O P O M E T R I C D A T A 3 evaluation. Exhibit 5-K: Documenting Clinic Scale Testing is a form that may be used to record the dates and results of the scale checks. Guidance ▪ All participants, including women, must be measured and weighed. Self-reported height and/or weight may not be used. ▪ If a woman is > 20 years of age, staff need measure her height only once (typically at her at her initial certification). ▪ Each time height/length and weight are measured, a single measurement is adequate when care is taken to assure that proper measuring techniques are used. Staff need not measure more than once. ▪ Whenever there is any doubt about the accuracy of a measurement (including measurements obtained by referral), staff should re-measure. Errors could occur in measuring, reporting, plotting, or entry into the Information System. ▪ If an accurate measure is not possible (e.g., child is wearing a cast or is very uncooperative), mark that the measure may not be accurate and select the appropriate reason for the inaccuracy. Document additional information about the suspected inaccuracy in the Notes section. ▪ If it is not possible to measure the participant (e.g., because the participant is medically fragile and unable to come to clinic) and no referral data is available, use the “Unknown ht/wt” button to provide a placeholder for the measurement in the anthropometric tabs of the Information System. Describe the situation more fully in the Notes section, and if possible, obtain these measurements when referral data is available or the condition is resolved. ▪ Clothing: WIC participants must be clothed as specified in the Minnesota WIC Program Anthropometric Manual to ensure accurate weights. ▪ Since it is essential that infants be in a dry diaper for weighing, it is advantageous to have a dedicated diaper-changing area in the near vicinity of the weighing area. ▪ It is also helpful to have a supply of diapers available. ▪ Drapes: Staff should use drapes on infant scales, recumbent measuring boards, foot beds on scales, and on the headpiece of the length measuring board. ▪ Scales must be zero-balanced with the drape prior to each use. 5.3.1.1 Using Referral Weight and Height/Length Data References: 7 CFR 246.7 (e)(1)(i)(A) and 246.7 (e)(1)(i)(B)

S E C T I O N 5 . 3 . 1 : A N T H R O P O M E T R I C D A T A 4 Policy: Referral anthropometric data must meet all the requirements for anthropometric data collected in the clinic. Purpose: To ensure an accurate assessment of the participant’s weight and height/length using referral data, anthropometric data must reflect the participant’s current category, and have been done within the scheduling requirements to be valid. Procedures Weight and height/length data collected by a medical provider other than WIC staff, may be used for certification/recertification/mid-certification provided the following conditions are met. Use of referral data does not pre-empt the requirement that the participant be physically present at the certification (see Section 5.2.5: Physical Presence ). For referral data to be used, the following conditions must be met: ▪ The data is provided by a health care provider. ▪ The referral data should be provided on letterhead from the source or another form that specifies the medical clinic/provider, and includes: ▪ Participant’s name ▪ Date of collection ▪ The referral data may be obtained from the participant’s electronic medical record (EMR). The parent must show the WIC staff the value in the EMR. ▪ The CPA may obtain this information by phone from the medical clinic or health care provider. ▪ The participant was in the same categorical status (i.e., pregnant or postpartum) at the time of data collection as at the certification at which the data is used. ▪ The anthropometric measurements were taken within sixty days of the certification. ▪ The actual measurement date is entered in the Information System so that plotting is accurate. ▪ The source of the measurement date is entered in the Information System. ▪ Self-reported data may not be used. Guidance Because infants grow so rapidly, it is best clinical practice to weigh and measure infants at the certification appointment whenever possible. If referral data must be used, it should be as recent as possible, collected no more than 30 days prior to the infant certification.

S E C T I O N 5 . 3 . 1 : A N T H R O P O M E T R I C D A T A 5 Reference – Complete Listing of Hyperlinks Minnesota WIC Program Anthropometric Manual (https://www.health.state.mn.us/docs/people/wic/localagency/training/nutrition/nst/anthro.p df) Weight Gain During Pregnancy: Reexamining the Guidelines (http://www.nap.edu/catalog.php?record_id=12584) Section 5.2.5: Physical Presence (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_2_5.pdf) Exhibit 5-K: Documenting Clinic Scale Testing (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5k. pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.3.2)Minnesota WIC Operations Manual (MOM) Section 5.3.2: Hematologic Assessment#

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Section 5.3: Nutrition Risk Assessment 1/2025 Section 5.3.2 Hematologic Assessment References: 7 CFR 246.7 (e)(1)(i)(A) and 246.7 (e)(1)(i)(B) Policy: Local Agency staff must obtain and record accurate hematologic data reflective of the participant’s category at certification, re-certification, and mid-certification. Purpose: To ensure that accurate applicant/participant hematologic data is included in the health status assessment so that correct risks are identified, risk codes assigned, and relevant education provided. It is important to assess iron status as part of a nutritional assessment because individuals eligible to participate in WIC have been shown to be at risk, and the consequences of iron deficiency anemia on development are potentially serious and long-term in nature. WIC has been shown to positively impact iron status through nutrition education, supplemental food, and referrals to health care providers. Procedures Local agency staff must obtain hematologic data either by: ▪ Measuring hemoglobin or hematocrit using approved equipment and following the procedures described by the manufacturer, or ▪ Obtaining hematologic data from a medical provider through referral. See Section 5.3.2.2: Using Referral Hematological Data. All WIC staff who will be conducting hemoglobin testing must complete training on the equipment they will be using prior to doing tests in clinic (Section 4.5: Staff Training). ▪ Review hematological procedures as part of the ongoing monitoring and supervision of CPA staff (Section 4.6: CPA Performance and Evaluation). Local agencies must use the following schedules Blood Work Schedule for Women Hematologic data must be entered for all women certified in WIC. ▪ Bloodwork must have been done at a time that reflects their current status (i.e., blood work measured during pregnancy if certifying a pregnant woman, or following delivery if certifying a postpartum woman).

S E C T I O N 5 . 3 . 2 : H E M A T O L O G I C A S S E S S M E N T 2 ▪ For women certified for a year: if blood values obtained at their certification indicated low hemoglobin, blood work must be repeated during the year and recorded in the participant’s record. Blood Work Schedule for Infants & Children Infants ▪ To meet the scheduling requirement, blood work must be done at or after nine months of age, generally at the infant’s mid-certification appointment. ▪ Infants certified on or after nine months old always need hemoglobin tested at the first certification. Children ▪ For children certified between 12 and 15 months: ▪ Blood work must be done at 12 month certifications, unless: o Blood work was done on or after nine months of age o AND the hemoglobin value was normal. ▪ Blood work must be done again at 15-18 months for all children. ▪ For children certified between 15 and 24 months: ▪ Blood work must be done at the certification/re-certification/mid-certification, regardless if the previous hemoglobin value was normal or not. ▪ Blood work must be done at mid-certification (18-21 months), regardless of the previous hemoglobin status (i.e., even if it was normal). ▪ Children 24 months and older must have blood work done at the certification/re- certification/mid-certification in the following circumstances: ▪ If the most recent blood work indicated low hemoglobin. ▪ If the most recent blood work was approximately 12 months prior to the current certification/mid-certification appointment. ▪ If a child aged 20 to 26 months old did not have blood work done between 13 and 24 months, the hemoglobin must be measured. Guidance ▪ If the hematologic value at the child’s previous certification was near the cut-off point, and the child has risk factors for low hemoglobin (such as late weaning, excessive juice intake and/or excessive milk intake), it is best practice to repeat blood work at the next certification/ recertification/mid-certification.

S E C T I O N 5 . 3 . 2 : H E M A T O L O G I C A S S E S S M E N T 3 ▪ For children over two years of age and the most recent blood work was done more than 10 months ago, it would be best practice to do blood work. ▪ The blood work schedule outlined above takes priority over Information System requirements. The Information System does not accept blood work done 90 days prior. However, if the test was done within the required timeframes, and the value indicated a normal blood work measure, staff may enter the value in a note rather than the blood work tab. ▪ Guidance from the Department of Justice indicates that it would be discriminatory to require HIV-infected applicants to have blood work required for WIC certification done elsewhere if it is the policy of the WIC clinic to perform these tests on site. However, if it is determined, on a case-by-case basis, that the health and safety of others is severely at risk, providing the service by other means may be justified. Applicants cannot be required to obtain such data at their own expense. With rare exception, WIC clinics should be prepared to obtain WIC blood collections from all applicants, following recommended health and safety protocols. Machines for hemoglobin testing ▪ Hemoglobin measuring equipment for obtaining capillary blood samples is used in Minnesota WIC. Equipment manufacturers have created training materials specific to their equipment (available both online and in print). ▪ Local Agencies must assure that equipment is maintained and cleaned according to manufacturers’ instructions. ▪ Before changing to a new type of hemoglobin measuring equipment, LAs must discuss with their State WIC Consultant to assure it meets WIC requirements. Lancets should be ▪ A single use retractable skin puncture device that punctures the skin by either a blade or needle. ▪ Labeled with length of blade/needle and gauge. Shorter and narrower blades or needles are thought to be less painful. This must be balanced with a need for a puncture deep enough to assure adequate blood for the sample. ▪ For children: the blade or needle should be about 1.5mm. ▪ For women: the blade or needle should be less than 2.4 mm. Collection site (Collection of Capillary Blood Specimens, Blood Specimens-Specimen Collection): Local Agencies are responsible for training and oversight of hematological testing (See Introduction to Hematological Assessment for more information about technique.)

S E C T I O N 5 . 3 . 2 : H E M A T O L O G I C A S S E S S M E N T 4 ▪ The finger or toe may be used for infants nine months of age or older. ▪ For children over one year and adults, the best site for collecting a capillary sample is the middle or ring finger. ▪ The finger used should not have a ring. ▪ For children under eight years, the puncture depth should be less than 1.5mm thus the lancet depth should be about 1.5 mm (WHO Guidelines on drawing blood). Precaution: ▪ When conducting a hemoglobin measurement on young children, be cautious about bandages due to choking risk. Low Hemoglobin ▪ Hemoglobin measures below 10 should be re-tested. ▪ The second sample should be from a different site instead of taking a second sample from the first puncture site. ▪ A referral to a health care provider is required when the hemoglobin value meets the high risk criteria (see Exhibit 6-A: High Risk and Medical Referral Criteria) 5.3.2.1 Exceptions to Required Hematological Measurements Reference: Policy Memorandum 92-10: Bloodwork Protocols WIC clinics should be prepared to obtain and record hematologic data from all applicants per hemoglobin schedule (Section 5.3.2: Hematologic Assessment) unless the following exceptions occur: 1. Refusal based on religious beliefs 2. If blood drawing could cause harm to the applicant because of medical conditions documented by a physician (e.g., hemophilia, fragile bones, certain skin diseases, etc.) If it is determined that the health and safety of others (WIC clinic personnel) are at risk, defer the measurement and obtain referral data. These situations should be handled on a case-by- case basis with the assistance of the WIC Coordinator or Public Health Supervisor. These situations would be extremely rare. Document the plan to obtain referral data (see Implementation of WIC ARPA Waivers for deferral procedures). Local Agencies should monitor records to verify that staff are documenting deferrals in Notes as required.

S E C T I O N 5 . 3 . 2 : H E M A T O L O G I C A S S E S S M E N T 5 Procedures ▪ CPA will discuss the importance of anemia screening with the family. When either of the two exceptions apply and blood work is not done in clinic, the agency will make every reasonable effort to obtain the hematological data from the Health Care Provider. ▪ If referral data is not available, certify the applicant based on other identified risk criteria, and refer to a laboratory that can collect blood from such persons. ▪ Applicants cannot be required to obtain referral data at their own expense. ▪ If an applicant refuses blood work due to religion or medical condition, the reason blood work was not collected must be documented in the Notes section of the Information System. Guidance Train staff on the purpose and importance of hemoglobin screening. Hemoglobin Screening - Talking Points provides staff talking points, tips for preparing families for the hemoglobin screening, and ideas for reducing resistance to the hemoglobin screening. 5.3.2.2 Using Referral Hematological Data References: 7 CFR 246.7 (e)(1)(i)(A) and 246.7 (e)(1)(i)(B) Policy: Referral hematologic data must meet all the requirements for hematologic data collected in the clinic. Purpose: To ensure an accurate assessment of the participant’s hematological status using referral data, hematological data must reflect the participant’s current category, and have been done within the scheduling requirements to be valid. Procedures Hematologic data collected by a medical provider other than WIC staff, may be used for certification/recertification/mid-certification provided the following conditions are met. Use of referral data does not pre-empt the requirement that the participant be physically present at the certification (see Section 5.2.5: Physical Presence). For referral data to be used, the following conditions must be met: ▪ The data is provided by a health care provider. ▪ The referral data should be provided on letterhead from the source or another form that specifies the medical clinic/provider, and includes: ▪ Participant’s name ▪ Date of collection

S E C T I O N 5 . 3 . 2 : H E M A T O L O G I C A S S E S S M E N T 6 ▪ The referral data may be obtained from the participant’s electronic medical record (EMR). The participant must show the WIC staff the value in the EMR. ▪ The CPA may obtain this information by phone from the medical clinic or health care provider. ▪ The participant was in the same categorical status (i.e., pregnant or postpartum) at the time of data collection as at the certification at which the data is used. ▪ If unable to enter the actual date of the hematological data in the Information System, and blood work was done within the timeframes appropriate for WIC Category, the value should be entered in a note. If the blood work value indicates anemia, the date of measurement must be within 30 days (Infants) or 60 days (other Categories). ▪ Self-reported data may not be used. ▪ For hematological data, the blood work schedule outlined in Section 5.3.2 takes priority over Information System requirements. The Information System does not accept blood work done 90 days prior. However, if the test was done within the required time frames, and the value indicated a normal blood work measure, staff may enter the value in a note rather than the blood work tab. 5.3.2.3 Preventing Blood Borne Pathogen Transmission All Local Agencies employing individuals who may be exposed to blood borne pathogens and other infections agents must have a written Exposure Control Plan. Refer to the Occupational Safety and Health Standards: Bloodborne Pathogens. The Exposure Control Plan establishes guidelines, precautions, laboratory rules and standard operating procedures that will limit occupational exposure to blood borne pathogens and other infectious agents. ▪ All employees must be trained in all aspects of the agency Exposure Control Plan. Precautions described in the Exposure Control Plan which are intended to prevent transmission of blood borne pathogens are referred to as “Universal Precautions”. All employees must practice “Universal Precautions” at all times when working with blood and body fluids. All individuals/patients are considered potentially infectious for human immunodeficiency virus (HIV), hepatitis B virus (HBV), and other blood borne pathogens. Reference – Complete Listing of Hyperlinks Section 4.5: Staff Training (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_5.pdf) Section 4.6: CPA Performance and Evaluation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_6.pdf)

S E C T I O N 5 . 3 . 2 : H E M A T O L O G I C A S S E S S M E N T 7 Collection of Capillary Blood Specimens (https://clsi.org/standards/products/general- laboratory/documents/gp42/) Blood Specimens-Specimen Collection (https://www.cdc.gov/dpdx/diagnosticprocedures/blood/specimencoll.html) Introduction to Hematological Assessment (https://www.health.state.mn.us/docs/people/wic/localagency/training/nutrition/nst/blood.pd f) WHO guidelines on drawing blood: best practices in phlebotomy (https://www.who.int/publications/i/item/9789241599221) Exhibit 6-A: High Risk and Medical Referral Criteria (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex6/6a. pdf) Policy Memorandum 92-10: Bloodwork Protocols (https://www.fns.usda.gov/wic/bloodwork- protocols) Implementation of WIC ARPA Waivers (https://www.health.state.mn.us/docs/people/wic/localagency/arpaguide.pdf) Hemoglobin Screening - Talking Points (https://www.health.state.mn.us/docs/people/wic/localagency/hemoglobintp.pdf) Section 5.2.5: Physical Presence (https:/www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_2_5.pdf) Occupational Safety and Health Standards: Bloodborne Pathogens (https://www.osha.gov/laws-regs/regulations/standardnumber/1910/1910.1030) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.3.3)Minnesota WIC Operations Manual (MOM) Section 5.3.3: Health and Nutrition Information#

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Section 5.3: Nutrition Risk Assessment 12/2023 5.3.3: Health and Nutrition Information References: Immunization Screening and Referral in WIC Policy: Local Agency CPAs must assess a participant’s health and nutrition status at certification, recertification, and mid-certifications. Purpose: To ensure all applicants receive a standardized assessment of their medical/health/nutrition status that is based on currently accepted practice and Value Enhanced Nutrition Assessment (VENA) guidelines. Procedures Follow the Nutrition Assessment Process for a comprehensive screening of the participant’s health/medical/nutrition status. Nutrition Assessment Process 1. Only after completing an anthropometric and hematologic assessment, assess the participant’s medical/health/nutrition status. 2. Use the appropriate Nutrition Assessment Tool as a guide for collecting and evaluating relevant information about the participant’s health and diet and eating/feeding patterns. Collect adequate information to assess for all possible risk codes for the participant’s category, including risk assessment for postpartum/perinatal depression. 3. Clarify and synthesize information as needed. 4. Identify and assign all applicable risk codes. 5. Document the health/medical/nutrition assessment. 6. After all components of the assessment are complete (anthropometric, hematologic, health, diet, and breastfeeding) and all applicable risk codes assigned, provide education based on prioritized needs. Screening and Referral for Immunizations ▪ Assess immunization status of infants and children. Use the appropriate Nutrition Assessment Tool as a guide:

S E C T I O N 5 . 3 . 3 : H E A L T H A N D N U T R I T I O N I N F O R M A T I O N 2 ▪ At a minimum, ask if the child’s immunizations are up-to-date. Refer to Are Your Kids Ready? Minnesota K-12 Immunization Law for the current recommendations. ▪ Indicate in the Information System when the participant is not up-to-date for age by current recommendations ▪ If a child’s immunization status is not current, refer to immunization program(s). Document the referral in the Information System Referrals or in a note. If the family declines an immunization referral, note that in the participant record. ▪ Coordinate with public health immunization program staff to ensure infants’ and children’s immunization status is assessed and appropriate referrals are made. Screening and Referral for Blood Lead Testing ▪ Assess blood lead testing status of infants and children. Use the appropriate Nutrition Assessment Tool as a guide: ▪ Ask if the child has had a blood lead test. Refer to Minnesota Childhood Blood Lead Screening Guidelines for the current recommendations ▪ Indicate in the Information System when the participant has not had a blood lead test per current recommendations ▪ If a child’s blood lead testing is not current, refer to blood lead testing program(s). Document the referral in the Information System Referrals or in a note. If the family declines a blood lead test referral, document that in the participant record. Guidance ▪ Use a participatory, interactive approach when collecting health and diet/breastfeeding information: ▪ CPAs may ask the assessment questions in any order. ▪ CPAs may rephrase questions, provided the intent of each question is not changed. ▪ Actively involve the participant through dialogue, information exchange, listening and feedback. ▪ Clarify information by using probing, open-ended questions. ▪ Keep discussion at a level appropriate to participants’ level of education. ▪ Avoid judgmental language. ▪ Conduct the assessment with respect and warmth to aid in building rapport. ▪ Refer to VENA for more information. ▪ PCS training materials and tools are available to develop CPA skills. ▪ Refer to Nutrition Assessment Tools for further information.

S E C T I O N 5 . 3 . 3 : H E A L T H A N D N U T R I T I O N I N F O R M A T I O N 3 ▪ Ensure the privacy of each participant when gathering and discussing information. See Section 1.7: Data Privacy. Reference – Complete Listing of Hyperlinks Immunization Screening and Referral in WIC (https://www.fns.usda.gov/wic/immunization- screening-referral) Nutrition Assessment Tool (https://www.health.state.mn.us/people/wic/localagency/training/na.html#NaN) Are Your Kids Ready? Minnesota K-12 Immunization Law (https://www.health.state.mn.us/people/immunize/basics/readyk12.pdf) Minnesota Childhood Blood Lead Screening Guidelines (https://www.health.state.mn.us/communities/environment/lead/docs/reports/leadscreengui de.pdf) VENA (https://wicworks.fns.usda.gov/resources/value-enhanced-nutrition-assessment-vena- guidance) PCS training and tools (https://www.health.state.mn.us/people/wic/localagency/training/pcs/index.html) Section 1.7: Data Privacy (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_7.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164- 0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942. This institution is an equal opportunity provider.

(5.3.4)Minnesota WIC Operations Manual (MOM) Section 5.3.4: Nutrition Risk Code and Priority Assignment#

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Section 5.3: Nutrition Risk Assessment 4/2023 5.3.4 Nutrition Risk Code and Priority Assignment Policy: Local Agency CPAs must assign all applicable risk codes at each certification and recertification. Purpose: To ensure that all identified risks are documented in the participant’s record for determining WIC eligibility and for providing the most appropriate nutrition services. To ensure risk codes are assigned consistently throughout the state. Procedures 1. Compare assessment data to the WIC nutrition risk criteria. Refer to Exhibit 5-T: MN WIC Risk Criteria and the allowed WIC Risk Criteria. 2. Select all applicable risk codes in the Information System. 3. Provide justification for all assigned risk codes by documenting supporting information in the Information System. Guidance ▪ All applicable risk codes must be assigned and documented at certification and recertification, but it is not expected that all nutrition risk conditions be counseled on or addressed. WIC staff, in collaboration with the participant, should prioritize the nutrition issues to determine which will be addressed at the certification appointment. ▪ Begin education or counseling only after all information has been reviewed and nutritional risks assessed. Proceeding in this way will provide the CPA with a more comprehensive picture of the participant’s nutrition status, so that he/she can counsel accordingly. ▪ When a complete nutrition assessment has been done and no other dietary risk criteria (400 codes) have been identified, use a presumed dietary risk code: ▪ Assign risk code 428, Dietary Risk Associated with Complementary Feeding Practices, for infants 4-12 months or children 12-23 months. ▪ Assign risk code 401, Failure to Meet Dietary Guidelines for Americans, for individuals 2 years of age and older. ▪ During the certification period, the Information System may assign or delete risk codes based on data added to the participant’s record. However, the CPA is not required to assign or delete risk codes during the certification period, e.g., at the Midcertification

S E C T I O N 5 . 3 . 4 : N U T R I T I O N R I S K C O D E A N D P R I O R I T Y A S S E S S M E N T 2 appointment or Additional Nutrition Education contacts. If a new risk is identified during the certification period, the CPA should address the risk through counseling as appropriate. ▪ CPAs should be familiar with the federal priority system. Refer to Exhibit 5-U: Minnesota WIC Participant Priority System and Exhibit 5-V: Nutrition Risk and Priority Assignment Table for detailed information. Reference – Complete Listing of Hyperlinks Exhibit 5-T: MN WIC Risk Criteria (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5t_ new.pdf) WIC Risk Criteria (https://www.health.state.mn.us/people/wic/localagency/riskcodes/index.html) Exhibit 5-U: Minnesota WIC Participant Priority System (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5u. pdf) Exhibit 5-V: Nutrition Risk and Priority Assignment Table (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5v_ new.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164- 0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942. This institution is an equal opportunity provider.

(5.4)Minnesota WIC Operations Manual (MOM) Section 5.4: Notification of Ineligibility/Disqualification#

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Section 5.4: Notification of Ineligibility/ Disqualification 3/2021 References: 7CFR Part 246.7 (j) (5-8) Policy: Persons determined to be ineligible at the time of certification or mid-certification, or disqualified at any time, must be informed in writing of the reason for ineligibility or disqualification, and of their right to a fair hearing. The reason for ineligibility must be documented. Purpose: To inform an applicant or participant of his/her ineligibility for the WIC Program. Procedures Ineligibility at Certification Persons determined to be ineligible during a certification or recertification appointment, must receive written notification of ineligibility including the reason(s) for ineligibility, and of their right to a fair hearing. 1. Assess whether the participant (in the case of an early termination of a previous certification) or any household members still in a current certification are eligible to receive food benefits. See Income Ineligibility During the Certification Period section below. 2. Complete the applicable portions in the WIC Information System. 3. Sign the signature pad as confirmation that the WIC staff person has completed final ineligibility determination. 4. Provide the applicant the Notice of Ineligibility generated by the WIC Information System (see Exhibit 5-GG: Sample Letter of Ineligibility for a sample notice). 5. Offer nutrition education and referrals, and if provided, document those in the participant record. Ineligibility after Pending Eligibility Applicants who are missing required documentation at certification, determined to be temporarily eligible for 30 days and later, when documentation is provided, are determined to

S E C T I O N 5 . 4 : N O T I F I C A T I O N O F I N E L I G I B I L I T Y / D I S Q U A L I F I C A T I O N 2 be ineligible, must receive written notification of ineligibility, the reason for ineligibility, and of their right to a fair hearing. 1. Assess whether any other household members, who are in a current certification (not pending eligibility), are eligible to receive food benefits and issue those. See Income Ineligibility During the Certification Period section below. 2. Initiate a termination in the participant record. 3. Provide the applicant the signed Letter of Ineligibility. Income Ineligibility During the Certification Period Occasionally, participants are determined to be income-ineligible during their certification period. (For more details, see Section 5.2.4: Income (Certification Procedures), Reassessment of Income Eligibility During the Certification.) In these situations, participants must receive written notice of the ineligibility, the reason for ineligibility, and of their right to a fair hearing, not less than 15 days before the termination. 1. After determining that the participant will be income-ineligible, provide a food package to the participant and other household members depending on how many days are left in the certification: ▪ Participants with > 90 days left in their current certification are eligible to receive food benefits for 15 days (i.e., a half food package). ▪ Participants with < 90 days left are eligible to receive all of their remaining sets of food benefits. 2. Initiate a manual termination, selecting to generate a Letter of Ineligibility and a note in the participant record. 3. Write on the notice the names of any other family members who were also determined ineligible at this time. 4. Give the participant the signed Letter of Ineligibility. 5. Offer nutrition education and referrals, and if provided, document those in the participant record. Ineligibility due to Participant Violations Only the state office can disqualify participants for program violations and will provide guidance to local agencies on how to proceed. Those participants must receive a written notice of disqualification, the reason for disqualification, and of their right to a fair hearing, not less than 15 days before the disqualification. Once it has been determined that there will be a disqualification, no benefits may be issued. 1. Follow instructions received from the state office about the disqualification. 2. Initiate a Manual Termination in the participant record as directed.

S E C T I O N 5 . 4 : N O T I F I C A T I O N O F I N E L I G I B I L I T Y / D I S Q U A L I F I C A T I O N 3 3. See Section 1.11: Potential Participant Violations for additional information. Categorical Ineligibility Participants must be notified (either verbally or in writing) at least 15 days in advance that their certification will be ending due to categorical ineligibility. ▪ For example, verbally notify the parents of a 4 year old, that the child is no longer eligible to receive WIC services after they turn 5 years old. ▪ Breastfeeding women who discontinue breastfeeding after 6 months postpartum and become categorically ineligible, must also be given 15 days advance notice. ▪ Issue a final month of food benefits for the participant. ▪ Then update the breastfeeding status in the participant and infant records. This update will trigger system termination for the non-breastfeeding woman, after which no benefits can be issued for her. ▪ Offer and document nutrition education as appropriate. Letter of Ineligibility Not Necessary in these Situations Written ineligibility notices are not necessary when: ▪ Participants become categorically ineligible (e.g., child turns 5, non-breastfeeding woman reaches 6 months postpartum, breastfeeding woman discontinues breastfeeding after 6 months postpartum) ▪ A participant does not return for food benefits or recertification ▪ A person only requests information, inquires about the program, or is pre-screened by phone, walk-in, etc. Guidance ▪ When ineligibility is determined in situations where the participant and/or household members are eligible for final food benefits, the CPA must issue those benefits before completing ineligibility. Otherwise, the Information System will not permit food benefits to be issued. ▪ See Income Assessment modules for more guidance about ineligibility procedures. ▪ The Information System will document the reason for ineligibility; if this does not occur, it should be documented in a note. Related Policies Section 1.13: Fair Hearing Procedures Section 3.3: Transferring Participants

S E C T I O N 5 . 4 : N O T I F I C A T I O N O F I N E L I G I B I L I T Y / D I S Q U A L I F I C A T I O N 4 Section 5.2: Certification Procedures Section 6.3: Initial Education Reference – Complete Listing of Hyperlinks Exhibit 5-GG: Sample Letter of Ineligibility (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5gg .docx) Section 5.2.4: Income (Certification Procedures) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_2_4.pdf) Section 1.11: Potential Participant Violations (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_11.pdf) Income Assessment (https://www.health.state.mn.us/people/wic/localagency/winnie/training.html#income) Section 1.13: Fair Hearing Procedures (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_13.pdf) Section 3.3: Transferring Participants (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch3/sct n3_3.pdf) Section 5.2: Certification Procedures (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_2all.pdf) Section 6.3: Initial Education (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_3.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.5)Minnesota WIC Operations Manual (MOM) Section 5.5: Change in Guardianship and/or Foster Care - Provision of WIC Services#

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Section 5.5: Change in Guardianship and/or Foster Care – Provision of WIC Services 10/2024 References: 7CFR 246.4; Section 5.2: Certification Procedures; DHS Data Practices Manual Section 16.18 Policy: Infants/children in foster care are eligible to be certified for WIC program services if they meet age, residency, income, and nutritional risk requirements. Purpose: To ensure eligible infants and children receive appropriate WIC services, and that WIC services continue if guardianship changes. Definition of Foster Care A system in which minor children are placed into the home of a state-licensed foster parent. Minnesota’s foster care system is state-supervised and county-administered, generally through county or tribal social service agencies. Separate from foster care, there are informal custody arrangements in which the child’s parent/ guardian has placed the child in the care of another family member or friend. These arrangements are not considered foster care as administered by the MN Department of Human Services. See Guidance for more information. Procedures Eligibility criteria for applicants not currently active in WIC ▪ At the time of application, the foster infant/child is screened according to procedures described in Section 5.2: Certification Procedures. ▪ A foster child is considered a household of one, with their own household ID. ▪ If siblings enter the same foster care home, those siblings comprise a single household and one household ID number is assigned to them. ▪ Most infants/children in foster care are eligible for MA. Verify status of adjunct eligibility at certification/recertification appointments. ▪ If the child is not adjunctively eligible, their income is the payment made by the social service agency for the care of the child.

S E C T I O N 5 . 5 : C H A N G E I N G U A R D I A N S H I P A N D / O R F O S T E R C A R E 2 ▪ If this documentation is not available, the child can be certified temporarily, provided one month of food benefits, and the foster parent asked to provide the information the following month. ▪ Confirm guardianship/custody by reviewing appropriate documents. ▪ If documentation of guardianship is not available, the child can be certified temporarily, provided one month of food benefits, and the foster parent asked to provide the information next month. ▪ Document any exceptions and reasons if guardianship/custody information is not available. ▪ Assign risk factor 903 Foster Care at the certification if the infant/child entered foster care, or moved from one foster home to another foster home, during the previous 6 months. ▪ Provide careful nutrition assessment and counseling. Foster children are among the most vulnerable participants and may require additional follow-up, support and/or referral to other health care programs. Transferring a participating child from parent to foster care or other custody arrangements ▪ Verify placement of the infant/child in foster care. ▪ Give the infant/child a new household ID. The state ID number will remain the same; only the household number will change. ▪ Issue a new WIC card to the guardian. ▪ If another family member in the foster child’s original household is also enrolled in WIC, place an alert in the foster child’s original household record stating that the child in foster care has a new household ID number. When a child returns to the original household (biological family) or is adopted ▪ The child continues in an active certification. ▪ Add the child to the biological family or adoptive family household if applicable. ▪ If there are no remaining household members, the card issued to the previous household is automatically deactivated. Issuing food benefits ▪ Assess if unredeemed food benefits and/or foods redeemed but not used (including infant formula), are available to the new guardian. ▪ The information system will suggest transferring the remaining food benefits to the new household. Additionally, the CPA may reissue current month’s benefits based on the

S E C T I O N 5 . 5 : C H A N G E I N G U A R D I A N S H I P A N D / O R F O S T E R C A R E 3 assessment of foods available to the new guardian and how much of the benefit month remains. ▪ Transfer any remaining food benefits to the new household, if appropriate. In addition, the CPA may reissue current month’s benefits based on the assessment of foods available to the new guardian and how much of the benefit month remains. The previous household will no longer have access to the child's benefits. ▪ Issue food benefits monthly if there are questions about how long the child will be in foster care and/or in that particular foster home. ▪ Remind foster caregivers that any current and future food benefits belong to and should go with the child when the child leaves their home, and may not be used by foster caregivers. Data Privacy related to foster care ▪ The foster parent is acting as the child’s legal guardian. Therefore, information cannot be released to anyone other than the foster parent/legal guardian without a signed release from the foster parent/legal guardian. ▪ Foster conditions may vary depending on the family situation, foster administrator, and court decisions. Data privacy procedures may need to be handled differently if the WIC agency receives documentation of other legal arrangements. ▪ Protect privacy of foster parents (see guidance). Documentation related to foster care ▪ Place an Alert in the child’s record indicating the child is in foster care. It will be a reminder to the next staff person to ask if there have been changes. ▪ Document health and feeding information in Notes. Guidance Lack of custody documentation ▪ Ask the foster parent to have the infant/child’s social worker send an email or written statement verifying foster placement. ▪ Changes in household may be informal or formal. The intent of this policy is to ensure that certified children have access to their food benefits. Informal custody arrangements that are not formal foster care through the state ▪ When certifying the child, if not adjunctively eligible, determine who is providing the financial support for the child, and use the income of that household.

S E C T I O N 5 . 5 : C H A N G E I N G U A R D I A N S H I P A N D / O R F O S T E R C A R E 4 ▪ A note from the birth parent, MA/SNAP caseworker, or social worker may be used to confirm the child’s residence in that home. Managing multiple WIC Cards ▪ If a foster family has multiple foster children who are unrelated participating in WIC, each child or sibling group is a unique household with their own WIC card. ▪ For each child, along with their household ID, you might include the child's initials on the back of the card, to link the Card to the corresponding child. Concerns about safeguarding the foster parent’s identity ▪ The correct names and addresses of foster parents must be listed in Demographics. ▪ Do not include the name of the foster parent or other identifying information in Notes, because Notes remain part of the permanent record. ▪ In situations where there is a heightened need to protect the identity of the foster parent, use an Alert to notify staff - make it meaningful and succinct to ensure it is read (e.g.,“FOSTER CARE - MUST READ” or similar text). ▪ Instruct staff to “edit” information, if updated, rather than creating new alerts. ▪ Remind staff to read all Alerts each time, as well as to delete unnecessary Alerts. ▪ It’s not necessary to scan documents regarding foster placement into the child’s record. The CPA can indicate in Notes that they reviewed the documents. Reference – Complete Listing of Hyperlinks Section 5.2: Certification Procedures (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_2all.pdf) 903 Foster Care (https://www.health.state.mn.us/people/wic/localagency/riskcodes/903.html) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.6)Minnesota WIC Operations Manual (MOM) Section 5.6: Homeless Applicants and Participants#

(5.6)(document-1)#

Section 5.6: Homeless Applicants and Participants 4/2021 References: 7CFR 246.2 and 246.7(m) Definition: “Homeless individual” means a woman, infant or child: ▪ Who lacks a fixed and regular nighttime residence or ▪ Whose primary nighttime residence is: ▪ A supervised publicly or privately operated shelter (including a welfare hotel, congregate shelter, or a shelter for victims of domestic violence) designated to provide temporary living accommodations ▪ An institution that provides a temporary residence for individuals intended to be institutionalized ▪ A temporary accommodation of not more than 365 days in the residence of another individual, or ▪ A public or private place not designed for, or normally used as, a regular sleeping accommodation for human beings The definition is broad and includes people who may: ▪ Live in cars, abandoned buildings/barns or under bridges ▪ Camp outdoors ▪ Shuttle between friends and relatives ▪ Live in homeless shelters Purpose: To provide eligible homeless participants with appropriate WIC services to which they are entitled. Procedures: Follow standard certification procedures, adapting as needed to accommodate special circumstances of homeless individuals. ▪ Schedule appointments for homeless individuals as promptly as possible. See Section 3.2: Processing Standards-Timeframes for Scheduling Certification Appointments, for required scheduling timeframes. Appointment scheduling should be flexible to meet transportation and other individual needs. ▪ Residency: Homeless applicants must reside in Minnesota.

S E C T I O N 5 . 6 : H O M E L E S S A P P L I C A N T S A N D P A R T I C I P A N T S 2 ▪ Physical Address: In the WIC Information System, record the address or location where the applicant/participant routinely lives or spends the night. Review proof of residency if this can be provided. ▪ If there is not a fixed or formal address for residence, write a description of the address in the “Address” field of the WIC Information System, or write “Homeless”. ▪ If the participant resides in a homeless facility, use the facility address. ▪ A post office box may not be used as the physical residence address except for participants enrolled in the Safe at Home program. (See Section 5.2.2: Residency) ▪ Document unusual situations in Notes if needed to explain the participant’s residence. ▪ Mailing address: Record the mailing address if there is one. If there is none, staff should write “No mailing address” in the “Mail” address section of the WIC Information System. ▪ Residency in a homeless facility: Evaluate eligibility of applicants residing in a homeless facility. Such an applicant may be eligible for the WIC Program if the facility meets all of the following conditions: ▪ The homeless facility does not gain financial or in-kind benefit from a person’s participation in its program (e.g., by reducing its expenditures or food service because its residents are receiving WIC foods). ▪ The WIC foods will be available exclusively to the WIC participant to whom they were issued and must not be used in the communal food service. ▪ The homeless facility places no restrictions on the ability of the participant to use the WIC foods and participate in the nutrition education and breastfeeding support available in WIC. ▪ Income: Standard income guidelines apply (see Exhibit 5-A: Minnesota WIC Income Eligibility Guidelines). ▪ Lack of income, identity or residency documentation – Waiver option ▪ Due to their living circumstances, homeless individuals may not have the necessary documentation of identity, residency or income. If no documentation can be provided, have the participant sign the Certification Notice waiver, confirming this. See Section 5.2: Certification Procedures -All for information about waiver procedures. ▪ Provide appropriate services: ▪ Nutrition Education: ▪ Tailor the nutrition education to the unique needs of the homeless individual. The homeless condition may predispose participants to nutritional risk. ▪ Assess if instruction is needed about how to prepare and store foods with limited refrigeration and cooking facilities is needed.

S E C T I O N 5 . 6 : H O M E L E S S A P P L I C A N T S A N D P A R T I C I P A N T S 3 ▪ Food Package considerations: see Section 7.14: Food Package Options for Homeless Participants. ▪ Referrals: Homeless individuals often have many needs and should be referred to appropriate health and social services and community resources (e.g., MFIP, Food Support, Medical Assistance, food pantries, meal programs, legal services, etc.). Guidance ▪ Residency - WIC Information System functionality ▪ Select the “Homeless” checkbox in Demographics to assign the “Homeless” risk factor (801). ▪ This disables the Residency Proof drop down options. ▪ Although proof of residency must be reviewed by WIC staff at the certification, or a waiver signed, it will not be possible to document that proof in Demographics. This is an exception to usual procedure. ▪ The household mailing address zip code is associated with the WIC Card and is one of the validations used to set the card’s PIN. The mail zip code, as entered in the WIC Information System, would also be needed by the participant to reset their PIN through the Customer Service site or by WIC staff to reset the PIN. ▪ If there are questions as to whether a homeless facility meets required conditions, the MDH Homeless Facility Assessment Form, (Exhibit 5-W) may be used. Contact your State WIC Consultant for more information. Reference – Complete Listing of Hyperlinks Section 3.2: Processing Standards-Timeframes for Scheduling Certification Appointments (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch3/sct n3_2.pdf) Section 5.2.2: Residency (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_2_2.pdf) Exhibit 5-A: Minnesota WIC Income Eligibility Guidelines (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5a. pdf) Section 5.2: Certification Procedures -All (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_2all.pdf) Section 7.14: Food Package Options for Homeless Participants (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_14.pdf)

S E C T I O N 5 . 6 : H O M E L E S S A P P L I C A N T S A N D P A R T I C I P A N T S 4 Exhibit 5-W: MDH Homeless Facility Assessment Form (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5w. pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.7)Minnesota WIC Operations Manual (MOM) Section 5.7: Referrals#

(5.7)(document-1)#

Section 5.7: Referrals 10/2024 References: 7 CFR 246.6 (b)(3); 246.7(b); Immunization Screening and Referral in WIC Policy: Local agencies must provide program applicants and participants information on health and social service programs to meet individual and federal requirements and document those referrals. Purpose: To promote the health and well-being of WIC participants by ensuring awareness of and referral to available resources. Procedures ▪ Establish consistent procedures for making and documenting referrals. ▪ Assess and determine the necessity of sending referrals. ▪ Discuss referrals with participants or parent/guardians, who retain the right to decline them. Medical referrals for High Risk participants Local agency staff must provide health care referrals for participants who meet criteria for high risk conditions and who do not have health care or lack a health care provider who is aware of and/or following their high risk condition. ▪ Refer to: ▪ Exhibit 6A: High Risk and Medical Referral Criteria ▪ Section 6.6: High Risk Individual Nutrition Care Plans ▪ Exhibit 5-Y: Request for Medical Follow Up, for a sample referral form ▪ Document the following items. The documentation should be in the participant record and/or on the scanned correspondence with the Health Care Provider and show: ▪ That a written referral was made and to whom or the reason a referral was deemed unnecessary or declined by the participant ▪ Contents of the medical referral if not scanned into the participant record ▪ Goals specific to the high risk condition ▪ Plans for follow-up ▪ Response from the medical provider, if any

S E C T I O N 5 . 7 : R E F E R R A L S 2 ▪ Follow-up must be provided to assess outcome of the referral and the need for further counseling, referral, and follow-up. ▪ The timeframe for follow-up must be based on the participant’s risk condition and urgency of the issue, such as a low hemoglobin or weight loss during pregnancy. ▪ Participants may not automatically be given tri-monthly benefits. ▪ Send referrals directly to the medical provider rather than requesting that participants take them to the provider. The participant may also be given a copy if requested. Drug and harmful substance abuse referrals ▪ Maintain a list of current and local resources for drug and other harmful substance abuse counseling and treatment. ▪ Provide resources to each family at their first certification, as well as whenever appropriate. Document that the resources were provided in the Information System. ▪ Refer to Section 6.4: Drug and Harmful Substance Use Education for nutrition education guidance. Medical Assistance referrals Local agencies must provide to all adult participants and parents/caregivers of infant and child participants written information about Medical Assistance and make referrals if a participant might be eligible and is not enrolled in the program. ▪ This includes participants who have other insurance coverage, but would also be eligible for Medical Assistance. ▪ Document in the participant record that Medical Assistance information was provided when applicable. Immunization and blood lead testing referrals Local agencies must screen for (at a minimum, ask about) the current immunization and blood lead testing status of infants and children. Refer to Section 5.3.3: Health and Nutrition Information. ▪ If a child’s immunization status is not current, refer to immunization program(s). Document the referral in the Information System. If the family declines an immunization referral, note that in the participant record. ▪ If a child’s blood lead testing is not current, refer to blood lead testing program(s). Document the referral in the Information System. If the family declines a blood lead test referral, document that in the participant record.

S E C T I O N 5 . 7 : R E F E R R A L S 3 Referrals to other community resources Local agencies must maintain a current list (at a minimum, phone numbers) of local community resources for health services, social services, and food assistance programs. Referrals, with adequate contact information, should be made to these programs when there is an identified need or upon participant request. Document referrals to other community resources in the Information System. Child abuse or child endangerment reporting Local agencies must follow local agency policies and procedures for reporting and documenting of child abuse or child endangerment identified by WIC staff. Child abuse or child endangerment reports initiated by WIC staff do not need to be discussed with or accepted by the child’s parent/guardian. Also see Section 1.7: Data Privacy. Release of information required for some referrals ▪ A Release of Information consent form signed by the participant: ▪ Is required if the local agency is sharing the participant’s name and/or personal information with any person or entity outside of the WIC program. Refer to Section 1.7: Data Privacy. ▪ Is not required when WIC staff give participants information about community resources or programs that the participant may then choose to contact on his/her own initiative. Guidance 1. To be most useful to participants, the resource list should include other written information about the various programs (e.g., addresses, brief descriptions). Review resource lists annually to ensure that contact information is still current.

The list of local resources should include but is not limited to: ▪ Health programs ▪ MNsure – Minnesota’s health insurance coverage marketplace ▪ Free or sliding fee medical clinics ▪ Child and Teen Checkup Program ▪ Immunization Program ▪ Lead Screening ▪ Early Childhood Screening Program ▪ Head Start ▪ Family Planning services

S E C T I O N 5 . 7 : R E F E R R A L S 4 ▪ HIV testing services ▪ Postpartum Depression support services ▪ Mental health services ▪ Dental clinics that accept Medical Assistance ▪ Food programs: SNAP, EFNEP, food shelves, and other emergency food programs ▪ Housing ▪ Housing Assistance Programs ▪ Homeless Shelters ▪ Battered Women’s Shelters ▪ Human Services ▪ Social services ▪ Crisis Nurseries ▪ Child Abuse Counseling centers ▪ Unemployment offices 2. Local agencies can obtain program brochures from their local county health and social service offices. 3. Local agencies should establish a process to facilitate referrals within and between programs. Reference – Complete Listing of Hyperlinks Immunization Screening and Referral in WIC (https://www.fns.usda.gov/wic/immunization- screening-referral) Exhibit 6A: Minnesota WIC Program High Risk and Medical Referral Criteria (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex6/6a. pdf) Section 6.6: High-Risk Individual Care Plans (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_6.pdf) Exhibit 5-Y: Request for Medical Follow Up (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5y. pdf) Section 6.4: Drug and Harmful Substance Abuse Education (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_4.pdf)

S E C T I O N 5 . 7 : R E F E R R A L S 5 Section 5.3.3: Health and Nutrition Information (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_3_3.pdf) Section 1.7: Data Privacy (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_7.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.9)Minnesota WIC Operations Manual (MOM) Section 5.9: Clinic Environment#

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Section 5.9: Clinic Environment 2/2024 References: 7 CFR 246.8 and 246.11 (c)(7)(i); Nutrition Service Standards, Standard 2 Policy: The clinic environment should support nutrition and breastfeeding services and protect participant privacy. Purpose: The physical environment of WIC clinics is very important to the effectiveness of nutrition services. The clinic space should be welcoming, user-friendly, and provide privacy for WIC applicants and participants. Procedures All WIC clinics must: ▪ Follow Civil Rights requirements regarding accessibility and display proper nondiscrimination and interpreter/accommodation signage. See Section 1.10: Civil Rights for Civil Rights requirements. ▪ Consider whether clinic site locations support health equity and whether services are easily accessible in areas of need where participants may be potentially underserved. ▪ Evaluate any change in clinic sites using Exhibit 1-R: Civil Rights Impact Analysis Survey and submit it to your State Consultant. See Section 1.10: Civil Rights for guidance. ▪ Inform your State Consultant as soon as you learn about a possible change (opening, closing, or relocation) at any clinic site so they can assist you in the planning process and completing the Civil Rights Impact Analysis Survey. ▪ Provide visual and auditory privacy for WIC applicants/participants. See Section 1.7: Data Privacy for data privacy requirements. ▪ Provide a comfortable attractive space that is: ▪ Well-lit and clean. ▪ Maintained at an appropriate temperature. ▪ Child-friendly and safe with age-appropriate toys and books to keep children busy and engaged. Consider kid-friendly/toddler sized furniture in waiting areas. ▪ Family-friendly with adequate space to accommodate multiple family members, strollers, or a wheelchair. Consider a variety of seating options (multiple seats, wide seats, etc.) Provide clear and visible signage directing participants to the clinic.

S E C T I O N 5 . 9 : C L I N I C E N V I R O N M E N T 2 ▪ Provide a supportive breastfeeding environment. ▪ Display positive and diverse images to encourage and support breastfeeding. ▪ Welcome breastfeeding anywhere, and if feasible, provide a quiet, private space for women to breastfeed. Display clear signage so that the space is easily located. ▪ Keep formula, and related materials and equipment, out of sight. ▪ Use Participant Centered procedures and skills (PCS) to provide appropriate Customer Service: ▪ Provide up-to-date messaging on WIC phones indicating when participants can expect a return call. ▪ Emphasize greeting and welcoming all participants upon entering the clinic. ▪ Be courteous and treat all participants and co-workers with dignity and respect. ▪ Be culturally sensitive. ▪ Be timely to minimize wait time for participants. ▪ Provide quality and timely customer service for phone and electronic communications, as well as for appointments. Guidance ▪ Ensure WIC clinics are: ▪ Located in a safe, well-lit area, with consideration for participant travel, such as available parking, public transportation, and pedestrian safety. ▪ Clearly identified and easy to find, with a well-marked and accessible entrance. Make sure there is adequate signage for the WIC clinic outside and inside the building. ▪ Laid out in a way that promotes efficient and high-quality service. ▪ Requirements and considerations also apply to satellite clinics, pop-up clinic sites, and mobile units. That staff should work closely with the Consultant when designing a new clinic space. ▪ Provide adequate and accessible seating, such as chairs with and without arms. ▪ Use signage that is easy to understand, at eye level (either when sitting or standing), and in the primary languages spoken in the clinic. ▪ Use positive signage over negative wording when possible. For example: ▪ Enjoy your food and drink outside. ▪ Thank you for silencing your cell phone during your appointment. ▪ If you are late for your appointment, we will do our best to work you in if it’s possible. ▪ Inform participants if their appointment start time is delayed.

S E C T I O N 5 . 9 : C L I N I C E N V I R O N M E N T 3 ▪ Ensure that phone voicemail messaging reflects current WIC clinic status. If staff availability to answer phones varies, messaging should be updated each time availability changes so participants will know when they can expect a return call. ▪ Consider health equity when designing clinic spaces so the clinic environment is welcoming to all community members. ▪ Display artwork, posters and other media that reflect the cultures and ethnic backgrounds served by the clinic. Rotate these periodically so that messages stay fresh and current. ▪ Coordinate appointments with other services delivered at the same site to the extent possible. ▪ Provide clinic rooms that: ▪ As possible, provide adequate space to accommodate a family, their belongings, and an interpreter. ▪ Are arranged to encourage and support conversation. To the extent possible, arrange the area in a way that allows participants and staff to sit face to face without physical barriers between them (e.g., knee-to-knee). ▪ Are not cluttered or loud. ▪ Display engaging nutrition-related materials directly visible to participants. ▪ Support safety and security for staff and participants. Consider working with local facilities management on these measures. ▪ Provide activities that keep children occupied in order to enhance communication between caregivers and WIC staff. ▪ Allow access to restrooms that are clean and sanitary, accessible to people with disabilities, and have a diaper changing station. Consider family and unisex restrooms to offer flexibility. ▪ Clearly label biohazard containers. Make sure those and medical supplies are out of the reach of children. ▪ Assess the clinic environment periodically to ensure all spaces meet the clinic environment requirements. Exhibit 5-AA: WIC Clinic Assessment is available to use for this assessment. ▪ Notify your State WIC Consultant when a new site is being considered and complete a Civil Rights Impact Analysis Survey (Exhibit 1-R). Reference – Complete Listing of Hyperlinks Nutrition Service Standards (https://wicworks.fns.usda.gov/sites/default/files/media/document/wic-nutrition-services- standards_0.pdf)

S E C T I O N 5 . 9 : C L I N I C E N V I R O N M E N T 4 Section 1.10 Civil Rights (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_10.pdf) Section 1.7 Data Privacy (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_7.pdf) Exhibit 5-AA WIC Clinic Assessment (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5aa .pdf) Exhibit 1-R: Civil Rights Impact Analysis Survey (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex1/1r. docx) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(5.10)Minnesota WIC Operations Manual (MOM) Section 5.10: Mid-certification#

(5.10)(document-1)#

Section 5.10: Mid-Certification 4/2020 References: 7CFR 246.7 (g) (1); 7CFR 246.11(e) (3); USDA Guidance for Providing Quality WIC Nutrition Services during Extended Certification Periods, August 2011 Policy: Participants with a certification period greater than 6 months require a mid- certification assessment. Purpose: To ensure participants certified for a period greater than 6 months continue to receive quality nutrition services and education. Procedures Timing of mid-certification appointment by category ▪ Infants: around 9 months of age ▪ Children: 6th month of certification (5-7 month time frame) ▪ Breastfeeding women: 6th month of certification or with infant’s mid-certification appointment Mid-certification assessment components To ensure that health and nutrition services are not diminished by an extended certification period, the mid-certification assessment must include: ▪ Anthropometric measurements ▪ Bloodwork (follow WIC bloodwork schedule, Section 5.3.2: Hematologic Assessment) ▪ Update health and nutrition assessment – an abbreviated assessment is necessary to identify any major changes in health status. It includes: ▪ Review information obtained at last certification to adequately compare previous and current screenings, nutrition education and referrals. ▪ New concerns of participant ▪ New medical diagnosis ▪ Changes in eating pattern/food intake ▪ Changes in physical activity

5 . 1 0 : M I D - C E R T I F I C A T I O N 2 ▪ Check on immunization, if appropriate ▪ Nutrition counseling or education ▪ Food package review and change, if needed ▪ Breastfeeding promotion and support ▪ Referrals, if needed Use the Mid-Certification Assessment Question resources as guides: ▪ Midcertification Assessment Questions - Infant ▪ Midcertification Assessment Questions - Child ▪ Midcertification Assessment Questions - Breastfeeding Woman The following components are not required at mid-certification: ▪ Proof of income ▪ Proof of address ▪ Proof of ID ▪ Physical presence ▪ Reviewing WIC Rights and Responsibilities If a mid-certification appointment is missed, local agency staff may issue only one month of benefits and reschedule the mid-certification appointment for the following month. Guidance ▪ Schedule infants’ mid-certification at, or after, the “9 month birthday” to correlate with the WIC bloodwork schedule, Section 5.3.2: Hematologic Assessment. ▪ Bloodwork must be done at or after nine months of age. ▪ In the very rare occasions when an infant’s mid-certification occurs before they are nine months of age, do not test the blood at the mid-certification. Instead, do bloodwork at the next certification (usually at approximately one year of age). ▪ Participants certified for a period of 6 months or less do not require a mid-certification. However, CPAs should follow-up on ht/wt/hgb measurements based on the individual’s nutrition and health status. For example, a premature infant certified at 6 months of age could benefit from a hgb measurement and evaluation around 9 months of age. ▪ Use this mid-certification appointment time to verify address & phone number.

5 . 1 0 : M I D - C E R T I F I C A T I O N 3 Reference – Complete Listing of Hyperlinks Section 5.3.2: Hematologic Assessment (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_3_2.pdf) Midcertification Assessment Questions - Infant (https://www.health.state.mn.us/docs/people/wic/localagency/training/pcs/assessment/mcain fant.pdf) Midcertification Assessment Questions - Child (https://www.health.state.mn.us/docs/people/wic/localagency/training/pcs/assessment/mcac hild.pdf) Midcertification Assessment Questions - Breastfeeding Woman (https://www.health.state.mn.us/docs/people/wic/localagency/training/pcs/assessment/mcab f.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(6.1)Minnesota WIC Operations Manual (MOM) Section 6.1: Introduction#

(6.1)(document-1)#

6.1-1

Section 6.1: Introduction APRIL 2006 Nutrition education is one of the three key elements of the WIC Program. The requirements for nutrition education are specified in federal regulation. This chapter describes: ▪ Required nutrition education contacts ▪ Required content of nutrition education contacts ▪ Documentation requirements for nutrition education Additional Information about Nutrition Education Nutrition Education as defined in the Child Nutrition Act of 1966: NUTRITION EDUCATION —The term ‘‘nutrition education” means individual and group sessions and the provision of material that are designed to improve health status and achieve positive change in dietary and physical activity habits, and that emphasize the relationship between nutrition, physical activity, and health, all in keeping with the personal and cultural preferences of the individual. Nutrition education in the WIC Program is designed to meet two broad goals as stated in the federal regulations: 1. Stress the relationship between proper nutrition and good health with special emphasis on the nutritional needs of pregnant, postpartum, and breastfeeding women, infants, and children under five years of age, and raise awareness about the dangers of using drugs and other harmful substances during pregnancy and while breastfeeding. 2. Assist the individual who is at nutritional risk in achieving a positive change in food habits, resulting in improved nutritional status and in the prevention of nutrition-related problems through optimal use of the supplemental foods and other nutritious foods. This is to be taught in the context of the ethnic, cultural, and geographic preferences of the participants and with consideration for educational and environmental limitations experienced by the participants. Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164- 0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942.

(6.2)Minnesota WIC Operations Manual (MOM) Section 6.2: General Nutrition Education#

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Section 6.2: General Nutrition Education 4/2020 References: 7CFR 246.11, WIC Nutrition Services Standards Policy: The local agency must make nutrition education available to WIC participants or caregivers according to federal and state requirements and to meet the nutrition education needs of families. Purpose: To ensure that WIC participants receive adequate nutrition education intended to improve the health of nutritionally at-risk women, infants, and children. Procedures ▪ Local agencies must designate a Nutrition Education Coordinator to plan and evaluate the agency’s nutrition services. See Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities ▪ All participants must be offered nutrition education at a rate equivalent to quarterly during each certification period. ▪ Provide nutrition education at the time of certification and mid-certification. See Section 6.3: Initial Education and Section 5.10: Mid-Certification. ▪ Provide additional nutrition education, or High Risk Care, at a rate equivalent to quarterly during the certification period. See Section 6.7: Additional Education and Section 6.6: High-Risk Individual Nutrition Care Plan. ▪ Nutrition education should: ▪ address the individual’s nutritional risks and nutritional interests ▪ emphasize the relationship between nutrition, physical activity habits and health ▪ be appropriate to the literacy level of the participant and easily understood ▪ meet the cultural and language needs of the participant ▪ Nutrition education is a benefit of the program and will be provided at no cost to the participant. ▪ Staff may not withhold WIC food benefits from participants who fail to participate in nutrition education.

S E C T I O N 6 . 2 : G E N E R A L N U T R I T I O N E D U C A T I O N 2 Guidance Provision of Nutrition Education ▪ Create and offer options to reduce barriers to nutrition education. Options include education in WIC clinic, by telephone or video call, or through self-guided modules (see Remote Nutrition Education for options). These options allow participants to choose how they would like to receive nutrition at follow-up visits. ▪ If multiple nutrition and health needs for education are identified, the CPA should prioritize those needs and focus education on just 1 or 2 topics. ▪ Use delivery methods/mediums and approaches that are appealing, creative, relevant, and interactive to engage the participant, as well as create opportunities for feedback. Examples include: ▪ Participant Centered Services (PCS): PCS is a counseling approach that helps participants identify their own motivation for change and set individualized, simple, and attainable goals; provides clear and relevant “how to” actions to accomplish those goals; and tailors nutrition education to the needs of the participant. ▪ Technology such as telephone, video calls, and computer modules when appropriate. ▪ Materials that reinforce the education message such as educational cards, a newsletter, video, bulletin boards, and displays. These materials supplement counseling, not replace it. ▪ Incorporate community/national nutrition and physical activity messages (e.g., Fruitsandveggies.org; Dietary Guidelines for Americans; Healthy People Goals; The Surgeon General's Call to Action to Support Breastfeeding; Physical Activity Guidelines for Americans; Bright Futures Nutrition). ▪ Promote WIC as an adjunct to good health care. Reference – Complete Listing of Hyperlinks WIC Nutrition Services Standards (https://wicworks.fns.usda.gov/resources/wic-nutrition- services-standards) Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_3.pdf) Section 6.3: Initial Education (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_3.pdf) Section 5.10: Mid-Certification (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_10.pdf)

S E C T I O N 6 . 2 : G E N E R A L N U T R I T I O N E D U C A T I O N 3 Remote Nutrition Education (https://www.health.state.mn.us/people/wic/localagency/edchoice/index.html) Participant Centered Services (https://www.health.state.mn.us/people/wic/localagency/training/pcs/index.html) Fruitsandveggies.org (https://fruitsandveggies.org/) Dietary Guidelines for Americans (https://health.gov/dietaryguidelines/) Healthy People Goals (https://odphp.health.gov/healthypeople) The Surgeon General's Call to Action to Support Breastfeeding (https://www.cdc.gov/breastfeeding/resources/calltoaction.htm) Physical Activity Guidelines for Americans (https://health.gov/paguidelines/) Bright Futures Nutrition (https://www.brightfutures.org/nutrition/) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(6.3)Minnesota WIC Operations Manual (MOM) Section 6.3: Initial Education#

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Section 6.3: Initial Education 01/2010 References: 246.11 (e)(2) Policy: The local agency must provide nutrition education (Initial Education) at certification and recertification. Purpose: To ensure that nutrition education is made available to all participants. Procedures ▪ Provide nutrition education to all adult participants, parents, or caregivers of infant or child participants at the time of certification or recertification. See Section 6.2: General Nutrition Education. ▪ Nutrition education should be individualized to the participant’s nutritional needs considering the participant’s nutritional risks, anticipatory guidance needs, and the concerns of the participant/caregiver. ▪ Competent Professional Authority (CPA) staff must provide initial education. See CPA policies in Chapter 4. ▪ Provide education regarding the harmful effects of drugs and alcohol at the time of the family’s first certification in WIC. See Section 6.4: Drug and Harmful Substance Use Education. ▪ Encourage all pregnant women to breastfeed unless medically contraindicated. See Section 6.5: Breastfeeeding Education for Pregnant Women. ▪ Participants with high-risk nutrition related conditions should receive appropriate WIC service. See Section 6.6: High Risk Individual Nutrition Care Plans. ▪ Refer participants to other programs and services as appropriate. See Section 5.7: Referrals. ▪ Inform participants of the plan for additional education. ▪ For applicants determined ineligible for WIC, nutrition education and referrals must be offered and documented. ▪ Document nutrition education in the participant’s record. See Section 6.8: Nutrition Education Documentation.

S E C T I O N 6 . 3 : I N I T I A L E D U C A T I O N 2 Guidance ▪ Provide a brief overview of the WIC Program to new participants. The overview should be provided as part of a positive, participant-centered assessment process. CPAs should address the topics below, as appropriate. (The “Welcome to WIC” handbook, which touches on the same topics, can be given to new participants as a resource on the program.) ▪ The purpose of the WIC Program is to provide nutritional support through nutrition education and counseling, nutritious foods, referrals, and breastfeeding promotion and support, to improve participant health. ▪ The nutrition assessment is necessary to identify nutrition needs (e.g., medical conditions, dietary practices) and participant interests so that WIC can provide benefits that are responsive to the participant’s wants and needs. ▪ The relationship between WIC staff and the participant is a partnership – with open dialogue and two-way communication – working to achieve positive health outcomes. ▪ WIC foods are supplemental. The foods satisfy some, but not all of the nutritional needs of participants. ▪ WIC foods are for the participant. WIC foods are prescribed for each participant to promote and support their nutritional well-being. ▪ Explain the length of the certification period. At the end of the period, eligibility will be reevaluated. ▪ Present WIC appointments as an opportunity to ask questions and learn more about nutrition and feeding their family. ▪ If the Minnesota WIC Program has implemented waiting lists, briefly explain that there is a priority system for participation in WIC based on nutritional needs. ▪ Advise the pregnant woman that she should know her HIV status. CPAs can inform the pregnant woman of the following: ▪ The doctor, as a part of prenatal care, can do HIV testing. ▪ There are medications available for HIV positive women that will reduce the chance of transmitting HIV infection to the baby during pregnancy, delivery, and postpartum. ▪ Women who are HIV positive should not breastfeed. ▪ See Section 6.5: Breastfeeeding Education for Pregnant Women for additional information about breastfeeding contraindications. Reference – Complete Listing of Hyperlinks Section 6.2: General Nutrition Education (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_2.pdf) Chapter 4 (https://www.health.state.mn.us/people/wic/localagency/mom.html#staffing) Section 6.4: Drug and Harmful Substance Use Education (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_4.pdf)

S E C T I O N 6 . 3 : I N I T I A L E D U C A T I O N 3 Section 6.5: Breastfeeeding Education for Pregnant Women (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_5.pdf) Section 6.6: High Risk Individual Nutrition Care Plans (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_6.pdf) Section 5.7: Referrals (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_7.pdf) Section 6.8: Nutrition Education Documentation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_8.pdf) Welcome to WIC (https://www.health.state.mn.us/docs/people/wic/ewic/welcometowic.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(6.4)Minnesota WIC Operations Manual (MOM) Section 6.4: Drug and Harmful Substance Use Education#

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Section 6.4: Drug and Harmful Substance Use Education 4 / 2 0 21 References: 7CFR 246.11 (a)(3); 7CFR 246.7 (a) Policy: Local agency must provide information regarding the harmful effects of drugs and alcohol at the time of the family’s first certification in WIC and make referrals as appropriate. Purpose: To improve the health status of WIC participants by preventing and/or reducing the use of alcohol, tobacco, or other drugs. Procedures ▪ Discuss the potential harmful effects of drugs or other harmful substances. This is required for all participants, regardless of current use of substances. ▪ Give printed education materials to pregnant women and the parents/caregivers of infants and children. The printed materials are an adjunct to the one-on-one discussion described in the first bullet, not a replacement. See Guidance for ways to provide materials at remote appointments. The materials should: ▪ Address the harmful effects of alcohol, tobacco, street drugs, and abuse of prescription medications. ▪ Include a current list of local resources for drug or other harmful substance abuse counseling and treatment. Each local agency must have and maintain a listing of these resources in their community. ▪ A specific referral for treatment or counseling for drug or other substance abuse must be provided any time a participant or parent/caregiver is identified as abusing drugs or other harmful substances. Document referral, if given. ▪ Document education and materials were given. ▪ If substance use and/or abuse is suspected or identified at recertification, the information should be given again. A referral for treatment or counseling may also be appropriate. Guidance ▪ For participants certified remotely, options for providing the educational materials and a current listing of local resources for drug or other harmful substance abuse counseling and treatment include:

S E C T I O N 6 .4 : D R UG A ND H A RMF UL S U BS TA NC E A B US E A N D E D UC A T IO N 2 ▪ Mail the materials to the participant. ▪ Send the materials to the participant electronically, e.g., by email. ▪ Send links to the materials to the participant electronically, e.g., email or text. ▪ Educational materials that address the harmful effects of alcohol, tobacco and street drugs are available from MDH. ▪ Local agencies should include smoking cessation programs on the resource listing. ▪ Refer to Risk Code 372 Alcohol and Substance Use for more information on risks and implications for WIC Nutrition Services. ▪ Refer to Section 6.7 for the education requirements of the Postpartum Exit Counseling Contact, which includes discussion of the health risks associated with the use of alcohol, tobacco and other drugs. Reference – Complete Listing of Hyperlinks Risk Code 372 Alcohol and Substance Use (https://www.health.state.mn.us/people/wic/localagency/riskcodes/372.html) Section 6.7: Additional Nutrition Education (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_7.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164- 0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942. This institution is an equal opportunity provider.

(6.5)Minnesota WIC Operations Manual (MOM) Section 6.5: Breastfeeding Education for Pregnant Women#

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Section 6.5: Breastfeeding Education for Pregnant Women 4/2021 References: 246.11(3)(1) Policy: The Local Agency must provide all pregnant women the opportunity to discuss breastfeeding, unless breastfeeding is medically contraindicated. Purpose: To enable pregnant women to make an informed decision about feeding their infant and to overcome any perceived barriers to breastfeeding. Procedures ▪ If the participant has not asked about breastfeeding, the CPA should begin a discussion, providing an opportunity for the participant to express her questions and concerns. ▪ If there are known reasons that breastfeeding is contraindicated, the CPA must document the reason breastfeeding was not discussed. ▪ If there is a concern that breastfeeding may be contraindicated, encourage the participant to discuss breastfeeding with her health care provider, so that the risk/benefit can be assessed. Information on potential contraindications to breastfeeding is listed below. Guidance Breastfeeding Counseling There are several ways to begin a discussion about breastfeeding. CPAs are encouraged to find a method that works best for the participant and the CPA’s counseling style. ▪ Training on breastfeeding counseling is offered regularly. The state can suggest proven/reputable breastfeeding counseling techniques and training opportunities. ▪ The “three – step” counseling method is recommended.

S E C T I O N 6 . 5 : B R E A S T F E E D I N G E D U C A T I O N F O R P R E G N A N T W O M E N 2 ▪ This uses open–ended questions, such as: “What have you heard about breastfeeding?” or “What are your thoughts about breastfeeding?” ▪ Training on the 3-step counseling method is offered when requested. To request training, contact the State WIC Breastfeeding Coordinator. ▪ Simply asking if the participant intends to breastfeed is not an effective counseling strategy. Breastfeeding Contraindications There are few true contraindications to breastfeeding and very few contraindications that will be apparent during pregnancy. The information that follows is for guidance only. Knowledge about breastfeeding is rapidly changing, resulting in changes to recommendations. Use this information as a starting point to seek additional information. Maternal conditions in which breastfeeding is contraindicated ▪ HIV positive or has AIDS. ▪ Human T-Cell Leukemia virus Type I (HILV-1). ▪ Medications such as antineoplastic agents, therapeutic radiopharmaceuticals, and lithium. Other medications may be contraindicated; however, there is usually an acceptable alternative to the medication. Advise participantsto discuss medications with their health care provider. ▪ Unusually heavy exposure to environmental contaminants. Contraindicated only if maternal levels are high. Maternal conditions in which breastfeeding is contraindicated until the condition resolves or is treated ▪ Herpes simplex virus (HSV) on the breast itself ▪ Current use of street drugs or abuse of prescription medications. ▪ Other diseases when infant contact with the mother is not recommended for either breast or bottle-feeding, such as varicella herpes (chicken pox) or active untreated tuberculosis, until it is permissible for the mother to be in contact with the infant. Resources for information about potential contraindications to breastfeeding. ▪ The Transfer of Drugs and Therapeutics into Human Breast Milk: An Update on Selected Topics)AAP Committee on Drugs. Pediatrics 132(3). September 2013. Reaffirmed May 2018. ▪ Medications and Mothers Milk, 19th edition, 2021 Thomas Hale. Springer Publishing. ▪ Infant Risk Center Texas Tech University Health Sciences Center. Staff answer questions from professionals about medication use while breastfeeding or during pregnancy. 8 am – 5 pm CST weekdays. ▪ Drugs and Lactation Database (LactMed®)

S E C T I O N 6 . 5 : B R E A S T F E E D I N G E D U C A T I O N F O R P R E G N A N T W O M E N 3 ▪ Drugs in Pregnancy and Lactation 11th edition, 2017. Gerald Briggs, et al. Lippincott (12th edition to be released April 2021) ▪ Contraindications to Breastfeeding or Feeding Expressed Breast Milk to Infants Centers for Disease Control and Prevention, 2019. Reference – Complete Listing of Hyperlinks The Transfer of Drugs and Therapeutics into Human Breast Milk: An Update on Selected Topics (https://pediatrics.aappublications.org/content/132/3/e796) Infant Risk Center (https://www.infantrisk.com/) Drugs and Lactation Database (LactMed®) (https://www.ncbi.nlm.nih.gov/books/NBK501922/?report=classic) Contraindications to Breastfeeding or Feeding Expressed Breast Milk to Infants (https://www.cdc.gov/breastfeeding-special-circumstances/hcp/contraindications/index.html) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(6.6)Minnesota WIC Operations Manual (MOM) Section 6.6: High Risk Individual Nutrition Care Plans#

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Section 6.6: High Risk Individual Nutrition Care Plans 10/2024 References: 7CFR 246.11(e)(5) and Nutrition Service Standards: 3, 7, and 14 Policy: Develop an individual nutrition care plan (INCP) for participants who meet the Minnesota WIC Program High Risk and Medical Referral Criteria and for any participant requesting one. Purpose: To ensure that participants with high risk nutrition related conditions receive appropriate WIC services and referrals. Goals of High Risk Care All WIC participants are at nutritional risk, but some health conditions put participants at greater risk for poor health outcomes. Some of the goals of WIC high risk nutrition education and follow-up are to: ▪ Reduce fetal deaths and infant mortality. ▪ Reduce the incidence of infants born at low birth weight. ▪ Reduce the impact of breastfeeding complications. ▪ Increase the duration of pregnancy. ▪ Improve growth of nutritionally at-risk infants and children. ▪ Reduce the incidence of iron-deficiency anemia. ▪ Assure regular medical care and follow-up. ▪ Make referrals for health care or for other resources as needed. Procedures 1. Grantees are responsible for having on staff (or by contract) a credentialed nutrition professional to provide nutrition services to high risk participants (see first bullet point under Guidance). 2. At a minimum, the Local Agency must use the high risk criteria defined in Exhibit 6-A: High Risk and Medical Referral Criteria, for determining when an INCP is required. Additionally, INCPs should be developed:

S E C T I O N 6 . 6 : H I G H R I S K I N D I V I D U A L N U T R I T I O N C A R E P L A N S 2 ▪ when the condition or situation warrants an INCP in the CPA’s professional judgment and ▪ when requested by a participant. 3. INCPs must be developed and documented specifically addressing the high risk condition(s) identified, and must include: ▪ Assessment of the individual’s overall situation including nutrition status, needs, and any problems. ▪ Review of health services for the high risk condition being provided elsewhere. ▪ Specific goals/recommendations regarding the high risk condition. ▪ Referrals to healthcare providers (HCP) and other programs and services as needed. ▪ Plans for follow-up visits. 4. Follow-up addressing the status of the high risk condition must be provided at least quarterly until the high risk condition is resolved or stable. Guidance Staffing High risk care should be provided and/or coordinated by the agency’s credentialed nutrition professional(s) which include registered dietitians (or registration-eligible), individuals with a bachelor’s or master’s degree in nutrition, or Minnesota Licensed Nutritionist/Dietitians. See Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities. ▪ Other CPAs may provide High Risk Care. All non-nutrition credentialed staff providing High Risk Care are required to have or obtain the specialized skills and knowledge before providing High Risk Care, which must include: ▪ At minimum, completion of the Nutrition Modules in the New Staff Training Plan is required for non-nutrition credentialed staff. See WIC New Staff Training. Additionally, a strong understanding of nutrition in health and disease, its application to public health practices, and knowledge of the nutrition needs of infants, children, and women during the prenatal, postpartum, and breastfeeding periods. ▪ Knowledge of effective counseling and educational concepts and methods. Completion of the High Risk Counseling modules in the New Staff Training Plan is required for all CPAs who will be providing High Risk care. See WIC New Staff Training. ▪ Ability to develop and carry out on-going plans for nutrition education. ▪ Agencies with paraprofessional CPAs (locally trained CPAs) are required to have procedures in place to assure paraprofessional staff refer high risk participants to a nutrition professional. See Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities.

S E C T I O N 6 . 6 : H I G H R I S K I N D I V I D U A L N U T R I T I O N C A R E P L A N S 3 High Risk Criteria ▪ Criteria for INCPs and medical referrals are found in Exhibit 6-A: High Risk and Medical Referral Criteria. If the participant is not receiving medical care for the identified high risk condition, a written medical referral should be made. Referrals should be discussed with participants/parents/guardians; they have the right to decline referrals. The CPA should exercise professional discretion in deciding the necessity of sending a referral. See Section 5.7: Referrals and Exhibit 5-Y: Minnesota WIC Program Request for Medical Follow-Up. ▪ Refer to the procedure for Resolving High Risk Designation below if the participant has been system-assigned as high risk but does not meet the high risk medical and referral criteria. Develop and Provide Individual Nutrition Care Plan (INCP) 1. Assessment of the individual’s overall situation: The nutrition assessment at certification/recertification identifies any high risk conditions or issues that need be addressed in an INCP. The assessment should include: ▪ Identification of most significant risk factors present ▪ Evaluation of anthropometric and blood-work data ▪ Diet assessment ▪ Instructions or prescriptions (if any) from health care provider(s) ▪ Participant's/caregiver's knowledge of and attitude toward the condition(s) ▪ Any relevant concerns expressed by the participant or caregiver 2. Review of health services for the high risk condition being provided elsewhere: ▪ Identify the medical/nutritional support services the participant currently receives, including the frequency and extent of nutrition counseling from other sources. ▪ Reinforce the medical/nutritional recommendations of other health care providers. 3. Provide specific goals/recommendations regarding the high risk condition: ▪ With the participant/caregiver, identify strategies that will be used to alleviate or resolve the condition(s) or issues. ▪ Individualize the strategies to the circumstances of the participant. 4. Provide referrals to health care providers and other programs and services as needed. 5. Determine Plans for follow-up visits: Frequency of follow-up should be based on the health condition and individual’s needs. ▪ Some participants may need to be seen monthly; others only bi- or tri-monthly. ▪ For example, it might be prudent to plan monthly follow-up for a pregnant woman with a low rate of weight gain, until expected or desired weight gain is observed.

S E C T I O N 6 . 6 : H I G H R I S K I N D I V I D U A L N U T R I T I O N C A R E P L A N S 4 ▪ At a minimum, follow-up should continue at least quarterly until the condition is resolved or stabilized. Documentation of INCPs Documenting INCPs is essential for providing the best-individualized and responsive services to participants. ▪ Documentation must be adequately detailed and comprehensive so that the condition, nutrition intervention, and planned follow-up are clear to others reviewing the record. ▪ Documenting in a SOAP (Subjective, Objective, Assessment, Plan) note in the WIC Information System is preferred, but another method may be used if approved in the local agency’s nutrition education plan. Providing High Risk Follow-up The CPA should exercise professional discretion when determining the specific course of high risk follow-up. This includes determining the frequency, type (in-person or remote), and nature of follow-up activities based on the participant's health condition and individual needs. Frequency and type of follow-up ▪ At a minimum, follow-up should continue at least quarterly until the condition is resolved or stabilized. Some participants may need to be seen more frequently (e.g., monthly, or bi- monthly). ▪ Type of follow-up (in-person versus remote) should be determined based on the participant’s needs and the follow-up activities that are of the most importance for managing or resolving the high risk condition. ▪ High risk follow-up examples: ▪ It might be prudent to plan monthly follow-up for a pregnant woman with a low rate of weight gain, until expected or desired weight gain is observed. ▪ For a breastfeeding dyad with breastfeeding complications (risk factor 602 or 603), monthly or more frequent follow up may be necessary due to the time sensitive nature of lactation. Frequent follow up allows for support in maintaining milk supply and monitoring for adequate infant growth. In cases where infant’s growth is slower than expected, monthly weight checks can prevent more serious issues. ▪ For a child assigned risk factor 113 after an initial certification whose assessment reveals no major concerns, it might be fitting to plan a verbal follow-up in three months, with a full re-assessment of height and weight in six months (at the Mid-certification). Follow-up may include some, or all, of the following: ▪ Dietary assessment. ▪ Monitoring anthropometric measurements and discussion of growth and weight gain/loss.

S E C T I O N 6 . 6 : H I G H R I S K I N D I V I D U A L N U T R I T I O N C A R E P L A N S 5 ▪ Monitoring hemoglobin and discussion of blood work results. ▪ Discussion of participant's/caregiver's nutrition or health-related concerns. ▪ Discussion or reinforcement of instructions given by other health care providers. ▪ Assessment of food package needs and/or revision of food package prescription. ▪ Individualized nutrition education. ▪ Monitoring participants with complex medical problems or serious risks to assure they are receiving adequate care from appropriate health/nutrition professionals. ▪ Referral to the Designated Breastfeeding Expert and/or another lactation professional for complex breastfeeding concerns. ▪ Referral to other programs and services, as needed. ▪ Follow-up on referral to other programs. ▪ Monitoring/modifying realistic goals established with participant/caregiver. Resolving High Risk Designation The CPA may resolve the system assigned high risk designation after a thorough assessment, and based on their professional discretion, in the following circumstances: 1. Participant does not meet the additional qualifying criteria for the high risk designation per Exhibit 6-A: High Risk and Medical Referral Criteria (e.g., risk codes 101 and 113) and no other high risk conditions are present. 2. High risk condition is beyond the scope of WIC and the participant is receiving appropriate ongoing care from a qualified healthcare provider. ▪ See Nutrition Support provided by another HCP section below for guidance on appropriate documentation and follow-up in this situation. ▪ This situation should be uncommon, as WIC plays a crucial role in helping participants resolve and manage their high risk condition(s). 3. High risk condition has resolved or stabilized, and further monitoring would be unnecessary or not beneficial. This may apply to anthropometric risk codes when growth is stable (e.g., risk codes 103, 131, 133). ▪ Always document the reason for resolving the high risk designation with a note in the information system. This is in addition to the system-generated High Risk Resolution note. ▪ Keep in mind that in some cases, it may be beneficial to continue high risk care to prevent relapse. ▪ A medical referral is not required if the high risk designation is resolved.

S E C T I O N 6 . 6 : H I G H R I S K I N D I V I D U A L N U T R I T I O N C A R E P L A N S 6 How to resolve the system-assigned high risk designation To resolve the system-assigned high risk designation in the Information System, the CPA shall: ▪ Go to: Risk Factors screen >> Select: “Assign Risk Factors” >> Check: “Resolve System- assigned High Risk Designations.” Nutrition Support provided by another HCP ▪ If appropriate nutrition support is provided by another HCP, with expertise in the condition, comprehensive care, and follow-up may not be necessary by WIC. ▪ To indicate that appropriate nutrition care is provided by another HCP, the CPA should document the following: ▪ The fact that the participant is receiving nutrition care elsewhere for the Condition. ▪ Name, location, and phone number of the provider if available. ▪ Expertise of the provider(s), e.g., MD, RD, Certified Diabetes Educator, Occupational Therapist, Physical Therapist, etc. ▪ How often the participant is being seen by care provider(s). ▪ Time frame for the next WIC nutrition education contact. ▪ Non-high risk follow-up could, therefore, be provided at the additional education contact. However, it may be beneficial to retain high risk status for the following reasons: ▪ To follow-up on referrals. ▪ To answer questions, especially if the condition is newly diagnosed. ▪ To assure that the participant is stable and has not relapsed. ▪ To assure that the participant continues to receive follow-up from the HCP if needed. NOTE: “High risk” is a term used in WIC to designate the need for more advanced nutrition care. When counseling WIC participants determined to have a high risk condition, you do not need to tell them they are “high risk”. Consider saying something like “I would like to follow-up with you in one month to see how you are doing.” or “This is an important time for growth and development. I would like to see you (your child) next month to see how you are doing, and to answer questions.” Related Policies: ▪ Section 6.4: Drug and Harmful Substance Abuse Education ▪ Section 5.7: Referrals

S E C T I O N 6 . 6 : H I G H R I S K I N D I V I D U A L N U T R I T I O N C A R E P L A N S 7 Reference – Complete Listing of Hyperlinks Nutrition Service Standards (https://wicworks.fns.usda.gov/sites/default/files/media/document/wic-nutrition-services- standards_0.pdf) Exhibit 5-Y: MN WIC Program Request for Medical Follow-Up (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5y. pdf) Exhibit 6-A: High Risk and Medical Referral Criteria (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex6/6a. pdf) Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sct n4_3.pdf) New Staff Training (https://www.health.state.mn.us/people/wic/localagency/training/nst.html) Section 5.7: Referrals (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_7.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(6.7)Minnesota WIC Operations Manual (MOM) Section 6.7: Additional Education#

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Section 6.7: Additional Nutrition Education 08/2026 References: 7CFR 246.11(e)(2) Policy: Provide additional nutrition education during the certification period. Purpose: To ensure that additional nutrition education is made available to all participants throughout their certification period. Definitions Additional Nutrition Education: Education contacts that occur at a time other than the certification appointment. Contact: A contact is an interaction between the nutrition educator and the participant to explore opportunities for behavior change, provide anticipatory guidance, and address areas of nutrition risk. Procedures Procedures for providing high risk care are not included in this policy. Participants with a high risk nutrition related condition receive additional care and follow up as outlined in Section 6.6: High Risk Individual Nutrition Care Plans. Content of additional nutrition education contacts: ▪ Is based on the participant’s nutritional needs and category (i.e., risks, participant concerns, and anticipatory guidance). ▪ Includes follow-up to medical referrals and other referrals as needed. See Section 5.7: Referrals. Number of additional nutrition education contacts is based on the length of the certification period. ▪ For participants certified for a period greater than 6 months, nutrition education contacts shall be made available at a rate equivalent to quarterly. This includes the education provided at the initial certification, see Section 6.3: Initial Education, and mid-certification appointments, see Section 5.10: Mid-certification.

S E C T I O N 6 . 7 : A D D I T I O N A L N U T R I T I O N E D U C A T I O N 2 ▪ For example: A child certified for one year will receive an initial contact at certification, an educational contact at mid-certification and two additional nutrition education contacts. This provides four contacts in the one year certification period. ▪ Participants certified for a period of six months or less should be provided a minimum of one additional nutrition education contact, in addition to the initial contact at certification. ▪ For example: Pregnant women certified for more than one month must be offered additional nutrition education before their due date. Delivery methods/mediums for additional nutrition education should be interactive and accommodate individual learning styles and needs. Types may include: ▪ Individual: Nutrition education provided to the participant/parent/guardian or proxy based on the unique needs of the participant and/or interests. Individual contacts may be provided in person, by phone or video calls. ▪ Group: A class or facilitated discussion with a qualified instructor. The group contact should be relevant to the participant’s category. ▪ Self-Guided: Pre-approved web-based nutrition education or other interactive media. This option requires that the participant be given the opportunity to interact with a CPA to discuss the content of the self-guided contact and to ask questions. The CPA should follow- up on any goals or strategies that the participant identified at the end of the self-guided contact. See Guidance for wichealth.org. ▪ Other methods as described and approved in the local agency Nutrition Education Plan. Documentation Documentation of additional nutrition education should promote continuity of care. Follow documentation procedures as outlined in the local agency Nutrition Education Plan. See Section 6.8: Nutrition Education Documentation. Maintain confidentiality Individual contacts should be conducted in a private area rather than in a public waiting room. Participants should not be asked to share private, confidential information in a public or group setting. Missed Contacts If an additional nutrition education contact is missed and not be rescheduled during the current benefit period due to the participant/parent/guardian’s availability, issue one month of benefits and schedule the contact for the following month. If the participant/parent/guardian refused nutrition education, document that in their record.

S E C T I O N 6 . 7 : A D D I T I O N A L N U T R I T I O N E D U C A T I O N 3 Guidance Create and offer options to reduce barriers to nutrition education. Transportation, childcare, and work obligations can make it difficult for families to participate in nutrition education activities. Participants can choose how they would like to receive nutrition education at follow up visits. Options include education by telephone, video call, self-guided modules, or in WIC clinic. Remote Nutrition Education provides guidance on strategies to offer nutrition education outside of the WIC clinic setting. Timing of contacts Additional nutrition education contacts should be provided at a rate equivalent to quarterly, but not necessarily every 3 months. Consider the needs of the participant when scheduling their follow-up. For example, a CPA may choose to provide an additional nutrition education contact one month after an infant’s initial certification to support continued breastfeeding, rather than waiting three months. Wichealth.org wichealth.org: is a pre-approved web-based program available to local WIC participants in Minnesota for self-guided nutrition education. It is intended for participants considered low- risk, with no high risk conditions. For guidance on using wichealth.org visit Remote Nutrition Education. For households with multiple members, the family may complete one lesson. However, as with in-person educational contacts, education should be relevant and individualized to the category and needs of each family member. ▪ Follow up to the on-line lesson should include discussion of any family member’s nutrition/health in a category not covered by the on-line lesson. Example: A family includes breastfeeding mother, 5 month old infant and a 4 year old child. Mom completed a wichealth.org lesson about snacking for children. When contacting the household for follow-up, the CPA should follow up on mom and infant’s nutrition and health needs/concerns and provide education as needed. Document education in each member’s record. ▪ Follow-up on self-guided nutrition education may be by phone, video call or text/email. When using texting/emailing, assure the same opportunities for follow-up are offered to the participant as with phone/video calls. This includes an interaction between the CPA and participant to allow the participant to ask questions and to schedule their next WIC recertification, mid-certification, or additional nutrition education contact. Assure Data Privacy is maintained, see Section 1.7: Data Privacy.

S E C T I O N 6 . 7 : A D D I T I O N A L N U T R I T I O N E D U C A T I O N 4 Additional Education provided by an outside entity An outside entity may provide additional nutrition education for participants if the following criteria are met: ▪ The additional nutrition education content is appropriate for the individual’s nutritional risks and nutritional interests, the encounter is within the current WIC certification period and the education is documented. ▪ Services provided by staff from an outside entity must be within their scope of practice. ▪ WIC CPA staff should be present in the area to respond to questions that are beyond the scope of knowledge/practice of the outside entity staff person. ▪ Lesson plans written by the outside entity for the additional nutrition education contacts should be reviewed and approved by the local agency Nutrition Education Coordinator. ▪ If an outside entity staff person is used for providing additional nutrition education, local agencies are encouraged to enter into an annual agreement with the entity addressing the following roles/expectations: ▪ Time period the agreement covers. ▪ Responsibilities of the staff from the outside entity: e.g., day(s) of month staff will provide contacts; topic(s); length of clinic day; arrangements for backup, if staff is unable to attend the WIC clinic; and assurance that participant confidentiality will be maintained. ▪ WIC responsibilities: providing space, setting up the room, communication regarding schedule changes and materials, and CPA staff present to answer participant questions. ▪ The contacts should be documented per the local agency documentation procedures. See Section 6.8: Nutrition Education Documentation. Exit Counseling ▪ Exit counseling is encouraged as part of an additional education individual contact for all breastfeeding and non-breastfeeding postpartum women before their certification ends. Exit Counseling helps build a solid foundation for good nutritional health, beyond a woman’s eligibility for WIC benefits. ▪ Exit counseling can include verbal education and/or written information (hard copy or electronic) on the topics listed below. The purpose of Exit Counseling is to reinforce the nutrition education and breastfeeding promotion provided during WIC participation. Document the exit counseling education and written information provided in the participant record: ▪ The importance of preconceptual folic acid intake in reducing neural tube defects. Share the message that folic acid supplementation before a future pregnancy can lower the risk of neural tube defects.

S E C T I O N 6 . 7 : A D D I T I O N A L N U T R I T I O N E D U C A T I O N 5 ▪ Encourage breastfeeding as the preferred method of infant feeding ▪ The importance of immunizations ▪ The health risks associated with the use of alcohol, tobacco, and other drugs ▪ The need for a well balanced diet ▪ Referrals as appropriate Reference – Complete Listing of Hyperlinks Section 6.6: High Risk Individual Nutrition Care Plans (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_6.pdf) Section 5.7: Referrals (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_7.pdf) Section 6.3: Initial Education (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_3.pdf) Section 5.10: Mid-Certification (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_10.pdf) Remote Nutrition Education (https://www.health.state.mn.us/people/wic/localagency/edchoice/index.html) Section 6.8: Nutrition Education Documentation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_8.pdf) Minnesota Department of Health - WIC Program, 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us; To obtain this information in a different format, call: 1-800-657-3942. This institution is an equal opportunity provider.

(6.8)Minnesota WIC Operations Manual (MOM) Section 6.8: Nutrition Education Documentation#

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Section 6.8: Nutrition Education Documentation 1/2024 References: 246.11(e)(4) Policy: The local agency must document nutrition education in each participant’s Information System Record. Purpose: To help WIC staff consistently follow-up and reinforce education already provided. To ensure that appropriate education is provided for the participant. Procedures Nutrition Education Documentation must: ▪ Describe the education provided to participants in a manner that is easy to retrieve and review. ▪ Facilitate communication between CPAs and promote continuity of care. Procedures for documenting Initial Education ▪ Initial education contacts, which are completed at the certification or recertification appointment, must be documented in the participant’s record. The required components are: ▪ Participant name ▪ Date the education was provided ▪ Topics discussed ▪ Plan for subsequent visits ▪ Name of CPA who provided the education (The Information System automatically records the User Name). ▪ Initial education contacts may be documented in one of the following locations in the Minnesota WIC Information System: ▪ Nutrition Education page (with Notes in the WIC Information System as needed) ▪ Is an option for documenting topics discussed, materials given, peer referrals, and goals.

S E C T I O N 6 . 8 : N U T R I T I O N E D U C A T I O N D O C U M E N T A T I O N 2 ▪ May be used to help minimize the time and effort needed to document nutrition education topics. ▪ Should be used in conjunction with the Notes function as needed. ▪ For some low-risk participants, documentation of nutrition education in the Nutrition Education page may be sufficient. ▪ Notes in the WIC Information System ▪ Use for High Risk Individual Nutrition Care Plan (INCP) documentation and other narratives. ▪ document the unique needs of a participant and facilitate care and follow-up. ▪ For example, if formula is issued to a breastfeeding infant per the family’s request, document the education provided to support continued breastfeeding and to facilitate appropriate follow up on the food package. See Section 7.4: Supporting Breastfeeding with the WIC Food Package. ▪ A local agency may elect to document all nutrition education in notes. ▪ For high-risk participants requiring an Individual Nutrition Care Plan (INCP), See Section 6.6: High Risk Individual Nutrition Care Plan. Procedures for documenting Additional Education ▪ Options for documenting individual additional education contacts: ▪ Nutrition Education page (with Notes in the WIC Information System as needed). This method may be adequate for low risk participants. ▪ Notes in the WIC Information System. ▪ Options for documenting additional education contacts that are provided in a group setting. (This includes a display board with an educator.) ▪ Nutrition Education page in the WIC Information System. (A separate record should be maintained of the class or display topics, content outline, instructor, and dates presented.) ▪ Notes in the WIC Information System – document the date and class title. (A separate record should be maintained of the class or display topics, content outline, instructor, and dates presented.) ▪ Options for documenting additional education contacts that are self-guided (this includes computer-based nutrition education): ▪ Nutrition Education page in the WIC Information System. ▪ Wichealth.org lesson documentation: When a participant completes a wichealth.org lesson, the lesson topic and date information imports from wichealth.org to the Nutrition Education page, Group Education Contacts in the Information System. Please see Procedures for using wichealth.org as an Education Choice for additional information.

S E C T I O N 6 . 8 : N U T R I T I O N E D U C A T I O N D O C U M E N T A T I O N 3 ▪ Notes in the WIC Information System. ▪ Documentation should also include a record of education offered and either missed or refused and the reason the participant did not attend. Documentation for Continuity of Care To facilitate continuity of care, local agency documentation procedures should: ▪ Promote seamless services across all staff. ▪ Be followed consistently by all staff in the agency to minimize duplication of information. ▪ Be clear so that other staff, including those in other local agencies, can easily understand what the author is communicating. Use established terminology and abbreviations. ▪ Describe the services provided to help other staff understand the plan for future services. ▪ Be concise so that it contains pertinent information and minimal extraneous information. Guidance ▪ For additional information on documentation best practices, see WIC Nutrition Education Documentation. Reference – Complete Listing of Hyperlinks Section 7.4: Supporting Breastfeeding with the WIC Food Package (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_4.pdf) Section 6.6: High Risk Individual Nutrition Care Plan (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_6.pdf) Procedures for using wichealth.org as an Education Choice (https://www.health.state.mn.us/docs/people/wic/localagency/nutrition/edchoice/procedures .pdf) WIC Nutrition Education Documentation (https://www.health.state.mn.us/people/wic/localagency/nedocumentation.html) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(6.9)Minnesota WIC Operations Manual (MOM) Section 6.9: Nutrition Education Materials#

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Section 6.9: Nutrition Education Materials 03/2024 References: 246.11(c)(3) Policy: Local agencies should use appropriate nutrition education materials that deliver accurate and consistent messages to participants and address the nutritional needs of participants. Purpose: To assure the use of appropriate, accurate, high-quality nutrition education materials. Procedures ▪ Nutrition education materials provided by the state office are designed to support and enhance nutrition-focused counseling efforts in local agencies. Materials are developed and evaluated for content accuracy and appropriateness for WIC participants. ▪ Materials are routinely reviewed for scientific accuracy and health literacy principles such as plain language, reading level, format, and graphic design. Language and cultural appropriateness are also considered. This review is conducted by State Consultants, working with the Nutrition Education workgroup. Local agencies are encouraged to order and utilize materials available from the state office. ▪ Local agencies may purchase or develop nutrition education materials. These materials must be reviewed for scientific accuracy and health literacy principles. See guidance for developing and reviewing nutrition education materials. Guidance ▪ When a local WIC agency uses nutrition education materials not provided or suggested by the state office, the nutrition coordinator for the agency should evaluate the materials. Consider the following criteria as you develop and/or evaluate nutrition education materials. These criteria apply to most educational materials, including printed and electronic. For a more detailed evaluation of nutrition education materials, use one of the resources listed in the Resources section below.

S E C T I O N 6 . 9 : N U T R I T I O N E D U C A T I O N M A T E R I A L S 2 ▪ The content should: ▪ Be current, accurate, and consistent with evidence-based recommendations. Use credible resources, e.g., American Academy of Pediatrics, United States Department of Agriculture, and Centers for Disease Control. ▪ Address relevant health issues for the target audience. Is the information appropriate for pregnant, breastfeeding, postpartum, infant and child participants? ▪ Have a clear purpose. Is the intent of the material apparent? ▪ Materials should be behavior focused and: ▪ Contain just one or two main themes, e.g., “Five strategies for increasing activity” is one theme. ▪ Clearly state the actions you want your audience to take. Focus on behavior rather than medical facts or statistics. ▪ Include specific examples of desired behaviors in a positive manner, e.g., play tag with your children. ▪ Be encouraging by offering small, practical steps. ▪ Consider culture: ▪ Use terms that your target audience uses and/or is comfortable with. ▪ Use culturally appropriate images for the target audience. ▪ Choose your words carefully and: ▪ Keep it short. Use simple, common words. Avoid abbreviations, acronyms, and technical jargon. If you need to use an unfamiliar term, explain it in the text. ▪ Avoid long, complex sentences containing multiple phrases and clauses. Keep most sentences to between eight to ten words. ▪ Use active voice. Active voice is where the subject does the action, e.g., “Use WIC foods for snacks between meals” rather than “WIC foods can be used as snacks between meals”. ▪ Be conversational. Communicate like you are talking to a friend. ▪ Promote Readability by: ▪ Displaying information in a logical order, with the most important messages first. ▪ Keeping sentences simple, short, and specific. ▪ Limiting paragraphs to one topic. ▪ Adding white space around headings and text. ▪ Using bullets, numbers, and tables to make information easier to scan and read. ▪ Choosing an easy-to-read font. Font should be at least 12 point.

S E C T I O N 6 . 9 : N U T R I T I O N E D U C A T I O N M A T E R I A L S 3 ▪ Using images that are relevant to the text and communicate a message. Images should show instruction or desired behaviors. ▪ Assuring material is written at 5th-grade reading level or lower. Suggested ways to test readability include: ▪ Pre-test the material readability with a sample group from your intended audience. ▪ Use a readability formula such as the SMOG Readability Formula. Making Health Communication Programs Work in the Resource section below includes a guide to using the SMOG Readability Formula. ▪ Accurately translate materials: ▪ Use a skilled professional translator with the necessary writing skills and cultural knowledge, or, at a minimum, have a skilled translator review a local translation. ▪ Translate for meaning, rather than word for word. ▪ Be cautious of online translation tools. These tools can have errors and may not correctly convey the meaning and nuances of the text. If an online translation tool is used, have a skilled translator review the translation before it is used. Resources and Reference – Complete Listing of Hyperlinks CDC Clear Communications Index (https://www.cdc.gov/ccindex/pdf/clear-communication- user-guide.pdf) Federal Plain Language Guidelines (https://www.plainlanguage.gov/guidelines/) Developing and Assessing Nutrition Education Handouts: Testing the Validity and Reliability of the New Tool (https://www.jandonline.org/action/showFullTableHTML?isHtml=true&tableId=tbl1&pii=S2212 -2672%2815%2900116-1) Developing and Assessing Nutrition Education Handouts (DANEH) Checklist https://higherlogicdownload.s3.amazonaws.com/THEACADEMY/332b30df-e065-46ce-94da- 9c8a13541862/UploadedImages/Foundation/files/DANEHChecklist.pdf Making Health Communication Programs Work (https://www.cancer.gov/publications/health- communication/pink-book.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(6.11)Minnesota WIC Operations Manual (MOM) Section 6.11: Supporting Breastfeeding Through Breast Pump Access and Education on Expressing Milk#

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Section 6.11: Supporting Breastfeeding Through Breast Pump Access and Education on Expressing Milk 1/2024 References: 7CFR 246.14 (b) (iii), USDA Breastfeeding Policy and Guidance Policy: If there is a need or desire to express breastmilk, provide information on milk expression and information on how to access a breast pump. In the rare case that other sources of breast pumps and lactation supplies are not available, WIC can provide select items. Purpose: To support breastfeeding and infant health and assure that WIC participants have information on expressing their breastmilk, including information on how to access a breast pump when a breast pump is indicated. Background: Expressing breastmilk, through hand expression or with a breast pump, can help participants reach their breastfeeding goals. Providing a breast pump without first assessing if milk expression is needed or desired, or by not providing a suitable pump, may make breastfeeding seem complicated, and could lead to shorter breastfeeding duration. Procedures Training - Train local staff on: ▪ Hand expression of breastmilk. ▪ Sources for obtaining breast pumps and supplies. ▪ Types of breast pumps to best meet the need when a breast pump is indicated (see Guidance). ▪ Assembly, use, and cleaning of all breast pumps and related supplies available through the local WIC program. ▪ Local procedures for recording breast pump and supplies issuance.

S E C T I O N 6 . 1 1 : S U P P O R T I N G B R E A S T F E E D I N G T H R O U G H B R E A S T P U M P A C C E S S A N D E D U C A T I O N O N E X P R E S S I N G M I L K 2 Serving Pregnant and Postpartum Participants ▪ WIC breast pumps, attachment kits, and/or supplies may not be given prenatally to WIC participants. ▪ If indicated, provide information on how to obtain a breast pump and/or supplies. ▪ Encourage participant to focus on breastfeeding and getting to know baby in the early days postpartum. Hand expression can be used if milk expression is needed early on. ▪ Inform and instruct about hand expression using a breast model and other print and electronic resources. Serving Postpartum Participants ▪ Refer to other sources for obtaining a breast pump, when available. ▪ Provide a breast pump and/or supplies from WIC when a need for a breast pump is determined and the participant does not have another source for obtaining a breast pump or supplies. ▪ Determine the appropriate breast pump to meet the need. ▪ Demonstrate assembly of the breast pump to the participant. ▪ Have the participant demonstrate assembly of the breast pump. Repeat teaching and demonstration if needed. ▪ Teach how to use and clean the breast pump. ▪ Teach how to store breastmilk. ▪ Teach how to use lactation supplies. ▪ Document the pump and/or supply issuance and that teaching was provided. Types of pumps and materials are listed in the WIC Information System’s “Materials Given” section of the Nutrition Education tab. ▪ Note on the breast pump and supplies inventory the item provided, the date provided, the participant’s name and ID number, and the WIC staff person who issued the breast pump and/or supplies. Program Integrity ▪ Store WIC pumps and supplies in a secure area. ▪ Maintain records of breast pumps and supplies. This includes: ▪ Inventory of pumps and supplies received and distributed. ▪ Record of the participant. ▪ Staff person who issued the pump and/or supplies.

S E C T I O N 6 . 1 1 : S U P P O R T I N G B R E A S T F E E D I N G T H R O U G H B R E A S T P U M P A C C E S S A N D E D U C A T I O N O N E X P R E S S I N G M I L K 3 ▪ If issuing electric breast pumps, first explore if the participant can obtain a pump from their insurance provider. If there are questions about Medical Assistance coverage, reach out to the State WIC Breastfeeding Coordinator for support. ▪ Document that a pump was issued. Additionally, if an electric breast pump is issued from the local agency, document the reason an electric breast pump was needed. ▪ A WIC staff person who is also a WIC participant may not issue any pump, pump kit or supplies to themself. Another WIC staff member must assess the need and document issuance of the pump and /or supplies. Oversight The local WIC Breastfeeding Coordinator, or an alternate identified within the local agency, is responsible for: ▪ Breast pump and lactation supplies procurement, including the type and number of breast pumps/supplies to purchase. ▪ Purchasing not more than a 9-to-12-month supply of breast pumps/supplies at one time. ▪ Contacting the State WIC Breastfeeding Coordinator prior to purchase if there is a need for an item that is not listed in this policy. ▪ Breast pump and lactation supplies inventory. ▪ Assuring that WIC staff who issue breast pumps/supplies are familiar with the different types of breast pumps and lactation supplies available through the WIC program. ▪ WIC staff should have access to a list of resources for obtaining breast pumps/supplies from other sources. ▪ Assuring that WIC staff who issue breast pumps and lactation supplies are trained on assembly, use, and cleaning of all breast pumps and supplies available through the local WIC program. ▪ Seeking reimbursement for breast pumps/supplies that are purchased according to MN WIC policy if the agency wishes to be reimbursed for breast pumps. See Section 2.2: Financial Procedures. Reimbursement and Allowable Purchases The method for purchasing breast pumps and a list of types of breast pumps and lactation supplies for which the state WIC office will reimburse local WIC programs is as follows: No Prior Authorization Needed ▪ Manual breast pumps ▪ Collection kits & tubing to be used with electric breast pumps

S E C T I O N 6 . 1 1 : S U P P O R T I N G B R E A S T F E E D I N G T H R O U G H B R E A S T P U M P A C C E S S A N D E D U C A T I O N O N E X P R E S S I N G M I L K 4 ▪ Flanges ▪ Nipple shields – Note: Before your agency may purchase nipple shields, you must develop an approval protocol for using nipple shields. Submit the protocol to the State WIC Breastfeeding Coordinator. ▪ Protocol should include: ▪ Reasons for nipple shield issuance ▪ Training of staff who issue nipple shields including: ▪ How to use a nipple shield ▪ How to protect milk supply ▪ How to wean from the nipple shield ▪ Documentation of: ▪ nipple shield issuance ▪ reason for issuing ▪ plan for follow-up ▪ Personal electric breast pumps, with conditions: ▪ Prior to purchasing a personal electric pump, you must first see if there is another funding source available – such as Medical Assistance (MA) or a Medical Assistance plan through a prepaid medical assistance plan (PMAP), private insurance, or military insurance. ▪ Document in a note in the WIC Information System why the personal electric breast pump was needed, that education was provided, and that the participant was told that the pump may not be sold. Prior Authorization Required ▪ Renting an electric breast pump ▪ Approval might be granted by the State Agency if the Local Agency determines that: ▪ The family needs an electric breast pump for medical reasons (e.g., baby too ill to be at breast) and ▪ There is no other funding source. ▪ Contact the State WIC Breastfeeding Coordinator to discuss the situation and request approval. If approved: ▪ The Local Agency can cover the rental cost on a month-to-month basis. ▪ The rental agreement and any required damage deposit will be between the family and the company that rents the pump.

S E C T I O N 6 . 1 1 : S U P P O R T I N G B R E A S T F E E D I N G T H R O U G H B R E A S T P U M P A C C E S S A N D E D U C A T I O N O N E X P R E S S I N G M I L K 5 ▪ The Local Agency will pay the pump company and submit for reimbursement as with other breast pump reimbursement claims. ▪ Purchasing a multi-user electric breast pump for use at WIC clinic by participants and staff when not in use by a WIC participant. ▪ Contact the State Breastfeeding Coordinator for purchase approval. You will not be reimbursed for any purchase of a multi-user electric breast pump for which you do not have prior approval. ▪ If you purchase a multi-user electric breast pump, it must be stored in a secure area. Keeping a record of the serial number for electric breast pumps will help in the unlikely event that a multi-user breast pump is stolen. ▪ Cleaning supplies and pressure gauges are allowable expenses. Obtaining Reimbursement ▪ When receiving the pumps/supplies, verify that the number of pumps received and cost for the pumps are correct. ▪ Local Agencies should submit these costs on the monthly Claim for Reimbursement form. Describe the costs under the ‘Other’ section, or if claimed under another category, explain that in the ‘Remarks’ section. ▪ Local Agencies will be reimbursed only for the items purchased according to this policy. If you feel you need a breast pump or supply that is not included in this policy, contact the State Breastfeeding Coordinator. Often there is a solution for participants that have a special need. Guidance Sources of breast pumps ▪ Participants who have MA or a prepaid medical assistance plan (PMAP) have access to breast pumps with a physician’s prescription. ▪ Participants who have private insurance or who have military insurance can often obtain a breast pump through their insurance. ▪ All Minnesota WIC Local Agencies must have hand pumps available for their WIC participants to meet the need when pumps from other sources are not available. What to consider before you purchase If you are considering a pump or supply you are not familiar with, we encourage you to obtain information from the company before purchasing.

S E C T I O N 6 . 1 1 : S U P P O R T I N G B R E A S T F E E D I N G T H R O U G H B R E A S T P U M P A C C E S S A N D E D U C A T I O N O N E X P R E S S I N G M I L K 6 Pump Characteristics (including manual pumps) ▪ Vacuum / Pressure: Range and pressure release mechanism (to prevent vacuum/negative pressure from getting too high) ▪ Flanges: What sizes come with the pump? Are alternate sizes available and easy to access? ▪ Supplies: Where to obtain replacement valves, membranes, tubing, etc. ▪ Sample pumps: Could a sample pump be offered and then WIC staff get a report back on how it works in comparison to other pumps tried? ▪ Electric pumps: Approved as single user or multiple user? Is there a motor warranty? How are problems with the pump handled by the manufacturer? ▪ Instructions: Are there multiple ways to learn about the pump, such as an online video and print materials? Pricing ▪ Ask about WIC and/or wholesale pricing. ▪ Compare prices if you are not purchasing directly from the manufacturer. ▪ Consider shipping costs when comparing prices. Determining need for a breast pump Is manually expressing milk an option? For milk supply concerns, hand expression after birth can increase milk supply. Teaching hand expression prenatally can empower parents and support milk production in the hours and days after birth. Providing breast pumps and supportive education may facilitate longer duration of breastfeeding. Providing a breast pump to someone who does not have a need for a pump, or providing a pump that is not suitable, may make breastfeeding seem complicated. Does the infant have special needs, such as a hospitalized infant, an infant who is not able to breastfeed, an infant with a suck too weak to obtain sufficient breastmilk? In these situations, an electric pump is recommended. The participant should check with their or their infant’s medical caregiver or insurance provider/Medical Assistance regarding breast pump coverage when pumping is indicated. What are the parents’ plans? Will they be away from baby and provide pumped milk only occasionally? Is parent returning to work or school? A manual pump may be an appropriate choice for occasional or short-term separations. For participants who are returning to work full time, a personal electric breast pump may be faster.

S E C T I O N 6 . 1 1 : S U P P O R T I N G B R E A S T F E E D I N G T H R O U G H B R E A S T P U M P A C C E S S A N D E D U C A T I O N O N E X P R E S S I N G M I L K 7 Is there a place and the time to pump milk? An electric pump may be more appropriate if there is limited time to pump. A manual pump may be helpful if there is no access to electricity. Providing follow-up on breast pumps ▪ Participants who are provided with breast pumps should receive a follow-up contact to determine how the pump is working for them, to assess any changes in their milk supply, and to answer any questions they might have. ▪ Sample forms, which can be used to track participants who have received pumps, are included as Exhibit 6-G: Breast Pump and Supplies Issuance and Inventory Log. This form can be modified to meet the needs of the local program. ▪ Another option for tracking breast pump and lactation supplies issuance is to record pump issuance in the WIC Information System and set an alert for providing a follow-up contact. Reuse of breast pumps ▪ Personal pump kits or personal electric pumps should be treated as a single-user item. They should not be re-used. Definitions - For the purposes of this policy, the following definitions have been used: Double or single personal pump kit a personal kit that is attached to, personal electric pump, or electric pump, to collect breastmilk. The kit may be either single (pumps one breast at a time) or double (pumps both breasts at the same time). Flange: the portion of the breast pump that fits over the breast and nipple. Flanges come in different sizes to accommodate different sized breasts and nipples. A properly fitting flange is essential for pumping. Reference – Complete Listing of Hyperlinks Breastfeeding Policy and Guidance (https://wicworks.fns.usda.gov/sites/default/files/media/document/WIC-Breastfeeding-Policy- and-Guidance_1.pdf) Section 2.2: Financial Procedures (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch2/sct n2_2.pdf) Exhibit 6-G: Breast Pump and Supplies Issuance and Inventory Log (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex6/6g. docx)

S E C T I O N 6 . 1 1 : S U P P O R T I N G B R E A S T F E E D I N G T H R O U G H B R E A S T P U M P A C C E S S A N D E D U C A T I O N O N E X P R E S S I N G M I L K 8 Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(7.2)Minnesota WIC Operations Manual (MOM) Section 7.2: Allowed WIC Foods#

(7.2)(document-1)#

Section 7.2: Allowed WIC Foods U P DAT ED 0 2 / 2 022 References: 7 CFR 246.10, State Rules Policy: Local agency staff must be familiar with and inform WIC participants of the foods allowed in the MN WIC Program. Purpose: To assure that WIC participants receive the appropriate foods and understand how those foods meet their specific nutritional needs. Background: WIC federal regulations specify the types of foods allowed in each food package category, and the nutritional criteria foods must meet to be included. For some foods, additional criteria are specified in Minnesota state rules. State WIC staff review product specifications of individual food items to evaluate conformance to the nutritional requirements stipulated in federal regulations. Refer to Exhibit 7-A: Minimum Requirements for Supplemental Foods. Food items that meet the nutritional requirements are then evaluated for price, availability, and participant preference. Procedures: 1. Local agency staff must know the food categories available through WIC, and the nutritional contribution of those foods. 2. Staff should be familiar with the specific types and brands of foods allowed in Minnesota. Refer to the WIC Shopping Guide. 3. Local agencies must use the most current version of the WIC Shopping Guide. Guidance ▪ Explain to participants that the foods provided by WIC are supplemental. ▪ WIC foods are good sources of selected nutrients often lacking in many diets. ▪ WIC offers more healthful forms of foods (such as low-fat milk, fruits without sugar, cereals with less sugar, etc.) to promote healthier family meals. ▪ Foods provided by WIC enable families to spend their food dollars on other foods they might wish to buy.

S E C T I O N 7 .2 : A L L OW E D W IC F O O D S 2 ▪ Provide a WIC Shopping Guide to each participant/family or demonstrate how to access it through the WIC App. Explain the food options that will be provided with their food benefits. Discuss the following: ▪ Types and amounts of foods the participant will be receiving. ▪ How to identify those foods in the grocery store, including when appropriate: brand name, container size, how to read labels to find pertinent information, etc. For harder to find foods, explain where in the store the food is located. ▪ Use visuals for key foods whenever possible to show which WIC foods are allowed. ▪ Useful education tools include pictorials, product labels or online label print-outs, empty packages/cartons, and the WIC Shopping Guide. For example, use a baby food jar to demonstrate how to determine whether the item has added sugar (i.e., using the Ingredients list rather than the Nutrition Facts Label). ▪ Visuals are especially important when educating participants on how to choose more complicated items such as WIC-allowed juices, canned fruits and vegetables, canned beans, infant foods, and soy beverage type. ▪ Ask open-ended questions and have the participant demonstrate understanding. ▪ Be familiar with availability of brands of WIC foods at local grocery stores. For example, a vendor may only carry a few brands of WIC-allowed bread. This information, along with a picture or sample package to show participants, will make it easier for them to identify the correct food item at the store. ▪ Explain the food benefits, and how to use them at the grocery store, to new participants and out-of-state transfers. Provide a list of local vendors or show how to find that information with the WIC App. Participants should understand: ▪ What to do if the WIC item is not in stock or there is not enough on the shelf. ▪ Procedures to follow when purchasing WIC foods with the WIC Card at the check-out register. ▪ What to do and/or who to call if there is a problem. ▪ No substitutions are allowed. WIC foods may not be returned to the store for cash refund or exchanged for another item. Exception: if the purchased item was found to be damaged or spoiled, it may be returned to the store for replacement with the same item, depending on store policy. ▪ The participant is responsible for instructing proxies on how to shop with the WIC Card and select the correct foods. ▪ For returning participants, ask open-ended questions to determine how their shopping experience was, if they were able to find the WIC foods they wanted, what kind of foods they are buying, etc. This can lead to opportunities for building on a participant’s current food practices, as well as for correcting any misunderstandings.

S E C T I O N 7 .2 : A L L OW E D W IC F O O D S 3 ▪ Communicate and partner with local vendors about food package issues, changes, and questions. Local Agencies and vendors can assist and support each other in ensuring that WIC foods are available for participants. ▪ Visit grocery stores and introduce yourself to the manager. See what foods and brands are available in your area. ▪ Ask if the manager or staff have any questions or concerns about WIC foods or participants. Find out if there are certain items that participants have greater difficulty in identifying at the store, and discuss how the Local Agency and the vendor can work together to address those issues. ▪ Share information that may be helpful to the vendor, such as when WIC clinic days are scheduled, WIC food items that may be in high demand, etc. ▪ If there are frequently - requested WIC food items not currently stocked, ask if the vendor can order those items. ▪ Refer to Food Package resources: ▪ UPC Codes – MN WIC APL (Approved Products List): a complete list of all WIC-allowed foods identified by brand name. ▪ Food Package Information website for Local Agencies: additional information about the Minnesota WIC Food Package. ▪ Minimum Stock Requirements (Anoka, Dakota, Hennepin or Ramsey) or Minimum Stock Requirements (stores outside Anoka, Dakota, Hennepin or Ramsey): a listing of the WIC foods (and quantities) vendors are required to stock or must order upon participant request. ▪ WIC vendor website: additional information about vendor topics. ▪ Contact the state WIC office with questions or comments about specific foods. Reference – Complete Listing of Hyperlinks Exhibit 7-A: Minimum Requirements for Supplemental Foods (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7a. pdf) WIC Shopping Guide (https://www.health.state.mn.us/people/wic/foods/guides.html) UPC Codes – MN WIC APL (Approved Products List) (https://www.health.state.mn.us/docs/people/wic/vendor/fpchng/upc/apl.xlsx) Food Package Information (https://www.health.state.mn.us/people/wic/localagency/index.html#foodpackage) Minimum Stock Requirements (Anoka, Dakota, Hennepin or Ramsey) (https://www.health.state.mn.us/docs/people/wic/vendor/appinfo/minstcktr_1.pdf) Minimum Stock Requirements (stores outside Anoka, Dakota, Hennepin or Ramsey) (https://www.health.state.mn.us/docs/people/wic/vendor/appinfo/minstcktr_2.pdf)

S E C T I O N 7 .2 : A L L OW E D W IC F O O D S 4 WIC vendor website (https://www.health.state.mn.us/people/wic/vendor/index.html) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164- 0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942

(7.3)Minnesota WIC Operations Manual (MOM) Section 7.3: Food Package Assignment Overview#

(7.3)(document-1)#

Section 7.3: Food Package Assignment Overview 1/2011 References: 7 CFR 246.10 Policy: ▪ Food packages must be assigned by CPAs and be appropriate to the category of eligibility. ▪ CPAs, in consultation with the participant or parent/caregiver, must tailor the food package to address the nutritional needs, circumstances, and preferences of the participant. ▪ The food package must support and protect breastfeeding. Purpose: To provide a food package that will best meet the participant’s needs and provide foods the participant will consume. Procedures 1. There are seven Food Package Categories. Refer to the specific policy for each food package category. See table below. 2. Food Package Assignment. Local Agencies must: ▪ Authorize only CPAs to assign food packages. ▪ Make available to participants the maximum monthly allowance of authorized supplemental foods in their food package category. ▪ Exception: If supplementation is determined necessary for a breastfed infant, prescribe the minimum amount of formula needed. ▪ Not exceed maximum monthly allowance of authorized supplemental foods in the food package category. ▪ Abide by authorized substitution rates for WIC foods. 3. Nutrition Tailoring. CPAs may individually tailor a food package and prescribe less than the maximum monthly allowance of supplemental foods only in the following situations: ▪ A breastfed infant is determined to require supplementation: the CPA must evaluate current feeding practices and prescribe the minimum amount of formula needed. ▪ A participant has a medical or nutritional condition warranting the restriction of certain foods. Examples include: ▪ Food allergies

S E C T I O N 7 . 3 : F O O D P A C K A G E A S S I G N M E N T O V E R V I E W 2 ▪ Diabetes, in which case fruit juice might be limited or eliminated. ▪ Cases in which providing the maximum allowance would exceed the amount of food prescribed by the medical provider. ▪ A participant refuses a food or cannot use the maximum monthly allowance. ▪ The quantities necessary to supplement another program’s contribution (e.g., MA) to fill a medical prescription would be less than the maximum monthly allowance. Food Package Categories Category Food Package designed for Food Package 1 Section 7.7 ▪ Infants 0 through 5 months Food Package 2 Section 7.8 ▪ Infants 6 through 11 months Food Package 3 Section 7.9 ▪ Women with qualifying conditions ▪ Children with qualifying conditions ▪ Infants with qualifying conditions Food Package 4 Section 7.10 ▪ Children 1 through 4 years Food Package 5 Section 7.11 ▪ Pregnant women ▪ Mostly-Breastfeeding women Food Package 6 Section 7.12 ▪ Some-Breastfeeding women up to 6 months postpartum (whose infants receive more formula than allowed in the Mostly-Breastfed Infant food package) ▪ Non-breastfeeding postpartum women up to 6 months postpartum Food Package 7 Section 7.13 ▪ Fully-Breastfeeding women up to 1 year postpartum, whose infants do not receive infant formula from WIC ▪ Women pregnant with multiples ▪ Women Mostly-Breastfeeding multiple infants (whose infants are receiving the Mostly-Breastfed Infant food package) ▪ Women breastfeeding multiple infants where one infant is receiving the Fully-Breastfed Infant food package and the other(s) receiving the Mostly- or Some- Breastfed Infant food package. ▪ Women pregnant and Fully- or Mostly-Breastfeeding an infant up to 1 year Food Package 7+ Section 7.13 ▪ Women Fully-Breastfeeding multiple infants

S E C T I O N 7 . 3 : F O O D P A C K A G E A S S I G N M E N T O V E R V I E W 3 Guidance ▪ Use information gathered during the health and nutrition assessment to individualize and tailor the food package as appropriate. Consider: ▪ Nutrition needs ▪ Personal and cultural preferences ▪ Environmental conditions ▪ Explain the food package to the participant. WIC foods are intended to help meet the participant’s nutrition needs and support his/her health. ▪ WIC foods are good sources of selected nutrients often lacking in many diets. ▪ WIC offers more healthful forms of foods (such as lowfat milk, fruits without added sugar, cereals with less sugar, etc.) to promote healthier family meals. ▪ Foods provided by WIC enable families to spend their food dollars on other foods they might wish to buy. ▪ Participants are not required to purchase all the foods (or full quantity of foods) available to them. ▪ Availability of some food items and specific brands varies between vendors. Refer to Minimum Stock Requirements and UPC WIC-Allowed Food Product Listing for more information. Reference – Complete Listing of Hyperlinks Section 7.7: Food Package for Infants 0-5 Months (Food Package 1) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_7.pdf) Section 7.8: Food Package for Infants 6-11 Months (Food Package 2) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_8.pdf) Section 7.9: Food Package for Infants, Women, and Children with Qualifying Medical Conditions (Food Package 3) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_9.pdf) Section 7.10: Food Package for Children 1 through 4 years old (Food Package 4) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_10.pdf) Section 7.11: Food Package for Pregnant Women and Mostly-Breastfeeding Women (Food Package 5)

S E C T I O N 7 . 3 : F O O D P A C K A G E A S S I G N M E N T O V E R V I E W 4 (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_11.pdf) Section 7.12: Food Package for Some-Breastfeeding and Non-Breastfeeding Postpartum Women (Food Package 6) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_12.pdf) Section 7.13: Food Package for Fully Breastfeeding Women (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_13.pdf) Minimum Stock Requirements (https://www.health.state.mn.us/people/wic/vendor/index.html#minimum1) UPC WIC-Allowed Food Product Listing (http://www.health.state.mn.us/divs/fh/wic/vendor/fpchng/upc/index.html) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(7.4)Minnesota WIC Operations Manual (MOM) Section 7.4: Supporting Breastfeeding with the WIC Food Package#

(7.4)(document-1)#

Section 7.4: Supporting Breastfeeding with the WIC Food Package 05/2026 References: 7CFR Part 246.10, USDA WIC Nutrition Services Standards, USDA Breastfeeding Policy and Guidance Policy: Breastfeeding participants whose infants receive formula from WIC are to be supported to breastfeed to the maximum extent possible with minimal infant formula supplementation. Formula amounts issued to breastfed infants are to be tailored to meet but not exceed the infant's nutritional needs. Purpose: To ensure that WIC food packages support and do not adversely impact breastfeeding and the participant’s infant feeding goals. Procedures ▪ When exclusive breastfeeding isn’t utilized, by circumstance or choice, the appropriate formula food package must be tailored to support the infant’s nutritional needs. Individual tailoring of food packages shall be completed after a comprehensive assessment. ▪ The agency must not develop a standard food package for breastfed infants that receive formula. Any formula issued must be based on an assessment of the individual situation. Assessment ▪ Individual tailoring of food packages shall be completed after a comprehensive assessment of the participant’s supplemental nutrition needs and to accommodate participant preferences. Assessment components: ▪ Find out why formula is being used or requested. Inquire what the family’s breastfeeding plan or goal is. ▪ Focus on the participant’s goals and work with the participant to create a plan to meet those goals. ▪ Refer to the Designated Breastfeeding Expert (DBE), health care provider, and/or community resources for lactation support if there are barriers to exclusively breastfeeding. See Section 4.7: Designated Breastfeeding Expert for additional information.

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▪ Review with participants that exclusive breastfeeding in the infant’s first month is ideal for the infant and critical for establishing milk supply. Supplementation with formula or other foods during that period may reduce milk supply and undermine continued breastfeeding. ▪ Discuss replacing some or all supplemental formula with expressed breastmilk, such as by hand expression, or pumping with a manual or electric breast pump to meet the infant’s needs and maintain milk supply. Tailoring ▪ Food package tailoring is a collaborative process. For breastfed infants, staff will estimate the amount of formula needed, based on the assessment information, and issue the amount of formula tailored to what the infant will likely consume during the benefit issuance period. See Table 1 below for assistance in estimating formula amounts. ▪ Only CPAs may assign food packages. Other WIC and non-WIC staff may not assign food packages or change the infant food package. Staff who are not CPAs must be trained on procedures for referring a participant to a CPA if the participant requests formula. Education Educate breastfeeding parents using formula on the following topics: ▪ Support lactation and provide counseling if there is a barrier to breastfeeding. ▪ Consider the age of the infant and the amount of formula being routinely offered. Inform parents of young infants who are using formula that they may be able to resume exclusive breastfeeding, if this is their goal. ▪ Explain that feeding formula can reduce the supply of breastmilk and interfere with a goal of exclusively breastfeeding. ▪ Educate on safe mixing and handling of infant formula. Refer to the USDA Infant Nutrition and Feeding Guide Chapter 4. ▪ Educate the family that the formula is only for their infant and can't be given to others or sold if not used. Documentation To promote continuity of care, the following should be apparent in the record when providing formula for a breastfed infant: ▪ Assessment of current breastfeeding and formula supplementation ▪ Education and counseling provided ▪ Referrals for breastfeeding support, as needed ▪ Plan for follow-up assessment, if needed

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If there are concerns about milk supply, the infant should be monitored for adequate intake while the mother’s milk supply is increasing and should be reassessed as necessary. Guidance Best practices to support breastfeeding participants and infants ▪ Certify the breastfeeding dyad as soon as possible. This provides an early opportunity to answer questions and offer support and encouragement. ▪ Schedule infants certified in their first month of life to be seen again one month later. Let the family know at certification that you want to check back with them and answer any questions during this important time in her child’s life. This is a good time to: ▪ Check baby’s weight and give families an opportunity to ask questions. ▪ Check how breastfeeding is going. It is important to discover what the underlying reason for formula supplementation is and determine if the parent may want to continue to breastfeed without a supplement. ▪ Support participants returning to work who want to continue breastfeeding. Offer suggestions for how to maintain breastfeeding after returning to work, based on the participant's situation. Breastfeeding amount categorization For a participant to be certified as breastfeeding they must first meet the definition of breastfeeding (feeding mother’s breastmilk on the average of at least once a day). Then, determine the amount of breastfeeding, based on the number of cans of WIC formula used in a month. If a participant is breastfeeding at least once a day and not receiving WIC formula, then they will be certified as fully breastfeeding. Assessment and counseling tips ▪ Teach new parents how to recognize that breastfeeding is going well, and provide resources for breastfeeding support if they have questions. ▪ If infant formula is requested by a breastfeeding woman or participant who intended to breastfeed: ▪ Assess the reason for the request. For example, “Tell me about why you’re requesting formula today,” or begin by asking about her goals: “What are your goals for breastfeeding?” ▪ Let her know you understand her concern and counsel her to address those concerns and help her meet her goal. ▪ To help maintain milk supply, discuss options for additional times she might breastfeed (e.g., before bed; when baby wakes; when she picks baby up from childcare; etc.)

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▪ If breastfeeding more often is not a viable option, discuss the possibilities of hand expressing milk, or pumping more often, to build or maintain milk supply. ▪ A breastfeeding infant is better at maintaining milk supply than a pump. ▪ In cases in which the infant cannot be at the breast for extended periods, ensure that the mother is manually expressing her milk, or is pumping with an appropriate breast pump as often as the infant would be nursing. See Section 6.11: Supporting Breastfeeding Through Breast Pump Access and Education on Expressing Milk. Tables on the following pages

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Table 1: Estimating the amount of formula to assign ▪ Counsel to encourage as much breastfeeding as possible based on the parent’s goals. ▪ If formula is used, assess if formula is used every day. ▪ If issuing formula, use the chart below to assess the number of cans of powdered formula to assign. ▪ Calculate: (Multiply the number of days per week the infant receives formula x the amount per day) x 4 weeks; then divide by the amount of formula in 1 can of powder. Note: One 12.5 oz can of contract powder formula reconstitutes to 90 oz. ▪ It may also be helpful to ask how long 1 can of powder formula lasts. ▪ When in doubt issue a lower amount of formula and plan to follow-up sooner to see if more formula is needed. If so, it can be added to the food package later. How many days per week is formula fed? How much formula is fed per day? Once or twice/week (1 - 2 days/week) About half the time (3 - 5 days/week) Almost every day (6 - 7 days/week) ≤ 3 oz 1 can per month 1 can per month 1 can per month 4 - 8 oz 1 can / month 1½ cans / month* 2½ cans / month* 9 -12 oz 1 can / month 3 cans / month 4 cans / month 13 -16 oz 1½ cans / month* 3½ cans / month* 5 cans / month 17 - 20 oz 2 cans/month 4½ cans / month* 6½ cans / month* * Half cans need to be rounded up. Assess at the next contact if less formula is needed. Table 2 on the following page.

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Guidance on individualizing the food package: breastfeeding dyad This table illustrates infant food packages and the corresponding mother’s food package. ▪ If a mother chooses to add formula and this changes what food package she receives (e.g., going from a food package for a Fully Breastfeeding Women (Food Package 7) to a food package for Some-Breastfeeding and Non-Breastfeeding Postpartum Women (Food Package 6); a CPA does not need to adjust the current month’s benefits if they have been already issued, only future months’ benefits Table 2: Mother and Infant Food Packages Infant Age and Food Package Breastfed Infant Food Package♥ Mom’s Food Package Comments 0 to 3 Months Infant Food Package 1 Priceless breast milk 7 (Full) This should be the norm for infant feeding. 1 to 4 cans 5 (Mostly) Formula assigned only after assessment and counseling. > 5 can 6 (Some) For breastfed infants in this category (Some breastfeeding), provide only the amount of formula to meet the assessed need. Providing the minimal amount of formula will best support milk supply. 4th and 5th Months Infant Food Package 1 Priceless breast milk 7 (Full) This should be the norm for infant feeding. 1 to 5 cans 5 (Mostly) Formula assigned only after assessment and counseling. 6 or more cans 6 (Some) For breastfed infants in this category (Some breastfeeding), provide only the amount of formula to meet the assessed need. Providing the minimal amount of formula will best support milk supply. 6th month to 1 year Infant Food Package 2 Infant Foods 7 (Full) This should be the norm for infant feeding. 1 to 3 cans + Infant Foods 5 (Mostly) Formula assigned only after assessment and counseling. 4 or more cans + Infant Foods 6 (Some) To best support milk supply, provide minimum amount of formula to meet assessed need. Mother receives nutrition education, breastfeeding support, midcert, and referrals. She does not receive WIC foods. ♥ Fully BF or # of cans powder formula (12.5 oz can that reconstitutes to 90 fl oz)

S E C T I O N 7 . 4 : S U P P O R T I N G B R E A S T F E E D I N G W I T H T H E W I C F O O D P A C K A G E 7

Reference – Complete Listing of Hyperlinks USDA WIC Nutrition Services Standards (https://wicworks.fns.usda.gov/sites/default/files/media/document/wic-nutrition-services- standards_0.pdf) USDA Breastfeeding Policy and Guidance (https://wicworks.fns.usda.gov/sites/default/files/media/document/WIC-Breastfeeding-Policy-and- Guidance_1.pdf) USDA Infant Nutrition and Feeding Guide (https:/wicworks.fns.usda.gov/sites/default/files/media/document/Infant_Nutrition_and_Feeding_ Guide.pdf) Section 4.7: Designated Breastfeeding Expert (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sctn4_ 7.pdf) Section 4.5: Staff Training (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch4/sctn4_ 5.pdf) Exhibit 4-F: Topics for WIC Staff Breastfeeding Orientation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex4/4f.pdf) Section 6.11: Supporting Breastfeeding Through Breast Pump Access and Education on Expressing Milk (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sctn6_ 11.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800- 657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(7.5)Minnesota WIC Operations Manual (MOM) Section 7.5: WIC Formulas#

(7.5)(document-1)#

Section 7.5: WIC Formulas NOVEMBER 2019 Human milk the most appropriate food for infants and breastfeeding is the natural method for feeding infants. Infant formula is inherently nutritionally inferior. The WIC Program has an obligation and unique opportunity to provide pregnant women and new mothers with the information they need to make an informed feeding decision and the support they need to reach their breastfeeding goals. For breastfed infants who may need a supplement to the breast milk they receive, and for infants whose mothers/caretakers choose not to breastfeed, WIC can provide infant formula. The CPA, together with the participant’s caregiver, should determine the type of food package which best meets the participant’s needs. Formulas available through WIC include standard contract formula, exempt infant formula, and medical foods. Only USDA-approved formulas may be provided. The most common infant formulas consumed by infants are made from modified cows’ milk with added carbohydrate (usually lactose), vegetable oils, and vitamins and minerals. The WIC Program is a supplemental nutrition program. As such, the amount of formula available through WIC might not be enough to meet the nutrition needs of an infant, particularly as an infant grows and requires more calories and nutrients. The amount of formula provided must not exceed the monthly maximums of the Minnesota WIC Program which are governed by WIC Federal Regulations. It is important that WIC staff inform caregivers who choose to formula-feed, that they may need to purchase additional formula. Background and Definitions ▪ Infant formula is “a food which purports to be or is represented for special dietary use solely as a food for infants by reason of its simulation of human milk or its suitability as a complete or partial substitute for human milk”. The Food, Drug, and Cosmetic Act mandates that all infant formulas marketed in the U.S. provide the same nutrition for healthy, full-term infants. ▪ Infant Formula Rebate: All WIC state agencies are required by WIC federal regulations to enter into cost-containment contracts for the purchase of infant formula. Competitive bidding is used to award the contract to a manufacturer of infant formula for the exclusive right to provide its product to WIC participants in that State, in exchange for a monetary rebate on the formula, which reduces the cost to WIC. Since the rebate money is used to support additional WIC participation, it is important that all infants receiving formula from WIC be provided the contract brands of formula unless there is a specific condition requiring an exempt formula or medical food. ▪ Standard Formula: Standard formulas are those nutritionally suitable for the majority of generally healthy infants who are supplemented with formula or fully formula fed.

S E C T I O N 7 . 5 : W I C F O R M U L A S 2 ▪ Primary Contract Formulas - are those that meet the federal requirements for formula and for which MN WIC receives rebate under the state’s formula contract. ▪ Alternate Contract Formulas – are those included in the state’s formula contract that do not meet federal requirements (e.g., because of a lower caloric density), and therefore require medical documentation. ▪ Standard Non-Contract Formula: Any brand of standard formula not covered by the contract. ▪ Exempt infant formula: An exempt infant formula is an infant formula intended for use by infants who have inborn errors of metabolism or low birth weight, or who otherwise have unusual medical or dietary problems. ▪ Medical food: The term medical food, as defined in section 5(b) of the Orphan Drug Act (21 U.S.C. 360ee (b) (3)) is "a food which is formulated to be consumed or administered enterally under the supervision of a physician and which is intended for the specific dietary management of a disease or condition for which distinctive nutritional requirements, based on recognized scientific principles, are established by medical evaluation." 7.5.1: Contract Formula References: 7CFR 246.10(c)(1)(i); 246.16a Policy: If infant formula is requested by the parent/caretaker of an infant, and the CPA determines that formula is appropriate, the CPA must provide through the appropriate food package, a contract formula. Purpose: To meet the federal mandate requiring all states to contain the cost of infant formula. Procedures 1. Breastfeeding is the normal method for feeding infants and every mother must be encouraged to breastfeed. All requests for infant formula by a breastfeeding mother must be assessed by a CPA to determine the appropriateness of supplementing the infant. See Section 7.4: Supporting Breastfeeding with the WIC Food Package. 2. Participants requesting formula must be informed of and offered a primary contract formula. If conditions warrant, CPAs may offer an alternate contract formula, but must obtain medical documentation. Section 7.6: Medical Documentation and Exhibit 7-B: WIC Formula Summary

S E C T I O N 7 . 5 : W I C F O R M U L A S 3 3. If parent/caretaker requests a standard non-contract infant formula, the CPA must explain the policy prohibiting the issuance of any infant formula other than standard contract formula. 4. A participant over 12 months of age (i.e., either a child or a woman) prescribed a standard contract formula by a Health Care Provider must meet the criteria for Food Package 3. Medical documentation is required. See Section 7.6: Medical Documentation. 5. Standard contract formula may be provided in either powder or concentrate form, depending on the caregiver’s preference. ▪ CPAs must encourage breastfeeding mothers for whom supplementation is determined necessary, to choose powdered formula to minimize the amount of formula that is prepared at one time, and therefore to better support breastfeeding and reduce the amount that is wasted. ▪ CPAs may issue Ready-to-Feed standard contract formula only if circumstances meet criteria described in Section 7.5.2 Ready-to-Feed/Use Formula. 6. If an exempt infant formula or a medical food is requested by a Health Care Provider, criteria described for Food Package 3 must be met. See Section 7.9: Food Package 3. Guidance 1. The American Academy of Pediatrics (AAP) and other professional health groups recommend breastfeeding. Full breastfeeding (without supplementation) is considered the norm for infant feeding. 2. For infants receiving formula, the AAP Committee on Nutrition, states that any standard iron-fortified infant formula is an appropriate source of nutrition for healthy infants birth to 12 months. 3. In compliance with federal regulations, the MN WIC Program contracts with a formula manufacturer for the exclusive right to provide its product to WIC participants in exchange for a monetary rebate on the formula WIC provides. Rebate received from the formula contractor allows MN WIC to serve additional participants. It is expected that CPAs will issue a standard contract formula if formula is determined to be appropriate. 4. If the parent/caregiver reports intolerance to the primary contract formula, assess formula preparation, feeding and storage practices. Use Exhibit 7-C: Assessment of Infant Formula Feeding as a guide. ▪ If feeding and/or storage problems are identified, provide appropriate education and counseling, and refer if necessary. Continue issuing primary contract milk- or soy-based formula and schedule follow-up appointment to reassess. ▪ If it appears that the infant has an intolerance to primary contract formulas, an alternate infant formula (e.g., alternate contract formula or exempt infant formula) might be warranted. See related policies: Section 7.6: Medical Documentation, Section

S E C T I O N 7 . 5 : W I C F O R M U L A S 4 7.7: Food Package 1 for Infants 0-5 Months, Section 7.8: Food Package 2 for Infants 6-11 Months, and Section 7.9: Food Package 3. 5. Powdered formula is the most appropriate form for the following participants: ▪ Breastfeeding infants who are being fed any formula. ▪ Homeless participants who do not breastfeed. With powdered formula, participants can prepare the amount needed, limiting unnecessary waste and need for refrigeration. Ready-to-Feed formula may be appropriate in some cases (e.g., if storage is a problem). See policy on Ready-to-Feed Formula, Section 7.5.2. 6. Soy Formula The AAP updated its review on the use of soy formulas in 2008. All soy formulas on the market are iron-fortified and meet USDA and AAP guidelines for vitamin, mineral, and electrolyte content. Soy formulas do not contain cows’ milk protein or lactose. The protein is a soy isolate and the carbohydrate sources are corn maltodextrin, corn syrup solids, and sucrose. Concerns have been raised about the phytoestrogens and isoflavones in soy formula and their potential negative effects on human development, reproduction, and/or endocrine function. Other studies have suggested that isoflavones may play a protective role in some diseases such as coronary heart disease. Although studied extensively, there is no conclusive evidence that soy isoflavones are contraindicated. Soy formula usage: Soy formula may be used to provide nutrition for full-term infants, however, there are few indications for its use in place of cow’s milk-based formula. Indications for use include: ▪ Infants with galactosemia ▪ Infants with hereditary lactase deficiency ▪ Vegan diets Soy formula is not indicated for: ▪ Infants with documented cow milk protein allergy. For infants with a documented cow milk protein allergy, an extensively hydrolyzed protein formula such as Nutramigen should be considered. See Section 7.9: Food Package 3 ▪ Pre-term infants ▪ Prevention of colic or fussiness -- There is no proven value in using soy-formula. For more information, refer to the AAP Clinical Report: Use of Soy Protein-Based Formulas in Infant Feeding.

S E C T I O N 7 . 5 : W I C F O R M U L A S 5 7.5.2 Ready-to-Feed/Use Formula References: 7CFR 246.10(c)(1)(i) Policy: CPAs may issue ready-to-feed (RTF) or ready-to-use (RTU) formula in the following situations only: Infants: Food Packages 1 and 2 ▪ Water supply is unsanitary or restricted due to emergency circumstances (e.g., in flooding) ▪ Refrigeration is inadequate ▪ Participant/caregiver might have difficulty preparing formula ▪ The particular formula needed is available only as RTU Infants, Children, Women: Food Package 3 ▪ All of the above reasons, and/or ▪ The RTU form better accommodates the participant’s condition (e.g., premature infants at risk of Enterobacter sakazakii) ▪ The RTU form improves the participant’s compliance in consuming the prescribed formula Purpose ▪ To meet the federal mandate to contain cost of infant formulas. ▪ To assure that participants receive the formula that meets their medical and/or nutritional needs and special circumstances. Procedure 1. CPAs must Assess the need for RTU formula and determine appropriateness. 2. CPAs must Document the reason for issuance of RTU formula in the participant record. Guidance 1. If a participant has unsanitary water or is uncertain of its safety: ▪ Encourage and support breastfeeding. ▪ Full breastfeeding does not require water for washing bottles or bottle nipples, and provides protection against illness for the breastfed infant. ▪ Encourage a return to full breastfeeding for women who are supplementing.

S E C T I O N 7 . 5 : W I C F O R M U L A S 6 ▪ Explore interest in and feasibility of re-lactating or inducing lactation for women who are not breastfeeding. ▪ Issue one month’s supply of RTU formula, if appropriate. ▪ Assist the participant in determining how to obtain safe water (e.g., purchasing bottled water or acquiring water from a safe municipal water supply). ▪ Refer the participant to the agency in the county that tests water. 2. If refrigeration is inadequate: ▪ Refer as needed to local housing assistance programs. ▪ Encourage and support breastfeeding. ▪ Encourage a return to full breastfeeding for women who are supplementing, ▪ Explore interest in and feasibility of re-lactating or inducing lactation for women who are not breastfeeding. 3. If a participant returns RTU formula to the local agency and the formula cannot be used by another participant in your agency, contact the State WIC agency to request that a notice of availability be included on the Medical Formulas Available at Local Agencies webpage. 7.5.3 Standard Non-Contract Formula References: 7CFR 246.10(c)(1)(i); 246.16a Policy: CPAs may not issue any standard non-contract formula. Purpose: To meet the federal mandate to contain food costs by issuing standard contract formula, and to enable Minnesota WIC to serve more participants with funds recovered through rebates for contract formula. Definition: Non-contract formulas are “standard infant formulas” not included in the Minnesota WIC Formula Rebate Contract. Procedures 1. There are no circumstances for which a standard non-contract milk- or soy-based formula may be provided. For a list of standard contract formulas, see Exhibit 7-B: Minnesota WIC Formula Summary. Guidance ▪ Although there are small differences in protein, fat, and carbohydrates among all standardized formulas, there are no medically proven advantages of one formula brand over another.

S E C T I O N 7 . 5 : W I C F O R M U L A S 7 ▪ WIC CPAs need to work with the family and their primary care provider in transitioning to a standard contract formula. ▪ If it appears the infant has a “true” intolerance to standard contract formulas, an exempt infant formula might be warranted. See related policy Section 7.9: Food Package 3. 7.5.4 Medically Prescribed Formula See Section 7.9: Food Package 3. 7.5.5 Returned Formula References ▪ USDA WIC Food Package Policy and Guidance - March 2018 Chapter 6 ▪ USDA March 2019, Re: Clarification on Unused and Returned WIC Formula ▪ 7 CFR 246.4 (a)(14)(xviii) ▪ Public Health Security and Bioterrorism Preparedness and Response Act ▪ Food Safety Modernization Act ▪ Bill Emerson Good Samaritan Food Donation Act Policy ▪ Local agencies may not reissue formula returned to clinic by participants. ▪ Standard formula returned to clinic may be donated if in good condition. Any formula not donated, must be disposed of. Medical formula cannot be donated; it must be disposed of. ▪ Current month’s formula benefits can be replaced only if there are unredeemed formula benefits available, or redeemed but unused formula is returned to WIC clinic. ▪ Formula that is redeemed, but not returned to clinic, may not be replaced. ▪ Agencies must document all returned formula and what was done with it on a formula log. Purpose To ensure participants are provided benefits for an appropriate formula in a quantity to meet their infant’s needs, but not to exceed the maximum monthly allowance; to minimize the potential for fraudulent use of redeemed, but unused WIC formula; and to assist Local Agencies in managing returned formula.

S E C T I O N 7 . 5 : W I C F O R M U L A S 8 Procedures Minimizing Unused Formula ▪ Always encourage participants to purchase only an amount they think their infant will tolerate and consume. ▪ Request that unused WIC formula be returned to clinic. Handling Returned Formula Log all returned formula, including date returned, participant ID, formula name and quantity, and staff initials. ▪ Store in a secure, locked area (e.g., a locked cabinet or room), with access limited to a minimum number of essential WIC staff, and not accessible to non-WIC staff (e.g., custodians, etc.). ▪ Minimize amounts of formula stored/held in clinic – it should be donated or discarded as soon as possible or practical. Donating or Disposing of Returned Formula Medical formula Medical formula returned to WIC by participants must be disposed of; it may not be donated. Standard formulas ▪ Assess condition of returned formula: consider reason for the return, condition of the cans (container should be unopened and undamaged, with original label), where and how the formula was stored, and expiration date. ▪ Formula deemed to be in good condition, may be donated to a local non-profit agency. Formula may not be donated or given to other programs within your agency. ▪ Identify local non-profits which distribute foods and formula. ▪ Develop a process for handling formula returned to clinic: logging it, storing it and arranging delivery or pick-up. ▪ Document the donation on the log. ▪ Dispose of any formula not in good condition or which your Agency cannot, or chooses not, to donate. To minimize the chance of discarded formula being reclaimed or removed from the garbage: ▪ Either open and pour contents out, or dispose of containers in opaque plastic bags. ▪ Dispose of bags in a secure or protected receptacle to reduce the risk of it being inappropriately removed. ▪ Document disposal on the log.

S E C T I O N 7 . 5 : W I C F O R M U L A S 9 Documenting Receipt and Action Taken ▪ Document receipt of returned formula, including date, formula name & amount, participant ID, and initial of staff person receiving the formula. ▪ Document whether the formula was disposed of or donated, including date and two signatures. See Guidance. ▪ Use Exhibit 7-I: Tracking Log for Returned Formula or a log you develop which includes the required information. Guidance Minimizing unused redeemed formula ▪ For a new infant receiving formula, or a new formula provided to any infant, staff should encourage the parent/caregiver to purchase only one or two cans to ensure tolerance, before purchasing full month’s benefits. ▪ For older infants (i.e., 11 month olds) transitioning off formula, and who will soon be receiving a “child’s food package”, encourage caregivers to purchase smaller amounts as needed. Donating ▪ You might need to discuss formula donation with your administrator or agency legal counsel. ▪ Before donating formula, with a permanent marker, put an X across the bar code to deter people from trying to sell it. ▪ Establish a relationship with a reputable organization that accepts and redistributes formula. ▪ If possible, arrange for the organization to pick up the formula on a regular basis (e.g., once/week or once/month) – depending on how quickly you accumulate it. ▪ Some organizations will provide a receipt for the formula you donate; if not, have them initial your formula log. ▪ Potential donation sites include (but are not limited to) homeless shelters, food shelves/pantries, and crisis nurseries. If none of these exist in your community, you could consider animal shelters. Disposing of formula - You might need to make arrangements with your facilities management to ensure secure and timely disposal. Some buildings secure their garbage/dumpsters. Documenting action taken

S E C T I O N 7 . 5 : W I C F O R M U L A S 1 0 ▪ If formula is disposed of, two WIC staff must sign the log attesting to disposal. If only one WIC staff person is available, obtain the signature of staff person from another program in your agency. ▪ If donating the formula, two WIC or agency staff, or one WIC staff and the initials of a representative from the organization accepting the donation must sign the log. In lieu of the second signature, a receipt from the organization can be obtained. ▪ Assessing formula returned to clinic ▪ Storage conditions: Unopened powder and liquid formulas should be stored at “normal” room temperature (i.e., 68-80 degrees F). “Shelf life” is based on the best estimate of the time during which certain changes may occur at normal temperatures. Shelf life is established to assure that ingredients will satisfy label claim until the expiration date. Excessive heat or freezing should be avoided. Many of the normal chemical and physical changes that occur over time at room temperature will be accelerated at constantly elevated temperatures, such as near a furnace or a water heater. Long-term exposure to heat may cause the fat to separate in liquid formulas and may cause powder formula to darken and change odor. Generally, freezing does not affect the nutritional quality, but it may break down the fatty acids. It also may affect the appearance (separation, increased sedimentation, or lumps) and functionality. If a product is for a tube feeding, it could clog the tubing. ▪ Expiration date: The format used for expiration dates is: day of month/month/year. The day of the month is always the first day of the month. Depending on the manufacturer, the number “1” may or may not be included (e.g., 1FEB2012, 1MAR12 or 08/2011). A product may be used until that date; it should not be used the day of or beyond the expiration date. Reference – Complete Listing of Hyperlinks Section 7.4: Supporting Breastfeeding with the WIC Food Package (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_4.pdf) Section 7.6: Medical Documentation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_6.pdf) Exhibit 7-B: WIC Formula Summary (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7b. pdf) Section 7.9: Food Package 3 (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_9.pdf)

S E C T I O N 7 . 5 : W I C F O R M U L A S 1 1 Exhibit 7-C: Assessment of Infant Formula Feeding (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7c. pdf) Section 7.7: Food Package 1 for Infants 0-5 Months (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_7.pdf) Section 7.8: Food Package 2 for Infants 6-11 Months (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_8.pdf) Use of Soy Protein-Based Formulas in Infant Feeding (https://publications.aap.org/pediatrics/article/121/5/1062/73488/Use-of-Soy-Protein-Based- Formulas-in-Infant) Medical Formulas Available at Local Agencies (https://www.health.state.mn.us/people/wic/localagency/medformulas.html) Exhibit 7-B: Minnesota WIC Formula Summary (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7b. pdf) USDA WIC Food Package Policy and Guidance - March 2018 (https://wicworks.fns.usda.gov/sites/default/files/media/document/WIC%20Food%20Package %20Policy%20Guidance%20Mar2018_508c.pdf) Public Health Security and Bioterrorism Preparedness and Response Act (https://www.govinfo.gov/content/pkg/PLAW-107publ188/pdf/PLAW-107publ188.pdf) Food Safety Modernization Act (https://www.fda.gov/food/food-safety-modernization-act- fsma/full-text-food-safety-modernization-act-fsma) Bill Emerson Good Samaritan Food Donation Act (http://www.gpo.gov/fdsys/pkg/PLAW- 104publ210/pdf/PLAW-104publ210.pdf) Exhibit 7-I: Tracking Log for Returned Formula (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7i_ fill.docx) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(7.6)Minnesota WIC Operations Manual (MOM) Section 7.6: Medical Documentation#

(7.6)(document-1)#

Section 7.6: Medical Documentation 1/2023 References: 7 CFR 246.10 Policy: Some formulas and supplemental foods may be provided by WIC only with appropriate medical documentation. Purpose: To assure participants receive WIC supplemental foods that meet their medical and/or nutritional needs. Procedures Medical Determination Medical determination documenting a qualifying condition is required for participants receiving Food Package 3, including: ▪ Standard contract infant formula prescribed to a child ▪ Exempt infant formula ▪ WIC-eligible medical food ▪ Supplemental foods issued to participants receiving Food Package 3. Supplemental foods are available from the standard food package for the participant’s WIC type, e.g., a child receiving Food Package 3 may receive any of the foods from Food Package 4 that are appropriate. ▪ Whole or 2% milk issued to children age 2 and over or women in Food Package 3. ▪ Infant fruit and vegetables and infant cereal provided to a child receiving medical formula Qualifying conditions. The table Foods/Formula Requiring Medical Documentation below lists the qualifying medical conditions for the issuance of medical formulas and supplemental foods. Formula and supplemental foods may not be issued for a non-qualifying condition. Medical documentation requirements ▪ Documentation must be obtained prior to issuance of:

S E C T I O N 7 . 6 : M E D I C A L D O C U M E N T A T I O N 2 ▪ medical formula using Exhibit 7-D: Minnesota WIC Program Request for Formula Documentation ▪ Medical documentation may be submitted on another form as long as all Federally required components are present. ▪ Documentation must be from a Health Care Professional licensed to write medical prescriptions under Minnesota state law. ▪ M.D. ▪ Physician’s Assistant supervised by a medical physician ▪ Certified Nurse-Midwife ▪ Nurse Practitioner (Certified Clinical Nurse Specialist) who has an agreement with a physician based on standards established by the Minnesota Nurses Association and the Minnesota Medical Association ▪ Licensed Doctor of Osteopathy duly licensed to practice medicine ▪ Health Care Provider must document in writing all the following: ▪ Qualifying medical condition; see the table Foods/Formula Requiring Medical Documentation below ▪ Name of formula and/or any WIC foods ▪ Prescribed amount(s) per day ▪ Length of time required ▪ Health Care Provider signature, date, and contact information ▪ Medical documentation must be obtained in writing as an original written document, electronically, or by fax and scanned into the participant record. ▪ Medical documentation may be provided by telephone to a CPA, when necessary to prevent a delay that would place a participant at increased nutritional risk (determined on case-by-case basis) and until written confirmation is received, which must be within 1 month. Voucher issuance is limited to one month with verbal verification. ▪ At a minimum, new documentation is required when the Health Care Provider’s intended length-of-use expires, or the prescription has changed. ▪ Transfer participants ▪ In-state transfers: CPAs may honor the medical prescription, documented by the originating local agency in the participant record, if still applicable. ▪ Out-of-state transfers: For participants who don’t have a medical prescription with them, contact their Health Care Provider or previous WIC agency to verify the medical documentation information. Prescription Renewal Requirements:

S E C T I O N 7 . 6 : M E D I C A L D O C U M E N T A T I O N 3 ▪ Prescriptions for participants receiving Food Package 3 must be obtained at least every 6 months or any time the food package changes. ▪ Evaluation of Medical Documentation: CPAs must assess the appropriateness of the formula/food requested, considering the health condition and/or diagnosis and make food package changes as appropriate. The following information should be considered for approval: ▪ Medical diagnosis or condition(s) which necessitates the need for the formula/food ▪ Approval should not be made for women and children who have a food intolerance to lactose or milk protein that can be successfully managed with the use of other WIC supplemental foods. ▪ Current growth status (i.e., weight and length/height plotted on growth chart) ▪ Pattern of growth over time, when information is available (e.g., weight gained over previous months) ▪ Health and diet history (including a diet recall) ▪ Interview with caregiver to determine if formula is prepared/stored properly ▪ Consultation with the prescribing Health Care Provider, when necessary to determine need ▪ CPA Professional Judgment: CPAs may deny a request for a formula/food if, in their professional judgment, there is no justifiable medical need. (Note: “Parental preference” and “picky eater” do not establish medical need and therefore are not qualifying conditions.) See Guidance in Section 7.9: Food Package 3. Foods/Formula Requiring Medical Documentation Participant Category Supplemental Food/Formula Requiring Medical Documentation Qualifying Medical Condition Non-qualifying Condition Infants 0-5 months Food Package 3 ▪ Exempt infant formula ▪ Medical food ▪ Premature birth ▪ Low birth weight ▪ Failure to thrive ▪ Inborn errors of metabolism ▪ Metabolic disorders ▪ Gastrointestinal disorders ▪ Malabsorption syndromes ▪ Immune system disorders ▪ Severe food allergies that require an elemental formula ▪ Life threatening disorders, diseases, and medical conditions that impair ingestion, digestion, absorption, or utilization of nutrients that could adversely affect the participant’s nutrition status ▪ Non-specific formula or food intolerance ▪ Suspected or non-confirmed allergy ▪ Only condition is a diagnosed formula intolerance or food allergy to lactose, sucrose, milk protein or soy protein that does not require an exempt infant formula, or non-specified formula or food intolerance ▪ Participant preference

S E C T I O N 7 . 6 : M E D I C A L D O C U M E N T A T I O N 4 Participant Category Supplemental Food/Formula Requiring Medical Documentation Qualifying Medical Condition Non-qualifying Condition Infants 6-12 months Food Package 3 ▪ Exempt infant formula ▪ Medical food As above As above Infants 6-12 months Food Package 3 ▪ Infant fruits and vegetables ▪ Infant cereal Health Care provider indicates complementary foods are appropriate Health Care provider indicates complementary foods are not appropriate Children 1-4 years Food Package 3 ▪ infant formula ▪ Exempt infant formula ▪ Medical food ▪ Premature birth ▪ Low birth weight ▪ Failure to thrive ▪ Inborn errors of metabolism ▪ Metabolic disorders ▪ Gastrointestinal disorders ▪ Malabsorption syndromes ▪ Immune system disorders ▪ Severe food allergies that require an elemental formula ▪ Life threatening disorders, diseases, and medical conditions that impair ingestion, digestion, absorption, or utilization of nutrients that could adversely affect the participant’s nutrition status ▪ Solely for the purpose of enhancing nutrient intake or managing body weight without an underlying condition ▪ Lactose intolerance ▪ Participant preference ▪ Food dislike Children 1-4 years Food Package 3 ▪ Milk/milk alternatives (includes whole/2% milk) ▪ Cereal ▪ Eggs ▪ Fruits & vegetables ▪ Whole grains ▪ Peanut butter/beans ▪ Juice Health Care Provider indicates supplemental foods are appropriate Health Care Provider indicates supplemental foods are not appropriate.

S E C T I O N 7 . 6 : M E D I C A L D O C U M E N T A T I O N 5 Participant Category Supplemental Food/Formula Requiring Medical Documentation Qualifying Medical Condition Non-qualifying Condition Women Food Package 3 ▪ Medical food ▪ Inborn errors of metabolism ▪ Metabolic disorders ▪ Gastrointestinal disorders ▪ Malabsorption syndromes ▪ Immune system disorders ▪ Severe food allergies that require an elemental formula ▪ Life threatening disorders, diseases, and medical conditions that impair ingestion, digestion, absorption, or utilization of nutrients that could adversely affect the participant’s nutrition status ▪ Solely for the purpose of enhancing nutrient intake or managing body weight without an underlying condition ▪ Lactose intolerance ▪ Participant preference ▪ Food dislike Women Food Package 3 ▪ Milk/milk alternatives (includes whole/2% milk) ▪ Cereal ▪ Eggs ▪ Fruits & vegetables ▪ Whole grains ▪ Peanut butter/beans ▪ Juice Health Care Provider indicates supplemental foods are appropriate Health Care Provider indicates supplemental foods are not appropriate. Reference – Complete Listing of Hyperlinks: Exhibit 7-D: Medical Formula Documentation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7d. pdf) Section 7.9: Food Package 3 (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_9.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(7.7)Minnesota WIC Operations Manual (MOM) Section 7.7: Food Package 1 Infants 0-5 Months#

(7.7)(document-1)#

Section 7.7: Food Package 1 (Food Package for Infants 0-5 Months) 04/2014 References: 7 CFR 246.10 Policy ▪ Food packages must be prescribed by CPAs, in consultation with the participant or parent/caregiver, and must be prescribed to minimize any adverse impact on breastfeeding. ▪ The food package must be appropriate to the category of eligibility and must be specifically tailored to address the nutritional needs, circumstances, and preferences of the participant. Purpose: To provide a food package that will best meet the participant’s needs and will be used by the participant. Procedures Issuance requirements Food Package 1 is issued to infants 0 through 5 months of age. There are 3 feeding options in this Food Package. The feeding options reflect the amount of breastfeeding, and determine the infant’s Food Package. The infant’s Food Package determines the mother’s Food Package. ▪ Fully Breastfed Infants receiving no formula from WIC --- This is the ideal. (Mother is eligible for Food Package 7) ▪ Mostly-Breastfed Infants receiving limited amount of formula. (Mother is eligible for Food Package 5, or Food Package 7 - if breastfeeding multiples) ▪ Some-Breastfed/Fully Formula Fed Infants (Mother is eligible for Food Package 6) Breastfeeding Breastfeeding is the normal method for feeding infants; therefore breastfeeding must be considered the first and preferred method to feed infants. Every mother must be encouraged to breastfeed. See Section 6.5: Breastfeeding Education for Pregnant Women. Breastfeeding is how infants were meant to be fed, with human milk the only complete, and most nutritious, infant food. CPAs must consider it first and encourage every mother to breastfeed, without supplementing with formula. ▪ CPAs may only prescribe formula after assessment and counseling.

S E C T I O N 7 . 7 : F O O D P A C K A G E 1 2 ▪ For breastfed infants receiving formula, CPAs must evaluate current feeding practices and prescribe only the minimum amount of formula that is necessary. ▪ CPAs must not automatically provide 1 can of powder formula to breastfeeding infants. ▪ CPAs are not required to issue the maximum amount of formula allowed in the food package. ▪ Breastfed infants receiving WIC formula should be provided powder formula, rather than concentrate or Ready-To-Use (unless the criteria for Ready-To-Use formula is met). With powder formula, smaller amounts can be prepared -- better supporting breastfeeding and reducing waste. ▪ Food packages for the breastfeeding mother and infant dyad are closely tied and must match (except for rare situations). ▪ If the mother is breastfeeding multiple infants with differing breastfeeding statuses, the mother’s food package corresponds to the food package of the infant with the most breastfeeding. Formula Feeding At 4-5 months of age, the maximum formula quantities allowed increase. CPAs must assess feeding and adjust the food package as needed. ▪ Issue the food package as indicated in the table below. ▪ Maximum formula quantities vary by breastfeeding status and by age. ▪ If formula is prescribed for a breastfed infant, provide the minimum amount of formula needed (as determined by assessment) to support mother’s milk supply and infant health. ▪ CPAs must change the food package accordingly. ▪ Ready-to-Use formula may be issued in only in specific situations. Refer to Section 7.5.2: Ready-to-Feed/Use Formula. ▪ Only contract formulas -- including both primary and alternate contract formulas -- are available in this Food Package. Standard non-contract formulas are not allowed. Refer to Section 7.5: WIC Formulas and Exhibit 7-B: WIC Formula Summary. Counseling ▪ CPAs must counsel on infant feeding practices. See Guidance below. ▪ If formula is provided, CPAs must instruct participants on safe and appropriate formula preparation and handling. For additional information, see WIC Infant Nutrition and Feeding Guide, Chapter 4.

S E C T I O N 7 . 7 : F O O D P A C K A G E 1 3 Tables for Food Package 1: Infants 0-5 months Available range of cans of formula or amount of food/month based on breastfeeding status Maximum number of ounces in ( ) Birth to 1 Month Food item Fully Breastfed Mostly-Breastfed Some-Breastfed/ Fully Formula Fed Powdered Formula/Month (a 12.5-oz can of Enfamil Infant yields approximately 90 fl. oz. reconstituted) None 1 can (104 fluid ounces reconstituted) 2-9 cans (870 fluid ounces reconstituted) Concentrate Formula/Month None None 1-31 cans (806 fluid ounces reconstituted) Ready-To Use Formula/Month (RTF) None None 11-26 quarts (832 fluid ounces) 1 to 3 Months Food item Fully Breastfed Mostly-Breastfed Some-Breastfed/ Fully Formula Fed Powdered Formula/Month None 1-4 cans (435 fluid ounces reconstituted) 5-9 cans (870 fluid ounces reconstituted) Concentrate Formula/Month None 1-14 cans (364 fluid ounces reconstituted) 15-31 cans (806 fluid ounces reconstituted) Ready-To Use Formula/Month (RTF) None 1-12 quarts (384 fluid ounces) 13-26 quarts (832 fluid ounces) 4 to 5 Months Food item Fully Breastfed Mostly-Breastfed Some-Breastfed/ Fully Formula Fed Powdered Formula/Month None 1-4 cans (435 fluid ounces reconstituted) 5-9 cans (870 fluid ounces reconstituted) Concentrate Formula/Month None 1-17 cans (442 fluid ounces reconstituted) 15-31 cans (806 fluid ounces reconstituted) Ready-To Use Formula/Month (RTF) None 1-12 quarts (448 fluid ounces) 13-26 quarts (832 fluid ounces) Mom’s Corresponding Food Package (Applies to all infant age categories) 7 5 7 (if multiples) 6 See Exhibit 7-J: Mom and Baby WIC Food Packages which displays mom and baby’s food packages together.

S E C T I O N 7 . 7 : F O O D P A C K A G E 1 4 Guidance The following items should be part of nutrition education and counseling: ▪ CPAs must counsel on infant feeding practices, including hunger cues, signs of fullness, and guidelines on feeding frequency. Information about normal infant gastrointestinal behaviors such as spitting up and stooling can be very helpful so that caregivers do not misinterpret normal patterns or overlook abnormal behaviors. Refer to Chapter 2 and Chapter 6 in the WIC Infant Nutrition and Feeding Guide for more information. ▪ If infant is breastfed, CPAs must counsel on breastfeeding basics, including milk supply, feeding positions, and frequency of feeding. See Section 7.4: Supporting Breastfeeding with the WIC Food Package. ▪ If formula is provided, CPAs must: ▪ Counsel on how formula intake affects breastmilk supply. ▪ Instruct on safe and appropriate formula preparation and handling. For additional information see Chapter 4 in WIC Infant Nutrition and Feeding Guide. ▪ Provide guidance on the mechanics of formula feeding, such as appropriate bottle or cup use (if these are used), positioning, etc. ▪ For more information on formula, refer to Section 7.5: WIC Formulas. ▪ CPAs must assess for Vitamin D adequacy and counsel as appropriate. ▪ All infants need a source of Vitamin D. Refer to the American Academy of Pediatrics clinical report on Prevention of Rickets and Vitamin D Deficiency in Infants, Children, and Adolescents and the Institute of Medicine Dietary Reference Intakes for Calcium and Vitamin D report. ▪ Mostly-Breastfeeding and Fully-Breastfeeding infants need a daily Vitamin D supplement of 400 IU to ensure adequacy. ▪ Infant formula is fortified with Vitamin D, but the infant’s Vitamin D adequacy depends on how much formula is consumed. AAP recommends Vitamin D supplementation for partially breastfed and non-breastfed infants ingesting less than 1 quart (or 1 liter) per day of Vitamin D-fortified formula. ▪ If there are questions, refer to the Health Care Provider. ▪ Before issuing formula to a breastfed infant, consider the following: ▪ If only a small amount of formula would be prescribed, encourage the family to purchase the formula. If the infant is not receiving formula from WIC, the mother remains eligible to receive more foods from WIC, as indicated in the table above. ▪ If formula is prescribed for a breastfed infant, issue the minimum amount needed. For example, a 2 month old receiving 6 ounces of formula a day (186 oz/month) does not need the maximum quantity of 435 ounces of reconstituted powder formula from the

S E C T I O N 7 . 7 : F O O D P A C K A G E 1 5 Mostly-Breastfed Infant Food Package. Tailor the Food Package to provide only the amount of formula needed. ▪ Infant foods are not provided until 6 months of age. See Section 7.8: Food Package 2 (Food Package for Infants 6-11 Months). ▪ Adding foods before 6 months displaces breastmilk, and may decrease mother’s milk supply. ▪ Most infants are developmentally ready for semisolid foods around 6 months of age. ▪ Goat milk is inappropriate for infants and is not available for issuance. See WIC Infant Nutrition and Feeding Guide for more information. ▪ Additional food package information is available on the WIC Local Agency website, including CPA tools and participant educational resources that may be downloaded. Reference – Complete Listing of Hyperlinks Section 7.13: Food Package 7 (Food Package for Fully Breastfeeding Women) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_13.pdf) Section 7.11: Food Package 5 (Food Package for Pregnant Woment and Mostly-Breastfeeding Women) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_11.pdf) Section 7.12: Food Package 6 (Food Package for Some-Breastfeeding and Non-Breastfeeding Postpartum Women) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_12.pdf) Section 6.5: Breastfeeding Education for Pregnant Women (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_5.pdf) Section 7.5: WIC Formulas (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_5.pdf) Exhibit 7-B: WIC Formula Summary (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7b. pdf) WIC Infant Nutrition and Feeding Guide (https://wicworks.fns.usda.gov/sites/default/files/media/document/Infant_Nutrition_and_Fee ding_Guide.pdf)

S E C T I O N 7 . 7 : F O O D P A C K A G E 1 6 Exhibit 7-J: Mom and Baby WIC Food Packages (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7j. pdf) Section 7.4: Supporting Breastfeeding with the WIC Food Package (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_4.pdf) Prevention of Rickets and Vitamin D Deficiency in Infants, Children, and Adolescents (http://pediatrics.aappublications.org/content/122/5/1142.full) Institute of Medicine Dietary Reference Intakes for Calcium and Vitamin D (https://nap.nationalacademies.org/catalog/13050/dietary-reference-intakes-for-calcium-and- vitamin-d) Section 7.8: Food Package 2 (Food Package for Infants 6-11 Months) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_8.pdf) WIC Local Agency (https://www.health.state.mn.us/people/wic/localagency/index.html) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(7.8)Minnesota WIC Operations Manual (MOM) Section 7.8: Food Package 2 Infants 6-11 Months#

(7.8)(document-1)#

Section 7.8: Food Package 2 (for Infants 6-11 months) 2/2020 References: CFR 246.10 Policy ▪ Food packages must be prescribed by CPAs, in consultation with the participant or parent/caregiver, and must be prescribed to minimize any adverse impact on breastfeeding. ▪ The food package must be appropriate to the category of eligibility and must be specifically tailored to address the nutritional needs, circumstances, and preferences of the participant. Purpose: To provide a food package that will best meet the participant’s needs and will be used by the participant. Procedures Issuance Requirements ▪ Food package 2 is issued to infants 6 through 11 months of age. There are three feeding options in this Food Package. The feeding options reflect the amount of breastfeeding. The amount of breastfeeding determines the infant’s Food Package. The infant’s Food Package determines mom’s Food Package. ▪ Fully Breastfed Infants receiving no formula from WIC--this is the ideal. (Mother is eligible for Food Package 7) ▪ Mostly-Breastfed Infants receiving limited amount of formula (Mother is eligible for Food Package 5, or Food Package 7 - if breastfeeding multiples) ▪ Some-Breastfed/Fully Formula Fed Infants (Mother is not eligible for a Food Package, beginning at 6 months after delivery) ▪ Breastfeeding is the normal method for feeding infants; therefore, breastfeeding must be considered the first and preferred method to feed infants. Every mother must be encouraged to breastfeed. See Section 6.5: Breastfeeding Education for Pregnant Women. ▪ For breastfed infants receiving formula, CPAs must evaluate current feeding practices and issue the minimum amount of formula that is necessary. ▪ CPAs are not required to issue the maximum amount of formula allowed in the food package.

S E C T I O N 7 . 8 : F O O D P A C K A G E 2 ( F O R I N F A N T S 6 - 1 1 M O N T H S ) 2 ▪ For all infants receiving formula, the maximum formula amounts decrease when the infant turns 6 months old. CPAs must adjust the food package accordingly. ▪ Food packages for the breastfeeding mother and infant dyad are closely tied and must match except when the mother is breastfeeding multiple infants with differing breastfeeding statuses. ▪ I f the mother is breastfeeding multiple infants with differing breastfeeding statuses, the mother’s food package corresponds to the food package of the infant with the most breastfeeding. ▪ Issue the food package as indicated in the table below. Maximum amounts of formula vary by breastfeeding status. ▪ Only contract formulas – including both primary and alternate contract formulas -- are available in this Food Package. Standard non-contract formulas are not allowed. ▪ Infants on medically prescribed formulas receive Food Package 3. Food Package 2: Infants 6-11 months Available range of cans of formula or amount of food/month based on breastfeeding status Maximum number of ounces in ( ) Food item Fully Breastfed Mostly-Breastfed Some-Breastfed/ Fully Formula Fed Powdered Formula/Month (a 12.5-oz can of Enfamil Infant yields approximately 90 fl. oz. reconstituted) None 1-4 cans (384 fluid ounces) 5-7 cans (696 fluid ounces reconstituted) Concentrate Formula/Month None 1-12 cans (312 fluid ounces) 13-24 cans (624 fluid ounces reconstituted) Ready-To Use Formula/Month (RTF) None 1-10 quarts (320 fluid ounces) 11-20 quarts (640 fluid ounces) Infant Cereal 24 ounces 24 ounces 24 ounces Infant Fruits and Vegetables 64 (4 oz) jars (256 oz) 32 (4 oz) jars (128 oz) 32 (4 oz) jars (128 oz) Infant Meats 31 (2.5 oz) jars (77.5 oz) None None

S E C T I O N 7 . 8 : F O O D P A C K A G E 2 ( F O R I N F A N T S 6 - 1 1 M O N T H S ) 3 Tailoring ▪ Assess developmental readiness and provide foods if appropriate. Individualize and tailor the food package. Do not provide foods that participant will not consume or refuses. Counseling ▪ CPAs must counsel on infant feeding practices. See Guidance below. ▪ If formula is provided, CPAs must instruct participants on safe and appropriate formula preparation and handling. See additional information in Chapter 4 of the Infant Nutrition and Feeding Guide. Guidance ▪ Additional Food Package information is available on the WIC Local Agency website. CPA tools and participant educational resources may be downloaded. ▪ For information on introduction of complementary foods, refer to Chapter 5 of the Infant Nutrition and Feeding Guide. Frequently asked questions about Food Package 2 Are CPAs required to issue the maximum amount of formula to breastfed infants? ▪ No, CPAs are not required to issue the maximum amount of formula. ▪ For example, a 7 month old breastfed infant receiving 8 ounces of formula a day (248 ounces a month) does not need the maximum quantity of 384 ounces of reconstituted powdered formula from the Mostly-Breastfed Infant Food Package. Tailor the Food Package to the appropriate amount of formula needed. Why do maximum amounts of formula in the food package decrease at 6 months? ▪ Infant fruits and vegetables are added to the food package, replacing calories from formula. Formula needs decrease as an infant starts complementary foods. ▪ Infant fruits and vegetables enhance the nutritional value of the food package and introduce variety to the infant’s diet. ▪ Decreased amounts of formula better promote and support breastfeeding. ▪ Reduction of formula helps keep the food package cost neutral. What are typical nutrition education and counseling topics for this age? ▪ Signs of developmental readiness and feeding cues ▪ How to introduce solids ▪ How to use jarred infant foods ▪ Progression of solids, variety, and incorporating appropriate table foods

S E C T I O N 7 . 8 : F O O D P A C K A G E 2 ( F O R I N F A N T S 6 - 1 1 M O N T H S ) 4 ▪ For additional information, see Chapter 5-Complementary Foods, Infant Nutrition and Feeding. How do I assess for and counsel on Vitamin D adequacy? ▪ All infants need a source of Vitamin D. Refer to the American Academy of Pediatrics clinical report on Prevention of Rickets and Vitamin D Deficiency in Infants, Children, and Adolescents. ▪ Mostly-Breastfeeding and Fully Breastfeeding infants need a daily Vitamin D supplement of 400 IU to ensure adequacy. ▪ Infant formula is fortified with Vitamin D, but the infant’s Vitamin D adequacy depends on how much formula is consumed. AAP recommends Vitamin D supplementation for partially breastfed and non-breastfed infants ingesting less than 1 quart (or 1 liter) per day of Vitamin D-fortified formula. ▪ If there are questions, refer to the Health Care Provider. Why are jarred infant foods added to the infant’s food package at 6 months? ▪ The addition of jarred infant foods contributes to an overall dietary pattern that is consistent with established dietary recommendations for infants. (It is consistent with AAP recommendations.) ▪ Most infants are developmentally ready for solids around 6 months. ▪ Infant food fruits and vegetables introduce infants to new flavors and textures. Why do Fully Breastfed infants receive larger quantities of jarred infant foods? ▪ To encourage and promote full breastfeeding, the recommended amounts of baby food fruits and vegetables are more generous for fully breastfed infants than for other infants. Why do Fully Breastfed infants receive meat? ▪ Fully breastfed infants require additional sources of iron and zinc beginning at 6 months. Infant food meat provides added iron and zinc in a highly bioavailable form. Why commercial infant foods? Commercial infant foods are: ▪ Available in single-item formulations, and in varying textures appropriate for varying ages. ▪ More likely to provide nutritionally appropriate foods in low-income families. ▪ More likely to be consumed by the baby and not by other family members. ▪ Lower sodium content than many table foods ▪ Small quantities provide appropriate amounts per feeding and promote food safety.

S E C T I O N 7 . 8 : F O O D P A C K A G E 2 ( F O R I N F A N T S 6 - 1 1 M O N T H S ) 5 What are some ways to offer jarred infant foods to older infants, 9-12 months of age? Most infants advance to more textured, finely-chopped table foods during late infancy. Infant foods with puree-like consistency may not be appealing to them. Here are some counseling suggestions for using the jarred infant foods during that period: ▪ Use jarred foods to supplement an infant’s meal when the family meal does not include many infant-appropriate foods. ▪ Mix infant applesauce or vegetables with finely-chopped table meats to provide moisture. ▪ Mix infant fruits and vegetables with regular fruits and vegetables or other table foods that have been mashed. ▪ Add infant fruit to infant cereal or to regular oatmeal or other cooked cereals. What if a participant does not wish to use jarred infant foods? ▪ These foods can offer important nutrition benefits to an infant but are not absolutely necessary if table foods are used appropriately. Some participants, particularly those from traditional or cultural backgrounds, are accustomed to preparing homemade baby foods. Jarred infant foods should not replace those foods, but rather, should supplement them. ▪ Explain to participants ▪ Key nutrients that jarred infant foods can provide ▪ How jarred foods can be used to supplement table foods that are given ▪ How to incorporate jarred foods with table foods ▪ Encourage participants to continue to include appropriate home-prepared foods for infants. Will participants think that jarred baby foods are the only appropriate foods for the 1st year? ▪ Jarred infant foods provide nutrients and flavors as part of the infant’s overall diet. As an infant gains developmental skills, it is important that they try progressive textures and a variety of foods, including appropriate table foods. ▪ Counsel the participant on when and how to add table foods to the baby’s diet to match developmental skills. Under what circumstances should the food package be tailored? When a participant will not consume or refuses a particular food. Examples include: ▪ Food allergy to a WIC food ▪ Exclusive tube feeding ▪ Vegan family that does not wish to give meat to their child ▪ Premature or developmentally-delayed infant not yet ready for solids Reference – Complete Listing of Hyperlinks Section 7.13: Food Package 7 (for Fully Breastfeeding Women) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_13.pdf)

S E C T I O N 7 . 8 : F O O D P A C K A G E 2 ( F O R I N F A N T S 6 - 1 1 M O N T H S ) 6 Section 7.11: Food Package 5 (for Pregnant Women and Mostly-Breastfeeding Women) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_11.pdf) Section 6.5: Breastfeeding Education for Pregnant Women (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_5.pdf) Section 7.9: Food Package 3 (for Infants, Women, and Children with Qualifying Medical Conditions) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_9.pdf) Infant Nutrition and Feeding Guide (https://wicworks.fns.usda.gov/sites/default/files/media/document/infant-feeding-guide.pdf) WIC Local Agency website (https://www.health.state.mn.us/people/wic/localagency/index.html#foodpackage) Prevention of Rickets and Vitamin D Deficiency in Infants, Children, and Adolescents (http://pediatrics.aappublications.org/content/122/5/1142.full) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164- 0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity employer.

(7.9)Minnesota WIC Operations Manual (MOM) Section 7.9: Food Package 3 Infants, Women and Children with Qualifying Medical Conditions#

(7.9)(document-1)#

Section 7.9: Food Package for Infants, Women, and Children with Qualifying Medical Conditions (Food Package 3) FEBURARY 2018 References: 7 CFR 246.10 Policy: CPAs may issue WIC-eligible standard contract infant formula, exempt infant formula or WIC-eligible medical foods to women, infants, and children who have a documented qualifying medical condition that requires the use of a WIC formula because the use of conventional food is precluded, restricted, or inadequate to address their special nutritional needs. Supplemental foods also may be issued in conjunction with medical formula with adequate medical documentation. Purpose: To assure participants receive the WIC-eligible medical formulas and supplemental foods that meet their medical and/or nutritional needs and will be used by the participant. Definitions Exempt infant formula: An exempt infant formula intended for use by infants who have inborn errors of metabolism or low birth weight, or who otherwise have unusual medical or dietary problems. Medical food: The term medical food, as defined in section 5(b) of the Orphan Drug Act (21 U.S.C. 360ee (b) (3)) is "a food which is formulated to be consumed or administered enterally under the supervision of a physician and which is intended for the specific dietary management of a disease or condition for which distinctive nutritional requirements, based on recognized scientific principles, are established by medical evaluation." Procedures Processing Formula Requests ▪ Local agencies must designate a CPA (preferably a Registered Dietitian to serve as the lead person in the agency for processing and overseeing of Food Package 3 requests. ▪ The lead person should ensure that all CPAs are trained on the appropriate use of specific formulas and maximum amounts allowed; are aware of new products, including product formulation changes; and product availability.

S E C T I O N 7 . 9 : F O O D P A C K A G E F O R I N F A N T S , W O M E N , A N D C H I L D R E N W I T I H Q U A L I F Y I N G M E D I C A L C O N D I T I O N S ( F O O D P A C K A G E 3 ) 2 Issuance Requirements ▪ Participants who are eligible to receive this food package must have one or more qualifying conditions as determined by a Health Care Professional licensed to write medical prescriptions. Food Package 3 provides: ▪ Infants with exempt infant formula. ▪ Children with standard contract infant formula, exempt infant formula or WIC-eligible medical food and allowable WIC foods. ▪ Women with WIC-eligible medical food and allowable WIC foods. ▪ Supplemental Foods - if included in the Health Care Provider’s prescription. For infants, see table below. ▪ For qualifying conditions (and non-qualifying) and medical documentation requirements, see Section 7.6: Medical Documentation and Exhibit 7-D: Medical Documentation form. ▪ Infants birth through 11 months: ▪ Issue the food package as indicated in the tables below. Refer to the Formula Amounts Guide for the allowed quantities of each formula. ▪ Maximum formula quantities vary by breastfeeding status and by age. ▪ CPAs must tailor the food packages accordingly. To support milk supply and infant health, only the minimal amount of formula needed (as determined by assessment) should be provided for infants who are breastfed. ▪ Prescriptions for specialized premature formulas for very premature infants may only be approved 1 month at a time, e.g., Human Milk Fortifier, Similac Special Care 20/24, Enfamil Premature 20/24. ▪ Infants 6 months of age or older: ▪ Infants receiving exempt infant formula must have medical documentation for issuance of complementary foods. Medical documentation must be obtained prior to issuance of complementary food. ▪ Infants, whose medical condition prevents them from consuming complementary infant foods, are eligible to receive a larger quantity of infant formula. See tables below. ▪ The increased quantity is equal to the monthly allowance for infants 4 through 5 months of age with the same feeding option. ▪ This applies to both infants receiving exempt (medical) formula and those receiving standard contract formula. ▪ Medical documentation, including the reason why the infant cannot eat solid foods (e.g., prematurity, tube feeding), must be obtained from the health care provider prior to increasing the formula amount.

S E C T I O N 7 . 9 : F O O D P A C K A G E F O R I N F A N T S , W O M E N , A N D C H I L D R E N W I T I H Q U A L I F Y I N G M E D I C A L C O N D I T I O N S ( F O O D P A C K A G E 3 ) 3 ▪ Children 1-4 years of age: ▪ Issue the food package as indicated in the tables below. The Formula Amounts Guide for Medical Formula and the Contract Formula Amounts Guide list the allowed quantities of each formula. ▪ Children may receive whole or 2% milk if indicated as appropriate by the Health Care Provider on the medical documentation form. ▪ 32 oz. infant cereal or 36 oz. regular breakfast cereal is available for children 1-4 years of age. Issue the appropriate type of cereal based on the child’s developmental abilities. ▪ 32 – 4 oz. jars (128 oz.) of infant pureed fruits/vegetables may be substituted for the $8.00 fruit/vegetable food benefit for children with qualifying medical conditions that would benefit from pureed food. Medical documentation is required. ▪ Women: ▪ Issue the food package as indicated in the tables below. The Formula Amounts Guide lists the allowed quantities of each formula. ▪ Women may receive whole or 2% milk if indicated as appropriate by the Health Care Provider on the medical documentation form. This food package may not be provided for: ▪ Solely for the purpose of enhancing nutrient intake or managing body weight without an underlying qualifying medical condition. ▪ Infants whose only condition is: ▪ A diagnosed formula intolerance or food allergy to lactose, sucrose, milk protein or soy protein that does not require the use of an exempt formula; ▪ A non-specific formula or food intolerance ▪ Women and children who have a food intolerance to lactose or milk protein that can be successfully managed with the use of other WIC supplemental foods. Items not provided by WIC per Federal Regulations ▪ Any apparatus or devices (e.g., enteral feeding tubes, bags, pumps) designed to administer WIC formulas ▪ Thickening agents ▪ Flavor packets ▪ Medicines or drugs ▪ Parenteral or intravenous nutrition products ▪ Enzymes ▪ Oral rehydration fluids or electrolyte solutions (e.g., Pedialyte)

S E C T I O N 7 . 9 : F O O D P A C K A G E F O R I N F A N T S , W O M E N , A N D C H I L D R E N W I T I H Q U A L I F Y I N G M E D I C A L C O N D I T I O N S ( F O O D P A C K A G E 3 ) 4 ▪ Sport or breakfast drinks ▪ Over-the-counter weight control/loss products Tailoring ▪ CPAs should tailor the food package to provide only the types and amounts of medical formula and supplemental foods most appropriate for the participant based on Health Care Provider’s documentation and CPA assessment. ▪ The maximum amount should not automatically be provided. Do not provide foods the participant will not consume or refuses. Examples include: ▪ Food allergy to a WIC food item ▪ Exclusive tube feeding ▪ If a WIC participant is receiving medical food or exempt infant formula from Medical Assistance (MA) or another source, and is not receiving the full amount needed as prescribed by the Health Care Provider, WIC may provide: ▪ The difference up to the maximum, but may not exceed the maximum. ▪ Supplemental foods as documented by Health Care Provider. High Risk ▪ All participants who receive this food package are “high risk” and require an Individual Nutrition Care Plan (INCP). INCP follow-up must be provided at least once during the certification to evaluate the appropriateness of the type and amount of formula and complementary/supplemental food. Refer to Section 6.6: High Risk Individual Nutrition Care Plans for additional information. Guidance Appropriate Follow-Up and Consultation with Medical Provider ▪ CPAs need to work with the Health Care Provider to assure the most appropriate food package is provided. If a CPA questions the appropriateness of a prescribed formula/food, she should contact the Health Care Provider to discuss his/her findings and share any pertinent information gathered at WIC. ▪ For example, if a child has been on a medical formula for some time (e.g., 6 months) and the CPA thinks the formula may be contributing to excessive weight gain, she/he should contact the physician to discuss: ▪ Why the formula was prescribed ▪ How long the child should be on the formula ▪ The plan for the child to progress to eating regular foods.

S E C T I O N 7 . 9 : F O O D P A C K A G E F O R I N F A N T S , W O M E N , A N D C H I L D R E N W I T I H Q U A L I F Y I N G M E D I C A L C O N D I T I O N S ( F O O D P A C K A G E 3 ) 5 Complementary/Supplemental Foods ▪ When appropriate, the use of conventional foods is important due to the additional nutrients, fiber, and other benefits that conventional foods provide. ▪ WIC nutrition education should support the importance of obtaining nutrients from foods when appropriate and that a balanced diet remains the preferred overall source of nutrients. ▪ Child participants who have developmental delays or swallowing disorders may benefit from receiving infant cereal in lieu of adult cereal. ▪ If the Health Care Provider indicates that both formula and milk/cheese/yogurt are appropriate for a child or woman participant, the CPA should tailor the formula and the milk/cheese/yogurt to appropriate quantities. Obtaining exempt infant formula and medical foods ▪ It is important that WIC participants be able to obtain their prescribed formula in a timely manner without difficulties or additional stress. ▪ Formulas such as Nutramigen, Alimentum, Similac Neosure, and Enfamil Enfacare are often available at retail stores. ▪ For formulas that are not available, the local agency has two options: ▪ Help locate the formula at a nearby pharmacy and determine that it will be available on a regular basis for the participant. ▪ Order through the state WIC office, using the Medical Formula Order Form. Transitional premature formulas, e.g. Similac Neosure and Enfamil Enfacare may be appropriate for infants born premature until up to 9-12 months Corrected Gestational Age. ▪ These formulas provide a slightly increased calorie level (22 calories/ounce) and increased amounts of calcium and phosphorous to promote adequate bone mineralization in premature infants. Pediatric Formulas and Drink Mixes: CPAs must assure there is a medical diagnosis for pediatric formulas and drink mixes in order to approve issuance. (Pediatric formulas and drink mixes include, but are not limited to the following products: PediaSure, Boost Kids Essentials, Nutren Jr, and Bright Beginnings Pediatric Drink. ▪ Some justifiable uses: These products may be appropriate for oral motor feeding disorders; tube feedings; failure-to-thrive from an underlying medical condition; or medical conditions that increase calorie requirements beyond what is expected for the child’s age. Some conditions associated with increased caloric need include cystic fibrosis, cancer, and congenital heart disease. ▪ Failure-to-thrive (FTT): FTT is a complex condition of diverse origins and must be diagnosed by a physician. Generally the diagnosis takes into account growth over time,

S E C T I O N 7 . 9 : F O O D P A C K A G E F O R I N F A N T S , W O M E N , A N D C H I L D R E N W I T I H Q U A L I F Y I N G M E D I C A L C O N D I T I O N S ( F O O D P A C K A G E 3 ) 6 development, dietary status, and psychosocial factors. Some of the indicators a physician might use to diagnose FTT include: ▪ Weight consistently below the 3rd percentile for age (some use 5th percentile) ▪ Weight < 80% of ideal weight for height/age ▪ Progressive fall-off in weight to below the 3rd percentile ▪ Decrease in expected rate of growth along the child’s previously defined growth curve irrespective of its relationship to the 3rd percentile ▪ “Picky Eaters” ▪ When a parent/caregiver requests a pediatric formula or drink mix because the child is a “picky eater”, or “just to be on the safe side”, the CPA should deny the request and explore the child’s “picky eating” through an assessment of the family’s feeding practices and the child’s intake. For example, assess: ▪ Child’s growth (using the growth chart) and if appropriate assure parents the child is growing adequately ▪ Food availability in the household ▪ Family meal patterns: Are there regular meals? Does the child eat alone? Does child/family watch TV during meals? ▪ Snacking: Are snacks scheduled? Is snacking excessive? ▪ Child’s intake: Does the child consume excessive amounts of milk? Or juice, Koolaid, or other sweet beverages? ▪ If child is taking a bottle ▪ For problems in the family ▪ Following the assessment, the CPA can focus counseling on the specific factors possibly contributing to the problem and assist the caregiver in establishing healthier eating patterns. If appropriate, the CPA can suggest other foods for increasing the child’s caloric intake. ▪ Providing these products in such cases doesn’t address the underlying issues, and may reinforce poor eating habits. For example, a “picky eater” who drinks several cans/day of a pediatric drink will likely have little appetite or interest in regular foods. Furthermore, it may contribute to excessive caloric intake and lead to childhood overweight. ▪ Another option in some cases is to provide a regular child’s food package and suggest the family purchase a product like Carnation Instant Breakfast on their own. Compare: ▪ 8 oz. can of PediaSure  237 kcal, 7 g protein. ▪ 8 oz. 1% milk w/ 1 pkt. Carnation Instant Breakfast  240 kcal, 13 g protein ▪ 8 oz. 1% milk  110 kcal, 8 g protein.

S E C T I O N 7 . 9 : F O O D P A C K A G E F O R I N F A N T S , W O M E N , A N D C H I L D R E N W I T I H Q U A L I F Y I N G M E D I C A L C O N D I T I O N S ( F O O D P A C K A G E 3 ) 7 Product information: Specific product information is available in the Minnesota WIC Formulary and Medical Reasons for Issuance. Letters to medical professionals: Letters communicating approval or denial of medically-prescribed formula are included in: ▪ Exhibit 7-F: Sample Approval Letter ▪ Exhibit 7-G: Sample Denial Letter ▪ Exhibit 7-H: Sample Letter Denying PediaSure High Risk Manual: Refer to the High Risk Counseling Guide for more information on Medically-Prescribed Formulas. Children and Women (Maximum Amounts/Month)- Food Package 3 WIC Category Children 1-4 years of Age Fully Breastfeeding Women up to 1 Year Postpartum Pregnant and Mostly- Breastfeeding Women up to 1 Year Postpartum Some- Breastfeeding and Non- Breastfeeding Women up to 6 Reconstituted Concentrate Formula (Powder and Ready-to Feed may be substituted at comparable nutritive value) 910 oz 910 oz 910 oz 910 oz Supplemental Foods may be provided with Medical Documentation Any types and amounts of foods from Food Package 4* Any types and amounts of foods from Food Package 7 Any types and amounts of foods from Food Package 5 Any types and amounts of foods from Food Package 6 *Infant cereal (32 oz.) and pureed fruits/vegetables (128 oz.) may be provided in place of regular cereal and fruits/vegetables to medically fragile children who would benefit from pureed foods. See next page for tables on infants receiving Food Package 3.

S E C T I O N 7 . 9 : F O O D P A C K A G E F O R I N F A N T S , W O M E N , A N D C H I L D R E N W I T I H Q U A L I F Y I N G M E D I C A L C O N D I T I O N S ( F O O D P A C K A G E 3 ) 8 Mostly-Breastfed Infants (Maximum Amounts/Month)- Food Package 3 *Ready-to-use may be issued in specific situations only. See Section 7.5.2. **Infants 6-11 with healthcare provider’s approval can be issued complementary foods, up to 128 oz of Infant Fruits and Vegetables and 24 oz of Infant Cereal. See next page for table on some-breastfed and fully formula fed infants receiving Food Package 3 Age 0-1 month 1-3 Months 4-5 Months 6-11 Months with Infant Foods** 6-11 Months No Infant Foods Reconstituted Powder Formula Ounces 104 435 522 384** 522 Reconstituted Concentrated Formula Ounces 104 364 442 312** 442 Ready-to-Use* Formula Ounces 104 384 448 320** 448 Mom’s Food Package 5 5 5 5 5

S E C T I O N 7 . 9 : F O O D P A C K A G E F O R I N F A N T S , W O M E N , A N D C H I L D R E N W I T I H Q U A L I F Y I N G M E D I C A L C O N D I T I O N S ( F O O D P A C K A G E 3 ) 9 Some-Breastfed and Fully Formula Fed Infants (Maximum Amounts/Month) – Food Package 3 *Ready-to-use may be issued in specific situations only. See Section 7.5.2. **Infants 6-11 with healthcare providers approval can be issued complementary foods, up to 128 oz of Infant Fruits and Vegetables and 24 oz of Infant Cereal. ***A Breastfeeding Woman, whose infant is 6-11 months old and categorized "Some Breastfeeding", will not get a food package. She can remain on the program as a breastfeeding woman, but her benefits will include breastfeeding support, nutrition education, and she may receive a breastpump as appropriate. Reference – Complete Listing of Hyperlinks Section 7.6: Medical Documentation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_6.pdf) Exhibit 7-D: Medical Documentation form (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7d. pdf) Formula Amounts Guide (https://www.health.state.mn.us/docs/people/wic/localagency/nutrition/formula/medical.pdf) Section 6.6: High Risk Individual Nutrition Care Plans (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch6/sct n6_6.pdf) Medical Formula Order Form (https://survey.vovici.com/se/56206EE346B198E1) Age 0-3 months 4-5 Months 6-11 Months with Infant Foods** 6-11 Months No Infant Foods Reconstituted Powder Formula Ounces 870 960 696** 960 Reconstituted Concentrated Formula Ounces 806 884 624** 884 Ready-to-Use* Formula Ounces 832 896 640** 896 Mom’s Food Package 6 6 *** ***

S E C T I O N 7 . 9 : F O O D P A C K A G E F O R I N F A N T S , W O M E N , A N D C H I L D R E N W I T I H Q U A L I F Y I N G M E D I C A L C O N D I T I O N S ( F O O D P A C K A G E 3 ) 1 0 Minnesota WIC Formulary and Medical Reasons for Issuance (https://www.health.state.mn.us/docs/people/wic/localagency/nutrition/formula/formulary.p df) Sample Approval Letter (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7f. pdf) Sample Denial Letter (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7g. pdf) Sample Letter Denying PediaSure (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7h. pdf) Section 7.5: WIC Formulas (https:/www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_5.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(7.10)Minnesota WIC Operations Manual (MOM) Section 7.10: Food Package 4 Children 1 through 4 years#

(7.10)(document-1)#

Section 7.10: Food Package 4 for Children 1 through 4 Years Old 1/2011 6/2025- Note: ▪ see Draft Section 7.10: Food Package for Children 1 through 4 Years Old (Food Package 4) for most current guidance. ▪ Exhibit 7-E: Authorization of Milk Substitute has been retracted (link removed) as it contrary to current federal regulations. References: 7 CFR 246.10 Policy ▪ Food packages must be prescribed by CPAs, in consultation with the participant or parent/caregiver. ▪ The food package must be appropriate to the category of eligibility and must be specifically tailored to address the nutritional needs, circumstances, and preferences of the participant. Purpose: To provide a food package that will best meet the participant’s needs and will be used by the participant. Procedures Issuance requirements Food Package 4 is issued to one category of participants: ▪ Children 1 through 4 years of age who do not have a condition qualifying them for Food Package 3. Issue the food package as indicated in the table below. ▪ Allowed substitutions are listed. ▪ Medical documentation is required for some substitutions. Refer to Section 7.6: Medical Documentation. Provide the appropriate type of milk for age and need: ▪ Whole milk is the only type of milk allowed for 1-year-old children (12 through 23 months).

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2 1 / 2 0 1 1 ▪ Low-fat 1% and fat-free skim milk are the only types of milk allowed for children > 24 months of age. ▪ Participants with reported lactose intolerance must try lactose-free milk before other milk substitutes can be considered. ▪ Other cow’s milk options include acidophilus, evaporated and powdered milk. Provide the appropriate type (whole, lowfat, and/or fat free) if available as a food package selection. ▪ Goat milk may be provided upon participant request. ▪ More than one type of milk may be given. Soy-based milk substitutes may be provided in cases of qualifying medical need up to the total maximum milk allowance. ▪ Medical documentation must be received before these foods can be issued, using Exhibit 7- E: Authorization of Milk Substitutes (exhibit retracted). ▪ For qualifying conditions, see table below. ▪ Medical authorization may be provided by telephone to a CPA, when necessary to prevent a delay that would place a participant at increased nutritional risk (determined on case-by- case basis) and until written confirmation is received, which must be within 1 month. Voucher issuance is limited to 1 month with verbal verification. Document the temporary verbal approval in the participant’s record. ▪ See Section 7.6: Medical Documentation. Do not provide a food if the child cannot consume or refuses the food. Examples include: ▪ Food allergy ▪ Medical condition for which the food is inappropriate ▪ Vegan family who will not use the food Homeless Package: To better meet the needs of homeless participants, adjust the food package accordingly. ▪ Fluid milk quantities may be issued in quart containers. ▪ Powdered and evaporated milk are also available. ▪ Juice quantities may be issued in the small juice box containers. See Section 7.14: Homeless Food Package.

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3 1 / 2 0 1 1 Children 1 through 4 Years Old (Food Package 4) Food item Maximum monthly allowances Allowed substitutions Substitution rates and maximums Milk, Fluid Cow and goat milk While milk for children up to 2 years of age Low-fat 1% or fat-free skim milk for children 2 years and older 16 quarts Cheese 1 pound cheese / 3 quarts of milk Max: 1 pound Acidophilus milk Max: 8 half-gallon containers Lactose-free milk Max: 8 half-gallon containers Evaporated milk 16 fluid ounces evap. / 32 fluid ounces of fluid milk (1:2 ratio) Max: 16 reconstituted quarts= 21 (12 oz.) cans Powdered milk Reconstituted amount equal to fluid milk Max: 16 reconstituted quarts Soy-based beverage** 1 quart soy-based beverage / 1 quart fluid milk Max: 16 quarts = 8 half-gallons Tofu** 1 pound tofu / 1 quart of milk Max: 16 pounds Juice, single variety 128 fluid ounces juice NA

Breakfast Cereal 36 ounces Infant cereal Max: 32 ounces Eggs 1 dozen eggs NA

Fruits and Vegetables $6.00 Cash value voucher NA

Whole grains including: bread, tortillas, oatmeal, and brown rice 2 pounds NA

Peanut butter or Dry/Canned beans 18 ounces peanut butter or 1 pound dry beans or 64 ounces canned beans

**Soy substitutions (soy-based beverage or tofu) for milk require medical documentation. Qualifying reasons include: ▪ Milk allergy ▪ Sever lactose maldigestion (cannot tolerate lactose-free milk)

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4 1 / 2 0 1 1 ▪ Vegan/vegetarian diet ▪ Medical condition requiring use of soy-based beverage ▪ Religious or cultural observance or practice Guidance Lactose intolerance Assess the degree of the intolerance. Often lactose intolerance does not require complete avoidance of dairy foods. Determine what approaches the participant has used to reduce symptoms. Individualize counseling. Some approaches include: ▪ Introduce milk slowly (e.g. ¼ - ½ cup); gradually increase the amount if tolerated. ▪ Drink only small amounts of milk at a time; spread milk intake out during the day (rather than drinking a large amount at one time). ▪ Drink milk with food. This will help slow digestion and release of lactose. ▪ Try yogurt with live and active cultures which may help digest the lactose. ▪ Try lactose-free milk. ▪ Consider some chocolate milk which may be better tolerated. Discuss food package options. Several different types of milk may be provided based on the participant’s need and tolerance. ▪ Lactose-free milk ▪ Lactose-free milk + cheese ▪ Lactose-free milk + regular milk ▪ Lactose-free milk + regular milk + cheese If the participant expresses reluctance to try lactose-free milk, use open-ended questions to identify and address participant perceptions and concerns. Counsel the participant on choosing the lactose-free milk with the appropriate fat content. It may be helpful to show a picture or sample carton to help the participant identify the correct item when shopping. ▪ Lactose-free whole milk: for children 1 year of age ▪ Lactose-free low fat 1% or fat-free skim milk: for children > 2 years Lactose-free milk may taste different to the participant. Offer suggestions if this is an issue or concern (note: do not suggest that taste will be an issue). ▪ Make sure the milk is served cold. ▪ Use on cereal, mixed with other foods, in hot cocoa, etc. where the difference in taste will not be noticed.

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5 1 / 2 0 1 1 ▪ If some regular milk is tolerated, mix with lactose-free milk. ▪ Try different brands of lactose-free milk. ▪ Give it time. Assure the participant that most people become accustomed to the slight difference. If lactose-free milk did not offer relief in cases of severe lactose maldigestion, soy-based beverage and/or tofu may be provided. Goat milk may be requested by some participants. Goat milk may be useful in some cases of cow’s milk insensitivity/intolerance or allergy to soy- based beverage. The types of casein in goat milk, plus the evaporation process (in evaporated milk), may render the milk more digestible and less allergenic. The fat has a high proportion of short chain and medium-chain fatty acids and thereby may be more digestible. Goat milk is not appropriate in these situations: ▪ Goat milk is not recommended for participants with cow’s milk allergy. Cross-reactivity of proteins may increase allergic potential to goat milk. For example, research has shown that most infants who are allergic to cow’s milk are or will become allergic to goat’s milk as well. ▪ Goat milk is unlikely to be helpful for lactose intolerance since the lactose content is comparable to cow’s milk. WIC-allowed goat milk is pasteurized and fortified with Vitamin D. Evaporated goat milk is also fortified with folic acid. Peanut butter Allergies: Updated guidance from AAP states that there is no convincing evidence that delaying the introduction of foods considered allergenic (such as peanut protein, fish, eggs, etc.) has any significant protective effect on the development of allergies. Refer to the Health Care Provider if there are concerns. (Source: Effects of Early Nutritional Interventions on the Development of Atopic Disease in Infants and Children; PEDIATRICS Volume 121, Number 1, January 2008.) Choking hazard: Since peanut butter may pose a choking hazard for younger children, it should not be provided until the child is developmentally ready. ▪ Instruct the caregiver on lower risk ways of offering peanut butter (spread on toast, cracker or other firm surface). ▪ Peanut butter should never be given for a child to eat off a spoon. Soy-based beverage and tofu When milk substitutes are used, assess intake and counsel to ensure adequate intake of nutrients that would have been provided by milk. For example:

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6 1 / 2 0 1 1 ▪ Tofu does not contain Vitamin D. ▪ Tofu often contains less calcium than milk. A 3-ounce tofu serving typically contains 2% to 30% of the Daily Value for calcium, depending on the brand. This is in comparison with 30 % DV for calcium found in 1 cup of milk. Reference – Complete Listing of Hyperlinks Section 7.9: Food Package 3 for infants, woman, and children with qualifying medical conditions (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_9.pdf) Section 7.6: Medical Documentation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_6.pdf) Exhibit 7-E: Authorization of Milk Substitutes (exhibit retracted) Section 7.14: Homeless Food Package (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_14.pdf) Effects of Early Nutritional Interventions on the Development of Atopic Disease in Infants and Children (https://pubmed.ncbi.nlm.nih.gov/18166574/) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(7.11)Minnesota WIC Operations Manual (MOM) Section 7.11: Food Package 5 Pregnant and Mostly-Breastfeeding Women#

(7.11)(document-1)#

Section 7.11: Food Package 5 for Pregnant Women and Mostly-Breastfeeding Women 1/2011 6/2025- Note: ▪ Exhibit 7-E: Authorization of Milk Substitute has been retracted (link removed). Documentation for soy foods is no longer required. References: 7 CFR 246.10 Policy: Food packages must be prescribed by CPAs, in consultation with the participant or parent/caregiver. The food package must be appropriate to the category of eligibility and must be specifically tailored to address the nutritional needs, circumstances, and preferences of the participant. Purpose: To provide a food package that will best meet the participant’s needs and will be used by the participant. Procedures Issuance requirements Food Package 5 is issued to two categories of participants: ▪ Pregnant women with singleton pregnancies; ▪ Mostly-Breastfeeding women, up to 1 year postpartum, whose Mostly-Breastfed infants receive formula from WIC in amounts that do not exceed the maximum formula allowance for Mostly-Breastfed infants and who do not have a condition qualifying them to receive Food Package 3. For maximum formula allowances, refer to: ▪ Food Package 1 (infants 0-5 months): MN WIC Contract Formula Amounts Guide ▪ Food Package 2 (infants 6-11 months): MN WIC Contract Formula Amounts Guide ▪ Food Package 3: MN WIC Medical Formula Amounts Guide For maximum formula allowances in ounces: MN WIC Formula Amounts Guide: Maximum Amounts by Federal Regulation.

S E C T I O N 7 . 1 1 : F O O D P A C K A G E 5 F O R P R E G N A N T A N D M O S T L Y - B R E A S T F E E D I N G W O M E N 2 For breastfeeding dyads, the infant’s food package will determine mom’s food package. For infant food packages, refer to Exhibit 7-J: Mom and Baby WIC Food Packages. Issue the food package as indicated in the table below. ▪ Allowed substitutions are described below. ▪ Medical documentation is required for some substitutions. Refer to Section 7.6: Medical Documentation. Do not provide a food if the participant cannot consume or will not use the food. Examples include: ▪ Food allergy ▪ Medical condition for which the food is inappropriate ▪ Vegan family who will not use the food Milk Low-fat 1% and fat-free skim are the only types of milk allowed for women. ▪ Participants with reported lactose intolerance must try lactose-free milk before other milk substitutes may be considered. ▪ Other cow’s milk options include acidophilus, evaporated and powdered milk. Provide the lowfat and/or fat free versions if available as a food package selection. ▪ Goat milk may be provided upon participant request. ▪ More than one type of milk or milk substitute may be issued. ▪ 1 pound cheese may be substituted for milk (see table below). Soy-based beverage Soy-based beverage may be provided as a milk substitute without medical documentation to replace some or all of the milk, up to the total maximum milk allowance (22 quarts). Tofu Up to 4 pounds tofu may be substituted for milk without medical documentation. See table below for substitution rates. ▪ Amounts > 4 pounds tofu may be provided in cases of qualifying medical need, up to the total maximum milk allowance. Medical documentation must be obtained prior to issuance using Exhibit 7-E: Authorization of Milk Substitutes. ▪ For qualifying conditions, see table below. ▪ Medical authorization may be provided by telephone to a CPA, when necessary to prevent a delay that would place a participant at increased nutritional risk (determined on case-by-case basis) and until written confirmation is received, which must be within 1

S E C T I O N 7 . 1 1 : F O O D P A C K A G E 5 F O R P R E G N A N T A N D M O S T L Y - B R E A S T F E E D I N G W O M E N 3 month. Voucher issuance is limited to 1 month with verbal verification. Document the temporary verbal approval in the participant’s record. ▪ Refer to Section 7.6: Medical Documentation. Bean/Peanut Butter issuance options Participants receive 2 choices, with multiple options for issuing beans and peanut butter. These include: ▪ 1 (18 ounce) jar peanut butter and 1 pound dry beans ▪ 1 (18 ounce) jar peanut butter and 4 (16 oz.) cans of beans ▪ 4 (16 ounce) cans of beans and 1 pound dry beans (no peanut butter) ▪ 2 (18 ounce) jars of peanut butter (no beans) ▪ 2 pounds dry beans (no peanut butter) ▪ 8 (16 ounce) cans of beans (no peanut butter) Homeless Package To better meet the needs of homeless participants, adjust the food package accordingly. ▪ Fluid milk quantities may be issued in quart containers. ▪ Powdered and evaporated milk are also available. ▪ Juice quantities may be issued in the small juice box containers. ▪ See Section 7.14: Homeless Food Package. See table on next page.

S E C T I O N 7 . 1 1 : F O O D P A C K A G E 5 F O R P R E G N A N T A N D M O S T L Y - B R E A S T F E E D I N G W O M E N 4 Food package 5: Pregnant and Mostly-Breastfeeding Participants **Tofu substitutions > 4 pounds for milk require medical documentation. Qualifying reasons include: ▪ Milk allergy ▪ Sever lactose maldigestion (cannot tolerate lactose-free milk) ▪ Vegan/vegetarian diet Food Item Maximum monthly allowances Allowed Substitutions Substitution rates and Maximums Milk, Fluid Cow and goat milk Low-fat 1% or fat- free skim milk 22 quarts Cheese 1 pound cheese / 3 quarts of milk Max: 1 pound Acidophilus milk Lowfat 1% or Fat free Max: 11 half-gallon containers Lactose-free milk Lowfat 1% or Fat free Max: 11 half-gallon containers Evaporated milk Lowfat 1% or Fat free 16 fluid ounces evap. / 32 fluid ounces of fluid milk (1:2 ratio) Max: 22 reconstituted quarts= 29 (12 oz.) cans Powdered milk Nonfat Reconstituted amount equal to fluid milk Max: 22 reconstituted quarts Soy-based beverage 1 quart soy-based beverage / 1 quart fluid milk Max: 22 quarts = 11 half-gallons Tofu** 1 pound tofu / 1 quart of milk Max: 4 pounds If > 4 pounds (Medical Documentation required)** Max: 22 pounds Juice, single variety 144 fluid ounces juice NA

Breakfast Cereal 36 ounces NA

Eggs 1 dozen eggs NA

Fruits and Vegetables $10.00 Cash value voucher NA

Whole grains including: bread, tortillas, oatmeal, and brown rice 1 pounds NA

Peanut butter 18 ounces peanut butter

Dry/Canned beans 1 pound dry beans or 64 ounces canned beans

S E C T I O N 7 . 1 1 : F O O D P A C K A G E 5 F O R P R E G N A N T A N D M O S T L Y - B R E A S T F E E D I N G W O M E N 5 ▪ Medical condition requiring use of soy-based beverage ▪ Religious or cultural observance or practice Guidance Lactose intolerance Assess the degree of the intolerance. Often lactose intolerance does not require complete avoidance of dairy foods. Determine what approaches the participant has used to reduce symptoms. Individualize counseling. Some approaches include: ▪ Introduce milk slowly (e.g. ¼ - ½ cup); gradually increase the amount if tolerated. ▪ Drink only small amounts of milk at a time; spread milk intake out during the day (rather than drinking a large amount at one time). ▪ Drink milk with food. This will help slow digestion and release of lactose. ▪ Try yogurt with live and active cultures which may help digest the lactose. ▪ Try lactose-free milk. ▪ Consider some chocolate milk which may be better tolerated. Discuss food package options. Several different types of milk may be provided based on the participant’s need. ▪ Lactose-free milk ▪ Lactose-free milk + cheese ▪ Lactose-free milk + regular milk ▪ Lactose-free milk + regular milk + cheese Instruct the participant on how to identify the lowfat version in the grocery store. It may be helpful to show a picture or sample carton. When issuing lactose-free milk in the Information System select “Fat Free or Lowfat 1%” lactose-free milk. If the participant expresses reluctance to try lactose-free milk, use open-ended questions to identify and address participant perceptions and concerns. Lactose-free milk may taste different to the participant. Offer suggestions if this is an issue (note: do not suggest to the participant that taste will be an issue). ▪ Make sure the milk is served cold. ▪ Use on cereal, mixed with other foods, in hot cocoa, etc. where the difference in taste will not be noticed. ▪ If some regular milk is tolerated, mix with lactose-free milk. ▪ Try different brands of lactose-free milk.

S E C T I O N 7 . 1 1 : F O O D P A C K A G E 5 F O R P R E G N A N T A N D M O S T L Y - B R E A S T F E E D I N G W O M E N 6 ▪ Give it time. Assure the participant that most people become accustomed to the slight difference. Goat milk may be preferred by some participants. Goat milk may be useful in some cases of cow milk insensitivity/intolerance or allergy to soy- based beverage. The types of casein in goat milk, plus the evaporation process (for evaporated milk), may render the milk more digestible and less allergenic. The fat has a high proportion of short chain and medium-chain fatty acids and thereby may be more digestible. Goat milk is not appropriate in these situations: ▪ Cow’s milk protein allergy: cross-reactivity of proteins may increase allergic potential to goat milk. ▪ Lactose intolerance: goat milk may not be helpful since the lactose content is comparable to cow’s milk. WIC-allowed goat milk is pasteurized and fortified with Vitamin D. Evaporated goat milk is also fortified with folic acid. Peanut butter Allergy prevention for the infant: updated AAP guidance states that there is lack of evidence that maternal dietary restrictions during pregnancy or lactation play a significant role in the prevention of allergies in infants. More study is needed to draw any definite conclusions. (Source: Effects of Early Nutritional Interventions on the Development of Atopic Disease in Infants and Children; PEDIATRICS Volume 121, Number 1, January 2008.) Refer to the Health Care Provider if there are concerns. Soy-based beverage and tofu When milk substitutes are used, assess intake and counsel to ensure adequate intake of nutrients that would have been provided by milk. For example: ▪ Tofu: does not contain Vitamin D. ▪ Tofu often contains less calcium than milk. A 3-ounce tofu serving typically contains 2% to 30% of the Daily Value for calcium, depending on the brand. This is in comparison with 30 % DV for calcium found in 1 cup of milk. Reference – Complete Listing of Hyperlinks Section 7.9: Food Package for Infants, Women, and Children with Qualifying Medical Conditions (Food Package 3) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_9.pdf)

S E C T I O N 7 . 1 1 : F O O D P A C K A G E 5 F O R P R E G N A N T A N D M O S T L Y - B R E A S T F E E D I N G W O M E N 7 MN WIC Contract Formula Amounts Guide (https://www.health.state.mn.us/docs/people/wic/localagency/nutrition/formula/contract.pdf) MN WIC Medical Formula Amounts Guide (https://www.health.state.mn.us/docs/people/wic/localagency/nutrition/formula/medical.pdf) MN WIC Formula Amounts Guide: Maximum Amounts by Federal Regulation (https://www.health.state.mn.us/docs/people/wic/localagency/nutrition/formula/maxamounts. pdf) Exhibit 7-J: Mom and Baby WIC Food Packages (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7j.p df) Section 7.14: Homeless Food Package (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_14.pdf) Effects of Early Nutritional Interventions on the Development of Atopic Disease in Infants and Children (https://pubmed.ncbi.nlm.nih.gov/18166574/) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(7.12)Minnesota WIC Operations Manual (MOM) Section 7.12: Food Package 6 Some-Breastfeeding and Nonbreastfeeding Postpartum Women#

(7.12)(document-1)#

1 1 / 2 0 1 1

Section 7.12: Food Package 6 for Some-Breastfeeding and Non-Breastfeeding Postpartum Women 1/2011 6/2025- Note: ▪ Exhibit 7-E: Authorization of Milk Substitute has been retracted (link removed) as it contrary to current federal regulations. References: 7 CFR 246.10 Policy: Food packages must be prescribed by CPAs, in consultation with the participant or parent/caregiver. The food package must be appropriate to the category of eligibility and must be specifically tailored to address the nutritional needs, circumstances, and preferences of the participant. Purpose: To provide a food package that will best meet the participant’s needs and will be used by the participant. Procedures Issuance requirements Food Package 6 is issued to two categories of participants: ▪ Non-breastfeeding postpartum women up to 6 months postpartum ▪ Some-Breastfeeding women up to 6 months postpartum, whose infants receive more formula than allowed in the Mostly-Breastfed Infant food package. This includes women breastfeeding multiple infants who are receiving the Some-Breastfeeding Infant food package. For maximum formula allowances, refer to: ▪ Food Package 1 (infants 0-5 months): Contract Formula Amounts Guide ▪ Food Package 2 (infants 6-11 months): Contract Formula Amounts Guide ▪ Food Package 3: MN WIC Medical Formula Amounts Guide ▪ For maximum formula allowances in ounces: MN WIC Formula Amounts Guide: Maximum Amounts by Federal Regulation. For breastfeeding dyads, the infant’s food package will determine mom’s food package. For infant food packages, refer to Exhibit 7-J: Mom and Baby WIC Food Packages. Issue the food package as indicated in the table below.

S E C T I O N 7 . 1 2 : F O O D P A C K A G E 6 F O R S O M E - B R E A S T F E E D I N G A N D N O N - B R E A S T F E E D I N G P O S T P A R U T M W O M E N

2 1 / 2 0 1 1 ▪ Allowed substitutions are described below. ▪ Medical documentation is required for some substitutions. Refer to Section 7.6: Medical Documentation. Do not provide a food if the participant cannot consume or will not use the food. Examples include: ▪ Food allergy ▪ Medical condition for which the food is inappropriate ▪ Vegan family who will not use the food Milk Low-fat 1% and fat-free skim are the only types of milk allowed for women. ▪ Participants with reported lactose intolerance must try lactose-free milk before milk substitutes may be considered. ▪ Other cow’s milk options include acidophilus, evaporated and powdered milk. Provide the lowfat and/or fat free versions if available as a food package selection. ▪ Goat milk may be provided upon participant request. ▪ More than one type of milk or milk substitute may be issued. ▪ 1 pound of cheese may be substituted for milk (see table below). Soy-based beverage Soy-based beverage may be provided as a milk substitute without medical documentation to replace some or all of the milk, up to the total maximum milk allowance (16 quarts). Tofu Up to 4 pounds tofu may be substituted for milk without medical documentation. See table below for substitution rates. ▪ Amounts > 4 pounds tofu may be provided in cases of qualifying medical need, up to the total maximum milk allowance. Medical documentation must be obtained prior to issuance using Exhibit 7-E: Authorization of Milk Substitutes. ▪ For qualifying conditions, see table below. ▪ Medical authorization may be provided by telephone to a CPA, when necessary to prevent a delay that would place a participant at increased nutritional risk (determined on case-by-case basis) and until written confirmation is received, which must be within 1 month. Voucher issuance is limited to 1 month with verbal verification. Document the temporary verbal approval in the participant’s record. ▪ Refer to Section 7.6: Medical Documentation.

S E C T I O N 7 . 1 2 : F O O D P A C K A G E 6 F O R S O M E - B R E A S T F E E D I N G A N D N O N - B R E A S T F E E D I N G P O S T P A R U T M W O M E N

3 1 / 2 0 1 1 Some-Breastfeeding after 6 months postpartum Some-Breastfeeding women receiving Food Package 6 do not receive a food package after the infant turns 6 months. However, these women remain as active participants and receive breastfeeding support, breastpumps (if needed) and nutrition education. ▪ If the family reports food insecurity, determine whether a referral to MAC would be appropriate to best meet participant needs. ▪ If the participant chooses to participate in MAC rather than WIC in order to benefit from MAC supplemental foods, terminate the WIC certification if still active. Non-breastfeeding women after 6 months postpartum Eligibility for non-breastfeeding women ends at 6 months postpartum. ▪ Refer these women to the MAC program for supplemental foods. Homeless package To better meet the needs of homeless participants, adjust the food package accordingly. ▪ Fluid milk quantities may be issued in quart containers. ▪ Powdered and evaporated milk are also available. ▪ Juice quantities may be issued in the small juice box containers. ▪ See Section 7.14: Homeless Food Package. See table on next page.

S E C T I O N 7 . 1 2 : F O O D P A C K A G E 6 F O R S O M E - B R E A S T F E E D I N G A N D N O N - B R E A S T F E E D I N G P O S T P A R U T M W O M E N

4 1 / 2 0 1 1 Food Package 6: Some-Breastfeeding/Non-Breastfeeding Women up to 6 months Postpartum **Tofu substitutions > 4 pounds for milk require medical documentation. Qualifying reasons include: ▪ Milk allergy ▪ Sever lactose maldigestion (cannot tolerate lactose-free milk) ▪ Vegan/vegetarian diet ▪ Medical condition requiring use of soy-based beverage ▪ Religious or cultural observance or practice Food Item Maximum monthly allowances Allowed Substitutions Substitution rates and Maximums Milk, Fluid Cow and goat milk Low-fat 1% or fat- free skim milk 16 quarts Cheese 1 pound cheese / 3 quarts of milk Max: 1 pound Acidophilus milk Lowfat 1% or Fat free Max: 8 half-gallon containers Lactose-free milk Lowfat 1% or Fat free Max: 8 half-gallon containers Evaporated milk Lowfat 1% or Fat free 16 fluid ounces evap. / 32 fluid ounces of fluid milk (1:2 ratio) Max: 16 reconstituted quarts= 21 (12 ounce) cans Powdered milk Nonfat Reconstituted amount equal to fluid milk Max: 16 reconstituted quarts Soy-based beverage 1 quart soy-based beverage / 1 quart fluid milk Max: 16 quarts = 8 half-gallons Tofu** 1 pound tofu / 1 quart of milk Max: 4 pounds If > 4 pounds (Medical Documentation required)** Max: 16 pounds Juice, single variety 96 fluid ounces juice NA

Breakfast Cereal 36 ounces NA

Eggs 1 dozen eggs NA

Fruits and Vegetables $10.00 Cash value voucher NA

Whole grains including: bread, tortillas, oatmeal, and brown rice NA

Peanut butter or Dry/Canned beans 18 ounces peanut butter or 1 pound dry beans or 64 ounces canned beans

S E C T I O N 7 . 1 2 : F O O D P A C K A G E 6 F O R S O M E - B R E A S T F E E D I N G A N D N O N - B R E A S T F E E D I N G P O S T P A R U T M W O M E N

5 1 / 2 0 1 1 Guidance Lactose intolerance Assess the degree of the intolerance. Often lactose intolerance does not require complete avoidance of dairy foods. Determine what approaches the participant has used to reduce symptoms. Individualize counseling. Some approaches include: ▪ Introduce milk slowly; gradually increase the amount over time. ▪ Drink only small amounts of milk at a time; spread milk intake out during the day (rather than drinking a large amount at one time). ▪ Drink milk with food. This will help slow digestion and release of lactose. ▪ Yogurt with active and live cultures may help digest the lactose. ▪ Try lactose-free milk. ▪ Consider some chocolate milk which may be better tolerated. Discuss food package options. Several different types of milk may be provided based on the participant’s need. ▪ Lactose-free milk ▪ Lactose-free milk + cheese ▪ Lactose-free milk + regular milk ▪ Lactose-free milk + regular milk + cheese Instruct the participant on selecting the lowfat version in the grocery store. It may be helpful to show a picture or sample carton to help her identify the correct item when shopping. When issuing lactose-free milk in the Information System, select “Fat Free or Lowfat 1%” lactose-free milk. Lactose-free milk may taste different to the participant. Offer suggestions if this is an issue (note: do not suggest that taste will be an issue). ▪ Make sure the milk is served cold. ▪ Use on cereal, mixed with other foods, in hot cocoa, etc. where the difference in taste will not be noticed. ▪ If some regular milk is tolerated, mix with lactose-free milk. ▪ Try different brands of lactose-free milk. ▪ Give it time. Assure the participant that most people become accustomed to the slight difference. If the participant expresses reluctance to try lactose-free milk, use open-ended questions to identify and address participant perceptions and concerns.

S E C T I O N 7 . 1 2 : F O O D P A C K A G E 6 F O R S O M E - B R E A S T F E E D I N G A N D N O N - B R E A S T F E E D I N G P O S T P A R U T M W O M E N

6 1 / 2 0 1 1 Goat milk Goat milk may be preferred by some participants. ▪ Goat milk may be useful in some cases of cow milk insensitivity/intolerance or allergy to soy- based beverage. The types of casein in goat milk, plus the evaporation process (for evaporated milk), may render the milk more digestible and less allergenic. The fat has a high proportion of short chain and medium-chain fatty acids and thereby may be more digestible. ▪ Goat milk is not appropriate in these situations: ▪ Cow’s milk protein allergy: cross-reactivity of proteins may increase allergic potential to goat milk. ▪ Lactose intolerance: goat milk may not be helpful since the lactose content is comparable to cow’s milk. ▪ WIC-allowed goat milk is pasteurized and fortified with Vitamin D. Evaporated goat milk is also fortified with folic acid. Peanut butter Allergy prevention for the infant: updated AAP guidance states that there is lack of evidence that maternal dietary restrictions during lactation play a significant role in the prevention of allergies in infants. More study is needed to draw any definite conclusions. (Source: Effects of Early Nutritional Interventions on the Development of Atopic Disease in Infants and Children; PEDIATRICS Volume 121, Number 1, January 2008.) Refer to the Health Care Provider if there are concerns. Soy-based beverage and tofu When milk substitutes are used, assess intake and counsel to ensure adequate intake of nutrients that would have been provided by milk. For example: ▪ Tofu: does not contain Vitamin D. ▪ Tofu often contains less calcium than milk. A 3-ounce tofu serving typically contains 2% to 30% of the Daily Value for calcium, depending on the brand in comparison with 30 % DV for calcium found in 1 cup of milk. Reference – Complete Listing of Hyperlinks Contract Formula Amounts Guide (https://www.health.state.mn.us/docs/people/wic/localagency/nutrition/formula/contract.pdf) MN WIC Medical Formula Amounts Guide (https://www.health.state.mn.us/docs/people/wic/localagency/nutrition/formula/medical.pdf)

S E C T I O N 7 . 1 2 : F O O D P A C K A G E 6 F O R S O M E - B R E A S T F E E D I N G A N D N O N - B R E A S T F E E D I N G P O S T P A R U T M W O M E N

7 1 / 2 0 1 1 MN WIC Formula Amounts Guide: Maximum Amounts by Federal Regulation (https://www.health.state.mn.us/docs/people/wic/localagency/nutrition/formula/maxamounts. pdf) Exhibit 7-J: Mom and Baby WIC Food Packages (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7j.p df) Section 7.6: Medical Documentation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_6.pdf) Section 7.14: Homeless Food Package (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_14.pdf) Effects of Early Nutritional Interventions on the Development of Atopic Disease in Infants and Children (https://pubmed.ncbi.nlm.nih.gov/18166574/) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(7.13)Minnesota WIC Operations Manual (MOM) Section 7.13: Food Package 7 Fully Breastfeeding Women#

(7.13)(document-1)#

1 1/2011

Section 7.13: Food Package 7 for Fully Breastfeeding Women 1/2011 6/2025- Note: ▪ Exhibit 7-E: Authorization of Milk Substitute has been retracted (link removed). Documentation for soy foods is no longer required. References: 7 CFR 246.10 Policy: Food packages must be prescribed by CPAs, in consultation with the participant or parent/caregiver. The food package must be appropriate to the category of eligibility and must be specifically tailored to address the nutritional needs, circumstances, and preferences of the participant. Purpose: To provide a food package that will best meet the participant’s needs and will be used by the participant. Procedures Issuance requirements Food package 7 is issued to three categories of participants, none of whom have a medical condition qualifying them to receive Food Package 3 (Section 7.9: Food Package for Infants, Women, and Children with Qualifying Medical Conditions). ▪ Fully-Breastfeeding women up to 1 year postpartum whose infants do not receive infant formula from WIC. ▪ This includes pregnant women who are fully breastfeeding an infant less than 1 year of age. ▪ Women pregnant with multiples ▪ Women who are Mostly-Breastfeeding multiple infants who are receiving the Mostly- Breastfed formula package from WIC. For maximum formula allowances, refer to: ▪ Food Package 1 (infants 0-5 months): Contract Formula Amounts Guide ▪ Food Package 2 (infants 6-11 months): Contract Formula Amounts Guide ▪ Food Package 3: MN WIC Medical Formula Amounts Guide

S E C T I O N 7 . 1 3 : F O O D P A C K A G E 7 F O R F U L L Y B R E A S T F E E D I N G W O M E N

2 1 / 2 0 1 1 ▪ For maximum formula allowances in ounces: MN WIC Formula Amounts Guide: Maximum Amounts by Federal Regulation. For breastfeeding dyads, the infant’s food package will determine mom’s food package. For infant food packages, refer to Exhibit 7-J: Mom and Baby WIC Food Packages. Issue the food package as indicated in the table below. ▪ Allowed substitutions are described below. ▪ Medical documentation is required for some substitutions. Refer Section 7.6: Medical Documentation. Do not provide a food if the participant cannot consume or will not use the food. Examples include: ▪ Food allergy ▪ Medical condition for which the food is inappropriate ▪ Vegan family who will not use the food Fully breastfeeding multiples Women fully breastfeeding multiples receive Food Package 7+ which is larger, providing 1.5 times the amount in FP 7. ▪ Assess whether these amounts are appropriate: ▪ Will the participant be able to use the full amount (e.g., 9 gallons milk/month)? ▪ Provide the maximum amount if appropriate. If not, tailor amounts to meet the participant’s needs. Fully breastfeeding multiples with different breastfeeding statuses For Women breastfeeding multiples with different breastfeeding statuses, the mother’s food package corresponds to the food package of the infant with the most breastfeeding. ▪ If one of the multiples is receiving the Fully-Breastfed Infant food package and the other(s) is receiving the Mostly- or Some- Breastfed food package, the mother may receive Food Package 7 (Fully-Breastfeeding). ▪ If one of the multiples is receiving the Mostly-Breastfed Infant food package and the other(s) is receiving the Some-Breastfed food package, the mother will receive Food Package 5 (Mostly-Breastfeeding). Milk Low-fat 1% and fat-free skim are the only types of milk allowed for women. ▪ Participants with reported lactose intolerance must try lactose-free milk before other milk substitutes may be considered.

S E C T I O N 7 . 1 3 : F O O D P A C K A G E 7 F O R F U L L Y B R E A S T F E E D I N G W O M E N

3 1 / 2 0 1 1 ▪ Other cow’s milk options include acidophilus, evaporated and powdered milk. Provide the lowfat and/or fat free versions if available as a food package selection. ▪ Goat milk may be provided upon participant request. ▪ More than one type of milk or milk substitute may be issued. ▪ 2 pounds cheese may be substituted for milk (see table below). Soy-based beverage Soy-based beverage may be provided as a milk substitute without medical documentation to replace some or all of the milk, up to the total maximum milk allowance (24 quarts). Tofu Up to 6 pounds tofu may be substituted for milk without medical documentation. See table below for substitution rates. ▪ Amounts > 6 pounds tofu may be provided in cases of qualifying medical need, up to the total maximum milk allowance. Medical documentation must be obtained prior to issuance using Exhibit 7-E: Authorization of Milk Substitutes. ▪ For qualifying conditions, see table footnote below. ▪ Medical authorization may be provided by telephone to a CPA, when necessary to prevent a delay that would place a participant at increased nutritional risk (determined on case-by-case basis) and until written confirmation is received, which must be within 1 month. Voucher issuance is limited to 1 month with verbal verification. Document the temporary verbal approval in the participant’s record. ▪ Refer to Section 7.6: Medical Documentation. Bean/Peanut Butter issuance options Participants receives 2 choices (or 3 choices for FP 7+ Breastfeeding Multiples), with various options for issuing beans and peanut butter. For example, FP 7+ options could include: ▪ One of each item: 1 jar peanut butter + 1 lb. dry beans + 4 (16 oz.) cans of beans ▪ Two of one item and one of another item: e.g., 2 jars of peanut butter + 1 lb. dry beans ▪ Three of the same item: e.g., 12 (16 oz.) cans of beans. Homeless Package To better meet the needs of homeless participants, adjust the food package accordingly. ▪ Fluid milk quantities may be issued in quart containers. ▪ Powdered and evaporated milk are also available. ▪ More than one kind of milk may be given.

S E C T I O N 7 . 1 3 : F O O D P A C K A G E 7 F O R F U L L Y B R E A S T F E E D I N G W O M E N

4 1 / 2 0 1 1 ▪ Juice quantities may be issued in the small juice box containers. ▪ See Section 7.14: Homeless Food Package. See tables on next pages

S E C T I O N 7 . 1 3 : F O O D P A C K A G E 7 F O R F U L L Y B R E A S T F E E D I N G W O M E N

5 1 / 2 0 1 1 Food package 7: Fully breastfeeding women up to 1 year postpartum, Mostly Breastfeeding multiple infants, Pregnant with multiples, and Pregnant while Fully breastfeeding **Tofu substitutions > 6 pounds for milk require medical documentation. Qualifying reasons include: ▪ Milk allergy ▪ Sever lactose maldigestion (cannot tolerate lactose-free milk) ▪ Vegan/vegetarian diet Food Item Maximum monthly allowances Allowed Substitutions Substitution rates and Maximums Milk, Fluid Cow and goat milk Low-fat 1% or fat- free skim milk 24 quarts Cheese 1 pound cheese / 3 quarts of milk Max: 2 pound Acidophilus milk Lowfat 1% or Fat free Max: 12 half-gallon containers Lactose-free milk Lowfat 1% or Fat free Max: 12 half-gallon containers Evaporated milk Lowfat 1% or Fat free 16 fluid ounces evap. / 32 fluid ounces of fluid milk (1:2 ratio) Max: 24 reconstituted quarts= 32 (12 oz.) cans Powdered milk Nonfat Reconstituted amount equal to fluid milk Max: 24 reconstituted quarts Soy-based beverage 1 quart soy-based beverage / 1 quart fluid milk Max: 24 quarts = 12 half-gallons Tofu** 1 pound tofu / 1 quart of milk Max: 6 pounds If > 6 pounds (Medical Documentation required)** Max: 24 pounds Cheese 1 pound

Juice, single variety 144 fluid ounces juice NA

Breakfast Cereal 36 ounces NA

Eggs 2 dozen eggs NA

Fruits and Vegetables $10.00 Cash value voucher NA

Whole grains including: bread, tortillas, oatmeal, and brown rice 1 pounds NA

Peanut butter 18 ounces peanut butter

Dry/Canned beans 1 pound dry beans or 64 ounces canned beans

Canned Fish 30 ounces fish; Light Tuna or Pink Salmon NA

S E C T I O N 7 . 1 3 : F O O D P A C K A G E 7 F O R F U L L Y B R E A S T F E E D I N G W O M E N

6 1 / 2 0 1 1 ▪ Medical condition requiring use of soy-based beverage ▪ Religious or cultural observance or practice Food package 7+: Fully breastfeeding multiples up to 1 year post partum Food Item Maximum monthly allowances Allowed Substitutions Substitution rates and Maximums Milk, Fluid Cow and goat milk Low-fat 1% or fat-free skim milk 36 quarts Cheese 1 pound cheese / 3 quarts of milk Max: 2 pound Acidophilus milk Lowfat 1% or Fat free Max: 18 half-gallon containers Lactose-free milk Lowfat 1% or Fat free Max: 18 half-gallon containers Evaporated milk Lowfat 1% or Fat free 16 fluid ounces evap. / 32 fluid ounces of fluid milk (1:2 ratio) Max: 36 reconstituted quarts= 48 (12 oz.) cans Powdered milk Nonfat Reconstituted amount equal to fluid milk Max: 36 reconstituted quarts Soy-based beverage 1 quart soy-based beverage / 1 quart fluid milk Max: 36 quarts = 18 half-gallons Tofu** 1 pound tofu / 1 quart of milk Max: 6 pounds If >6 pounds (Medical Documentation required)** Max: 36 pounds Cheese* 1.5 pound

Juice, single variety 216 fluid ounces juice NA

Breakfast Cereal 54 ounces NA

Eggs 3 dozen eggs NA

Fruits and Vegetables $15.00 Cash value voucher NA

Whole grains* including: bread, tortillas, oatmeal, and brown rice 1 pounds or 2 pounds (alternating months) NA

Peanut butter 18 ounces peanut butter

Dry/Canned beans 2 pound dry beans or 128 ounces canned beans

Canned Fish 45 ounces fish; Light Tuna or Pink Salmon NA

S E C T I O N 7 . 1 3 : F O O D P A C K A G E 7 F O R F U L L Y B R E A S T F E E D I N G W O M E N

7 1 / 2 0 1 1 *Whole Grains and Cheese: to provide the maximum benefit (1.5 pounds) Issue 1 pound for the 1st and 3rd months, and 2 pounds for the 2nd month of voucher issuance. **Tofu substitutions > 6 pounds for milk require medical documentation. Qualifying reasons include: ▪ Milk allergy ▪ Sever lactose maldigestion (cannot tolerate lactose-free milk) ▪ Vegan/vegetarian diet ▪ Medical condition requiring use of soy-based beverage ▪ Religious or cultural observance or practice Guidance Lactose intolerance Assess the degree of the intolerance. Often lactose intolerance does not require complete avoidance of dairy foods. Determine what approaches the participant has used to reduce symptoms. Individualize counseling. Some approaches include: ▪ Introduce milk slowly (e.g. ¼ - ½ cup); gradually increase the amount if tolerated. ▪ Drink only small amounts of milk at a time; spread milk intake out during the day (rather than drinking a large amount at one time). ▪ Drink milk with food. This will help slow digestion and release of lactose. ▪ Try yogurt with live and active cultures which may help digest the lactose. ▪ Try lactose-free milk. ▪ Consider some chocolate milk which may be better tolerated. Discuss food package options. Several different types of milk may be provided based on the participant’s need. For example: ▪ Lactose-free milk ▪ Lactose-free milk + cheese ▪ Lactose-free milk + regular milk ▪ Lactose-free milk + regular milk + cheese Instruct the participant on how to identify the lowfat version in the grocery store. It may be helpful to show a picture or sample carton. When issuing lactose-free milk in the Information System, select “Fat Free or Lowfat 1%” lactose-free milk. Lactose-free milk may taste different to the participant. Offer suggestions if this is an issue (note: do not suggest to the participant that taste will be an issue). ▪ Make sure the milk is served cold. ▪ Use on cereal, mixed with other foods, in hot cocoa, etc. where the difference in taste will not be noticed. ▪ If some regular milk is tolerated, mix with lactose-free milk.

S E C T I O N 7 . 1 3 : F O O D P A C K A G E 7 F O R F U L L Y B R E A S T F E E D I N G W O M E N

8 1 / 2 0 1 1 ▪ Try different brands of lactose-free milk. ▪ Give it time. Assure the participant that most people become accustomed to the slight difference. If the participant expresses reluctance to try lactose-free milk, use open-ended questions to identify and address participant perceptions and concerns. Goat milk Goat milk may be preferred by some participants. ▪ Goat milk may be useful in some cases of cow milk insensitivity/intolerance or allergy to soy- based beverage. The types of casein in goat milk, plus the evaporation process (for evaporated milk), may render the milk more digestible and less allergenic. The fat has a high proportion of short chain and medium-chain fatty acids and thereby may be more digestible. ▪ Goat milk is not appropriate in these situations: ▪ Cow’s milk protein allergy: cross-reactivity of proteins may increase allergic potential to goat milk. ▪ Lactose intolerance: goat milk may not be helpful since the lactose content is comparable to cow’s milk. ▪ WIC-allowed goat milk is pasteurized and fortified with Vitamin D. Evaporated goat milk is also fortified with folic acid. Peanut butter Allergy prevention for the infant: updated AAP guidance states that there is lack of evidence that maternal dietary restrictions during lactation play a significant role in the prevention of allergies in infants. More study is needed to draw any definite conclusions. (Source: Effects of Early Nutritional Interventions on the Development of Atopic Disease in Infants and Children; PEDIATRICS Volume 121, Number 1, January 2008.) Refer to the Health Care Provider if there are concerns. Soy-based beverage and tofu When milk substitutes are used, assess intake and counsel to ensure adequate intake of nutrients that would have been provided by milk. For example: ▪ Tofu does not contain Vitamin D. ▪ Tofu often contains less calcium than milk. A 3-ounce tofu serving typically contains 2% to 30% of the Daily Value for calcium, depending on the brand, in comparison with 30 % DV for calcium found in 1 cup of milk.

S E C T I O N 7 . 1 3 : F O O D P A C K A G E 7 F O R F U L L Y B R E A S T F E E D I N G W O M E N

9 1 / 2 0 1 1 Reference – Complete Listing of Hyperlinks Section 7.9: Food Package for Infants, Women, and Children with Qualifying Medical Conditions (Food Package 3) (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_3.pdf) Contract Formula Amounts Guide (https://www.health.state.mn.us/docs/people/wic/localagency/nutrition/formula/contract.pdf) MN WIC Medical Formula Amounts Guide (https://www.health.state.mn.us/docs/people/wic/localagency/nutrition/formula/medical.pdf) MN WIC Formula Amounts Guide: Maximum Amounts by Federal Regulation (https://www.health.state.mn.us/docs/people/wic/localagency/nutrition/formula/maxamounts. pdf) Exhibit 7-J: Mom and Baby WIC Food Packages (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7j.p df) Section 7.6: Medical Documentation (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_6.pdf) Section 7.14: Homeless Food Package (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_14.pdf) Effects of Early Nutritional Interventions on the Development of Atopic Disease in Infants and Children (https://pubmed.ncbi.nlm.nih.gov/18166574/) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(7.14)Minnesota WIC Operations Manual (MOM) Section 7.14: Food Package Options for Homeless Participants#

(7.14)(document-1)#

1 4/2021

Section 7.14: Food Package Options for Homeless Participants 4/2021 References: 7 CFR 246.10 Policy: Local agencies must make food package adjustments as requested to accommodate participants who are homeless. Purpose: To provide foods that are suited to a homeless individual’s resources and needs. Procedures Assess the participant’s circumstances, including availability of food storage and refrigeration, transportation, access to grocery stores and use of specific foods, to determine what food package adjustments are needed to accommodate the participant’s situation. Additional considerations include: ▪ Residence in a shelter or other living quarters that lack cooking facilities or with very limited cooking and food preparation facilities. ▪ Inconsistent access to sanitary food storage and preparation facilities and/or unsanitary or restricted water supply. ▪ Residence in a homeless facility, provided that: ▪ The homeless facility does not accrue financial or in-kind benefit from a person’s participation in the Program. ▪ Foods provided by the WIC Program are not subsumed into a communal food service, but available exclusively to the WIC participant for whom they are issued. ▪ The homeless facility places no constraints on the ability of the participant to partake of the supplemental foods from WIC, breastfeeding support or nutrition education. WIC staff should assist the participant with determining which WIC foods will best meet the facility’s storage or refrigeration requirements. ▪ Living “between” places, including migrants. Residency in a homeless facility or other institution does not automatically determine need for food package adjustments. A standard food package may be appropriate for homeless participants that have adequate food storage and preparation facilities. Determine the appropriate benefit issuance schedule based on the individual’s needs/circumstances and when follow up is needed.

S E C T I O N 7 . 1 4 H O M E L E S S F O O D P A C K A G E

2 4 / 2 0 2 1 See Section 5.6: Homeless Applicants and Participants, Homeless Applicants and Participants for more information. Guidance ▪ Homeless participants represent a higher risk population. The homeless condition may predispose participants to health and nutritional risks. ▪ Provide what the participant can actually use. Certain food selections may be helpful such as: ▪ Powdered or evaporated milk ▪ Small juice cans - which may be offered if living conditions lack refrigeration, and/or adequate or sanitary food storage facilities. ▪ Soy beverage in shelf-stable packaging (note: Pacific brand soy beverage is shelf-stable, but not widely available. Check local availability before recommending.) ▪ Provide information about options such as: ▪ Canned beans ▪ Fluid milk available in half-gallon containers ▪ Option to receive all dairy as milk, rather than including yogurt and cheese ▪ Assess the participant’s situation and whether homeless-friendly food options are needed at each benefit issuance. Revise the food package as circumstances and resources change. ▪ Provide counseling on ways to best use, prepare and keep foods safe, taking into consideration the participant’s situation. ▪ Refer to community assistance programs as appropriate. Reference – Complete Listing of Hyperlinks Section 5.6: Homeless Applicants and Participants (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_6.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(8.2)Minnesota WIC Operations Manual (MOM) Section 8.2: WIC Card Management: Ordering, Inventory & Security#

(8.2)(document-1)#

Section 8.2: WIC Card Management: Ordering, Inventory, and Security 02/2020 References: 7CFR 246.12 (p) Policy: Local Agencies are responsible for managing WIC Card inventory – ordering, tracking, and securing cards. Purpose: To ensure adequate inventory to meet operational needs and to reduce risk of fraudulent card usage. Procedures: Local Agencies should have enough WIC Cards on hand for at least 6 months of operations. Ordering WIC Cards ▪ Routine ordering: Local Agencies must submit orders for WIC Cards quarterly (see Guidance for dates), using Quarterly WIC Card Stock Order Form. ▪ If the Local Agency does not need WIC Cards for the quarter, they must submit an order with a quantity of zero. ▪ Emergency orders: Local Agencies may receive WIC Cards outside of the established quarterly schedule only for true emergencies, such as natural disasters in which cards were destroyed. Staff must contact the State WIC Office if this occurs. Receiving and Tracking Inventory ▪ Upon receipt of a card shipment, verify that the quantity ordered was received. It is not necessary to retain packing slips. ▪ Log on a tracking sheet the # boxes received and the cards’ serial number range. When cards are sent to another clinic/location, document how many WIC Cards (# boxes or individual cards) were sent. See sample, Exhibit 8-X: WIC Card Inventory Log. You may use this log, or one you develop yourself.

S E C T I O N 8 . 2 : W I C C A R D M A N A G E M E N T : O R D E R I N G , I N V I N T O R Y , A N D S E C U R I T Y 2 Security WIC Cards must be secured to minimize risk of cards and food benefits being misused. ▪ WIC Cards needed for daily clinic operations can be readily available to WIC staff (e.g., at their workstations), but should be kept out of sight (e.g., in a desk drawer). ▪ WIC Cards should never be in “public view” or unattended. ▪ Any cards not needed in clinic, must be stored in a locked area (e.g., a locked room or cabinet), with access limited to a few authorized WIC staff. ▪ At the end of the day, all WIC Cards must be secured in a locked area not accessible by non- WIC staff (e.g., cleaning staff). Guidance Cards must be secured, and access limited to a few authorized WIC Staff. ▪ When holding clinic “off-site” or in a space in which there is no secure locked space, staff must arrange to store and secure the cards in an opaque closable container or receptacle (e.g., a money pouch or passport holder), ideally “on their person” or in a bag under the control of staff. ▪ If stored in a locked room or cabinet, only a very limited number of WIC staff should have access to the key (e.g., the clinic supervisor). ▪ Cards must never be accessible to non-WIC staff during both work and non-work hours. If your agency has questions or concerns related appropriate secure storage or staffing issues that impact limiting access, contact your WIC Consultant to discuss. Quarterly orders are required. ▪ If the Local Agency does not need WIC Cards for the quarter, submit an order with a quantity of zero. ▪ If the Local Agency does not submit an order, you will be contacted by the State WIC Office. Card Stock Quarterly Schedule ▪ Shipment of cards takes approximately 6-7 weeks.

S E C T I O N 8 . 2 : W I C C A R D M A N A G E M E N T : O R D E R I N G , I N V I N T O R Y , A N D S E C U R I T Y 3 Card Stock Quarterly Ordering Schedule Quarter Ordering Deadline Delivery 1st Quarter December 15th February 2nd Quarter March 15th May 3rd Quarter June 15th August 4th Quarter September 15th November Estimating number of cards to order: ▪ Cards are issued to households. ▪ Households are issued only one card at a time. ▪ Local Agencies need enough cards to issue to new households and to provide as a replacement for cards for reported lost/stolen, damaged, or inoperable. ▪ If you need assistance in estimating the number of cards to order, contact your WIC Consultant. Reference – Complete Listing of Hyperlinks Quarterly WIC Card Stock Order Form (https://redcap.health.state.mn.us/redcap/surveys/?s=7KMMC4DCJJ) Exhibit 8-X: WIC Card Inventory Log (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex8/8xfi ll.docx) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(8.3)Minnesota WIC Operations Manual (MOM) Section 8.3: Issuing WIC Cards#

(8.3)(document-1)#

Section 8.3: Issuing WIC Cards 6/2024 References: 7CFR 246.12 (r)(1)(2)(3) Policy: Issue a WIC Card to the household of WIC participant(s) within a valid certification period to ensure access to household food benefits. Purpose: To ensure that certified participants have access to the food benefits for which they are eligible. Procedures These procedures pertain to initial WIC card issuance only. To replace a previously issued WIC card that has been lost, stolen, or damaged, see Section 8.5: Replacing WIC Cards. 1. Verify identification of the adult participant, authorized representative (e.g., parent/guardian), or proxy whenever issuing a WIC Card. See Guidance. 2. Issue the card to the adult participant, authorized representative (e.g., parent/guardian), or proxy whose identity was verified. Note: The person issued the WIC Card is designated the Primary Card Holder (PCH) in the Information System, whether that person is the adult participant, authorized representative (parent/gaurdian) or proxy. 3. Ensure the PCH signs the signature pad to acknowledge receipt of the WIC card. See Guidance for primary cardholder signature options. 4. Explain to the Primary Card Holder (PCH) how to use the WIC Card, reviewing either the flyer “How to use your WIC Card” or the information in the Shopping Guide. 5. Review the WIC Rights and Responsibilities associated with using the WIC Card. Staff must inform participants that neither redeemed nor expired food benefits can be replaced. 6. Assist the PCH in setting up their 4-digit PIN either by calling the WIC customer service line or through the Web Portal; benefits cannot be accessed until a PIN is set-up. ▪ The person setting up the PIN will need to provide the PCH’s date-of-birth and the zip code for the household’s mailing address. See Guidance below. ▪ The PIN is private - it should be set by the PCH. It should not be known to WIC staff and is not stored in the system.

S E C T I O N 8 . 3 : I S S U I N G W I C C A R D S 2 Guidance ▪ Only issue one WIC card per household. ▪ Alternate Representative/proxy must be a competent person, at least 16 years old. ▪ Identity of an Adult Participant may be verified during certification according to the ID requirements in Section 5.2.3 - Identity. ▪ See Exhibit 5-C: Identification Requirements by WIC Contact Type for acceptable forms of parent/guardian or proxy identification. ▪ Ensure that a participant whose address is listed as the local agency or Safe at Home address is informed of the appropriate zip code to use when setting up or changing their PIN number. See Section 5.2.2 - Residency for more about Safe at Home. ▪ Primary Card Holder Signature Options: If staff are unable to collect the Primary Card Holder’s signature when setting or changing the WIC Card’s Primary Card Holder, the staff member must enter the reason on the signature pad. Use one of the following options to obtain the signature and scan the form into the Information System: ▪ Obtain an electronic signature using the Primary Cardholder Signature Register or by another electronic signature platform like DocuSign. ▪ Use Exhibit 5-B: Registers for Manual Signatures. Reference – Complete Listing of Hyperlinks Section 5.2.2 - Residency (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_2_2.pdf) Section 5.2.3 - Identity (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_2_3.pdf) Section 8.5: Replacing WIC Cards (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch8/sct n8_5.pdf) Primary Cardholder Signature Register (https://redcap.health.state.mn.us/redcap/surveys/?s=KCRNPKHRRJ) Exhibit 5-B Registers for Manual Signatures (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5b. docx)

S E C T I O N 8 . 3 : I S S U I N G W I C C A R D S 3 Exhibit 5-C Identification Requirements by WIC Contact Type (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5c. pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(8.4)Minnesota WIC Operations Manual (MOM) Section 8.4: Issuing Food Benefits#

(8.4)(document-1)#

Section 8.4: Issuing Food Benefits 6/2024 References: 7CFR 246.12 (r) Policy: Issue food benefits to certified participants when nutrition service requirements are met. Purpose: To provide supplemental food to help meet a participant’s nutrition needs. Procedures 1. Ensure that a WIC Card has been issued to the household. If a card has not yet been issued, refer to Section 8.3: Issuing WIC Cards. 2. Verify identification of the adult participant, authorized representative (e.g., parent, guardian), or proxy requesting WIC food benefits. See Guidance below. 3. Ensure that the individual presenting identification is listed as an authorized or alternative representative in the participant record. Verbal verification of identity: If identification is unavailable and the WIC card has previously been issued, WIC staff may verbally verify that the person is authorized to obtain the WIC benefits; to do this, WIC staff must: a) Confirm the person’s identity by cross-referencing their name with that of an adult participant, authorized representative, or proxy listed in participant record, and b) Request validation of at least two of the following details: o The Primary Card Holder’s (PCH’s) date-of-birth, o The zip code of the household’s mailing address, and/or o The names of household members participating in WIC. If it is determined (or suspected) that the person is not authorized to obtain food benefits (i.e., they are neither the Authorized nor Alternate Representative) inform them that benefits cannot be issued and advise them to have the Authorized Representative or an Alternate Representative/proxy contact the WIC office so that benefits can be provided. Do not disclose any information from the participant record, including details about authorized or alternate representatives. 4. Complete all nutrition service requirements for the contact. See Section 5.3: Nutrition Risk Assessment and Chapter 6: Nutrition Education. ▪ Certification requirements (for initial-, re-, and/or mid-certification)

S E C T I O N 8 . 4 : I S S U I N G F O O D B E N E F I T S 2 ▪ Nutrition education and/or high risk follow-up ▪ Verifying certification status of transfers ▪ Moving a child to a new household due to a change in guardianship - including both informal arrangements and placement in foster care. 5. Prescribe or change food package, as needed- this step must be completed by a Competent Professional Authority (CPA). 6. Issue one to three months of food benefits at a time, if appropriate. See Guidance below. ▪ The food benefits for each WIC participant in the household are aggregated and accessible with the WIC Card once a PIN has been set. ▪ Participants are eligible for monthly food benefits through their certification period. Guidance ▪ CPA or non-CPA staff person may issue food benefits once a food package has been prescribed/adjusted by the CPA. ▪ See Exhibit 5-C: Identification Requirements by WIC Contact for acceptable forms of parent/guardian or proxy identification. ▪ Identity of an Adult Participant may be verified during certification according to the ID requirements in Section 5.2.3 - Identity. ▪ Use an InfoView report to identify and contact participants who have not received food benefits. ▪ If there is an outstanding participant violation, the family might not be eligible for food benefits. See Section 1.12: Termination or Suspension of Program Services ▪ Participants may designate a proxy by phone. If a Participant/Parent/Guardian (PPG) calls the Local Agency to request that a particular person be designated their proxy, staff must verify the identity of the person calling and making the request by following the steps outlined above for Verbal Verification of Identity. Section 8.4.2: Replacing Food Benefits References: 7CFR246.12 Policy: Redeemed and/or expired formula and food benefits may not be replaced except in very limited situations described below. Purpose: To provide food benefits to eligible participants, while maintaining program integrity.

S E C T I O N 8 . 4 : I S S U I N G F O O D B E N E F I T S 3 Redeemed formula may be replaced if: ▪ Cans of redeemed and unused formula are returned to clinic; OR ▪ Redeemed formula is no longer available due to extraordinary circumstances listed below and documented (see procedures): ▪ Formula was lost or destroyed in a natural disaster (e.g., flood or tornado) or other tragedy such as a house fire or theft (see Guidance). ▪ An infant or child is moved to a new household (e.g., foster care) and the redeemed formula does not accompany the child in the move, and the new guardian cannot safely retrieve it from the former household. See Section 5.5: Change in Guardianship Redeemed food benefits may be replaced only if the food was lost or destroyed in a natural disaster (e.g., flood or tornado) or other tragedy (such as a house fire or theft). Procedures Returned Formula ▪ A participant may be “reissued” formula (on a can-by-can basis) if they return redeemed, but unused cans to clinic within the current benefit month. ▪ Document the returned cans on the Returned Formula Tracking form (see Exhibit 7-I: Returned Formula Log) ▪ Document in the participant’s record the reason redeemed formula was replaced. ▪ Note: Returned cans may not be reissued to another participant (see Section 7.5.5: Returned Formula). ▪ If formula is not returned, or is returned after the end of the benefit month, it may not be replaced/reissued. Lost Formula and/or Food Benefits To replace redeemed food and/or formula that were lost in extraordinary circumstances, you must: ▪ Review the situation to determine whether replacement is appropriate: ▪ Known event in the area such as fire, flood, tornado, etc. ▪ Documentation of household’s loss as indicated by a police report or insurance claim ▪ Official documentation of a change in custody ▪ If replacement meets criteria, staff must: ▪ Change the Household ID for all members of the household; and ▪ Reissue the lost food benefits.

S E C T I O N 8 . 4 : I S S U I N G F O O D B E N E F I T S 4 ▪ Document in the participant’s record the reason redeemed food/formula was replaced. Guidance-Replacing Food Benefits ▪ Theft/Stolen Benefits Replacing food or formula benefits reported by a parent/participant/guardian (PPG) as “stolen” does not apply to contested possession between family members. ▪ To replace stolen food or formula, the LA must see documentation that a theft occurred (e.g., a police report or insurance claim). ▪ In situations in which food items were taken by another family member, the benefits are not considered “stolen” for purposes of this policy, and LAs may not replace them. ▪ Situations in which a child changes households are handled differently. See Section 5.5: Change in Guardianship ▪ Remind participants that they can purchase 1 or 2 cans of formula at a time (rather than full amount), to ensure the infant’s tolerance and minimize waste and/or inconvenience. ▪ If there is an outstanding program violations issue, the family might not be eligible for formula replacement. See Section 1.12: Termination or Suspension of Program Benefits ▪ Provide participant a list of local resources to assist them in meeting other needs related to their situation. Section 8.4.3: Food Benefits Management for Out of State Transfers Policy: Ensure WIC participants who move between state WIC programs continue to receive food benefits during their certification period. Purpose: To ensure certified participants continue to receive WIC benefits. Procedures Transferring from Minnesota to Another State 1. Provide participant a Verification of Certification (VOC). See Section 3.3: Transferring Participants Do not terminate certification, void benefits, or deactivate the WIC Card. This information may be requested by the receiving state WIC program to determine a participant’s eligibility and remaining food benefits. 2. Instruct the participant to keep their MN WIC Card to access food benefits until they move.

S E C T I O N 8 . 4 : I S S U I N G F O O D B E N E F I T S 5 3. Inform participant to bring VOC, WIC Card, and other document(s), such as Medical Formula Documentation, to a local WIC agency in the state to which they are moving, to complete the transfer. 4. If a MN WIC Card is returned to a MN WIC local agency from another state, deactivate the WIC Card. Transferring to Minnesota from Another State WIC program 1. Verify certification status and initiate a transfer in the WIC Information System. If unable to verify status, or if certification will end soon, complete a certification. See Section 3.3: Transferring Participants 2. Collect, review, and destroy any food benefits the participant has brought from another state WIC program. 3. Issue a WIC Card according to Section 8.3: Issuing WIC Cards. Provide additional education or high risk follow-up, and food benefits for the unredeemed foods in the current month. Reference – Complete Listing of Hyperlinks Section 8.3: Issuing WIC Cards (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch8/sct n8_3.pdf) Section 5.3: Nutrition Risk Assessment (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_3.pdf) Chapter 6: Nutrition Education (https://www.health.state.mn.us/people/wic/localagency/mom.html#education) Section 1.12: Termination or Suspension of Program Services (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_12.pdf) Section 5.5: Change in Guardianship (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch5/sct n5_5.pdf) Exhibit 5-C Identification Requirements by WIC Contact (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5c. pdf) Exhibit 7-I: Returned Formula Log (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex7/7i_ fill.docx)

S E C T I O N 8 . 4 : I S S U I N G F O O D B E N E F I T S 6 Section 7.5.5: Returned Formula (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch7/sct n7_5.pdf) Section 1.12: Termination or Suspension of Program Benefits (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_12.pdf) Section 3.3: Transferring Participants (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch3/sct n3_3.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(8.5)Minnesota WIC Operations Manual (MOM) Section 8.5: Replacing WIC Cards#

(8.5)(document-1)#

Section 8.5: Replacing WIC Cards 10/2024 References: 7CFR 246.12 (bb) Policy: Replace WIC Cards in a timely manner when reported lost, stolen, damaged, or unusable (L/S/D/U). Purpose: To ensure WIC participants have a functioning WIC Card to access their benefits. Procedures Only an Authorized or Alternative representative may report a L/S/D/U card to the Local Agency. However, anyone aware of the Primary Card Holder’s (PCH) date-of-birth and household zip code can report it through the Minnesota eWIC Customer Service Line. 1. Respond as soon as possible to the report of a L/S/D/U WIC card. Local Agencies must replace the Card within 5 business days of being notified. See Guidance below. 2. Verify identity of the person making the report to ensure they are a designated Authorized or Alternate Representative listed in the participant record. See Guidance below. Verbal verification of identity: If proof of identification is unavailable, WIC staff may verbally verify that the person is authorized to obtain a WIC card replacement; to do this, WIC staff must: a. Confirm the person’s identity by cross-referencing their name with that of an adult participant, authorized representative, or proxy listed in participant record, and b. Request validation of at least two of the following details: o The PCH’s date-of-birth, o The zip code of the household’s mailing address, and/or o The names of household members participating in WIC. If it is determined (or suspected) that the person is not authorized to obtain a card replacement, inform them that a new card cannot be issued. Advise them to have the Authorized or Alternate Representative/Proxy contact the WIC office for a replacement card. Replace the WIC card 1. Verify the identity of the person requesting a replacement card to ensure they are an authorized or alternative representative listed in the participant record (see above for verifying identity). 2. Replace the WIC card within 5 business days of original report of L/S/D/U card. The card:

S E C T I O N 8 . 5 : R E P L A C I N G W I C C A R D S 2 ▪ May be replaced only by WIC staff. Cards cannot be replaced by Minnesota eWIC Customer Service. ▪ Must be replaced as many times as needed for the household to access their WIC benefits. ▪ May be mailed, if preferred by the participant. See Mailing the WIC card below. 3. Set the person issued the card as the PCH in the WIC Information System. It can be changed later, if requested by the family. 4. Ensure the PCH signs the signature pad to acknowledge receipt of the WIC card. See steps below for Mailing the WIC card, as necessary. The previous PIN automatically transfers to the replacement card for immediate use. If needed, the PCH may call the Minnesota eWIC Customer Service Line to set a new PIN. If a WIC card is deactivated before its replacement (this should be rare), a new PIN must be set. See below for Deactivating the WIC Card. Deactivating the L/S/D/U WIC Card Only deactivate the WIC card if it is reported in possession of someone who should not have access to the benefits and immediate card replacement is not an option. This makes the card immediately unusable. The PIN will not automatically transfer to the new card once assigned. 1. Verify the identity of the person requesting to deactivate the card to ensure they are an authorized or alternative representative listed in the participant record (see above for verifying identity). 2. Deactivate the WIC card only when necessary to remove household access. ▪ WIC staff: Deactivate the WIC card in the Information System. ▪ Card holder: Participants may deactivate the WIC card any time by calling the Minnesota eWIC Customer Service Line. Note: WIC staff are not notified by the eWIC service provider when a card is deactivated by the card holder, but it is indicated in the participant’s record. 3. Follow steps above to Replace WIC Card, as necessary. See Guidance below. Food Benefits on Replacement Card ▪ Unredeemed food benefits for the current and future months will remain with the household and be accessible with the replacement card. ▪ Food benefits that expire before a new card is provided will not transfer to the replacement card. The participant will have access to benefits that are current as of the date the new card is received.

S E C T I O N 8 . 5 : R E P L A C I N G W I C C A R D S 3 Mailing the WIC Card 1. Verify the mailing address. 2. Inform the family that mailing the card might delay their access to food benefits. 3. Inform the PCH that their PIN automatically transfers to the replacement Card, so they can access their food benefits as soon as they receive the Card in the mail. 4. Initial the signature pad and indicate “mailed” in place of the PCH’s signature. 5. Include the following on the envelope: a) Local Agency’s return address. b) “Return Service Requested” in black ink directly below the return address. 6. Mail first class with adequate postage. If the Card is returned undelivered, create an alert documenting that the card was returned and contact the family to follow up. Do not re-mail the Card until the address is verified. Guidance ▪ Replacing Cards within 5 business days: For participants to access their benefits they need a functioning WIC Card. Local Agencies must establish policies and procedures, and staff accordingly, so that cards reported L/S/D/U are replaced as soon as possible. The expectation is that most Cards will be replaced within 5 business days of a Local Agency being notified. If a situation occurs such that the Card is not replaced within 5 business days, staff must document an explanation in a Note. ▪ See Exhibit 5-C: Identification Requirements by WIC Contact for acceptable forms of parent/guardian or proxy identification. ▪ The WIC card cannot be deactivated through the Web Portal. Reference – Complete Listing of Hyperlinks Exhibit 5-C Identification Requirements by WIC Contact (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/exhbts/ex5/5c. pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(9.2)Minnesota WIC Operations Manual (MOM) Section 9.2: Information System Hardware#

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Section 9.2: Hardware 07/2026 References: MN Chapter 13 Data Practices Act, 7 CFR 246.26 (d-h); 2027 WIC Grant Agreements, Exhibit A WIC Grantee Duties. Policy: All Local Agencies are required to provide computers and peripherals, that meet the State’s minimum hardware specifications to access the Minnesota WIC Program Information System. Purpose: To ensure consistency of the system, maximize operation efficiencies, and maintain data integrity and security. Procedures Hardware support Local Agencies must provide their own computers for using the WIC Information system. The State will provide the minimum specifications for the computer hardware needed to efficiently use the WIC Information System. The State will also provide an approved peripherals list that will include scanners, signature pads, and card readers that have been fully tested and approved for use with the WIC Information System. The Local Agency must also meet the following criteria: ▪ Provide adequate IT support that is available, responsive, and effective. ▪ Ensure Local IT support provides and maintains adequate inventory for new staff and replaces faulty hardware within 24 hours. ▪ Meet State security standards (found in Section 9.4) and minimum hardware specifications. ▪ Provide specific Windows operating system version and Office Suite. ▪ Provide real-time anti-virus protection. ▪ Provide regular security updates to the operating system and anti-virus software and definitions. ▪ Use full disk encryption software. ▪ Create a process to ensure temporary files in the Downloads folder MUST be set to delete after 1 day and deleting files from the Recycle Bin MUST be set to no more than 30 days or the state provided Download and Recycle Bin script may be used (See Guidance below).

S E C T I O N 9 . 2 : W I C I N F O R M A T I O N S Y S T E M - H A R D W A R E 2 ▪ Must have a default web browser of either Google Chrome or Microsoft Chromium Edge. Local Agencies must use the Minnesota WIC Help Desk as the first point of contact when in need of assistance in the event of an issue where the software is causing an issue with the approved list of hardware peripherals. Physical hardware security Hardware should not be left in vehicles. When available, computers should be securely locked to a stationary object using a Kensington Lock or equivalent. Local Agencies should follow any other local policies regarding physical security of computer equipment purchased using federal funds. Lost or stolen computer equipment Due to the risk of a potential data breach (see Section 1.7: Data Privacy), Local Agencies must immediately do the following if computer equipment is identified as lost or stolen: ▪ Contact Local IT and follow local protocol for lost/stolen equipment. ▪ Contact the following staff at State WIC office: ▪ WIC MIS & Data Unit Supervisor ▪ WIC Nutrition & Clinic Services Unit Supervisor ▪ Agency’s State WIC Consultant ▪ Provide the following information: ▪ List of missing equipment ▪ Agency name and number ▪ Location where loss/theft occurred ▪ Date and time the loss/theft occurred (actual if known or estimated) ▪ Circumstances around the occurrence ▪ Provide a copy of the police report if applicable Incidents involving lost or stolen equipment that may include unauthorized access to private data must also follow the cybersecurity incident notification requirements described in Section 9.4: Network, Browser, and User Access Security.

S E C T I O N 9 . 2 : W I C I N F O R M A T I O N S Y S T E M - H A R D W A R E 3 Training Annual security training is required for all WIC staff every federal fiscal year. Local Agencies are responsible for ensuring and tracking that all staff view the security module annually each year and new staff view this Security Module as part of Information System training. ▪ WIC Security Training ▪ Local Agency Security Training Module Tracking form Guidance A Download and Recycle Bin script was created to help Local Agencies meet security requirements after downloading documents that contain private data. This script creates a scheduled task to delete all files from the Downloads folder and the Recycle Bin each time a user logs onto their computer and at 8 pm daily if the computer is not shut down overnight. The Download and Recycle Bin Script and instructions are available from the State office. Local Agencies may use the provided script or create one of their own locally that performs the same function. Reference – Complete Listing of Hyperlinks Section 9.4: Network, Browser, and User Access Security (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch9/sct n9_4.pdf) Section 1.7: Data Privacy (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_7.pdf) WIC Security Training (https://www.health.state.mn.us/people/wic/localagency/infosystem/hubert/training/index.ht ml#security) Local Agency Security Training Module Tracking Form (https://www.health.state.mn.us/docs/people/wic/localagency/training/security/tracking.docx ) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(9.3)Minnesota WIC Operations Manual (MOM) Section 9.3: Information System Software#

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Section 9.3: Software 07/2026 References: MN Chapter 13 Data Practices Act, 7 CFR 246.26 (d-h); WIC Grant Agreements, Exhibit A WIC Grantee Duties. Policy: All Local Agencies are required to use the current version of the Minnesota WIC Program’s Information System. Purpose: To ensure consistency of the system, maximize operation efficiencies, ensure compliance with program rules and policies as well as maintain data integrity and security. Procedures Software support The State will provide software needed to use the Information System. This includes: ▪ Access to the Information System ▪ SWIPe installation; used with signature pads, portable scanners, and card readers ▪ Scanner Drivers for approved scanner models Local Agencies MUST use the Minnesota WIC Help Desk:  As the first point of contact when in need of assistance in operating the Information System software.  If an error message is received while using the Information System software Data entry Local Agency staff MUST enter only valid and accurate participant data into the information system. The State maintains three (2) environments for use by local agency staff:  Production Environment – Participant data must be entered ONLY into this environment of the WIC information system, contains only three (3) years of participant signatures and benefit history detailed information.  Training Environment – Used for practice when training, this environment contains desensitized data. Only practice data should be entered in this environment.

S E C T I O N 9 . 3 : S O F T W A R E 2 Training The State will provide comprehensive training materials for the use of the Information System, which includes but is not limited to: ▪ On-demand training modules ▪ Structured exercises ▪ An Information System Training environment which includes desensitized data ▪ Local Agencies must ensure that staff are adequately trained prior to using the Information System. ▪ Local Agencies are strongly encouraged to access the Information System Training environment to allow staff to complete training exercises and practice activities that regularly occur in daily clinic activities. Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(9.4)Minnesota WIC Operations Manual (MOM) Section 9.4: Network, Browser, and User Access Security#

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Section 9.4: Network, Browser, and User Access Security 07/2026 References: MN Statutes Ch 13 MN Data Practices Act; 7 CFR 246.26 (d-h), Minnesota WIC Annual Security Training Module Policy: All Local Agencies must provide a secure environment in which staff can access the WIC Information System and ensure browser and user security requirements are met. Purpose: To ensure data privacy and the integrity of the Minnesota WIC Information system by ensuring network, browser, and user security requirements are met. Procedures Network security Local Agencies must provide technical support for initial set-up, maintenance, and support of a network including any ongoing internet connectivity issues. Local Agencies must work with their network administrators to assist with any planning or installation of any network device. Internet support can be from county or Local IT staff, contractor, or Internet Service Providers. Secure wireless connectivity options can be used when a wired communication cannot be achieved. Local Agencies must follow local network and internet usage policies. Local Agencies must ensure that all computers use a firewall. This can be a software firewall or hardware device. Local Agencies must work with their local IT staff to ensure upgrades to networks and/or firewall settings do not negatively impact use of the WIC software. If issues, such as degradation of speed with the system or log in issues, occur the agency should first contact the Minnesota WIC Help Desk to ensure it is not a software issue. Once it is determined it is not a software issue work with your local IT staff to resolve the issue, if needed collaborating with the MIS & Data Unit and Minnesota Help Desk staff.

S E C T I O N 9 . 4 : N E T W O R K , B R O W S E R A N D U S E R A C C E S S S E C U R I T Y 2 Browser security The only approved browsers by which you can access the WIC Information system are: ▪ Google Chrome ▪ Microsoft Chromium Edge If prompted by the browser, NEVER select to save your username and/or password to the browser. The Information System should only ever be open in one browser at a time. The Information System should only ever be open in one tab of the browser at a time. Only one of the WIC Information System environments (Production or Training) should be open in a browser at a time. The downloads folder of the browser MUST be set to be cleared or deleted after 1 day, and the Recycle Bin MUST be set to delete files permanently at no more than 30 days. This can be done by a manual or automated process (see Guidance below). User access security Local agencies must ensure: ▪ Each user with access to the Information System MUST have a unique county or agency- maintained email address to allow for use with Multifactor Authentication (MFA) when logging into the Information System. ▪ Each user MUST ensure they are receiving the MFA daily. ▪ Each staff member MUST use their own username and password when accessing the Information System. ▪ Each user should only be logged into ONE Information System Environment at a time. ▪ Each user should only be logged into ONE browser window/tab at a time. ▪ Each user should only be logged into ONE workstation at a time. User access changes Only a local agency WIC coordinator or their designated alternate may submit requests to the State for the following user activities related to the WIC Information System: ▪ New user access requests ▪ Deactivations for current users ▪ Updates to current user’s access roles In the case of an unplanned departure of staff, a local agency coordinator or their designated alternate, must call the Help Desk immediately to have the username deactivated.

S E C T I O N 9 . 4 : N E T W O R K , B R O W S E R A N D U S E R A C C E S S S E C U R I T Y 3 In the case of a planned leave of absence or vacation lasting four weeks or longer, the local agency coordinator or their designated alternate must submit a request to have the staff member’s username placed on “HOLD”. When the staff person returns from the absence, the coordinator or designated alternate should submit a user access request to have the staff member’s username HOLD status removed. Security incident notification and coordination Local Agencies MUST notify the State WIC Office when a Cybersecurity incident occurs, or is reasonably suspected, that it may impact the confidentiality, integrity, or availability of the Information System or WIC participant data. Contact the same State staff outlined in Section 9.2: Information System Hardware for Lost or stolen computer equipment (WIC MIS & Data Unit Supervisor, WIC Nutrition & Clinic Services Unit Supervisor, and Agency’s State WIC Consultant). Incidents requiring notification include, but are not limited to: ▪ Malware or ransomware infections ▪ Unauthorized access to systems or user accounts ▪ Phishing or credential compromise involving WIC users ▪ Network intrusions or security breaches ▪ Any incident that may involve exposure of private participant data Notification timeline Initial notification MUST occur as soon as practicable, but no later than 24 hours after discovery of the incident. Notification must include, if known: ▪ Agency name and number ▪ Date and time the incident was discovered ▪ Type of incident (malware, phishing, unauthorized access, etc.) ▪ Systems or user accounts potentially impacted ▪ Whether participant data may be involved ▪ Local Agency response actions and immediate next steps Local Agencies MUST cooperate with the State WIC Office, MNIT, and Local IT staff during incident investigation, containment, and remediation activities. Incident follow-up and remediation Following a cybersecurity incident, Local Agencies MUST document and retain for 6 years from the remediation of the Incident:

S E C T I O N 9 . 4 : N E T W O R K , B R O W S E R A N D U S E R A C C E S S S E C U R I T Y 4 ▪ Summary of the incident and root cause (if determined) ▪ Actions taken to contain and remediate the incident ▪ User account resets, device reimaging, or system restoration performed ▪ Corrective actions taken to prevent recurrence Upon request, this documentation must be provided to the State WIC Office for review. Password security Passwords MUST meet the Minnesota Department of Information Technology Services requirements for passwords. Passwords must include the following: ▪ Eight or more characters in length ▪ At least 1 (one) upper case letter ▪ At least 1 (one) lower case letter ▪ At least 1 (one) number ▪ At least 1 (one) special character The Information System will require passwords to be changed every 90 (ninety) days. The Information System will not allow any of the past 9 (nine) passwords to be reused. Your password is confidential; be sure to keep it that way. Users should do the following: ▪ Never share your password with anyone whether in person or over the phone, no matter who asks or why they say they need it. ▪ Never keep your password written down, either under your keyboard, inside your desk, on your bulletin board or anywhere else in your workspace. ▪ If you must write down your password it should be kept on your person or in another secure location. If you believe for any reason that your password has been compromised, change it immediately. Enable screen savers with passwords on all computers. When you step away from your computer you must always lock your computer to ensure that any private information on your screen is not seen by someone walking by. If allowed by Local Agency policy, users may use a password manager. Guidance Network security guidance Whenever possible when working remotely a Virtual Private Network (VPN) should be used.

S E C T I O N 9 . 4 : N E T W O R K , B R O W S E R A N D U S E R A C C E S S S E C U R I T Y 5 If a wireless network is used it is recommended that a security protocol be used. It should either require a user to agree to legal terms, register an account, or type in a password before connecting to the network. Downloads from a browser A Download and Recycle Bin script was created to help Local Agencies meet security requirements after downloading documents that contain private data. This script creates a scheduled task to delete all files from the Downloads folder and the Recycle Bin each time a user logs onto their computer and at 8 pm daily if the computer is not shut down overnight. The Download and Recycle Bin Script and instructions are available and can be downloaded from FileZilla, Agency Gateway/Download, and Recycle Bin Script. Password guidance Passwords should follow the following guidance: ▪ Do not use common words, names, and/or keyboard sequences. ▪ Do not use the same password for all your sites. ▪ Do not use a correctly spelled word in any language. ▪ Do not use personal information such as your name (or that of a pet or relative), birthday, or hobby. ▪ Do not use references to favorite sports teams, numbers, or movies. ▪ Choose something that is difficult to guess but something you can remember without writing it down. ▪ Choose the first letters of words in a title, song, or poem. ▪ For example, Book One: Harry Potter and the Sorcerer’s Stone becomes b1HP&tss ▪ Choose a passphrase where several words are strung together adding numbers and special characters. ▪ For example, go to town becomes go2^ToWn ▪ Choose to insert punctuation and numbers into regular words. ▪ For example, regular becomes rEgu!4r ▪ When changing your password change it significantly, changing just a letter, a number or two in your password is not considered changing it significantly. Reference – Complete Listing of Hyperlinks Minnesota WIC Help Desk (https://www.health.state.mn.us/people/wic/localagency/mnhelpdesk.html)

S E C T I O N 9 . 4 : N E T W O R K , B R O W S E R A N D U S E R A C C E S S S E C U R I T Y 6 Section 9.2: Information System Hardware (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch9/sct n9_2.pdf) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(9.6)Minnesota WIC Operations Manual (MOM) Section 9.6: Electronic Communications Security#

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Section 9.6: WIC Electronic Communications Security 07/2026 References: MN Statutes Ch 13 MN Data Practices Act; 7 CFR 246.26 (d-h); Telephone Consumer Protection Act 47 U.S.C. § 227; Secure and Trusted Communications Networks Act of 2019, 47 U.S.C. § 1601(b)(2)(A)-(C).; Section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019, Pub. L. 115-232 (Aug. 13, 2018); Minnesota Information Technology (MNIT) Services: Prohibited Technologies Policy, Prohibited Technologies Standard Policy: Electronic communication (such as: email, text, etc.) between Local Agencies and WIC participants may only be conducted with permission from the participant and appropriate safeguards must be in place when the communication involves private data. Purpose: Local Agencies use electronic methods of communication with participants such as texting, emails, faxes, and the Mobile Management system. Local Agencies must ensure that communication methods are secure when private data is shared by the local agency. The following are procedures for ensuring the security of communications. Local Agencies must report any suspected compromise of electronic communication systems used for WIC business in accordance with Section 9.4: Network, Browser, and User Access Security. Procedures Email communications Email communications are generally not considered a secure form of communication for private information. To ensure participant privacy, the Local Agency must work with local partners (IT and Legal) to ensure the Local Agency is using a secure locally approved process to send a secure/encrypted email when communicating private data via email with participants. ▪ The Local Agency should NEVER: ▪ Use personal staff email addresses (e.g., @gmail.com) to communicate with participants. ▪ Save emails with private data in the agency’s network folders accessible to non-WIC staff.

S E C T I O N 9 . 6 : E L E C T R O N I C C O M M U N I C A T I O N S E C U R I T Y 2 Emails should only be kept for the minimum amount of time needed for business purposes and then deleted (see Section 1.7: Data Privacy). Text message communications Text messaging is NOT considered a secure form of communication. Although a texting platform may indicate they are HIPAA compliant, it is the Local Agency’s responsibility to ensure the participant’s data is kept private and to follow Local Agency IT and Legal requirements. If the Local Agency is using a texting platform, ▪ The Local Agency MUST: ▪ Receive and document the participant’s permission to receive text messages (see Section 1.7: Data Privacy). NOTE: documented permission is not required to use texting via the WIC Mobile Management system. To use the “Contact Us” feature in the MN WIC Mobile App the participant must Opt-In to text messaging. ▪ Ensure text messages are easy to understand and do not contain abbreviations. ▪ Delete text messages immediately after viewing. ▪ The Local Agency MUST NOT: ▪ Send private information via text message. ▪ Text a participant using a staff members personal cell phone. ▪ Save a participant’s name to personal or Local Agency issued phone contacts list. ▪ Use free versions of texting services. ▪ Use an iPhone, unless it is ensured that iMessages are turned off, as these are automatically saved to an iCloud account. ▪ Request that a participant send any of the following via text: ▪ Personal Health Information ▪ Identifiable data such as social security or driver’s license numbers ▪ Photos or proofs for certifications with personal information ▪ If a participant wants to submit personal information via text message the Local Agency MUST inform the participant that it is not considered a secure way to submit information and offer alternate ways to submit the information electronically (see Guidance below). Text Message Release of Information Local Agency staff may obtain an initial verbal temporary consent to communicate via text messaging with documentation in a local use field in the Information System. A written release

S E C T I O N 9 . 6 : E L E C T R O N I C C O M M U N I C A T I O N S E C U R I T Y 3 of information with a signature consent for text messaging must then be obtained at the next participant contact and be scanned/uploaded into the Information System. The Local Agency may create their own texting specific release of information. This release must include the following statement: I understand that sending information electronically may not be secure. I assume the risk that persons other than the intended recipient may observe information sent by these media. Depending on my phone plan, there may be charges I will be responsible for, and I can ask to stop receiving these types of communication at any time. Suggested text communication usage The following are suggested uses for text messaging: ▪ Scheduling appointments and appointment reminders that do not include names ▪ Inviting participants to phone calls ▪ Sending links to food or nutrition resources Fax Communications There are multiple ways a Local Agency may receive a Fax communication. The Local Agency is responsible for ensuring that transmission of the service they are using is private and secure and only appropriate WIC Staff have access to private participant information. Prior to implementing, the Local Agency should confirm with their Local Information Technology (IT) staff if the service they plan to use is considered private and secure. The following faxing technology is NOT considered private and secure: ▪ A centralized shared fax machine used by multiple programs The following faxing technology may be considered private and secure; confirm with Local IT: ▪ A business unit fax machine used only by Local Agency WIC staff ▪ VSI-Fax maintained by Local Agency Information Technology staff ▪ eFax maintained by Local Agency Information Technology staff WIC Mobile Management Portal “Contact Us” feature and text messaging Mobile Management is a browser-based application that can be used by Local Agency staff to directly communicate with WIC participants via text message and obtain documentation in a secure way. This communication is initiated by WIC participants using the “Contact Us” feature in the MN WIC Mobile App. ▪ For participants to use the “Contact Us” feature within the MN WIC Mobile app they must opt-in to text messaging. This consent is only for texting that occurs between the

S E C T I O N 9 . 6 : E L E C T R O N I C C O M M U N I C A T I O N S E C U R I T Y 4 participant and the Mobile Management Portal. If the Local Agency is using another texting platform an additional release for texting must be signed (see Section 1.7: Data Privacy). ▪ NEVER request that a participant send images or documents via a text message that contains personal information in the WIC Mobile Management Portal. The participant should be directed to start a new Contact Us contact via the MN WIC Mobile app and use the “Submit Documents to WIC” option; this process is considered secure. ▪ NEVER send a text message response that includes private information. Additional information on Mobile Management can be found on Mobile Management. Ban on purchase of select IT items Local Agencies MUST ensure that Federal funds are NOT used to purchase, either directly or indirectly, any IT related product(s) or service(s) from any vendor indicated as prohibited by the Secure and Trusted Communication Networks Act of 2019 and Section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019, Pub. L. 115-232 (Aug. 13, 2018). ▪ Information is also reflected in the WIC Grant Agreements and is written as follows: By signing this agreement Grantee certifies that, consistent with Section 889 of the John S. McCain National Defense Authorization Act for Fiscal Year 2019, Pub. L. 115-232 (Aug. 13, 2018), Grantee does not and will not use any equipment, system, or service that uses “covered telecommunications equipment or services” (as that term is defined in Section 889 of the Act) as a substantial or essential component of any system or as critical technology as part of any system. Grantee will include this certification as a flow down clause in any contract related to this agreement. The following link to resources containing the prohibited vendors list for IT related products and services: ▪ Federal Communications Commission (FCC) List of Equipment and Services Covered By Section 2 of The Secure Network Act ▪ Minnesota IT (MNIT) Services Prohibited Technology Standard Guidance Secure document submissions The following are considered secure ways to submit documentation electronically: ▪ MN WIC Mobile App “Contact Us” feature ▪ Minnesota WIC Participant Documents Submission Form ▪ Minnesota WIC Online Application ▪ Secure or Encrypted emails

S E C T I O N 9 . 6 : E L E C T R O N I C C O M M U N I C A T I O N S E C U R I T Y 5 Reference – Complete Listing of Hyperlinks Prohibited Technologies Policy (https://mn.gov/mnit/assets/Prohibited%20Technologies%20Policy_tcm38-566880.pdf) Minnesota IT (MNIT) Services Prohibited Technology Standard (https://www.health.state.mn.us/docs/people/wic/localagency/prohibtech.pdf) Section 9.4: Network, Browser, and User Access Security (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch9/sct n9_4.pdf) Section 1.7: Data Privacy (https://www.health.state.mn.us/docs/people/wic/localagency/program/mom/chsctns/ch1/sct n1_7.pdf) Mobile Management (https://www.health.state.mn.us/people/wic/localagency/infosystem/hubert/training/index.ht ml#mbm) John S. McCain National Defense Authorization Act for Fiscal Year 2019, Pub. L. 115-232 [Aug. 13, 2018] (https://uscode.house.gov/statutes/pl/115/232.pdf) List of Equipment and Services Covered by Section 2 of The Secure Networks Act (https://www.fcc.gov/supplychain/coveredlist) Minnesota Department of Health - WIC Program 625 Robert St N, PO BOX 64975, ST PAUL MN 55164-0975; 1-800-657-3942, health.wic@state.mn.us, www.health.state.mn.us. To obtain this information in a different format, call: 1-800-657-3942 This institution is an equal opportunity provider.

(1.1)Minnesota WIC Operations Manual (MOM) Section 1.1: Introduction#

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(1.1)Minnesota WIC Operations Manual (MOM) Section 1.1: Introduction#

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(1.2)Minnesota WIC Operations Manual (MOM) Section 1.2: State WIC Staff and Role#

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(1.3)Minnesota WIC Operations Manual (MOM) Section 1.3: Local Agencies and Role#

(1.3)(document-1)#

(1.4)Minnesota WIC Operations Manual (MOM) Section 1.4: Grant Application Process#

(1.4)(document-1)#

(1.6)Minnesota WIC Operations Manual (MOM) Section 1.6: Public Notification and Outreach#

(1.6)(document-1)#

(1.7)Minnesota WIC Operations Manual (MOM) Section 1.7: Data Privacy#

(1.7)(document-1)#

(1.9)Minnesota WIC Operations Manual (MOM) Section 1.9: Compliance Monitoring of Local Agencies#

(1.9)(document-1)#

(1.10)Minnesota WIC Operations Manual (MOM) Section 1.10: Civil Rights#

(1.10)(document-1)#

(1.11)Minnesota WIC Operations Manual (MOM) Section 1.11: Potential Participant Violations#

(1.11)(document-1)#

(1.12)Minnesota WIC Operations Manual (MOM) Section 1.12: Termination/Suspension of Program Benefits#

(1.12)(document-1)#

(1.13)Minnesota WIC Operations Manual (MOM) Section 1.13: Fair Hearing Procedure#

(1.13)(document-1)#

(1.14)Minnesota WIC Operations Manual (MOM) Section 1.14: Records and Records Retention Requirements#

(1.14)(document-1)#

(1.15)Minnesota WIC Operations Manual (MOM) Section 1.15: Electronic Signatures#

(1.15)(document-1)#

(1.17)Minnesota WIC Operations Manual (MOM) Section 1.17: Emergency Actions#

(1.17)(document-1)#

(1.18)Minnesota WIC Operations Manual (MOM) Section 1.18: Separation of Duties to Assure Program Integrity#

(1.18)(document-1)#

(1.19)Minnesota WIC Operations Manual (MOM) Section 1.19: Avoid Conflict of Interest to Assure Program Integrity#

(1.19)(document-1)#

(2.1)Minnesota WIC Operations Manual (MOM) Section 2.1: Introduction#

(2.1)(document-1)#

(2.2)Minnesota WIC Operations Manual (MOM) Section 2.2: Financial Procedures#

(2.2)(document-1)#

(3.1)Minnesota WIC Operations Manual (MOM) Section 3.1: Introduction#

(3.1)(document-1)#

(3.2)Minnesota WIC Operations Manual (MOM) Section 3.2: Processing Standards - Timeframes for Scheduling Certification Appointments#

(3.2)(document-1)#

(3.3)Minnesota WIC Operations Manual (MOM) Section 3.3: Transferring Participants#

(3.3)(document-1)#

(3.4)Minnesota WIC Operations Manual (MOM) Section 3.4: Waiting Lists#

(3.4)(document-1)#

(4.1)Minnesota WIC Operations Manual (MOM) Section 4.1: Introduction#

(4.1)(document-1)#

(4.2)Minnesota WIC Operations Manual (MOM) Section 4.2: Local Agency Management#

(4.2)(document-1)#

(4.3)Minnesota WIC Operations Manual (MOM) Section 4.3: Competent Professional Authority (CPA) Qualifications and Responsibilities#

(4.3)(document-1)#

(4.4)Minnesota WIC Operations Manual (MOM) Section 4.4: Breastfeeding Coordinator#

(4.4)(document-1)#

(4.5)Minnesota WIC Operations Manual (MOM) Section 4.5: Staff Training#

(4.5)(document-1)#

(4.6)Minnesota WIC Operations Manual (MOM) Section 4.6: CPA Monitoring and Oversight#

(4.6)(document-1)#

(4.7)Minnesota WIC Operations Manual (MOM) Section 4.7: Designated Breastfeeding Expert#

(4.7)(document-1)#

(4.8)Minnesota WIC Operations Manual (MOM) Section 4.8: Breastfeeding Peer Program Management#

(4.8)(document-1)#

(5.1)Minnesota WIC Operations Manual (MOM) Section 5.1: Introduction#

(5.1)(document-1)#

(5.2)Minnesota WIC Operations Manual (MOM) Section 5.2: Certification Procedures#

(5.2)(document-1)#

(5.2.1)Minnesota WIC Operations Manual (MOM) Section 5.2.1: Categories#

(5.2.1)(document-1)#

(5.2.2)Minnesota WIC Operations Manual (MOM) Section 5.2.2: Residency#

(5.2.2)(document-1)#

(5.2.3)Minnesota WIC Operations Manual (MOM) Section 5.2.3: Identity#

(5.2.3)(document-1)#

(5.2.4)Minnesota WIC Operations Manual (MOM) Section 5.2.4: Income#

(5.2.4)(document-1)#

(5.2.5)Minnesota WIC Operations Manual (MOM) Section 5.2.5: Physical Presence#

(5.2.5)(document-1)#

(5.3)Minnesota WIC Operations Manual (MOM) Section 5.3: Nutrition Risk Assessment Overview#

(5.3)(document-1)#

(5.3.1)Minnesota WIC Operations Manual (MOM) Section 5.3.1: Anthropometric Data#

(5.3.1)(document-1)#